Background:

The present case arose from the tragic death of a 17-year-old NEET aspirant, the daughter of Sukdeb Saha, who allegedly fell from the rooftop of her hostel in Visakhapatnam on 16 July 2023. Initially classified as a suicide by local authorities, the incident raised serious doubts due to numerous procedural and medical inconsistencies. These included the absence of a suicide note, the failure to record the victim's statement despite her being conscious with a Glasgow Coma Score of 10/15, discrepancies in CCTV footage, and questionable medical handling such as administering ventilator support without parental consent, a hurried post-mortem by a conflicted medical examiner, and premature destruction of viscera samples. Despite multiple petitions to the Andhra Pradesh High Court, including requests for a CBI investigation, the High Court refused to intervene, citing jurisdictional constraints due to a parallel FIR in West Bengal. Disturbed by the lack of a transparent and impartial investigation, the father appealed to the Supreme Court, seeking justice for his daughter and systemic accountability in cases involving student welfare and custodial care.

Issues

1. Whether the investigation into the suspicious death of a 17-year-old NEET aspirant initially declared a suicide by the Andhra Pradesh police was fair or impartial?

2. Whether it warranted transfer to the Central Bureau of Investigation (CBI) due to serious procedural lapses, medical irregularities, and potential conflict of interest?

3. Whether the Court should lay down binding guidelines to address the mental health and safety of students in educational and residential institutions, especially in the context of rising student suicides in coaching hubs across India?

Observations:

The following observations were made by the court:

• • The Court noted serious procedural lapses and irregularities in the police investigation, including the failure to record the victim’s statement despite her being conscious, destruction of viscera samples without proper analysis, and inconsistencies in CCTV footage.
• • Medical decisions (like placing the victim on a ventilator) and the post-mortem were done without the informed consent or presence of the father, violating basic procedural and ethical norms.
• • The Court affirmed that mental health care and emotional well-being are part of a student’s constitutional right to life and dignity, especially for minors under institutional supervision.
• • Observing the unregulated and profit-driven functioning of many coaching centres, the Court noted the lack of oversight and student protection mechanisms.
• • The Court observed that a uniform, enforceable framework was needed across India to address student mental health, infrastructure safety, and institutional accountability.

Decision:

The Supreme Court allowed the appeal and ordered an immediate transfer of the investigation from the Andhra Pradesh police to the Central Bureau of Investigation (CBI).

• - The court directed the CBI to:
• • Register a new case (RC) and conduct a fresh, independent and impartial investigation.
• • Complete the probe and file a final report/charge sheet within four months under Section 193(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023.
• - The Court framed and issued 15 binding guidelines under Article 141 of the Constitution, making them applicable nationwide.
• - Union Government was ordered to- Coordinate with State Governments and file a compliance affidavit within 90 days before the Court, confirming implementation of the mental health guidelines.

Why this case matters:

This case is significant for both individual justice and systemic reform. Here's why it matters:

• • Ensures impartial investigation- Ordered CBI probe due to police lapses and conflicts.
• • Mental health recognized as a constitutional right- Part of Right to Life (Article 21).
• • First-ever binding mental health guidelines- For all schools, hostels, and coaching centres nationwide.
• • Improves student safety and welfare- Mandates counselling, anti-bullying, and supportive infrastructure.
• • Makes institutional accountability mandatory- Coaching centres and schools must follow clear rules.
• • Creates enforceable national standards- Guidelines are binding law under Article 141.

Laws related thereto:

Under Constitution:

• Article 21: Guarantees the Right to Life and Personal Liberty, interpreted to include mental health and dignity. The Court emphasized that safeguarding students’ mental well-being is part of this fundamental right.

• Article 141: Declares that the law declared by the Supreme Court is binding on all courts and authorities in India. Used by the Court to make the 15 mental health and institutional safety guidelines binding nationwide.

Under BNSS:

• Section 193(2): The investigation in relation to an offence under sections 64, 65, 66, 67, 68, 70, 71 of the Bharatiya Nyaya Sanhita, 2023 or under sections 4, 6, 8 or section 10 of the Protection of Children from Sexual Offences Act, 2012 shall be completed within two months from the date on which the information was recorded by the officer in charge of the police station.

Judicial Precedents:

Francis Coralie Mullin v. Union of India (1981)

This landmark case established that the Right to Life under Article 21 includes the right to live with human dignity, which encompasses both physical and mental health.

It laid the foundation for recognizing mental health as a fundamental part of the right to life, a principle central to the Sukdeb Saha judgment.