Naveen G. v. State of Karnataka & Anr., 2026

The case concerned the death by suicide of a 22-year-old woman who was pursuing nursing studies in Mysuru.

The prosecution alleged that the accused, who was already married, had persistently pursued and harassed the deceased.

According to the allegations, the deceased had repeatedly expressed her unwillingness to enter into a relationship with the accused.

Despite her refusal, the accused allegedly continued to pursue her.

It was alleged that he stalked her at or around her workplace.

The accused allegedly compelled her to accompany him on his motorcycle under the pretext of friendship.

The prosecution alleged that he repeatedly interfered with her attempts to establish a matrimonial relationship with another person.

He was allegedly presented himself as an obstacle whenever the deceased's marriage prospects progressed.

On one occasion, the accused allegedly took the deceased to Dharmasthala, purportedly for a temple visit.

He allegedly threatened to circulate photographs of the two of them in order to damage her reputation.

On another occasion, he allegedly interfered with her proposed marriage by claiming that he was in a relationship with her.

The prosecution alleged that these acts created continuing pressure and fear in the deceased's life.

The deceased had allegedly attempted suicide on 5 July 2025.

Her family intervened and she survived that attempt.

Despite the earlier suicide attempt, the accused allegedly continued the same course of conduct.

The deceased ultimately died by suicide on 29 July 2025.

The deceased's mother subsequently lodged a complaint.

Criminal proceedings were initiated alleging offences under Sections 75, 78 and 108 BNS.

The accused approached the Karnataka High Court seeking quashing of the criminal proceedings.

He disputed the allegations and sought termination of the prosecution at the threshold.

The High Court examined whether the allegations, taken cumulatively, disclosed a prima facie case of stalking, sexual harassment and abetment of suicide.

The Karnataka High Court dismissed the petition seeking quashing of the criminal proceedings.

The Court held that the allegations could not be characterised as a case involving merely an isolated quarrel, angry exchange or incidental interaction between the accused and the deceased.

According to the Court, the allegations described a continuing course of conduct.

The deceased's alleged refusal was repeatedly ignored.

Her privacy was allegedly threatened through the proposed circulation of photographs.

Her workplace was allegedly subjected to repeated pursuit.

Her matrimonial prospects were allegedly interfered with on multiple occasions.

The prosecution also alleged that the accused continued his conduct despite the deceased's earlier suicide attempt.

The Court considered these allegations collectively rather than examining each incident in isolation.

It observed that the cumulative conduct allegedly placed the deceased under increasing pressure and restricted her ability to make independent choices about her life.

The Court identified three aspects relevant to the allegation of abetment: instigation, goading and proximity.

The alleged continuing coercive conduct was capable of constituting the prima facie element of instigation.

The alleged persistent pressure and threats were considered relevant to the element of goading.

The alleged continuation of the conduct until shortly before the suicide was considered relevant to proximity.

The Court stressed that it was not determining the accused's guilt.

It was only deciding whether the prosecution was so baseless that it should be terminated before trial.

The Court held that the allegations, if ultimately proved, could constitute abetment to suicide.

The Court therefore held that the matter required adjudication at trial.

Relying upon the principle in Rajeev Kourav v. Baisahab, the Court declined to conduct a detailed appreciation of the evidence at the quashing stage.

The petition was accordingly dismissed.

Cumulative conduct is central: The most significant aspect of the ruling is the Court's refusal to examine each alleged act in isolation. The alleged stalking, threats, interference with marriage prospects and continued pursuit were treated as components of one continuing course of conduct.

Abetment is not confined to one dramatic act: The judgment recognises that alleged abetment may arise from a sustained pattern of conduct rather than a single explicit instruction or act immediately preceding suicide.

Earlier suicide attempt matters: The deceased's alleged suicide attempt on 5 July 2025 was particularly important because the prosecution alleged that the accused continued his conduct afterwards. If established at trial, this could demonstrate that the accused was aware of the seriousness of the deceased's distress.

Proximity: The Court treated the alleged continuation of the conduct until shortly before the suicide as relevant to the proximity requirement. The closer and more continuous the alleged conduct is to the suicide, the more significant it may become at the prima facie stage.

Instigation and goading: The Court did not limit instigation to explicit words directing a person to commit suicide. It considered whether the alleged continuing coercive pressure and threats could prima facie amount to instigation or goading.

Autonomy and personal choice: The allegations were particularly serious because they concerned alleged interference with the deceased's ability to choose her own relationship and matrimonial future.

Threats involving photographs: The alleged threat to circulate photographs was relevant not simply as an isolated threat but as part of the broader allegation of intimidation and control.

Stalking: Persistent pursuit despite an expressed refusal is legally significant under the BNS framework. The Court therefore treated the stalking allegation as part of the broader factual matrix rather than as an unrelated allegation.

Quashing jurisdiction is limited: The judgment reinforces that a High Court should not convert a quashing petition into a mini-trial. Where the prosecution material, taken at face value, discloses the ingredients of an offence, the matter ordinarily has to proceed to trial.

Prima facie case is not conviction: The Court carefully distinguished between finding a prima facie case and finding guilt. The accused remains entitled to contest the allegations and evidence during trial.

Truthfulness remains for trial: Whether every allegation is true, whether the witnesses are credible and whether the accused's conduct actually caused or contributed to the suicide are questions to be determined after evidence is tested.

Importance of mens rea: The Court noted that the accused's precise mental state or mens rea had yet to be established. This was another reason why the matter should not be terminated at the preliminary stage.

Protection against premature termination: The ruling prevents serious allegations from being dismissed merely because the accused offers an alternative interpretation of the facts before the evidence has been tested.

Broader significance: The decision illustrates how courts may analyse persistent coercive conduct as a whole when considering allegations of abetment to suicide, particularly where the alleged conduct continued despite an earlier indication of severe distress.