The Supreme Court of India’s judgment in Sukdeb Saha v. State of Andhra Pradesh & Ors.[2025 INSC 893] delivered on July 25, 2025, is a landmark decision that operates on two critical levels. Primarily, it addresses the specific appeal of a father seeking a fair investigation into the suspicious death of his daughter, a NEET aspirant in a coaching hub. Concurrently, it confronts the escalating national crisis of student suicides
This analysis examines both facets of this pivotal judgment.
A case of investigative failure
The case was brought up by Sukdeb Saha after his 17-year-old daughter, Ms. X, died after a fall from her hostel building in Vishakhapatnam, where she was enrolled in a coaching institute. The appellant’s plea to the Supreme Court was precipitated by a series of glaring deficiencies and contradictions in the local police investigation, which led him to lose faith in the state machinery and seek a transfer of the case to the Central Bureau of Investigation (CBI).
The Court documented the investigative lapses, which collectively painted a picture of an inquiry that was, at best, ineffective and, at worst, designed to obscure the truth. Key failures identified by the Court included:
- The unsubstantiated suicide theory: The police hastily concluded the death was a suicide without a suicide note, psychological history, or corroborating witness statements, a conclusion the Court deemed a “post-facto justification.”
- Contradictory CCTV evidence: Footage showed a discrepancy in the clothing of the girl seen going to the terrace and the victim found on the ground, a contradiction the police made no effort to reconcile.
- Misrepresentation of medical state: The police and hospital claimed the victim was unconscious upon admission, but an AIIMS medical board report and eyewitness accounts confirmed she was conscious and responsive, indicating a missed opportunity to record her statement.
- Conflict of interest: A single medical officer served as the autopsy surgeon, the chemical analyst, and a member of the internal inquiry committee, an “egregious conflict of interest” that compromised the investigation’s integrity.
- Destruction of forensic evidence: The victim’s viscera were prematurely destroyed by the forensic lab before a court-mandated DNA comparison could be completed, an act that “irrevocably compromised the proceedings.”
- Withholding key reports: The authorities failed to produce the Chemical Analysis Report and the final opinion on the cause of death, documents of “foundational evidentiary value.”
Based on this litany of failures, the Court concluded that the case met the “compelling necessity” standard required for transferring an investigation. It held that a CBI probe was essential to ensure impartiality, restore public confidence, and deliver justice to the bereaved family.
1. The Sukdeb Saha Guidelines for Student Well-being
The judgment’s second, and more far-reaching, part transitions from the specific case to the systemic issue of student mental health. The Court framed the rising number of student suicides—over 13,000 in 2022 according to NCRB data—as a “deepening crisis” and a “systemic failure” of an education system that prioritizes relentless competition over holistic well-being.
Drawing a parallel to its intervention in Vishaka v. State of Rajasthan[(1997) 6 SCC 241], where it filled a legislative vacuum on workplace sexual harassment, the Court invoked its powers under Article 141 of the Constitution to issue binding interim guidelines. It grounded these guidelines in the constitutional “Right to Mental Health” as an integral part of the Right to Life under Article 21, as well as India’s international law obligations.
The following 15 guidelines were issued, establishing a preventive and supportive framework applicable to all educational institutions across India until a formal legislative framework is enacted.
The Guidelines
The following are the exhaustive guidelines as laid down by the Supreme Court in the judgment:
- All educational institutions shall adopt and implement a uniform mental health policy, drawing cues from the UMMEED [Understand, Motivate, Manage, Empathise, Empower, Develop] Draft Guidelines, the MANODARPAN initiative, and the National Suicide Prevention Strategy. This policy shall be reviewed and updated annually and made publicly accessible on institutional websites and notice boards of the institutes.
- All educational institutions with 100 or more enrolled students shall appoint/engage at least one qualified counsellor, psychologist, or social worker with demonstrable training in child and adolescent mental health. Institutions with fewer students shall establish formal referral linkages with external mental health professionals.
III. All educational institutions shall ensure optimal student-to-counsellor ratios. Dedicated mentors or counsellors shall be assigned to smaller batches of students, especially during examination periods and academic transitions, to provide consistent, informal, and confidential support.
- All educational institutions, more particularly the coaching institutes/centres, shall, as far as possible, refrain from engaging in batch segregation based on academic performance, public shaming, or assignment of academic targets disproportionate to students’ capacities.
- All educational institutions shall establish written protocols for immediate referral to mental health services, local hospitals, and suicide prevention helplines. Suicide helpline numbers, including Tele-MANAS and other national services, shall be prominently displayed in hostels, classrooms, common areas, and on websites in large and legible print.
- All teaching and non-teaching staff shall undergo mandatory training at least twice a year, conducted by certified mental health professionals, on psychological first-aid, identification of warning signs, response to self-harm, and referral mechanisms.
VII. All educational institutions shall ensure that all teaching, non-teaching, and administrative staff are adequately trained to engage with students from vulnerable and marginalised backgrounds in a sensitive, inclusive, and non-discriminatory manner. This shall include, but not be limited to, students belonging to Scheduled Castes (SC), Scheduled Tribes (ST), Other Backward Classes (OBC), Economically Weaker Sections (EWS), LGBTQ+ communities, students with disabilities, those in out-of-home care, and students affected by bereavement, trauma, or prior suicide attempts, or intersecting form of marginalisation.
VIII. All educational institutions shall establish robust, confidential, and accessible mechanisms for the reporting, redressal, and prevention of incidents involving sexual assault, harassment, ragging, and bullying on the basis of caste, class, gender, sexual orientation, disability, religion, or ethnicity. Every such institution shall constitute an internal committee or designated authority empowered to take immediate action on complaints and provide psycho-social support to victims. Institutions shall also maintain zero tolerance for retaliatory actions against complainants or whistle-blowers. In all such cases, immediate referral to trained mental health professionals must be ensured, and the student’s safety, physical and psychological, shall be prioritised. Failure to take timely or adequate action in such cases, especially where such neglect contributes to a student’s self-harm or suicide, shall be treated as institutional culpability, making the administration liable to regulatory and legal consequences.
- All educational Institutions shall regularly organise sensitisation programmes (physical and/or online) for parents and guardians on student mental health. It shall be the duty of the institution to sensitise the parents and guardians to avoid placing undue academic pressure, to recognise signs of psychological distress, and to respond empathetically and supportively. Further, mental health literacy, emotional regulation, life skills education, and awareness of institutional support services shall be integrated into student orientation programmes and co-curricular activities.
- All educational institutions shall maintain anonymised records and prepare an annual report indicating the number of wellness interventions, student referrals, training sessions, and mental health-related activities. This report shall be submitted to the relevant regulatory authority, which may be the State Education Department, University Grants Commission (UGC), All India Council for Technical Education (AICTE), Central Board of Secondary Education (CBSE), or as otherwise indicated.
- All educational institutions shall prioritise extracurricular activities, including sports, arts, and personality development initiatives. Examination patterns shall be periodically reviewed to reduce academic burden and to cultivate a broader sense of identity among students beyond test scores and ranks.
XII. All educational institutions, including coaching centres and training institutes, shall provide regular, structured career counselling services for students and their parents or guardians. These sessions shall be conducted by qualified counsellors and shall aim to reduce unrealistic academic pressure, promote awareness of diverse academic and professional pathways, and assist students in making informed and interest-based career decisions. Institutions shall ensure that such counselling is inclusive, sensitive to socio-economic and psychological contexts, and does not reinforce narrow definitions of merit or success.
XIII. All residential-based educational institutions, including hostel owners, wardens and caretakers, shall take proactive steps to ensure that campuses remain free from harassment, bullying, drugs, and other harmful substances, thereby ensuring a safe and healthy living and learning environment for all students.
XIV. All residential-based institutions shall install tamper-proof ceiling fans or equivalent safety devices, and shall restrict access to rooftops, balconies, and other high-risk areas, in order to deter impulsive acts of self-harm.
- All coaching hubs, including but not limited to Jaipur, Kota, Sikar, Chennai, Hyderabad, Delhi, Mumbai, and other cities where students migrate in large numbers for competitive examination preparation, shall implement heightened mental health protections and preventive measures. These regions, having witnessed disproportionately high incidents of student suicides, require special attention. The concerned authorities, namely, the Department of Education, District Administration, and management of educational institutions, shall ensure the provision of regular career counselling for students and parents, regulation of academic pressure through structured academic planning, availability of continuous psychological support, and the establishment of institutional mechanisms for monitoring and accountability to safeguard student mental well-being.
2. Enforcement and accountability
To ensure these guidelines are not merely advisory, the Court established a robust, time-bound enforcement and accountability mechanism:
- State-level action: All States and Union Territories were directed to notify rules for the registration and regulation of private coaching centers within two months, incorporating the mental health safeguards.
- District-level oversight: A District-Level Monitoring Committee, chaired by the District Magistrate/Collector, should be constituted in every district to oversee implementation, conduct inspections, and handle complaints.
- Central accountability & judicial supervision: The Union of India was directed to file a compliance affidavit within 90 days. The Supreme Court has retained supervisory jurisdiction, listing the matter for a follow-up hearing on October 27, 2025, to review compliance.
In conclusion, the Sukdeb Saha judgment is a powerful judicial intervention that addresses both an individual plea for justice and a national social crisis. It sets a new precedent for holding institutions accountable for the mental well-being of students and provides a comprehensive, actionable framework to foster safer and more supportive educational environments across India. However, whether this will materialise into effective implementation, that too in the face of powerful coaching and education business lobby across India is yet to be seen.
(The author is part of the legal research team of the organisation)
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