A wrongly stated death date on an official certificate, without fraudulent benefit, does not sustain IPC charges.

The appellant applied online, through a Jan Sewa Kendra, for a certificate recording her mother’s date of death as 21 November 2019; the certificate was issued by the competent authority of the Uttar Pradesh Panchayati Raj Department.

Following a complaint by a person unconnected with the appellant, an inquiry found that the death had occurred on 20 November 2019.

An FIR was registered, a charge-sheet was filed, and the Magistrate took cognizance.

The appellant said she had relied in good faith on information from her sister and that the complaint was instigated amid disputes between them.

The date was later corrected, and there was no allegation that the appellant used the certificate to obtain any benefit.

1. Whether the alleged furnishing of an incorrect date of death, resulting in an official certificate, could sustain prosecution of the appellant under Sections 420 or 465 of the Indian Penal Code, 1860

2. Whether, in the circumstances, the criminal proceedings should be quashed

The Court considered Sections 420 and 465 of the Indian Penal Code, 1860, concerning cheating and forgery, respectively.

It held, on the facts of this case, that an incorrect date supplied for an official certificate did not by itself establish an offence under either provision where the certificate was issued by the competent authority, the date was corrected, and there was no allegation that the appellant used it to obtain a benefit.

The Court cited no precedents.

The certificate was issued by the competent Panchayati Raj authority, and the Court found no forgery or criminal breach of trust in its issuance.

Although the date supplied by the appellant was wrong, the Court considered that the one-day discrepancy could have resulted from a mistake.

The date had been corrected, and the appellant was not alleged to have used the certificate to secure any benefit.

In these circumstances, the Court concluded that the facts did not warrant continuing the prosecution under Sections 420 or 465 IPC and that further proceedings would serve no useful purpose.

Any pending applications were rejected.