SUKDEB SAHA v. STATE OF ANDHRA PRADESH

Sukdeb Saha v. State of Andhra Pradesh & Ors. is one of the latest landmark judgement by the Supreme Court of India with a divisional bench consisting of Justice Sandeep Mehta and Justice Vikram Nath, passed on July 23, 2025.

Facts

• A young 17-year-old NEET aspirant, the daughter, Sukdeb Saha, who is the appellant fell from her hostel rooftop in Visakhapatnam in July 2023.
• The local police initially ruled it to be suicide without even conducting through investigation, however, the victim’s father raised grave concerns because of numerous inconsistencies and procedural and medical lapses in the probe.
• No suicide note was found, the victim’s statement was not recorded despite her being conscious post the fall, there were contradictions in CCTV footage and disputes in medical procedures, like putting on ventilator support without the consent of parents, the presence of rice in her stomach even after 48 hours of her death, a strange smell coming from it.
• The appellant initially filed a writ petition under Article 226 before the High Court of Andhra Pradesh to have the case transferred from the local police to the CBI. This petition was rejected by the High Court. The appellant then filed a Special Leave Petition before the Supreme Court under Article 136 for the same. 
• The Court found the local police investigation to be ineffective leading to it setting aside the High Court’s refusal to transfer the case and instead ordered the immediate transfer of the investigation from Andhra Pradesh police to the Central Bureau of Investigation (CBI) and directed CBI to conduct a fresh and impartial probe and file a report within four months.
• In a breakthrough move, the Court issued 15 binding guidelines for all educational institutions, hostels, and coaching centers nationwide to address student suicides and mental health issues.
• The Supreme Court’s judgment is significant because it recognized the right to mental health as an integral part of the constitutional right to life and dignity under Article 21.

Issues raised

The following issues of primary importance were raised in this case:

1. Whether the initial police investigation was fair and impartial.
2. Whether there is a “structural malaise” in the education system and whether institutions are accountable for student welfare.

Contention by the appellant

The learned council for the appellant argued regarding the insufficient police investigation. The investigation regarding the death of the daughter of the appellant by the local police was arbitrary and perfunctory. Despite repeated representations, the appellant’s FIR was not recorded in time and the case was prematurely concluded to be one of suicide. The names of potential accused as potential leads as disclosed by the appellant were ignored. The council also pointed out the medical negligence in the case as Venkataramana Hospital admitted Ms. X without informing the police or the parents of the victim and she was placed on ventilator support without her parent’s consent. The police also made no attempt to record her statement though she was conscious and capable of doing so. The Advocate Commissioner, appointed by the Andhra Pradesh High Court to secure CCTV footage and records faced non-cooperation from the local police and failed to seize CCTV hard disks which contained significant discrepancies, mark the incident spot, or collect forensic evidence all of which suggest deliberate suppression. They argued that the CCTV footage of the hostel showed a girl walking to the terrace in a t-shirt and salwar however the CCTV footage of the printing shop nearby showed the victim who fell down in t-shirt and shorts. This mismatch raises doubts about identity which the police failed to verify and hastily presumed suicide.

The council also stated that the police dictated the inquest report and ignored the Institute’s custodial responsibility for the victim. Additionally, the autopsy report shows a suspicious smell coming from her stomach and even after this, the chemical analysis and final opinion were withheld which clearly suggest concealment of evidence and contradict the suicide theory. They prayed for The Hon’ble Supreme Court to set aside the High Courts order and transfer the investigation to CBI.

Contention by the respondents

The learned council for the respondents argued that the police investigation conducted was fair and without any discrepancies. They claimed that the investigation was conducted diligently and lawfully and that the Io acted promptly based on medico-legal reports, the inspection scene, recorded statements of over 40 witnesses, the reviewed CCTV footage and also seized evidence for FSL. They also argued that there was no medical negligence on part of Venkataramana Hospital and the patient was treated according to proper medical protocols and they fully cooperated with the Advocate commissioner. 

They argued that there was no liability of Akash institute of which the victim was a student as the institute was only responsible for academics and had no role in hostel accommodation. Care hospital also denied claims of negligence stating the patient was admitted without prior medical record and that too in a vegetative state. The council stated that mere dissatisfaction or suspicion is insufficient and transfer to CBI must only happen in rare cases as laid down in Arnab Ranjan Goswami v. Union of India. They prayed that the appeal be dismissed and that the High Court’s order be affirmed. 

Rationale

The Supreme Court directed the transfer of the case to the CBI owing to multiple serious lapses and compromised objectivity in the local police probe. It took into account the lack of credible evidence supporting suicide. The deceased was conscious even after the fall with a Glasgow Coma Score of 10 out of 15 in spite of which her statement was not recorded. The discrepancies in CCTV footage were also considered. Additionally, medical negligence and evidence destruction was taken into account. It was noted that the autopsy findings noted a suspicious odour in the stomach contents, but the viscera were destroyed before forensic examination could be conducted and that a single doctor conducted the autopsy, forensic analysis, and was part of the medical committee investigating the matter which together constitutes a glaring conflict of interest. Thus, the Court held that the local investigation was biased and ineffective which raised serious doubts about integrity and to preserve public confidence and ensure a fair and impartial inquiry, the investigation must be handed over to the CBI.

Beyond the specific case, the Court recognized broader systemic failure in protecting students’ mental health and issued binding guidelines to be implemented nationwide. The Court said that mental health is an integral component of the right to life under Article 21 of the Constitution and requires proactive protection and institutional safeguards. It emphasized the need for holistic educational philosophy citing Rousseau’s Émile while affirming that education should nurture emotional, intellectual and ethical growth, not reduce students to exam scores and rankings. It recognized the alarming rates of increasing student suicides in the country. The Court highlighted that the deadly pressures in exam-centric systems, especially in high-stress coaching hubs like Kota, Hyderabad and Vishakhapatnam are an urgent call for attention to the structural failings of educational institutions. It highlighted India’s duty under Article 12 of the International Covenant on Economic, Social and Cultural Rights which includes mental health care and suicide prevention as essential rights. The Hon’ble Court under Article 141 laid down 15 guidelines to be followed by all educational and residential institutions. These are:

1. All institutions must adopt a uniform mental health policy aligned with national programs like UMMEED, MANODARPAN, and NSP, updated annually.
2. Institutions with 100+ students must have at least one qualified mental health professional (counsellor/psychologist/social worker).
3. Smaller institutions must create formal referral links with external mental health professionals.
4. Each student group must have a dedicated mentor or counsellor for confidential guidance and support.
5. Institutions must refrain from public shaming, batch segregation, or assigning unrealistic academic targets.
6. Suicide helpline numbers (e.g., Tele-MANAS) must be displayed prominently on campus and websites.
7. Institutions must have written emergency protocols for mental health crises and hospital referrals.
8. All staff must undergo biannual training in psychological first aid and crisis management.
9. Institutions must publish anonymized wellness records and submit annual reports to regulators.
10.  Awareness campaigns for parents or guardians of students must be conducted to increase recognition and address student suffering.
11. Institutions must encourage participation in extracurricular activities to encourage holistic growth and reduce stress.
12. Tamper-proof ceiling fans and restricted access to rooftops must be ensured in residential facilities for students.
13. A confidential grievance redressal system must be in place for complaint regarding harassment, bullying or discrimination.
14. Zero tolerance policy for retaliation against complainants or even whistle-blowers must be followed with mental health support given to them.
15. States and Union Territories must notify rules within two months for regulating private coaching centers along with setting up of district-level monitoring committees to ensure compliance to these rules.

Defects of law

The conviction rested largely on circumstantial evidence rather than direct proof. Courts have often cautioned that circumstantial evidence must form a complete chain, but here the linkages were not watertight which raising concerns about miscarriage of justice. Improper appreciation of evidence with contradictions in witness testimonies being overlooked was another defect. The principle that prosecution must prove guilt beyond reasonable doubt was not applied strictly which weakened the fairness of the trial.

Also, unexplained delay in FIR and investigation without satisfactory explanation as per criminal jurisprudence can create suspicion of fabrication but the Court did not adequately address this. Non-compliance with procedural safeguards like the mandatory provisions under CrPC, especially those regarding proper examination of witnesses and seizure procedure were not strictly followed. 

Conclusion

The judgment in Sukdeb Saha v. State of Andhra Pradesh is a crucial moment in social policy making and Indian jurisprudence at large. The decision of the Supreme Court surpasses the particulars of the case by not only ensuring a fair investigation but also by reframing student’s mental health as a constitutional right guaranteed under Article 21. By issuing the 15 binding guidelines, the Court has transcended beyond a reactive role to a rather proactive one, establishing a clear and enforceable framework regarding accountability. The judgment serves as a powerful call for action thereby compelling educational institutions to prioritize the emotional and mental well-being of the students and forcing a social reckoning with the hyper-competitive culture that has become toxic and contributed to the problem of student suicides. Conclusively, this is a witness to the role of judiciary as the supreme guardian of fundamental rights who is capable of creating systemic change to ensure that the right to education does not come at the cost of the right to life.

By: Dipika Sharma 

Bharati Vidyapeeth, New Law College, Pune.