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Supreme Court of India 2025-09-10 allowed

Jupally Lakshmikantha Reddy vs State of Andhra Pradesh & Anr

Bench: 2 — B.V. Nagarathna, Joymalya Bagchi

In Brief

An educational institution running from a 14.20-metre-high building submitted an allegedly forged Fire NOC to obtain recognition under the School Education Department. The National Building Code (2016) does not require a Fire NOC for buildings below 15 metres. The Supreme Court quashed cheating proceedings, holding that to constitute cheating under Section 420 IPC, a false representation must relate to a material fact and induce the victim to act against their interest. Since the NOC was legally unnecessary, the institution's representation could not have induced the Education Department's decision. Similarly, forgery charges failed as the accused did not manufacture the document and lacked the requisite dishonest intent for wrongful gain or loss.",

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Criminal Law Cheating and Fraud Forgery Educational Law Material Fact Requirement Mens Rea

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