Shriniwas Pandit Dharmadhikari vs. State of Maharashtra, 1980 SC
Facts:
The appellant, Shriniwas Pandit Dharmadhikari, was convicted of offences under Sections 417, 420 read with Section 511, and 471 read with Section 467 of the Indian Penal Code (IPC). He was sentenced to various terms of imprisonment and fined for forging certificates to gain admission to an Arts and Commerce College affiliated with Poona University.
Reasoning:
The Supreme Court of India found that the forged certificates did not qualify as “valuable security” under Section 30 of the IPC.
Conclusion
This landmark case by the Supreme Court established the precedent that a mark-sheet, while important, doesn’t fall under the definition of a valuable security as defined in Section 30 of the IPC. This means that forging a mark-sheet wouldn’t be punishable under Section 467, which deals with forging valuable securities. Therefore, the conviction under Section 471 read with Section 467 was altered to one under Section 471 read with Section 465 of the IPC.