Decoding the Law and Dilemmas of Suicide: The Sushant Singh Rajput case

The demise of Sushant Singh Rajput, Bollywood actor has created a surge of controversy and debate around the issue of suicide.

Decoding the Law and Dilemmas of Suicide: The Sushant Singh Rajput case

An actor died last week.

Cause of Death: Suicide

The irony of the whole affair comes to haunt us as a crude joke when the last theatrical release of the actor brought him in the light as a champion crusader against suicide and its tendencies. A fact, the 4th pillar of democracy, the ‘Honourable’ media brandishly exploited to spice up its sensationalism around the tragedy.

Sushant Singh Rajput, aged 34, was found hanging from his ceiling 12.30 pm on Sunday, 14th June 2020. The actor considered the bright-star of the current Bollywood landscape, flew away a ‘Sonchiraiya’, his act crucifying us with a debt of guilt and introspection around the topic of Suicide.

An underdog, who epitomized hard work, intellect, and fame, who succumbed under the weight of his own success: at least that is how media puts it when they taunt his sad demise to be a ‘Hit-Wicket’[1]. Is that so? Can an exceptionally talented man with a grit strong enough to forsake his Engineering degree in the last year to pursue his dreams, be termed weak?

Is suicide, a sign of weakness?

Ask the Social media and the TV Anchors, and you would get a rant of mindless rhetoric in affirmation. (Perhaps that is what happens when you are taught [and paid] to bark, but not to think). 

Perhaps they must be reminded, that concepts related to ‘Mental stress’ or ‘Suicide’ were out of the syllabus of their Mass Communication/ Journalism courses. And it would have been much sensible on their part to have sought some expert medical/psychological, sociological (or even sensible) opinion around the issue, if not, have the prudence to go through the respective guidelines laid down by the Press Council of India.

When the news channels are ready to consult the astrologer to determine the ‘grahan’ over Bollywood stars[2] but not dedicate even a pilot investigation into the issue of suicide, perhaps it is time we must re-negotiate over the definition of news and the role of such news channels.

When such circus of sensationalism overshadows the boiling issue at hand with its mockery, the relevance of such an issue becomes far more important to be addressed. The article thus shall be an exposition into the jurisprudence of Suicide.


Did Sushant commit suicide? Possibly Yes.

But what do we know of suicide? Can we claim to attribute his death to suicide without knowing about the concept? And what if suicide is nothing more than an umbrella concept, a compulsorily physical act with no definite mens rea, but can encompass diverse forms and kinds of mens rea? Can we still attribute suicide to be a function of weakness or cowardice?

Are all deaths by suicide, due to weakness of character or will? If that be the case, how can such claimants justify the legacy of the ‘Iron-willed’ Chandra Shekhar Azaad?

We epitomize his sacrifice[3], we revere the Alfred Park (now renamed Chandra Shekhar Azaad Park to commemorate his martyrdom and sacrifice).

Sanatan and Jain traditions have often galvanized certain modes of suicide into acts of valor and path to salvation. Manusmriti, in its Chapter on “The hermit in the forest”, says:

“31. Or let him walk, fully determined and going straight on, in a north-easterly direction, subsisting on water and air, until his body sinks to rest.

32. A Brahmana having got rid of his body by one of those modes (i.e. drowning, precipitating burning or starving) practised by the great sages, is exalted in the world of Brahamana, free from sorrow and fear.”

Lord Ram, the most revered deity in Indian imagination took ‘Jal-Samadhi’. Ma Sita willingly submitted herself to Bhumi in Ramayana. Balaram, the heroic elder brother of Lord Krishna took Jal-Samadhi. Bharbharik, considered one of the strongest warriors to arrive on the battlefield of Kurukshetra, ripped his head off on command of Lord Krishna.  We have countless such examples of valorized ‘suicides’ in our culture and literature.

The Indian law as well as the public discourse acknowledges authoritatively that, “Suicide (felo de se) means deliberate termination of one’s own physical existence or self-murder, where a man of age of discretion and compos mentis voluntarily kills himself. It is an act of voluntarily or intentionally taking one’s own life. Suicide by its very nature is an act of self-killing or self-destruction, an act of terminating one’s own life sans the aid or assistance of any other human agency.” [4]

The definition given by WHO also falls within same lines when it says, “Suicide is the act of deliberately killing oneself.”[5]

If such a definition is taken on its face value, one stands accused of adjudicating the martyrdom of Chandrashekhar Azaad as well as the legacy of our religious, mythological and historic heroes, etc, all to be equated on a same plane with every suicide, and valid for equivalent condemnation as pronounced for Sushant.

Now that seems to be a provocatively blasphemous proposition, but unfortunately, the logic deployed by media as well as the larger public discourse, by attaching stigma around any such death by suicide does not make any distinction or discrimination between ‘self-sacrifice’ and ‘suicide’.

The point I want to elucidate is that the logic of attaching stigma to a death by suicide as ‘hit-wicket’, and glorifying another as a sacrifice, without any substantially reasonable parameters for distinguishing between the two, is at its best- hypocrisy; and at its worst- a fallacy.

One may point out that if one submits oneself to death by suicide for a noble cause, it must be revered. I agree, but unfortunately, the definition given by WHO or Indian Law does not allow a stipulation for any such reverence. Rather the Indian Law goes one step ahead by criminalizing ‘Attempt to Suicide‘ under Section 309 of the Indian Penal Code.

Section 309 IPC: A mockery of Justice

Since there is no means available to punish a successful suicide nor its nature as a criminal act has been explicitly expounded, but a logical inference can be drawn from Section 309, that if an attempt of an act is criminalized, then the act itself must be criminal. Hence suicide is implicitly criminal.

In this context, the remarks of Justice Jahagirdar must be recalled, which he expressed in his article entitled “Attempt At Suicide – A Crime or A Cry“:

“A man commits suicide for various reasons and in diverse circumstances. The aim, in all cases, is to get deliverance from the several real or imaginary misfortunes to which that person is subjected. If he is successful in his attempt, it is regarded as deliverance; if unsuccessful it is regarded as an offence. Survival is an offence. It is impossible to find any rational justification for inflicting a punishment upon a person who has made an attempt to escape punishment which he thinks society is inflicting upon him. Is survival itself not sufficient punishment?

Section 309 was used initially by the British Empire for a variety of purposes from curbing hunger strikes to curtailing the practices of voluntary self-destruction practiced by austere pennants and saints. It could have had relevance in its times, but even at its best it serves as anachronism of our times. It must be noted at this juncture, that the British legal system is an upholder of the Christian morality.

All Abrahamic religions consider suicide a sin. However, in India suicide, as such, was never looked down with abhorrence or condemnation. Rather it was the objective of suicide/self-destruction which would determine if such an act would be granted the status of ‘Supreme Sacrifice’ or a ‘Sin’. For example: How so much we may despise the practices of ‘Johar’ or ‘Sati’ in current times, but in medieval and ancient India, the performance of such acts of suicide/self-destruction was looked up with reverence and adulation.

To have a provision in law that conflates an act of sacrifice and that of suicide to fall under a singular criminal definition of suicide is regressive on jurisprudential front. The section does not prescribe any requirement of criminal intent. Mere an actus reus of such an attempt would constitute sufficient requirement to attract punishment under Section 309.

After the development of medical and psychological sciences, today we have well-documented evidence that suicide, interestingly, is never an act of cowardice or a sign of mental weakness[6]. Suicide is never a choice for its subject, rather it is a call for help. Suicide can be triggered by mental illness, stress as well as several biological and environmental factors.

To punish a man for being a victim of an illness or condition, when he has no say to determine the onset or terminate such illness or condition is a proposition which does not qualify the basic fundamentals of criminal jurisprudence. And that is why time and again demands have been made both from the judicial quarters as well as from the public at large to remove this provision. The 42nd and 210th Law Commission Report recognized such facts and recommended the repeal of this provision. Several High Courts as well as the Supreme Court in many of its judgments have asked for its repeal. But the provision still stands as of June 2020 in spite of the enactment of the Mental HealthCare Act, 2017.

It has been conveniently assumed that Section 115 of the Mental HealthCare Act, 2017 which reads:

“115. Presumption of severe stress in case of attempt to commit suicide.

(1) Notwithstanding anything contained in section 309 of the Indian Penal Code any person who attempts to commit suicide shall be presumed, unless proved otherwise, to have severe stress and shall not be tried and punished under the said Code.

(2) The appropriate Government shall have a duty to provide care, treatment and rehabilitation to a person, having severe stress and who attempted to commit suicide, to reduce the risk of recurrence of attempt to commit suicide.

has had the effect of repealing Section 309. However, a closer reading of Section 115 would tell you, that it is rather a ‘Rule of Evidence’ for Section 309 IPC. Section 115 prescribes a presumption for the Courts that if any case is being brought under Section 309, the Courts shall presume the person to be possessing ‘severe stress’ unless proven otherwise. Hence, if you plan to emulate Chandra Shekhar Azaad’s brave act today, or for that matter want to take ‘Jal-Samadhi’ to fulfill your duties for salvation, if you fail in such an attempt, you would still be booked under Section 309. And even in cases where someone did attempt suicide due to ‘severe stress’ and survived, and is taken to a mental healthcare institution, that again does not bar the law to take recourse under Section 309 against him. He can still be booked under Section 309. He would still have to undergo a trial. And only it is at the trial stage that he can take the benefit of Section 115 of the Mental Healthcare Act, 2017. So, the whole purpose of subjecting such persons to mental healthcare instead of a criminal trial stands defeated.

In fact, this would prevent such persons who attempted suicide from seeking mental healthcare, for any such admission by a person on such grounds, would be serving a fertile case for prosecution under Section 309. It is because of this reason the rate of convictions under Section 309 is 30% as compared to other crimes where it is 10%.[7]

The operation of punishment under Section 309 though, has been barred in the cases of attempt to suicide, wherein it has been triggered by proved ‘severe stress’ (including mental illness), but prosecution under it has not been barred. Thus, the result being that the persons needing mental treatment who are driven to commit suicide, would be prevented from seeking the same for fear of being prosecuted if not punished.

Again, what constitutes ‘stress’ itself is a very subjective question. Strangely the Mental Healthcare Act, 2017 does not define stress and it shall be resting upon the discretion of the Courts on what would be the evidence or parameters it would consider to determine ‘stress’. Even if ‘stress’ has been proved and admitted, it must be established to be of a ‘severe’ nature to claim impunity from the said section.

Normally Courts can and would ideally resort to ‘Expert Opinion’ of Mental Health Experts, Psychologists or Neuro-scientists for determining what could constitute ‘stress’ but such expert opinion shall have only advisory character, as laid down in State of Karnataka v. J. Jayalalitha[8]. The question of admissibility however still remains the prerogative of courts.

A battle in Courts

The Supreme Court and the High Courts have time and again retracted their position when it comes to developing a coherent jurisprudence around Suicide and ‘Right to Life’ under Article 21. From Maruti Dubal[9] case to P.Rathinam[10] case where the Supreme Court declared Section 309 unconstitutional, all the way to Gian Kaur[11] case where it restored the constitutionality of Section 309 on grounds that ‘Right to Life‘ does not include ‘Right to die‘ under Article 21.  In later years it would still uphold the position in Gian Kaur case, with a small stipulation making way for passive euthanasia in the 2011 case of Aruna Shanbaug[12]  and 2018 case of Common Cause[13]. The position as of now stands that Section 309 is still valid, and Right to Life includes ‘Right to Die with Dignity’ but not to commit suicide.

Error of Presumption

Now given the above facts, one conclusion is very obvious on the face of it: The Law of the land while trying to address suicide either through legislation or through judicial discourse has presumed unquestionably that ‘severe’ stress in suicide cases is a logical derivate of clinical mental illness.[14] However that is not even remotely a true picture, if we look at the NCRB data of 2018, only in 17.7% cases the suicides were due to mental illness. If we exclude the 11% cases where the ‘Causes were unknown’, the rest 71.3% deaths by suicide have been more or less due to stress which was instigated by socio-economic environment of such persons, out of which ‘family problems’ happens to be the largest contributor with a share of 30.4%.[15]

The data clearly refutes and betrays the stance of legislation and legal presumption that stress can only be driven by clinical mental illness. It refutes the stand of medical experts who claim that suicide is driven only by severe stress which has a clinical and biological origin. In fact, the socio-economic conditions, as per the data, have shown to be the biggest trigger of suicide.

It is in this context, that answers to potential reasons and causal links to incidents of suicide must rather be investigated more into the domain of sociology than biology or psychiatry.

Émile Durkheim in his widely acclaimed book ‘Suicide‘ published in 1897, diagnosed suicide to be a social fact. According to Durkheim suicide almost always have social origins and is not an individual phenomenon. He said that any suicide must always be looked at from the perspective of the object and intention of such an act. On that basis he classified suicide into 4 broad heads:

  • Egoistic suicide: Where a person’s self-respect is hurt and insulted by the society
  • Altruistic suicide: Where a person commits suicide for a larger purpose or for society’s well-being. (For example: The sacrifice of Chandrashekhar Azaad)
  • Anomic suicide: When there is a collapse of social/economic norms of a person’s environment to such an extent that the person is unable to cope up or fit into the new paradigm. (For example: People who suffer bankruptcy often commit suicide)
  • Fatalistic suicide: When the society imposed its norms and regulations upon the individual forcefully to such an extent that the person believes that such norms and regulations constitute his fate and he feels suffocated bound by them. (For example: Rohit Vemula case, suicide by prisoners and slaves)

Durkheim claimed that suicide increases when society undergoes a transition from a traditional to a modern era. He believed that modern society based on the capitalism model is the most fertile group for breeding depression and deaths by suicide. According to his analysis, modern societies are marked by erosion of family and community ties as well as disintegration of belief in religion. Durkheim, though, himself was an atheist but he appreciated the role religion plays in the life of an individual. Both family and religion, in traditional societies provided for social security. Religion happened to be a powerful unifying force that fostered commune and consolation. But with the capitalist modern society, a shifted focus on individualism, freedom as well as atheism, has made man less social and more ambitious. Man being essentially a social animal and always in search for a place in the paradigm of society, when finds himself misplaced outside such a framework to fend alone, such unfettered position taxes a toll on his mental well-being as well as the perception of his own relevance. Finding himself irrelevant and worthless in the context of his immediate environment and then having no God or community to turn to, he is tempted to pursue a goal of self-destruction.

If we look at the statistics of Suicide Death Rate for the year 2018 from the NCRB reports, Maharashtra is the largest contributor with 13.4%, Tamil Nadu 10.3%, West Bengal 9.9%, Madhya Pradesh 8.8% and Karnataka 8.6% respectively. Now all these states also happen to be the comparatively more urban and developed states in the country. Compared to them, the most populated state of Uttar Pradesh which is still backward (and more traditional) contributes only 3.6%, Bihar even less than 0.5%.[16] So statistically speaking, perhaps the correlation between modern capitalist society and suicide rate, as pointed by Durkheim does hold some relevance. Suicide thus can be comfortably attributed to be a phenomenon of modern society.

Commentary

Sushant Singh Rajput committed suicide, possibly it was a fatalistic (and/or anomic) suicide in nature (as per the reports and given that no suicide note was found). Keeping Sushant as well as other prominent recent cases as our vessel to explore the concept of suicide as a modern social phenomenon, let us delve into the issue:

What can be reasonably deduced from Sushant’s choice of work, the inputs which came in from his personal circle, as well as examining the trajectory of his life, he cannot be accused of lacking grit. With each movie he bravely launched a direct attack on certain quarters of social issues, all the same time, exploring new dimensions of his artwork. Essentially if we look at his graph of work, he can easily be seen as a rebel. From addressing the sensitive topic of the Gujarat massacre and Hindutva brigade pogrom of 2002 in his very first film to Hindu-Muslim unity in Kedarnath, all the way, to a very sensitive topic of Caste-sponsored violence and child rape in Sonchiraiya. In a short span of time, he brought to life many characters, all of which happened to personify a crusade for justice against an unjust social culture.

If we examine the definition of crime: ‘Crime is essentially a man’s revolt against the established social order‘. Whenever a person commits a crime, he is breaking (and challenging) one or the other established law. ‘Nulla poena sine lege’ (No punishment without law) and ‘Nullum crimen sine lege’ (No crime without law), are two fundamental doctrines of criminal law. No act can be attributed as a crime if it has not been explicitly forbidden by law. Interestingly all revered national and international figures have always been essentially rebel. Even peaceful leaders such as Mahatma Gandhi, Nelson Mandela, Ram Manohar Lohiya, Martin Luther King Jr, who were committed to non-violence to the core, were all disrupters to the established order. It is no coincidence that all such legendary figures had to undergo prison sentences at one or the other time in their lives for challenging the dominant social and political norms of the day.

Every established order and social institution is built on the rubble of a redundant order or society. Feudalism was killed by Capitalism which was pushed back and later assimilated with Communism. The Mughal empire was challenged and overtaken by the British, which in turn was exiled away by a surge of Democratic sentiment. All successful revolutions are essentially revolts which gained mass popularity and acceptance. Every revolt was ignited by a rebel who audaciously committed an act that was branded a crime at that time. One can definitely see the sense of such provisions regarding ‘sedition’ and ‘preventive detention’, when one analyses such a discourse of the historical march. The project of building and maintaining an empire (or institution) goes hand in hand with preventing others from doing the same. Crime therefore must be stopped at all costs, as each incidence of crime has the potential to trigger a ‘Domino’ effect which can tear down the established system. One can definitely see how the culpable homicide (or disputable murder) of George Floyd snowballed into a mass-uprising and the ‘Black-Lives Matter‘ movement in America. Each crime punctures a fissure into the illusion of state order, and through that punctured hole, it always offers a different perspective to examine the viability and established divinity of the existing system. No wonder, crime is always seen to be directed against the state and the society as per law.

If we go by this definition, suicide for that matter posses a far more threat to the established system than any other crime. Murder is the most heinous of all crimes, for the sole reason that it garners far more attention and directs a bigger open challenge: the demise of an individual cannot be swept under the carpet or remedied, and the act of such violent demise undermines the invincibility of the social and government system which guarantees the security of life and property to all persons. Suicide thus happens to instigate a far more imposing challenge to the system. Why? Because unlike in cases of murder where there is always a murderer involved, the state or society does not have a soul in cases of suicide, to shift its blame and culpability on such a murderer. In murder, the establishment can still easily bluff its way out by diverting the public from raising questions or disputing the relevance of such an establishment.

A suicide always brings with itself speculation. Its occurrence cannot always be attributed directly to any person or agency. Suicide is a social fact that opens a direct room to question what were the institutional factors which triggered such a person to take such a step. For Durkheim it was Capitalist society, for Rohit Vemula, it was the caste system, for Manav[17] it was the social boycott he faced, for Sushant speculations are being sought into the work culture of the film industry.   

Allegations leveled against every suicide is that it is an act of cowardice. With the infamous Boys’ Locker Room, Manav suicide case[18], similar allegations were leveled up against him by the media as well as the accused girl who instigated the social boycott campaign against him. With Sushant’s case, the television media has pursued the same old rhetoric. Rohit Vemula also suffered the same character assassination from certain political quarters.

Such unfounded and erroneous ad-hominem attacks on the persons who suffer death by suicide, clearly indicates the dearth of any logical explanation of the occurrence of such incidents on part of the society and state. It is analogically similar to victim shaming of women complainants in a patriarchal society, in cases of sexual offenses. A culprit would always point to the follies of its victims to serve as a logical corollary for its victimization and to escape his culpability. Such a play of circular reasoning of blaming the victim for his own victimization has a singular motive of diverting the attack of allegations from the culprit to the victim himself. When state and the wider public discourse engages itself with such ad hominem attacks on suicide victims, it serves both as an acknowledgment of their connivance as well as a deflection tactic to impose their absolvance.

Even if we do consider clinical depression/mental illness to be the cause of suicide, it must be realised that mental stress/depression does not exist in vaccum, devoid of all social conditions. In this context it is relevant to recall the words of Mark Fisher from his book ‘Capitalist Realism: Is there no Alternative‘:

“It goes without saying that all mental illnesses are neurologically instantiated, but this says nothing about their causation. If it is true, for instance, that depression is constituted by lower serotonin levels, what still needs to be explained is why particular individuals have lower levels of serotonin….By privatising these problems- treating the as if they were only caused by chemical imbalances in the individual’s neurology and/or by their family background- any question of social systemic causation is ruled out.”

Suicide for that matter can be rationalized to mean “Institutional Murder”. It is a murder orchestrated by the social paradigm. It is either done for society or it is caused by society, either way, society always plays the role of an abettor in such cases. Thus the culpability of it cannot be attributed to the victim but rather to the social forces which triggered him to take such a step. Most of the suicides happening today are fatalistic and anomic in nature. The regressive social norms, the economic collapse, as well as systematic institutional discrimination are driving up such suicides. Adverse conditions drive a person to limits of depair and worthlessness, where the only way left for him is to challenge such a system.

According to Sellin’s Cultural Conflict theory, the law and social structure reflects only the values of the dominant classes and not of the non-dominant groups, even less, of individuals who don’t subscribe to the dominant discourse. In such a situation, a challenge is issued to the system in the form of vocal criticism, crime, revolt, or rebellion. But if the possibility of such initiatives is negated (which is always the case as the law prohibits such actions which challenge the authority of state or society by laws such as of sedition, preventive detention, special penal laws), the only room available to issue the challenge is by escaping such a system. When the society does not provide enough room for a person to address his dissent or exercise his liberty within its framework; when it fails to provide a consolation of social security, and rather suffocates a person under the weight of its institutional norms: it essentially is providing a whole ecosystem to an individual to pursue the path of suicide. 

Consider, for example, one’s fundamental right to live with dignity guaranteed under Article 21. How relevant is such a guarantee when the procedure to avail it (by approaching Courts under Article 32 or Article 226) happens to be the most expensive and delayed service in the country? And can everybody afford it?

And what if they cannot?

Should they continue suffer the trampling of their rights and dignity?

Or should they fight back?

Or should they escape?

Suicide essentially happens to construe an escape route in fatalistic and anomic situations. And they do challenge the institutional and social norms to introspect and look into their loopholes and excesses. The criminalization of any attempt to suicide under Section 309, is to prevent persons from challenging the overbearing divinity of the dominant social and political norms. No wonder the State would never strike it off the statute book, for the provision itself provides the state a shield to fend off any questions over the institutional violence it imposes. Such repeal would derail the culpability it traditionally and malignantly imposes onto the victim, towards itself.

Acknowledging clinical mental illness (under the Mental HealthCare Act, 2017) to be the only viable explanation for an imputed attempt to suicide, is again just a sugar-coated shadow-image, where the institution is still blaming the victim for such an attempt, without having any dirt on its coat. In fact, as long as any justification provides the institution and society impunity from its culpability, the state has historically been more than willing to acknowledge and incorporate it.  

Conclusion

Was Sushant’s act driven by mental illness?

Was it driven by cowardice?

Or was he trying to rebel against the system?

I believe he rebelled, and he did make his point. His suicide got the country talking and questioning subjects such as toxic workspace environment, institutional violence, systematic discrimination as well as the credibility of social security in one’s personal social space. The media sensationalism is just bogus propaganda to both capitalize on the event and to discredit such an incident of public concern into a mundane tragedy.

However, it must be noted, that though suicide is a revolt, it must not be confused with heroics. It may be revolt for the right reasons or wrong reasons, but at its roots it remains a revolt against society. Sushant revolted. Was he heroic in his actions? We don’t know.

The fact that matters is that he (like any other victim of death by suicide) perhaps do not deserve the stigma or the brunt of public condemnation. If the stigma must exist, it must be directed against the the tormenting and institutionalized paradigm of victimization and not the tormented.

Suicide, after all is the failure of society and not its victim.


[1] Coverage on Aaj Tak on 14th June, 2020
[2] Coverage on Zee News on 14th June, 2020
[3] Chandrashekhar Azad shot himself dead when surrounded by British soldiers to fulfil his vow that he shall not be killed by a British bullet
[4] Point 1.2, Introduction, 210th Law Commission Report on Humanization and Decriminalization of Attempt to Suicide
[5] Suicide, Source Link (accessed on 17th June, 2020)
[6] For more information refer to Source Link
[7] Shiv Sahay Singh, IPC law on suicide is ‘redundant’, say experts reported in The Hindu on December 24, 2019, Source Link (accessed on 17th June, 2020)
[8] (2017) 6 SCC 263
[9] (1986) MhLJ 913 (Bombay High Court)
[10] AIR 1994 SC 1844
[11] AIR 1996 SC 1257
[12] (2011) 1 SCALE 673
[13] (2018) 5 SCC 1
[14] The Mental Healthcare Act, 2017 has a limited ambit where it deals with mental illness which are specifically clinical in nature. For further reference see Section 2(s) of the said Act.
[15] Figure 2.4, Page 7 of Chapter 2 Suicide in India,  Source Link (accessed on 16th June,2020)
[16] Table 2.1, Chapter 2 Suicide in India,  Source Link (accessed on 17 June, 2020)
[17] Manav Singh was a teenager boy, who committed suicide after he was a subject of social media threats, ridicule and boycott after his name falsely cropped up in the hyped Boys Locker Room case of Delhi.
[18] Manya Lohita Ahuja, Social Media Shouldn’t Play Judge And Jury, And 17-Year-Old Manav Singh Is Testament To It reported on 15 May 2020, Source Link  (accessed on 18th June,2020)

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