Telangana HC Refuses to Quash FIR Against Journalist and Advocate Accused of Abetting Suicide Through Defamatory YouTube Interview
The High Court for the State of Telangana declined to quash proceedings against a TV journalist and an advocate accused of abetting a young woman's suicide by facilitating and attending a character-assassinating interview uploaded on YouTube.
The High Court for the State of Telangana, in a common order dated 21 April 2026, dismissed two petitions filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) seeking to quash FIR No. 194 of 2026 registered at Pocharam IT Corridor Police Station, Malkajgiri District. The petitioners — Seeloju Shiva Kumar, a practising advocate (Accused No. 7), and Sri Madupathi Vedhanth Swamy, a journalist with Vedhan Media TV (Accused No. 6) — were accused of abetting the suicide of a young woman by conducting and attending a defamatory television interview that was uploaded on YouTube and circulated on social media. Justice J. Sreenivas Rao, sitting singly, held that the allegations in the complaint prima facie disclosed the ingredients of an offence under Section 108 read with Section 3(5) of the Bharatiya Nyaya Sanhita, 2023 (BNS), and that quashing at the threshold was not warranted while investigation remained in progress.
The Events Leading to FIR No. 194 of 2026
The complainant, Respondent No. 2, is the mother of the deceased. She runs a flower business and has two daughters and one son. Her elder daughter, the deceased, was pursuing an M.Sc. degree.
In August 2025, the deceased informed her mother that Accused No. 1 was in love with her and wished to marry her. The complainant, aware that Accused No. 1's father had died of HIV/AIDS in 2008, insisted that both the deceased and Accused No. 1 undergo HIV testing before any marriage proposal was considered. The results showed Accused No. 1 was HIV positive; the deceased tested negative. The deceased thereafter refused to marry Accused No. 1.
On 11 March 2026, Accused No. 1 allegedly entered the deceased's house when she was alone and injected his own blood into her body using a syringe, with the intention of infecting her with HIV. A separate FIR, Crime No. 138 of 2026, was registered against Accused No. 1 at the same police station for an offence under Section 109 of the BNS. Accused No. 1 was arrested in that case.
Following the arrest, the petitioner Seeloju Shiva Kumar (Accused No. 7), in his capacity as a legal practitioner, filed a regular bail application, Crl.M.P. No. 184 of 2026, before the I Additional District and Sessions Judge, Medchal-Malkajgiri District, Kushaiguda, seeking bail for Accused No. 1. That application was dismissed on 1 April 2026.
Shortly thereafter, the petitioner Madupathi Vedhanth Swamy (Accused No. 6), as a journalist for Vedhan Media TV, conducted an interview with Accused No. 2 (the mother of Accused No. 1) and Accused No. 3 (her younger son). The interview was conducted in the presence of Accused No. 7. During the interview, Accused Nos. 2 and 3 allegedly made defamatory and derogatory statements and assassinated the character of the deceased. The video was uploaded on a YouTube channel and circulated on social media platforms.
The deceased, already under severe mental stress and undergoing treatment and counselling at Gandhi Hospital, was subjected to further distress by the social media circulation of the interview and by abusive comments posted by Accused Nos. 8 to 15 on the video. On 10 April 2026, at about 10:30 hours, the deceased left her house, went to her grandmother's residence, and committed suicide by hanging herself from a ceiling fan using a chunni. A five-page suicide note and a self-recorded video were found after her death. The suicide note named the accused persons and set out the reasons for her decision. Based on the complainant's statement, FIR No. 194 of 2026 was registered for the offence under Section 108 read with Section 3(5) of the BNS.
The Petitioners' Case for Quashing
Counsel for Accused No. 7, Seeloju Shiva Kumar, argued that the petitioner had been falsely implicated because of his professional involvement in filing the bail application for Accused No. 1. The only allegation against him, counsel submitted, was that he was present during the interview conducted by Vedhan Media TV. He did not make any statement during the interview and did not provoke or instigate the deceased. Counsel contended that mere presence at an interview, even accepting all allegations at face value, did not satisfy the essential ingredients of abetment under Section 45 of the BNS so as to attract Section 108 of the BNS.
Counsel for Accused No. 6, Madupathi Vedhanth Swamy, adopted the same submissions and added that the petitioner was a journalist acting in the course of his professional duties for Vedhan Media TV. The act of conducting and uploading an interview, he argued, did not by itself constitute instigation or incitement to suicide.
Both petitioners relied on the Supreme Court's decision in Laxmi Das v. State of West Bengal and Others, reported at 2025 SCC OnLine SC 120, which held that mere harassment, strained relations, or isolated utterances are insufficient to constitute abetment to suicide. The Supreme Court in that case required a clear, proximate, and intentional act of instigation or incitement, coupled with mens rea, of a nature that leaves the deceased with no option but to commit suicide.
The State's Response
The learned Additional Public Prosecutor, Mr. Jithender Rao Veeramalla, submitted that the complaint contained specific allegations against both petitioners. The interview was conducted at their instance; Accused Nos. 2 and 3 made statements assassinating the deceased's character; the content was uploaded on YouTube and circulated on social media; and the deceased committed suicide as a direct consequence. The prosecution's case was that the petitioners, along with Accused Nos. 2 to 5, entered into a criminal conspiracy to conduct and disseminate the interview.
The Additional Public Prosecutor placed before the court a copy of the suicide note, in which the deceased specifically mentioned the reasons for taking her own life. He also placed on record statements of Accused Nos. 2, 3 and 5 — the mother, brother, and grandmother of Accused No. 1 — in which the role of the petitioners was specifically mentioned. He submitted that investigation was still in progress and that quashing at this stage was not permissible in a matter involving such serious allegations.
How the Court Reasoned
Justice Sreenivas Rao accepted that the Laxmi Das principle correctly states the law on abetment to suicide: instigation requires a positive act, direct or indirect, with a live link and proximity to the act of suicide, and casual remarks or remote conduct do not ordinarily satisfy the threshold. However, the court held that the principle was not applicable to the facts of the present case.
The court's reasoning turned on the specificity of the allegations. The complaint did not merely allege that the petitioners were present at a gathering or made offhand remarks. It alleged that Accused No. 6 conducted the interview and Accused No. 7 was present throughout; that Accused Nos. 2 and 3 made defamatory statements assassinating the deceased's character in that interview; that the video was uploaded on YouTube and circulated on social media; and that the deceased, already in a fragile mental state following the blood-injection incident, committed suicide as a result. The suicide note, seized by the investigating officer, specifically mentioned the reasons for the deceased's decision. Statements of Accused Nos. 2, 3 and 5 also named the petitioners' roles.
The court held that these allegations, taken at face value, prima facie disclosed the ingredients of an offence under Section 108 read with Section 3(5) of the BNS. The question of whether the allegations were true, and whether the prosecution had material beyond the suicide note and the co-accused statements to link the petitioners to the crime, were matters to be determined during investigation, which was still ongoing.
The court then applied the principles from State of Haryana v. Bhajan Lal and Others (1992 Supp (1) SCC 335) and Neeharika Infrastructure Private Limited v. State of Maharashtra and Others ((2021) 19 SCC 401). From Bhajan Lal, the court recalled that the High Court's jurisdiction under Article 226 of the Constitution and Section 482 of the Code of Criminal Procedure to quash criminal proceedings is limited to exceptional cases — where allegations, even if accepted entirely, disclose no offence, are inherently improbable, legally barred, or manifestly mala fide. From Neeharika Infrastructure, the court drew the principle that the police have a statutory right and duty to investigate cognizable offences, that an FIR is not expected to be an encyclopaedia of all facts, and that “criminal proceedings ought not to be scuttled at their nascent stage.”
Applying these principles, the court found no ground to exercise its quashing jurisdiction. The allegations in the complaint prima facie attracted the offences charged, and the investigation had not yet concluded. The petitioners' argument that their conduct amounted to no more than professional activity — filing a bail application and conducting a news interview — was a matter of defence to be raised before the trial court, not a basis for quashing at the threshold.
Order
Both Criminal Petition Nos. 5635 and 5738 of 2026 were dismissed. Miscellaneous applications pending in the matters, if any, were directed to stand closed. The proceedings in FIR No. 194 of 2026 of Pocharam IT Corridor Police Station, Malkajgiri District, registered for the offence under Section 108 read with Section 3(5) of the BNS, will continue against the petitioners.