This Supreme Court ruling arose from an appeal filed by Nagarajan, who was convicted under Sections 354 (outraging modesty) and 448 (trespassing) IPC for entering the deceased Mariammal’s house at night and attempting to outrage her modesty. Following the incident, the deceased committed suicide with her infant. The Trial Court had acquitted him under Section 306 (abetment to suicide) due to lack of evidence. The High Court, however, not only dismissed his appeal under Sections 354 and 448 but also took up suo motu revision and convicted him under Section 306, enhancing his punishment. The Supreme Court allowed Nagarajan’s appeal in part, holding that he cannot be convicted under Section 306 as there was no evidence of instigation to suicide. Importantly, the Supreme Court laid down the principle of "reformatio in peius," emphasizing that when an accused appeals, the appellate court cannot enhance his sentence or put him in a worse position. This is grounded in fair procedure and natural justice.