In Chikham Amiraju v. Chikham Seshamma, the Madras High Court held that a threat by A to commit suicide, made to get B to execute a release deed, amounted to

Section 15 of the Indian Contract Act, 1872 defines coercion as committing or threatening to commit any act forbidden by the Indian Penal Code. By majority, the Madras High Court held that suicide was such an act, since the IPC punished its attempt (Section 309) and abetment, so the threat was coercion and the release deed could be avoided. Force and pressure are not the Act's terms, and the threat was not abetment, which means instigating another person to do a thing. The IPC was replaced by the Bharatiya Nyaya Sanhita, 2023 (BNS) from 1 July 2024; the BNS has no general offence of attempted suicide and, by Section 226, punishes only an attempt to commit suicide to compel or restrain the exercise of lawful power.