Forgery Alone Doesn’t Amount To Cheating Under Section 420 IPC: Supreme Court

The Supreme Court has ruled that forgery alone does not constitute cheating under Section 420 IPC unless the forged document is used to induce the delivery of property or pecuniary benefit.

The Court quashed cheating charges against an accused who created a forged NOC but had not used it to obtain any benefit, stressing that inducement and dishonest intent are essential for conviction.

The Court held that offences under Section 468 IPC and Section 471 IPC are not attracted, as the requisite mens rea, i.e., to cause wrongful loss to the Education Department or wrongful gain to the accused, was not established.

[Jupally Lakshmikantha Reddy Versus State of Andhra Pradesh & Anr.]