Published On: January 26th 2026
Authored By: Patel Krishna Natubhai
Faculty of Law, The Maharaja Sayajirao University of Baroda
- Title: Sukdeb Saha vs State of Andhra Pradesh 2025 INSC 893
- Court: Supreme Court of India
- Bench: Justice Vikram Nath & Justice Sandeep Mehta
- Date of Judgement: 25 July 2025
- Relevant provisions/ Statutes:
- Article 21 of Constitution of India, 1950
- Article 32 of Constitution of India, 1950
- Article 141 of Constitution of India, 1950
- Section 193(2) of Bhartiya Nagarik Suraksha Sanhita, 2023
Brief Facts:
The appellant resides in West Bengal with his family. In May 2022, the appellant’s daughter took admission in a coaching institute. The present case arose from the tragic death of a 17-year-old girl, daughter of appellant sukdeb saha. She was a student of undergoing coaching for National Eligibility cum Entrance Test (NEET) exam in Vishakhapatnam and was residing in hostel. She allegedly fell from the terrace of her hostel. She committed suicide according to the local authorities. This incident was treated as a suicide case.
However, this incident raises serious doubts due to the lapses in the investigation, mishandling of crucial evidence such as CCTV footage and medical care. The appellant was not satisfied as there was no proper investigation as there was absence of suicide note, failure to record victim’s statement despite her being conscious with Glasgow Coma Score 10 out of 15, premature destruction of crucial forensic evidence and suspectable circumstances surrounding medical facilities without parental consent, a hurried post-mortem report by a conflicted medical examiner.
The appellant sought multiple petitions to the Andhra Pradesh High Court requesting that the case to be transferred to Central Bureau of Investigation (CBI) for a fair and impartial probe. However, the high court rejected these petitions and allowed the investigations to remain with the state police. Dissatisfied with this decision appellant appealed to the supreme court seeking justice for his daughter and accountability in cases involving student welfare and custodial care.
In recent years, India has witnessed a rise in the number of student’s suicides, especially in educational institutes and coaching centres where exam pressure is extremely high. This incident also highlights the failure of systematic in ensuring student safety and mental health support.
Issues:
- Whether the investigations into the tragic and suspicious death of a 17-year-old NEET student declared into suicide as per the local authorities?
- Whether the case transferred to the CBI due to serious lapses in the investigation and medical facilities? 3. Whether the Supreme Court laid down the binding 15 guidelines to address mental health and safety in educational institutions?
Judgement:
The supreme court recognized mental health as an integral part of the right to life. It laid down the 15 interim guidelines for all educational institutions and coaching centers in India. The court set aside the orders of the high court after finding gaps in the investigation. It was transferred to CBI. This judgement was landmark judgement in the history of years by recognizing mental health as fundamental rights.
Also, there was need for survey to ensure the pressure of the exam, environment of institution, etc. as per the NCRB data representing student suicides increased from the 2021 to 2022. It also directed to state and union territories to notify the rules within months and also from the district level monitoring committees.
It ordered CBI to complete probe due to police lapses and conflicts within 4 months, while UOI was asked to file affidavit in 90 days. The court declared that the guidelines are binding law under Article 141. It further emphasized institutional accountability that states the neglect contributing to self-harm that attract liability.
The court has taken inspiration from the Vishakha v. State of Rajasthan precedent in formulating comprehensive guidelines for mental health protection. The sukdeb guidelines aims to fill the regulatory gap in student mental health. By linking mental heath and student safety with Article 21 of the constitution, the court also make it clear that it is not only about life but also about right to life with dignity.
Arguments:
Petitioner’s arguments:
The appellant’s counsel presented that the investigation conducted by the police was biased in nature and impartial. Serious lapses in procedural such as failure to record victim’s statement despite her being conscious, premature destruction of crucial forensic evidence and suspectable circumstances surrounding medical facilities without parental consent, a hurried post-mortem report by a conflicted medical examiner.
This incident raises serious doubts such as absence of suicide note and mishandling of crucial evidence such as CCTV footage and medical care. The investigation was transferred to CBI to ensure fair and impartiality. All the educational institutions and coaching centers have a duty of care regarding students’ negligence in case of safe infrastructure, mental health and medical care support amounts to violate Article 21. Especially those students who are preparing for competitive exams like NEET. The mental health of the students directly linked with right to life with dignity.
On these grounds, the appellant’s counsel appearing for the Court to accept this appeal, set aside the impugned judgment and direct the transfer the investigation to the CBI, in the interest of justice and to uphold the rule of law.
Respondent’s arguments:
The respondent’s counsel represented that police investigation was carried out and there was no sufficient evidence to prove foul play and the death was classified as suicide case due to as per the local authorities who confirmed that. There was no medical negligence or misconduct on the part of Care Hospital. When the deceased was admitted, no discharge summary or medical records were provided to the Hospital. Despite the patient arriving in a critical condition all necessary steps were taken to revive her.
The High Court had already examined on the request of the petitioner for transferring case to CBI. During the examination, there was no valid reason found to interfere with the investigation conducted by the police.
The appellant pointed out the lapses that were not substantial enough to transfer investigations to CBI. All the educational institutes and coaching centers can’t be held directly liable for the personal choices of students under academic or social stress or anxiety. Suicides are often multidimensional in nature. The state is already taking steps to regulate institutes and coaching centers that are strengthen to take student welfare measures.
Ratio Decidendi:
The Supreme Court emphasized that mental health is fundamental right under Article 21. The court held that mental health care and emotional well-being are part of a student’s right to life with dignity especially for minors. The educational institutes have the duty of care towards students’ negligence contribute to self-harm that attracts legal liability. Binding guidelines were given by the court under Article 141 to safeguard student welfare and mental health.
The court expanded the scope of Article 21 also safeguarding mental integrity and dignity. It relies on Shatrughan Chauhan v. Union of India and Navtej Singh Johar v. Union of India, which had already recognized the mental health as an integral part of the right to life and emphasized institutional accountability. The court laid down the principles like the Mental Healthcare Act, 2017 and International Covenant on Economic, Social and Cultural Rights affirms right to standard of mental health.
Obiter Dicta:
The court observed that educational institutions should actively monitor the mental health of students and tackle exam related pressures especially in coaching where competitive exams like NEET create extreme stress. Serious lapses in the investigation and medical facilities including absence of suicide note, failure to record victim’s statement, premature destruction of crucial forensic evidence and suspectable circumstances surrounding medical facilities without parental consent. Unregulated and profit-driven functioning of coaching centers with lack of oversight and student mechanisms. The court suggested that surveys and audits for student mental health in coaching centers and hostels need to identify systematic issues. There is a need a uniform, enforceable framework in India to address mental health, infrastructure safety and institutional accountability.
Final Decision:
The Supreme Court allowed the appeal and ordered an immediate transfer of the investigation. The Supreme Court transferred the investigation to Central Bureau of Investigation (CBI), ensuring fair and impartial creditability in the probe. It also laid down 15 interim guidelines for educational institutions and coaching centres under Article 141. The court not only provided fair justice but also addressed the issue of student welfare in India. The supreme court recognized mental health as an integral part of the right to life and emphasized institutional accountability.
This decision marked a history as it fills the gap between legal principles and social realities. The court emphasized that survey, and assessments need to identify the exam pressure on the students and safety of the students in educational institutions. The court by allowing the appeal not only ensured justice but also sets a precedent that can safeguard thousands of other students.
The decision highlighted that the law is evolving with society’s needs are changing. In today’s world, mental health is a primary concern and treated as the most important. The judgement shows that courts are willing to fill the gaps when the executive or legislature fails to act. This balances the justice and policy-making makes the case as a landmark in Indian legal history.
