Gudipalli Siddhartha Reddy v. State C.B.I., 2026 INSC 160 - S.306 IPC - Mutual Suicide Pact
Indian Penal Code 1860 - Section 306,107 -The surviving partner in a mutual suicide pact is legally culpable- A suicide pact involves mutual encouragement and reciprocal commitment to die together. The survivor’s presence and participation acts as a direct catalyst for the deceased’s actions -Abetting as defined under Section 107 IPC is not limited to physical act of supplying means to commit suicide. Accordingly, any psychological assurance or instigation, as long as the same is intentional and directly related to the commission of offence, also constitutes abetment - It is the reciprocal commitment of each party to commit suicide which provides necessary impetus/support to the other to go through with the act. In a suicide pact, it is implicit that each participant knows the intent of the other to commit the act knowing that their withdrawal from the pact will likely deter the other. Each party’s resolve to commit the act is, therefore, reinforced and strengthened due to the participation of the other party. Suicide in a suicide pact is conditional upon mutual participation of the other. In other words, if not for the active participation of both the parties, the act would not occur. The law treats such conduct as abetment because the State has a fundamental interest in preserving life. Any assistance in ending life is treated as a crime against the State. (Para 117-118)
Indian Penal Code 1860 - Section 107- In order to constitute abetment, the abettors must have intentionally aided the commission of offence. Aiding can be construed as an act of intentionally facilitating the commission of an offence. (Para 114)
Justice - High Profile Cases - Public outrage - Justice is not served by following majority sentiment or public pressure. Justice is served by truth, established through evidence and impartial investigation. While public outrage is understandable in high-profile cases, it should never dictate the course of inquiry. Investigations require careful collection of evidence, impartial analysis, and conclusions grounded in fact. Allowing public sentiment to shape outcomes risks miscarriages of justice. A society committed to fairness must recognise that investigators and courts serve the truth, not popularity. Their independence is not a luxury but the foundation of justice itself. (Para 105)
Professional Misconduct - Doctor - The impact of a doctor issuing an erroneous postmortem report and publicising it through the media goes far beyond individual misconduct. It spreads misinformation, erodes trust in investigative agencies and institutions such as the police and judiciary, prejudices public opinion, traumatises the victim’s family, and undermines the rule of law. Such misconduct does not merely harm one case; it corrodes public trust in medicine, law, and governance, destabilising peace and harmony in society. It also violates the sub judice rule, which restricts commentary on matters under judicial consideration to preserve fairness and integrity. (Para 104)
Case Info
Case name and neutral citationGudipalli Siddhartha Reddy v. State C.B.I., 2026 INSC 160
CoramHon’ble Mr. Justice Rajesh Bindal and Hon’ble Mr. Justice Manmohan
Judgment date17 February 2026 (New Delhi)
Case laws and citations referred(Only those clearly appearing in the extracted text)
- Velladurai v. State, (2022) 17 SCC 523
- Amalendu Pal v. State of W.B., (2010) 1 SCC 707 : (2010) 1 SCC (Cri) 896
- Umesh Chandra v. State of Uttarakhand, (2021) 17 SCC 616
- Ganpat Singh v. State of Rajasthan, (1997) 11 SCC 565
- Girja Shankar Misra v. State of U.P., 1994 Supp (1) SCC 26
- Amrik Singh v. State of Punjab, (2022) 9 SCC 402
- Dana Yadav @ Dahu v. State of Bihar, (2002) 7 SCC 295
- Abhinav Mohan Delkar v. State of Maharashtra & Ors., 2025 SCC OnLine SC 1725
- Patel Babubhai Manohardas & Ors. v. State of Gujarat, 2025 SCC OnLine SC 503
- Munna Kumar Upadhyay @ Munna Upadhyaya v. State of A.P., (2012) 6 SCC 174
- State of W.B. v. Mir Mohammad Omar & Ors., (2000) 8 SCC 382
- Raj Kumar v. State of Madhya Pradesh, (2014) 5 SCC 353
- Munish Mubar v. State of Haryana, (2012) 10 SCC 464
- Gian Kaur v. State of Punjab, (1996) 2 SCC 648
Statutes / laws referred
- Indian Penal Code, 1860: Sections 107, 114, 302, 306, 309
- Code of Criminal Procedure, 1973: Sections 174, 313, 386(b)
- Indian Evidence Act, 1872: Sections 8, 9, 32(1), 106, 114
- Probation of Offenders Act, 1958: Sections 3 and 4
- Andhra Pradesh Civil Services (Conduct) Rules, 1964: Rules 3(1)–3(4)
Three‑sentence brief summaryThe Supreme Court upholds the conviction of Gudipalli Siddhartha Reddy under Sections 306 and 309 IPC, holding that the deceased actress Pratyusha died due to organophosphate (Nuvacron) poisoning in a suicide pact, not by rape and manual strangulation. The Court relies on consistent medical, forensic and expert evidence (state FSL, CFSL, expert committees, AIIMS), accepts that the accused purchased the pesticide and participated in the joint suicide attempt, and draws an adverse inference from his false denials under Section 313 CrPC. It strongly criticises the autopsy surgeon Dr. B. Muni Swamy for an erroneous, sensational postmortem opinion and media disclosures, but, noting his death, limits itself to characterising his conduct as contemptuous and dismisses both the accused’s and the mother’s appeals.
