The Supreme Court upheld the Bombay High Court’s order quashing the FIR registered in connection with the death of Mohanbhai Sanjibhai Delkar, a seven-time Member of Parliament from Dadra and Nagar Haveli. The FIR had alleged offences of abetment to suicide, criminal intimidation, extortion, and conspiracy against senior Union Territory officials.
A Bench comprising Chief Justice of India B.R. Gavai and Justices K. Vinod Chandran and N.V. Anjaria dismissed the Special Leave Petition filed by Delkar’s son, Abhinav Mohan Delkar, challenging the Bombay High Court’s judgment dated September 8, 2022. The Court had reserved judgment on August 4, 2025, and pronounced its verdict today, affirming the High Court’s findings.
The Former MP was found dead in February 2021 at a hotel in Mumbai’s Marine Drive. His son subsequently lodged an FIR naming Union Territory Administrator Praful Khoda Patel, Collector Sandeep Kumar Singh, Superintendent of Police Sharad Darade, and others. They were booked under Sections 306, 506, 389, and 120-B of the IPC, along with Section 3 of the SC/ST (Prevention of Atrocities) Act, 1989. The FIR alleged that the Former MP was subjected to sustained harassment and humiliation aimed at seizing control of his educational institutions and preventing his participation in future elections.
In September 2022, a Division Bench of Justice Prasanna B. Varale (then Chief Justice, now a Supreme Court judge) and Justice Shrikant D. Kulkarni of the Bombay High Court quashed the FIR. The High Court held that while the allegations were grave in tenor, they lacked substantive material to constitute abetment under Section 306 IPC.
Challenging this, the petitioner argued before the Supreme Court that the FIR disclosed sufficient material of systematic harassment to survive at the threshold. The respondents, however, contended that the allegations were vague, unsubstantiated, and legally insufficient to attract charges of abetment.
The Supreme Court agreed with the High Court, reiterating that criminal liability for abetment to suicide cannot be inferred from general allegations of harassment or humiliation, unless supported by clear evidence of instigation or intentional aid. Accordingly, the FIR and proceedings against Praful Patel and other officials stand quashed, conclusively closing the case.