Supreme Court Directs CBI Investigation into Student’s Unnatural Death, Issues Comprehensive Guidelines for Mental Health in Educational Institutions

Introduction:

The Supreme Court of India, in the landmark judgment of Sukdeb Saha v. State of Andhra Pradesh & Ors[i], addressed a deeply disturbing incident involving the suspicious death of a 17-year-old student and NEET aspirant in a hostel in Vishakhapatnam. The case brought to the forefront significant concerns about institutional negligence, the integrity of local police investigations and the systemic failures contributing to the rising incidence of student suicides in India.

Facts:

• The appellant’s 17-year-old daughter, Ms. X, student and NEET aspirant residing in a hostel in Vishakhapatnam, died under suspicious circumstances on 14.07.2023, after falling from a hostel terrace.
• The appellant alleged institutional negligence by coaching centre, hostel management, and hospitals, doubting the suicide narrative and questioned the local police investigation’s integrity.
• FIRs were registered in Andhra Pradesh and West Bengal; the appellant requested transfer of investigation to the Central Bureau of Investigation (‘CBI’), which the High Court of Andhra Pradesh refused.
• There were serious discrepancies relating to CCTV footage, medical treatment, forensic examinations and alleged destruction of viscera.
• This appeal challenges the High Court’s refusal to transfer investigation and calls for stronger institutional safeguards against student suicides in educational contexts.

Issues:

1. Whether the High Court erred in refusing to transfer the investigation to the CBI despite credible allegations of flawed and biased local investigations?
2. What interim guidelines should be issued to address the rising incidence of student suicides and related mental health crises in educational institutions across India?

Held:

On Transfer of Investigation

• The Supreme Court emphasized that transfer of investigation to the CBI is an extraordinary remedy reserved for exceptional circumstances, guided by precedents including State of West Bengal v. CPDR[ii] and Arnab Goswami v. Union of India[iii].
• Having examined the material, the Court found compelling evidence indicative of ineffective, contradictory, and incomplete investigation by local authorities. Notably:
  • Contradictory CCTV evidence failing to conclusively identify the deceased’s movements.
  • Medical records, autopsy and independent AIIMS Medical Board findings showed a potentially conscious state post-incident ignored by local investigation.
  • Questionable conduct in forensic processes, including premature destruction of viscera, undermining forensic evidence.
  • Alleged institutional apathy and contradictory public statements by police officials.
• The Court set aside the High Court order refusing transfer and directed immediate handover of investigative records to the CBI for a comprehensive, impartial reinvestigation under supervision.

On Mental Health Guidelines in Educational Institutions

• Recognizing a wider social crisis marked by rising student suicides related to academic stress and insufficient support, the Court expressed constitutional and international law imperatives mandating proactive safeguards.
• The Court issued detailed, binding interim guidelines applicable nationwide, including:
  • Mandatory mental health policies and annual reviews by all educational institutions.
  • Appointment of qualified counsellors and targeted mentorship programs.
  • Prohibition on practices like public shaming and excessive academic pressure.
  • Strong anti-harassment, bullying and ragging protocols with zero tolerance for retaliation.
  • Regular sensitization programs for students, staff, parents addressing mental health, emotional well-being and inclusion of marginalized groups.
  • Facility safety measures like tamper-proof ceiling fans and restricted roof access.
  • Special measures for high-risk coaching hubs such as Kota, Jaipur, Vishakhapatnam, Hyderabad, Delhi, etc.
• The Court mandated state rulemaking for private coaching centres, district-level monitoring committees, and timely compliance affidavits by the Union Government, to be reviewed in 90 days.

Holding:

• The appeal was allowed.
• The impugned High Court order rejecting transfer to CBI investigation was quashed; investigation transferred to the CBI forthwith.
• The CBI directed to conduct a fair and thorough investigation and submit reports timely.
• The interim mental health guidelines shall remain binding until replaced by suitable legislation or regulations.
• This judgment emphasizes protection of fundamental rights under Article 21 of the Constitution and a holistic, dignified educational environment for youth.

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[i] 2025 INSC 893

[ii] (2010) 3 SCC 571

[iii] (2020) 14 SCC 12

Authored by Ascend Legal Editorial Team. The opinions expressed are personal and do not constitute any legal advocacy.