2 June 2025 Legal Updates

MERE SCOLDING OF STUDENT NOT ABETMENT OF SUICIDE: SUPREME COURT DISCHARGES TEACHER IN S.306 IPC CASE

(a) Case Title:

• Thangavel v. The State, Through Inspector of Police & Anr.

(b) Court:

• Supreme Court of India

(c) Date of Decision:

• May 22, 2025

(d) Bench:

• Justice Ahsanuddin Amanullah and Justice Prashant Kumar Mishra

Facts of the Case

The appellant, Thangavel, was a school correspondent (administrator) in charge of running both a school and hostel. A tragic incident occurred where a student died by suicide after being scolded by Thangavel. The scolding happened because another student had complained against the deceased student, and Thangavel, in his capacity as the correspondent, reprimanded the deceased student. Following this incident, the deceased student locked himself in a room and hanged himself with a nylon rope.

Legal Issue

The primary legal question was whether Thangavel could be charged under Section 306 of the Indian Penal Code (IPC), which deals with abetment of suicide. The prosecution alleged that his scolding constituted abetment that led to the student's suicide.

Court's Analysis

The Supreme Court examined whether the appellant possessed the necessary mens rea (criminal intent) required for the offense under Section 306 IPC. The Court noted several key factors:

• The scolding was based on a legitimate complaint made by another student
• As a school correspondent, Thangavel had a duty to address such complaints and maintain discipline
• The response was proportionate - it was merely a reprimand, not excessive punishment
• There was no personal animosity between the appellant and the deceased
• No reasonable person could have foreseen that such ordinary disciplinary action would lead to suicide

Court's Decision

The Supreme Court allowed the appeal and discharged Thangavel from all charges under Section 306 IPC. The Court held that under the admitted facts, no mens rea could be attributed to the appellant regarding abetment of suicide.

Key Legal Principles

• Mens Rea Requirement: For Section 306 IPC (abetment of suicide), the prosecution must prove criminal intent to abet suicide
• Reasonable Foreseeability: The accused's actions must be such that a reasonable person would foresee the possibility of suicide
• Duty vs. Criminal Intent: Performing legitimate duties (like maintaining school discipline) cannot constitute criminal abetment without clear intent
• Proportionality: The nature and severity of the alleged abetting act matters in determining criminal liability

DIVORCED WIFE REMAINING UNMARRIED ENTITLED TO MAINTENANCE REFLECTIVE OF STANDARD OF LIFE SHE HAD DURING MARRIAGE: SUPREME COURT

(a) Case Title:

• Rakhi Sadhukhan v. Raja Sadhukhan

(b) Court:

• Supreme Court of India

(c) Date of Decision:

• May 29, 2025

(d) Bench:

• Justice Vikram Nath and Justice Sandeep Mehta

Key Facts

The parties were married on June 18, 1997, with a son born on August 5, 1998. In 2008, the husband filed for divorce under Section 27 of the Special Marriage Act, 1954, alleging cruelty by the wife. The Trial Court initially dismissed the divorce petition in 2016, finding that cruelty was not proven. The Calcutta High Court reversed this decision in 2019, granting divorce on grounds of mental cruelty and irretrievable breakdown of marriage

High Court's Original Order (2019)

The High Court awarded permanent alimony of Rs. 20,000 per month to the wife with 5% increase every three years. It also transferred the matrimonial flat to wife's name and provided for educational expenses for the son

Issue:

The wife appealed specifically challenging the quantum of alimony.

Supreme Court decision

The Supreme Court enhanced permanent alimony from Rs. 20,000 to Rs. 50,000 per month and modified the increment cycle from every 3 years to every 2 years (5% increase). It discontinued mandatory financial support for the 26-year-old son and clarified that the son's inheritance rights remain unaffected

Legal Principles Established

• Standard of Living Test: Maintenance should reflect the standard of living enjoyed during marriage
• Inflation Adjustment: Courts must consider rising costs of living when determining alimony
• Financial Capacity Assessment: Husband's actual income and financial disclosures are crucial factors
• Adult Children: No mandatory support required for financially independent adult children
• Sole Financial Dependence: When maintenance is the wife's only source of income, higher amounts are justified

DELHI HIGH COURT PROTECTS PERSONALITY RIGHTS OF SADHGURU, PASSES JOHN DOE ORDER RESTRAINING MISUSE THROUGH AI

(a) Case Title:

• Sadhguru Jagadish Vasudev & Anr. v. Igor Isakov & Ors.

(b) Court:

• Delhi High Court

(c) Date of Decision:

• May 30, 2025

(d) Bench:

• Hon'ble Mr. Justice Saurabh Banerjee

Background

Sadhguru Jagadish Vasudev (a globally renowned spiritual leader and founder of Isha Foundation) filed a suit against multiple defendants for unauthorized use of his personality rights through AI-generated deepfake content.

Key Facts

Nature of Infringement: Defendants created deepfake content using AI tools to morph Sadhguru's voice, image, and likeness for: Financial scams (fake investment platforms), Product endorsements (hair products, pregnancy books) and unauthorized spiritual content on YouTube channels

Legal Issues

• Personality Rights Violation: Unauthorized commercial use of name, image, voice, and likeness
• Deepfake Technology Misuse: AI-generated content creating false endorsements
• Commercial Exploitation: Using Sadhguru's reputation for financial gain without consent

Court's Decision

The Delhi High Court granted a "Dynamic+" injunction - a modern form of injunctive relief designed to combat rapidly evolving online infringement.

Key Orders:

Restraint on Primary Defendants (1-41, 48): Prohibited from using Sadhguru's personality rights without written authorization

Platform-Specific Directions:

• Domain registrar to suspend infringing websites
• Twitter/X to take down fake NFT accounts
• Instagram to disable product promotion accounts
• YouTube to suspend channels with infringing content
• Government Authorities (DoT & MEITY): Directed to issue notifications for blocking infringing platforms
• Future Infringements: Plaintiffs can approach YouTube directly for takedown within 36 hours of discovery

Legal Significance

• Personality Rights Protection: Recognized unique personality traits (voice, appearance, articulation style) as protectable rights
• Technology and Law Interface: Court acknowledged challenges posed by AI and deepfake technology
• Dynamic+ Injunction: Preventive measure against "hydra-headed" websites that resurface with minor changes
• Irreparable Harm: Emphasized that misuse of spiritual leader's persona affects public trust and consumer protection

Important Legal Concepts

• Personality Rights: Individual's right to control commercial use of their identity
• Passing Off: Misrepresentation leading to confusion about source/endorsement
• Interim Injunction: Temporary restraint pending final trial
• Dynamic Injunction: Evolving court orders to address technological challenges
• Ex Parte Relief: Court action without hearing the other party (in urgent cases)