Sentence for Forged Document Used in Court Can Be Reduced When Convict Faced Decade-Long Trial and Has No Criminal Antecedents: Supreme Court

Case Name: Israfil @ Pappu @ Naimuddin Khan v. State of Madhya Pradesh

Citation: 2026 INSC 654

Date of Judgment/Order: 23 June 2026

Bench: Prashant Kumar Mishra, J. and N.V. Anjaria, J.

Held: The Supreme Court held that offences involving forgery and use of forged documents in judicial proceedings are serious and cannot be viewed lightly, but sentencing must still remain proportionate to the facts of the case, the role of the accused, the period of custody already undergone, the passage of time and other mitigating circumstances. The Court held that where the incident was old, the accused had faced criminal proceedings for more than a decade, no criminal antecedents or repeated conduct were shown, and the forged document was detected at the threshold stage without causing irreversible pecuniary or proprietary consequence, the sentence could be reduced while maintaining the conviction.

Summary: The appellant was convicted under Sections 420, 467, 468 and 471 IPC for producing a forged Bhu Adhikar Rin Pustika before a Judicial Magistrate at Rewa for furnishing surety in bail proceedings. The Trial Court sentenced him to rigorous imprisonment for five years on each count with fine, and the Madhya Pradesh High Court affirmed the conviction and sentence. Before the Supreme Court, notice was issued only on the question of sentence, and therefore the conviction itself was not under consideration. The appellant argued that the occurrence was of 2014, he had undergone criminal proceedings for over ten years, he was not a habitual offender and no subsequent criminal antecedents were shown. The State opposed leniency on the ground that use of a forged revenue document before a court strikes at the purity of administration of justice. The Supreme Court accepted the seriousness of the offence but applied the principle of proportionality, noting that the case did not involve organised crime, large-scale economic fraud, systematic forgery affecting public institutions or recurring deception causing widespread loss.

Decision: The Supreme Court partly allowed the appeal by maintaining the appellant’s conviction under Sections 420, 467, 468 and 471 IPC, but reducing the substantive sentence to the period already undergone. The fine imposed by the Trial Court and affirmed by the High Court was left unaltered. The Court directed that the appellant be released forthwith, if not required in any other case, subject to deposit of the fine if not already paid.