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Supreme Court Upholds Quashing of FIR Against Praful Khoda Patel, Eight Others in Mohan Delkar Case

The ruling underscores that harassment alone does not meet the legal threshold for abetment of suicide.

Overview

  • The bench of Chief Justice B. R. Gavai with Justices K. Vinod Chandran and N. V. Anjaria confirmed the Bombay High Court’s September 2022 order and dismissed Abhinav Delkar’s appeal.
  • The court said there was “no modicum of material” showing instigation or intentional aid under Section 306 IPC, stressing the need for a positive act and mens rea.
  • It described the purported suicide note as “suspect” and noted hearsay statements and delay in registering the case, finding these insufficient to sustain charges.
  • The March 9, 2021 FIR, based on the son’s complaint, named nine accused including UT administrator Praful Khoda Patel and cited IPC sections 306, 506, 389, 120B and the SC/ST Act.
  • Allegations that officials pressured Delkar to seize control of SSR College and deter his political activity were found unsubstantiated, effectively closing the matter under this FIR.