Supreme Court Quashes Proceedings in Forgery Case Due to Lack of Criminal Intent. Incorrect Date on Death Certificate Found to be a Mistake, Not Forgery under IPC Sections 420 and 465.

In Favour of Accused
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Case Note & Summary

The case involved an appeal to quash proceedings against the appellant, who was accused of providing false information and forging a death certificate regarding her mother's date of death. The appellant contended that the date on the certificate was a mistake and that she had applied for the certificate in good faith, believing the date provided by her sister was correct. The complaint was initiated by a third party, leading to an investigation and subsequent charge-sheet filed against the appellant. The court examined the nature of the allegations and determined that the issuance of the certificate by the Competent Authority did not involve any forgery or criminal breach of trust. It noted that the discrepancy in the date of death did not imply any intent to commit an offense under the relevant sections of the Indian Penal Code. Ultimately, the court concluded that continuing the prosecution would not serve any useful purpose and quashed the proceedings against the appellant, allowing the appeal.

Headnote

Criminal Law - Quashing of Proceedings - No Criminal Intent Established - Indian Penal Code, 1860, Sections 420, 465 - The court found that the appellant's submission of a death certificate with an incorrect date did not constitute forgery or false information as there was no intent to deceive or gain benefits. The court quashed the proceedings, stating that continuing the prosecution would serve no useful purpose (Paras 5-6).

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Issue of Consideration

Whether the prosecution against the appellant for forgery and false information should continue.

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Final Decision

The Supreme Court quashed the proceedings in Case No.16720 of 2024, arising from Crime No.94 of 2024, stating that no useful purpose would be served in continuing the prosecution.

Law Points

  • Quashing of proceedings
  • false information
  • forgery
  • Indian Penal Code
  • 1860
  • Section 420
  • Section 465
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Case Details

2026 LawText (SC) (10) 57

Criminal Appeal No.4902 of 2026 [ @ Special Leave Petition (Crl.) No.6715 of 2026 ]

2026-10-12

J. B. Pardiwala J. , K. Vinod Chandran J.

2026 INSC 1119

Pooja

State of U.P. & Anr.

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Nature of Litigation

Criminal appeal to quash proceedings for forgery and false information.

Remedy Sought

Appellant sought to quash the proceedings against her.

Filing Reason

Allegations of providing false information and forgery regarding a death certificate.

Issues

Whether the prosecution for forgery and false information should continue. Whether the appellant had criminal intent in submitting the death certificate.

Submissions/Arguments

The appellant argued that the date was a mistake and she acted in good faith. The prosecution contended that the incorrect date constituted forgery.

Ratio Decidendi

The court held that the mere submission of a death certificate with an incorrect date did not amount to forgery or false information under the Indian Penal Code, as there was no intent to deceive.

Judgment Excerpts

The allegation is that the appellant deliberately gave false information and forged the death certificate of her mother. That the wrong date was furnished cannot lead to an allegation of an offence under Section 420 or Section 465 of the Indian Penal Code, 1860.

Procedural History

The appellant filed a criminal appeal to quash the proceedings initiated against her for alleged forgery and false information regarding a death certificate.

Acts & Sections

  • Indian Penal Code, 1860: Section 420, Section 465
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