Mental health of person cannot be compressed into one size fits all approach: Supreme Court

The bench said a HC observation that there is no material to corroborate the allegations made in a suicide note is erroneous

The mental health of a person cannot be compressed into a ''one size fits all' approach, the Supreme Court has said while setting aside an order of the Karnataka High Court which quashed criminal proceedings against a government official in a case of abetment of suicide.

A bench of justices D Y Chandrachud and B V Nagarathna said the observation of the high court that there is no material to corroborate the allegations made in the suicide note is erroneous.

"The Single Judge, other than deciding on the merits of the case while exercising the power under Section 482 of the CrPC, has also made observations diminishing the importance of mental health. The mental health of a person cannot be compressed into a one size fits all approach," the bench said.

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The apex court said it is not a consideration for the high court while exercising its power under Section 482 of the CrPC, particularly in view of the fact that the trial has not begun.

The top court said the Single Judge of the high court has termed a person who decided to commit suicide a 'weakling' and has also made observations on how the behavior of the deceased before he committed suicide was not that of a person who is depressed and suffering from mental health issues.

"Behavioural scientists have initiated the discourse on the heterogeneity of every individual and have challenged the traditional notion of 'all humans behave alike'. Individual personality differences manifest as a variation in the behavior of people.

"Therefore, how an individual copes up with a threat- both physical and emotional, expressing (or refraining to express) love, loss, sorrow and happiness, varies greatly in view of the multi-faceted nature of the human mind and emotions. Thus, the observations describing the manner in which a depressed person ought to have behaved deeply diminishes the gravity of mental health issues," the bench in its recent judgement said.

The top court's judgement came on an appeal filed by Karnataka against the high court decision to quash a case of abetment of suicide against a government officer.

The government officer's driver died by suicide and left a note in which referred to the illegal activities of the accused in amassing wealth in excess of Rs 100 crores, converting black money into white and transferring funds from the bank account of the deceased through his mobile to the accounts of the relatives of the accused.

The bench said that the high court by its order has prevented the completion of the investigation in the complaint pending on the file of the IInd Additional Civil Judge (Junior Division) and JMFC Court, Maddur, Mandya District.

"The alleged suicide is of a person who was working as a driver of a Special Land Acquisition Officer, who is a public servant and against whom serious and grave allegations of amassing wealth disproportionate to the known sources of income were made by the deceased.

"The suicide note contains a detailed account of the role of the accused in the events which led to the deceased committing suicide. These are matters of investigation and possibly trial," the apex court said.

The top court said the high court stalled the investigation by granting an interim order of stay.

If the investigation had been allowed to proceed, there would have been a revelation of material facts which would aid in the trial against the accused, the bench said.