Forgery of record of Court or of public register, etc
Section 337 of the Bharatiya Nyaya Sanhita, 2023 deals with forgery of record of Court or of public register, etc. Whoever forges a document or an electronic record, purporting to be a record or proceeding of or in a Court or an identity document issued by Government including voter identity card or Aadhaar Card, or a register of birth, marriage or burial, or a register kept by a public servant as such, or a cer The Act came into force on 01 Jul 2024.
Whoever forges a document or an electronic record, purporting to be a record or proceeding of or in a Court or an identity document issued by Government including voter identity card or Aadhaar Card, or a register of birth, marriage or burial, or a register kept by a public servant as such, or a certificate or document purporting to be made by a public servant in his official capacity, or an authority to institute or defend a suit, or to take any proceedings therein, or to confess judgment, or a power of attorney, shall be punished with imprisonment of either description for a term which may extend to seven years, and shall also be liable to fine.
Explanation.—For the purposes of this section, "register" includes any list, data or record of any entries maintained in the electronic form as defined in clause (r) of sub-section (1) of section 2 of the Information Technology Act, 2000 (21 of 2000).
Section 337, The Bharatiya Nyaya Sanhita, 2023 (Act 45 of 2023).
Replaces a provision of the Indian Penal Code
IPC 466 Forgery of record of Court or of public register, etc Text carried over almost unchanged 95%
Measured by comparing the text of the two provisions, not taken from an official correspondence table — there is no machine-readable one. See both texts side by side before relying on it.
Both regimes are live. The repealed enactment still governs what happened while it was in force. We never redirect one to the other.
Cross-references
Extracted from the operative text of the enactments themselves. Every destination below exists in our corpus.
Referred to by 4
- Assam Compulsory Registration of Muslim Marriages and Divorces Act s. 18
- Bharatiya Nagarik Suraksha Sanhita, 2023 (Draft stage of translated version) s. 243
- s. 339 Having possession of document described in section 337 or section 338, knowing it to be forged and intending to use it as genuine
- Bharatiya Nagarik Suraksha Sanhita s. 243 Trial for more than one offence
How this offence is classified
From the First Schedule to the Bharatiya Nagarik Suraksha Sanhita, 2023, which classifies every offence under the Sanhita. Cognizable means a police officer may arrest without warrant; bailable means bail is a matter of right rather than of the court's discretion.
| Offence | Punishment | Cognizable | Bailable | Triable by |
|---|---|---|---|---|
| Forgery of a record of a Court or of a Registrar of Births, etc., kept by a public servant. | Imprisonment for 7 years and fine | Non-cognizable. | Non-bailable. | Magistrate of the first class. |
Related judgements & precedents
These are some judgments that construed this section, and hold precedence value. They hold authority on how to read, interpret and use this section.
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Pratap Kumar Choudhury vs The State of Odisha
Decided under Indian Penal Code 466, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
When public servants, particularly police officers whose primary duty is to protect law and order, abuse their official position and commit acts of brutality resulting in death, such offences cannot be compounded even with the agreement of the victim's family and the settlement of compensation, as they constitute violations of fundamental rights under Article 21 of the Constitution and are matters of grave public concern affecting the entire society. The punishment for such violations must be proportionately stringent to have effective deterrent effect and instill confidence in the criminal justice system. However, the fact of settlement and compensation between parties can be considered as a relevant circumstance for determining the quantum of sentence even when compounding is refused.
On this section: Forgery of record - applied in conjunction with Section 471
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Sasikala Pushpa vs The State of Tamil Nadu Rep. by the Inspector of Police
Decided under Indian Penal Code 466, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
A clerical error or incorrect statement regarding date and place in a procedural document like a vakalatnama, where the party admits to the genuine signatures and provides a plausible explanation for the error, does not constitute forgery or fraud upon the court warranting criminal prosecution under Sections 193, 466, 468, and 471 IPC. Fraud requires mens rea (criminal intention) to deceive and cause wrongful gain or loss. Before exercising jurisdiction under Section 340 Cr.P.C. to direct a criminal complaint, the court must be satisfied that it is 'expedient in the interest of justice' by weighing the effect on administration of justice, not merely the injury to a person. A mere incorrect statement in a procedural document that has no bearing on the merits of the case and causes no demonstrable harm to the administration of justice does not justify criminal prosecution.
On this section: Forgery of valuable security; cited as basis for FIR registration
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Suvarna Vijayrao Raskar vs State of Maharashtra
Decided under Indian Penal Code 466, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
Fraud vitiates all orders including those that have attained finality. When a State Government, after examining representations from original landowners and relying on criminal convictions proving fraudulent fabrication of revenue records and manipulation of land ceiling proceedings, exercises its executive power under Article 162 to appoint an Enquiry Officer to investigate the fraud in the larger public interest, such administrative enquiry is not barred by statutory limitation periods or finality of prior orders. An administrative enquiry directing investigation is not an adverse order requiring prior notice and hearing, and constitutional property rights are not immediately affected at the investigative stage. The doctrine that 'fraud unravels everything' operates as exception to statutory limitations and principles of finality in administrative law, particularly when the fraud involves massive wrongful appropriation of agricultural land and violation of landholding ceiling laws.
On this section: Offences of forgery, fabrication of documents, conspiracy and abetment; shareholders were convicted under these sections for fabricating revenue records; Court relied on criminal convictions to establish fraud
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Surinder Kaur vs State of Haryana
Decided under Indian Penal Code 466, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
In criminal trials, particularly where charges rest on circumstantial evidence and expert opinion (such as forensic handwriting analysis), the court must distinguish between proof beyond reasonable doubt and mere suspicion or probability. While hospital records showing interpolations and missing pages may indicate tampering, and while one individual's (Dr. Ravinder Kaur's) direct involvement in issuing false admission slips may be established through credible witness testimony, the involvement of other staff members in a conspiracy to forge records cannot be inferred from handwriting matches alone without clinching evidence of their guilty mind and knowledge of the conspiracy. The standard of proof required in criminal law is significantly higher than establishing suspicion; each accused must be judged on individual evidence establishing their participation in the alleged conspiracy beyond reasonable doubt. Further, charges under Section 13(1)(d) of the Prevention of Corruption Act requiring abuse of official position for illegal gratification cannot be sustained without explicit evidence of demand and acceptance of such gratification.
On this section: Forgery - Applied to forging hospital admission records and bed head tickets by altering genuine documents to create false medical evidence.
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Jasbir Kaur vs State of Haryana
Decided under Indian Penal Code 466, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
In criminal trials, the standard of proof required is proof beyond reasonable doubt, not merely a preponderance of probabilities. Suspicion, however strong, cannot substitute for proof beyond reasonable doubt. Conviction cannot be based on handwriting expert evidence alone without clinching corroborating evidence of guilty mind and direct participation in the criminal act. A public servant's conviction under Section 13(1)(d) of the Prevention of Corruption Act requires proof of taking or obtaining pecuniary advantage or illicit benefit, which cannot be presumed without explicit evidence. Direct evidence of participation and guilty mind is essential to convict co-accused in conspiracy cases, especially where circumstantial evidence does not establish their individual culpability beyond reasonable doubt.
On this section: Applied for forgery - conviction upheld for forging hospital documents including admission slips and bed head tickets
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Madhukar Sadbha Shivarkar (d) by Lrs vs State of Maharashtra & ORS
Decided under Indian Penal Code 466, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
The doctrine that fraud unravels everything operates to negate the bar of limitation prescribed under Section 45(2) of the Maharashtra Agricultural Lands (Ceiling on Holdings) Act, 1961, allowing the State Government to reopen finalized land ceiling proceedings and conduct administrative enquiry into allegations of fabricated revenue records and false sub-leases created to circumvent land ceiling limits. The appointment of an Enquiry Officer to investigate alleged fraud in revenue records is administrative in nature and does not directly affect substantive rights of affected parties at the stage of enquiry initiation, and therefore does not require prior notice and opportunity of hearing. The State Government's executive power under Article 162 of the Constitution extends to conducting such enquiries in matters of larger public interest involving allegations of substantial fraud affecting both the State and original landowners.
On this section: Criminal offences for forgery, fabrication of documents, and conspiracy; charges against which shareholders and others were convicted in criminal proceedings linked to revenue record manipulation
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Balwinder Kaur vs State of Haryana
Decided under Indian Penal Code 466, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
In criminal prosecution, proof beyond reasonable doubt is the required standard, not mere suspicion or preponderance of probabilities. Circumstantial evidence can establish guilt only when the circumstances are of clinching nature and directly point to guilt. Handwriting expert analysis has corroborative value but cannot be the sole basis for conviction. Each accused must have their individual culpability established beyond reasonable doubt; mere suspicion arising from involvement in conspiracy does not warrant conviction. For conviction under Section 13(1)(d) of the Prevention of Corruption Act, pecuniary advantage is an essential ingredient and must be established. Inquiry reports containing hearsay evidence are not sufficient for conviction unless the persons whose version formed the basis of the inquiry are examined and cross-examined.
On this section: Forgery; applied to the act of forging hospital admission and medical records
The holding above is the ratio decidendi as extracted from the judgment by eCourts India, reproduced unaltered — it is a rendering of the court's reasoning, not a substitute for its words. Read the order itself before relying on it.
Judgments citing this section
These may be obiter dicta or a precedent, for you to study. These are the judgments where this section is quoted.
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… (c) A has in his possession several seals, knowing them to be counterfeit and intending to use them for the purpose of committing several forgeries punishable under section 337 of the Bharatiya Nyaya Sanhita, 2023. A may be separately charged with, and convicted of, the possession of each seal under sub-section (2) of section 341 of the Bharatiya Nyaya Sanhita, 2023. (d) With intent to cause injury to B, A institutes a criminal proceeding against him, knowing that there is no just or …
Questions about Section 337
What have the courts held on Section 337 of the Bharatiya Nyaya Sanhita?
Pratap Kumar Choudhury vs The State of Odisha (11 Feb 2021) is the leading judgment on this section among those set out below, though it was decided under IPC 466, which this section replaced -- the court never mentioned this Act: Forgery of record - applied in conjunction with Section 471. Another 6 judgments on this section are set out below, all of them from the Supreme Court. They run from 2014 to 2021.
Is Section 337 of the Bharatiya Nyaya Sanhita bailable?
Non-bailable, under the First Schedule to the Bharatiya Nagarik Suraksha Sanhita, 2023.
Is Section 337 of the Bharatiya Nyaya Sanhita cognizable?
Non-cognizable. "Cognizable" means a police officer may arrest without warrant; "non-cognizable" that they may not. An offence under this section is triable by Magistrate of the first class.
How do I find court cases under Section 337 of the Bharatiya Nyaya Sanhita?
In judgments and charge sheets this section is written several ways, and each form finds a different set of orders. These search the full text of every order eCourtsIndia holds, best matches first: BNS 337, section 337 BNS, section 337 of the Bharatiya Nyaya Sanhita. People searching for it also type bns 337 in ipc and bns 337 2 in hindi. Each opens the full list of orders on eCourtsIndia, where it can be narrowed by court, year and outcome. 7 reported judgments on this section are set out on this page, beginning with Pratap Kumar Choudhury vs The State of Odisha (11 Feb 2021).
What should I read with Section 337 of the Bharatiya Nyaya Sanhita, and has it changed?
4 other provisions in this corpus refer back to it. It carries forward IPC 466 (Forgery of record of Court or of public register, etc), so the judgments decided under that provision are the case law on this one.
When did Section 337 of the Bharatiya Nyaya Sanhita come into force?
Section 337 of the Bharatiya Nyaya Sanhita, cited as BNS 337, came into force on 01 Jul 2024, having been enacted on 25 Dec 2023. It is in force as at the date shown on this page.
Other sections of this Act
- 2. Definitions2199 words
- 356. Defamation1543 words
- 335. Making a false document1318 words
- 101. Murder1177 words
- 303. Theft1104 words
- 3. General explanations858 words
Source and method. Compiled from the enactments of Parliament and of the State legislatures as published on India Code, and republished together with commentary and other original matter under section 52(1)(q)(ii) of the Copyright Act, 1957. Structured, cross-referenced and maintained by eCourtsIndia. Text as in force on 15 Oct 2026. This page is not a substitute for legal advice.