What was decided in Chikham Amiraju v. Chikham Sesamma?

The High Court set aside the release deed. A suicide threat used to force consent counted as coercion, so the appeal by defendants failed and the plaintiffs won.

Does a suicide threat amount to coercion under Section 15 ICA?

Yes. The judges reasoned that threatening suicide is an act forbidden by law or treated as such for Section 15; it prejudices the family and vitiates consent.

Was free consent present when the deed was signed?

No. The deed was signed because of a suicide threat by the plaintiffs’ close relative. Consent was not free; it was obtained by coercion.

What legal test should I write in exams?

Ask: Was there a threat/act forbidden by the IPC or unlawful detention of property, intended to make a person agree? If yes, consent is not free (Section 15).

What prejudice did the court recognise?

The real risk of the husband’s death leaving wife and child uncared for. That possibility was enough prejudice to show coercion.

chikham-amiraju-v-chikham-sesamma-coercion-suicide-threat

Chikham Amiraju v. Chikham Sesamma (1917) — Coercion & Suicide Threat

Court: Madras High Court Year: 1917 Citation: 41 Mad. 33 Area: Contract Law — Consent Reading time: ~7 min

Author: Gulzar Hashmi Location: India Publish Date: 26 Oct 2025

PRIMARY_KEYWORDS: coercion, suicide threat, Section 15 ICA SECONDARY_KEYWORDS: free consent, release deed, undue influence vs coercion, Madras High Court

Quick Summary

The dispute was about land held by the defendants. The plaintiffs had earlier proved that an alienation was not binding on reversion. Later, the defendants pressured a close relative, who told the plaintiffs he would end his life unless they gave up their rights. Fearing this, the plaintiffs signed a release deed. They later sued to cancel that deed. The Madras High Court agreed with them: a suicide threat is coercion under Section 15 of the Indian Contract Act. Consent taken that way is not free.

Issues

Was the release deed obtained by coercion or through free consent?
Does a threat to commit suicide fall within “an act forbidden by the IPC” for Section 15?

Rules

Section 15, ICA: Coercion includes committing or threatening to commit any act forbidden by the IPC, or unlawfully detaining/threatening to detain property, with intent to make someone agree.
Consent caused by coercion is not free (Sections 13–14), and the agreement is voidable at the option of the party coerced (Section 19).

Facts (Timeline)

Property Dispute: Land with defendants; plaintiffs claimed through reversionary rights.

Earlier Suit: Alienation held not binding on reversion.

Pressure Applied: Defendants pressured the husband/brother related to the plaintiffs.

Suicide Threat: He told the plaintiffs he would kill himself unless they relinquished their rights.

Release Deed: Plaintiffs signed a deed giving up rights; later sued to set it aside.

Lower Courts: Found that threat was used and that it amounted to coercion; decree for plaintiffs.

Second Appeal: Defendants appealed to the High Court and lost.

Timeline: threat to commit suicide leading to release deed

Arguments

Plaintiffs

Consent came from a suicide threat; therefore, not free.
Threatened act is forbidden by law and causes clear prejudice to wife and child.

Defendants

Denied any threat; deed said to be voluntary.
Argued that suicide threat is not expressly penalised and hence not “forbidden” within Section 15.

Judgment

The High Court dismissed the appeal and upheld the decree for the plaintiffs. The judges held that a suicide threat used to compel a release is coercion under Section 15. One line of reasoning treated the act as forbidden (or necessarily implied as forbidden) by the IPC; another judge held directly that it is an act forbidden by the IPC. The prejudice to the family—risk of death leaving wife and child uncared for—was enough to show coercion. The release deed was set aside.

Ratio Decidendi

A deed signed because of a suicide threat is obtained by coercion under Section 15, ICA. Threatening suicide is treated as an act forbidden by the IPC (or necessarily implied as forbidden). Consent given under such pressure is not free; the deed is voidable.

Why It Matters

Clarifies that non-economic threats, like suicide, can vitiate consent.
Shows courts read Section 15 to protect families from extreme emotional pressure.
Guides practice: releases and settlements must be free of any unlawful threat.

Key Takeaways

Section 15 Scope: Covers threats of acts forbidden by IPC—even when aimed at self-harm.

Prejudice Test: Real risk to spouse/child counts as prejudice.

Remedy: Deed is voidable; courts can set it aside.

Do	Avoid
Check for any unlawful threats affecting consent.	Assuming only physical violence qualifies as coercion.
Record circumstances of signing releases.	Ignoring emotional/extreme pressure signs.
Seek independent advice before executing deeds.	Rushing parties where family pressure exists.

Mnemonic + 3-Step Hook

Mnemonic: “NO FREE WILL = NO FREE DEED.”

Spot the Threat: Suicide or other IPC-forbidden act?
Link to Consent: Was the agreement signed because of that threat?
Apply Section 15: If yes → coercion → deed voidable.

IRAC Outline

Issue

Is a release deed valid when signed after a suicide threat? Does such a threat fall within Section 15 ICA?

Rule

Coercion includes committing or threatening to commit an act forbidden by the IPC, intended to make someone enter an agreement (Section 15).

Application

The plaintiffs signed only after the relative threatened suicide. Courts found the threat real and prejudicial to wife and child. Judges treated the threat as an act forbidden by law (expressly or by necessary implication).

Conclusion

Consent was not free; the release deed was set aside as obtained by coercion.

Glossary

Coercion (ICA s.15): Threat/act forbidden by IPC, or unlawful detention of property, used to force agreement.
Free Consent: Consent not caused by coercion, undue influence, fraud, misrepresentation, or mistake.
Voidable: Valid until the aggrieved party chooses to avoid it; court can set it aside.