Author: Sneha Ghosh
College: Dept. of Law, University of Calcutta
To The Point
Educational institutions occupy a unique position in the constitutional framework. The IIT Bombay case has brought this institutional responsibility into sharp focus.
Sahil Wakode, a second-year B.Tech student, died by suicide on 18 September 2026, after an examination in which he was found using a mobile phone and accessing ChatGPT. Professor Suryanarayana Doolla was reportedly the invigilator during the examination. Wakode’s parents subsequently alleged that their son had experienced caste-based discrimination and casteist remarks. These allegations resulted in the invocation of the SC/ST (Prevention of Atrocities) Act, 1989 against Professor Doolla. An FIR sets criminal law in motion; it does not constitute proof of guilt. The prosecution must ultimately establish the statutory ingredients of each alleged offence through legally admissible evidence.
Use of Legal Jargon
The SC/ST Act is a special penal legislation enacted to prevent atrocities against members of Scheduled Castes and Scheduled Tribes and to provide special courts and protective mechanisms for victims. Section 3(1)(r) states intentional insult or intimidation with intent to humiliate a member of an SC/ST community in any place within public view and Section 3(1)(s) of the act addresses abusing a member of an SC/ST community by caste name in any place within public view. Under the Bharatiya Nyaya Sanhita, 2023, Section 108 provides the offence of abetment of suicide. The legal inquiry is not simply whether a person engaged in conduct that preceded a suicide.The prosecution must establish the ingredients of abetment, including the requisite mental element and a legally sufficient nexus between the accused’s conduct and the suicide. The investigation into Wakode’sdeath is therefore examining the entire chain of events rather than merely the examination incident. CCTV footage, digitalevidence, witness statements and the student’s communications may become relevant in reconstructing that chain.
The right to life under Article 21 encompasses dignity and personal liberty. Educational institutions exercising significant authority over students therefore carry substantial responsibilities concerning the preservation of a safe and dignified educational environment.
The Proof
Potential evidentiary material may include CCTV footage, examination records, invigilation reports, electronic and digital evidence, mobile-phone data, statements of classmates and faculty members, family members, forensic evidence.
Abstract
The death by suicide of IIT Bombay student Sahil Wakode on 18 September 2026 has raised significant questions concerning academic discipline, institutional accountability, student welfare, caste-based discrimination and the criminal liability of faculty members. The controversy intensified after Wakode’s parents alleged that he had faced caste-based discrimination and harassment and named IIT Bombay Professor Suryanarayana Doolla in their complaint. An FIR was subsequently registered invoking provisions relating to abetment of suicide and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (“SC/ST Act”). Professor Doolla has been sent on leave, and the Mumbai Crime Branch is separately investigating the circumstances surrounding the death. The Institute has also apologised for an earlier communication concerning the circumstances of Wakode’s death, stating that the relevant facts remain under investigation.
Case Laws
A. Hitesh Verma v. State of Uttarakhand (2020) 10 SCC 710
The Supreme Court held that an insult involving an SC/ST person does not automatically attract the SC/ST Act. The prosecution in the IIT Bombay case must establish the ingredients of the specific SC/ST Act offences alleged.
B. Swaran Singh v. State (2008) 8 SCC 435
The Supreme Court considered the expression “within public view” and distinguished it from the broader expression “public place.” The circumstances and witnesses surrounding any alleged caste-based remarks become legally significant.
Conclusion
The IIT Bombay student suicide case presents a complex intersection of criminal law, caste justice, institutional accountability, academic discipline and constitutional rights.
The invocation of the SC/ST Act against Professor Suryanarayana Doolla places the allegations within a specialised statutory framework designed to protect members of Scheduled Castes and Scheduled Tribes against caste-based atrocities. However, registration of an FIR is the beginning of investigation and not a judicial determination of guilt.
The Supreme Court’s jurisprudence, particularly Hitesh Verma, demonstrates that the statutory ingredients of the alleged offence must be established through evidence.
At the institutional level, IIT Bombay’s subsequent apology, constitution of a 10-member inquiry committee and decision to send Professor Doolla on leave demonstrate an attempt to separate administrative responsibilities from the ongoing investigation. Neither the tragic death of a student nor the seriousness of caste discrimination should be diminished. Equally, criminal liability cannot be determined through public pressure, institutional solidarity or media narratives.
The appropriate course is a fair, independent, evidence-based investigation, followed by determination of liability strictly in accordance with the SC/ST Act, the Bharatiya Nyaya Sanhita and constitutional provisions.
FAQs
1. Does registration of an FIR under the SC/ST Act mean that the professor is guilty?
No. An FIR records allegations and initiates investigation. Guilt must be established through the criminal justice process.
2. Can academic disciplinary action amount to an offence under the SC/ST Act?
Not automatically. The prosecution must establish the specific statutory ingredients of the offence, including the caste-related element where required.
3. What is significant about Section 3(1)(r) of the SC/ST Act?
It concerns intentional insult or intimidation of an SC/ST person with intent to humiliate on the ground of caste in any place within public view.
4. Why was Professor Doolla sent on leave?
Reports state that IIT Bombay sent him on leave while the investigation was underway, facilitating an impartial inquiry. This administrative step should not itself be treated as a finding of criminal guilt.
5. What is the most important legal issue in the SC/ST Act aspect of the case?
The central issue will be whether the evidence ultimately establishes the essential ingredients of the particular SC/ST Act offences invoked, rather than merely establishing that the student belonged to an SC/ST community or that an academic dispute occurred.
