Aarzoo Challana*
Introduction
Suicide is one of the most important public health concerns, as it ranks as the 17th most common cause of death worldwide. According to the World Health Organization’s estimate, more than 7,20,000 people die due to suicide every year. Although this figure is concerning for all age groups, it is the third highest cause of death for people between the ages of 15 and 29 and is, therefore, considered a greater health risk for young people.
In India, about 35% of all suicides are committed by young people. The National Crime Records Bureau has released data showing that 13,892 student suicides occurred in India in 2023, a record higher than previous years. Even though the courts and legislature are aware of the current situation, the problem remains unsolved because there is still a legislative and regulatory gap in the nation regarding a cohesive, legally binding framework for preventing student suicide at educational institutions, coaching centres, and student-centred settings. The step, in this regard, has been taken by the Hon’ble Supreme Court recently, by releasing guidelines in the case of Sukdeb Saha v. State of A.P., safeguarding the mental health of students in educational settings and recognising the Right to Mental Health as one of the most important fundamental rights, which the State is duty-bound to protect.
This framework, preceding the Saha framework, was not one of inaction as much as one of toothless action. Advisories pertaining to student wellness and ragging prevention were issued by the University Grants Commission, but these could not be considered regulations due to their advisory nature. Institutions could choose to act upon the recommendations or ignore them, as they pleased. Equal Opportunity Cells, as well as institutional mechanisms for grievance redressal, were present in most institutions of higher learning, but in actuality, they existed in name only, and there was no question of institutional accountability regarding their ineffectiveness. Coaching centres, where many cases of student suicide have taken place owing to academic pressure, were not part of this patchwork either. Only some states had laws regarding coaching centres, and those too came after some local tragedy. Most of the coaching centre sector remained unregulated at a national level. It followed that the access of students to the means of protection was dependent more on a particular state or city, or institution that the student may happen to be in, rather than any right. And it is this failure on all fronts of advice without enforceability, supervision without accountability, and an industry devoid of regulation that the Saha guidelines sought to address, and it is in this context that one must assess the importance of these guidelines as mandatory pan-India directions.
The Saha Guidelines: A Framework for Student-Suicide Prevention
The Hon’ble apex court, in the landmark ruling delivered in July, 2025, acknowledged and addressed the gravity of the mental health crisis affecting a large number of the student population across the country. The Saha guidelines marked a significant constitutional evolution in recognising the Right to Mental Health as a facet of the Right to Life. The judgment expanded the interpretation of Article 21 to include mental health, reinforcing that if the students still face the continuum of stress, anxiety, and neglect, they are not able to realise their right to life and dignity.
In what may be called “Saha guidelines,” the Supreme Court, by using its inherent power provided by the Constitution under Article 141, formulated a comprehensive regulatory mechanism to deal with the immediacy of mental health crises and to prevent further loss of lives due to neglect and unplanned interventions. These guidelines require all educational institutions, whether public or private, aided or unaided, to implement a uniform mental health policy, which shall include appointing qualified psychologists and counsellors, refraining from actions that lead to segregation among students, and establishing protocols for immediate referral to mental health services, hospitals, helplines, etc.
Moreover, the Court mandated that every institution shall have robust, confidential grievance mechanisms in place to receive allegations of either harassment or discrimination and shall conduct regular sensitisation programmes for parents on the mental health of students. These guidelines prepared a framework for an annual report detailing the quantity of training sessions, student referrals, wellness initiatives, and actions pertaining to mental health.
Finally, the highest court suggested that all institutions and colleges should endeavour to maintain their campuses as safe and drug-free zones by fitting tamper-proof facilities and limiting access to unsafe zones so as to avoid self-injury. The coaching centres located in highly stressed cities such as Kota, Jaipur, and Hyderabad should always offer counselling sessions, manage stress levels of their students academically and ensure that sufficient support structures are put in place for the well-being of their students. Together, all these instructions and procedures represent a major judicial step towards realising the constitutional provision of the right to mental health (right to life).
The Constitutional Dimension: Article 21 and the Right to Mental Health
The evolving jurisprudence on Article 21 of the Indian Constitution has resulted in widening the ambit and exposure of this fundamental right to include the right to health as an important component. This right includes, among many things, the right to access medical facilities, medications, nutritious food and nutrition, safe air and water, a safe and secure environment, occupational health and safety at work, physical health and reproductive health, maternity and menstrual benefits, mental health and emotional health, etc.
As one of the fundamental rights granted to citizens, the State is obliged by the constitution to guarantee its citizens health care of a certain standard. The responsibility does not stop with care; rather, it entails the duty to create a context that is safe in both a physical and psychological sense that furthers positive mental health and prevents individuals, students in particular, from excessive stress, anxiety and emotional distress.
This is something which has been acknowledged by the judiciary as well. The Court has accepted the fact that mental well-being, psychological autonomy and the lack of being subjected to treatment that would otherwise amount to dehumanisation have been treated as an aspect of human dignity under Article 21 of the Indian Constitution in the cases of Shatrughan Chauhan v. Union of India and Navtej Singh Johar v. Union of India. Besides this, there has also been recognition of the duty on the part of the State in furnishing timely healthcare facilities as a part of Article 21 of the Indian Constitution. In the case of Paschim Banga Khet Mazdoor Samity v. State of West Bengal, the apex court made it clear that the right to life included the right to livelihood, the right to dignity and the right to health. It made an emphasis on the synergy between constitutional rights and the effectiveness of public health institutions. This was further widened in the case of Consumer Education & Research Centre and Others v. Union of India and Others, wherein the court recognised that the right to health is intrinsic to the right to life, and not merely a directive principle to be realised at the convenience of the State.
The Mental Healthcare Act, 2017, is a rights-based statute that formally enshrines this obligation in law; it recognises the right to mental healthcare and the right to freedom from cruel or degrading treatment or behaviour in relation to mental health treatment. It is simple to overstate the importance of the MHCA when reading alongside Sukdeb Saha. The Act already establishes a statutory right to mental healthcare and forbids cruel and degrading treatment in its provision; thus, mental health is not left unattended under Indian law. It does not, however, address institutions in their everyday, preventive capacity, that is, schools, coaching centres, and colleges as locations where mental health crises begin rather than as treatment facilities. Therefore, Sukdeb Saha does not create a new right; rather, it expands an already-existing statutory right into an area where the Act was silent. This distinction is important for determining how comprehensive a solution the guidelines actually are because the MHCA’s own implementation provides a warning example: State Mental Health Authorities under the Act continue to be unevenly constituted and under-resourced across states. This implies that the risk facing the Saha guidelines is not just the lack of legislation but also the same enforcement deficit that has already limited a comparable statutory right. In Common Cause v. Union of India, the Supreme Court treated the Act as authoritative Parliamentary intent even in a situation it did not directly address by drawing directly on its provisions on Advance Directives and its decriminalisation of attempted suicide to formulate guidelines on passive euthanasia. Similar to this, the Delhi High Court had to order an insurer to abide by the MHCA’s non-discrimination provision under Section 21 in Shikha Nischal v. National Insurance Company Limited because the statute’s own regulatory framework had not ensured that compliance on its own. These examples imply that the Saha guidelines are entering a legal environment where the institutional enforcement of the MHCA has already had to be replaced by judicial intervention, rather than one where that enforcement can be presumed.
What was incredibly striking about these cases is the fact that they have the support of the Supreme Court, but they lack any kind of coherent guidelines on student mental health. The policies were unresolved and unpreventive. Only after the Supreme Court’s decision in the Sukdeb Saha case could the courts mandate a level of protection of mental health in schools and establish guidelines regarding the prevention of suicide among students.
Beyond Recognition: A Critical Appraisal of the Saha Judgment
The judgment in Sukdeb Saha highlights the need to be careful of an important and meritorious provision in Article 21. In its broad sense, this Article encompasses the right to the psychological well-being and mental stability of people. The Hon’ble Supreme Court, while delivering its decision in this particular case, has acknowledged the gravity of the student suicide problem in coaching institutes, schools, and colleges throughout India. With this ruling, the Court also established a rights-based strategy to address mental health concerns among Indian students. To fill the gaps in regulations, it required mandatory compliance under Articles 32 and 141 of the Constitution, citing the notable case of Vishaka v. State of Rajasthan. This case is required to be seen because it recognises and upholds a very important principle of international human rights law and standards, covered under Article 24 of the UN Convention on the Rights of the Child and Article 12 of the International Covenant on Economic, Social, and Cultural Rights (ICESCR). Under international law, the court can enforce treaty obligations of the planet, as long as these fundamental principles of human rights have been adopted into Indian constitutional law. This has played a major role in reinforcing that mental health is now a constitutional guarantee instead of just a privilege.
The rights-based model in the Sukdeb Saha ruling has three main advantages. This is an overall view. They have provided preventative measures, and they are very well-integrated in nature. In this way, they stress taking mental issues seriously and tackling them in reality. It is due to the fact that there will be an increase in awareness of mental health in schools, as well as the responsibility of the education system.
Furthermore, these policies are comprehensive. It means that these guidelines take into consideration the fact that students are faced with problems coming from various overlapping categories such as caste, class, gender, sexuality, and disability. Third, through a focus on institutional accountability and an acknowledgement of the failure to prioritise mental health, Sukdeb Saha connects this to applicable legal principles about collective and productive responsibility, as found in Vishaka.
However, the improvements in the Saha Judgment have their limitations as well. Even though the Court’s acceptance of the Right to Mental Health is a significant shift in the constitutional process, unless there is a proper legislative framework to uphold and enforce it, the problems will remain at the ground level. Much like the Vishaka framework, where parliament later passed the (POSH) Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, the Saha guidelines will need institutional compliance and support through a parliamentary law. These guidelines can only be effective if we have strong enforcement measures. The actual value of the Sukdeb Saha ruling will not be in the wording of the law but also in our commitment as a society to protect every student’s mental health as a constitutional promise.
Conclusion and Way Forward
The Sukdeb Saha decision has played a role in involving policymakers, teachers and the general public in the discussion of mental health issues in schools in India. But for this decision to be relevant, it must not be seen as merely a change in policy. The way to follow is to pass a law to address the issue of the mental health of students at the school level with clear expectations, funding, and accountability.
In the meantime, all schools should have grievance redressal cells and psychological support units in their schools. These should operate similarly to the Internal Complaints Committees (ICCs) established under POSH. Moving forward, we need a National Authority for Student Mental Health and regional authorities to provide oversight, standards and a communication channel between schools and government. We need a program that includes the spirit of fraternity as described by the Constitution. We also need a program that teaches empathy, peer support, and community care in our schools. The actual significance of the Saha decision is less about legal mechanisms and regulatory tales and more about the enhancement of an educational system in which higher value is placed on compassion and care than on competition and mastery. And that is only when mental health can become a lived experience and not just a legislative intent.
* The author is a fourth-year law student at Rajiv Gandhi National University of Law, Punjab. The author may be contacted at aarzoochallana23214@rgnul.ac.in.
This blog reflects the personal views of the author and does not necessarily represent the views of The Policy Chronicle.