The Madhya Pradesh High Court has rejected the plea of five doctors from Netaji Subhash Chandra Bose Medical College, Jabalpur, who sought the quashing of an FIR registered against them under Section 306 of the Indian Penal Code (IPC) in connection with the death of their junior during the post-graduation course.
Background of the Case
The doctors argued that they had been cleared by the college’s anti-ragging committee and claimed that the deceased was suffering from depression, mental stress, and financial troubles. They asserted that he had suicidal tendencies and that his death was a result of his mental condition, not due to any ragging, humiliation, or harassment by them.
However, the court observed that there is sufficient material at first glance to proceed against the accused and that their defense should be presented before the trial court.
Details of the Incident
The FIR was filed based on a complaint by the deceased’s brother after the victim was found hanging in his hostel room on October 1, 2020. Following an investigation, the police filed a charge-sheet against the five doctors, who were seniors of Bhagwat Devangan in the postgraduate Orthopaedics course, for abetment to suicide.
Court’s Observations
Justice B P Sharma, after hearing the case, stated that the charge-sheet and witness statements reveal strong material suggesting continuous harassment, humiliation, and ragging of the deceased by the petitioners. The court noted: “The allegations are not confined merely to ordinary workplace discipline or isolated verbal exchanges. The material collected during investigation specifically reflects allegations of repeated abuse, physical punishment and humiliation in the operation theatre, forcing the deceased to assume humiliating positions, assaulting him, compelling him to perform excessive work and continuously target him despite knowledge of his fragile mental condition.”
The court also pointed out that witness statements were recorded under Sections 161 and 164 of the Code of Criminal Procedure (CrPC).
Defense Arguments Rejected
The court said that the argument that the deceased was depressed, short of money, and had previously shown suicidal tendencies may be part of the defense, but that alone cannot absolve the accused at this stage when prosecution material indicates they continued to harass and humiliate him despite knowing his condition.
It further stated that it will be for the trial court to decide whether the suicide was solely due to depression and financial problems or whether the doctors’ conduct also played a role in pushing him to take the extreme step.
Anti-Ragging Committee Findings
The judges also remarked that the anti-ragging committee’s findings do not assist the petitioners at this stage. A college or departmental inquiry is distinct from a criminal case, and the fact that the committee did not find sufficient material for action within the institution does not nullify the criminal investigation, especially when police have gathered separate evidence.
The court emphasized that while hearing a plea to quash an FIR, it must assess whether there is prima facie material, not whether the prosecution will inevitably win the case. Consequently, the petition was dismissed.
