The Supreme Court has reduced the sentence of a man convicted for using a forged land record document to furnish surety in a bail proceeding, while affirming his conviction under Sections 420, 467, 468 and 471 of the Indian Penal Code.

A Bench of Justice Prashant Kumar Mishra and Justice N. V. Anjaria held that although offences involving forgery and use of forged documents in judicial proceedings are serious and strike at the sanctity of the justice delivery system, sentencing must remain proportionate to the facts and circumstances of each case.

The case arose from an incident in 2014 when the appellant allegedly produced a forged Bhu Adhikar Rin Pustika (Land Rights and Loan Book) before a Judicial Magistrate in Rewa, Madhya Pradesh, to stand as surety for an accused seeking bail. During scrutiny, irregularities in the document were noticed, leading to registration of an FIR and subsequent prosecution. The Trial Court convicted the appellant and sentenced him to five years' rigorous imprisonment under each count, with sentences running concurrently. The conviction and sentence were later affirmed by the Madhya Pradesh High Court.

The Court noted that forgery-related offences cannot be viewed lightly, especially when forged documents are used before a court of law. However, it emphasized that sentencing must take into account mitigating factors such as the passage of time, the offender's background, and the overall degree of criminality involved.

The Bench observed that:

• The incident occurred in 2014 and the appellant had faced criminal proceedings for more than a decade.

• No material was placed before the Court showing that he was a habitual offender or had engaged in similar criminal conduct thereafter.

• The forged document was detected at the threshold stage and did not ultimately result in any irreversible pecuniary or proprietary loss.

• The case did not involve organized crime, large-scale economic fraud, or systematic forgery affecting public institutions.

The Court further noted that the appellant had already undergone more than two years of incarceration and had remained under the shadow of criminal litigation for over ten years.

Considering the overall facts, the long lapse of time, absence of criminal antecedents, and the period already spent in custody, the Supreme Court modified the sentence and reduced it to the period already undergone. However, it maintained the conviction under Sections 420, 467, 468 and 471 IPC and left the fine imposed by the Trial Court untouched. The Court directed that the appellant be released forthwith if not required in any other case.

Case: Israfil @ Pappu @ Naimuddin Khan v. State of Madhya Pradesh, Criminal Appeal No. 3081 of 2026, decided on 23 June 2026.

Representation:- 

For Appellant(s) : Mr. Sarvam Ritam Khare, AOR, Ms. Shweta Chaurasia, Adv., Mr. Kushagra Sharma, Adv., Mr. Anuj Agrawal, Adv., Mr. Akarsh Khare, Adv.

For Respondent(s) : Mr. Amit Sharma, AAG, Mr. Rajan Kumar Chourasia, Adv., Ms. Mrinal G. Elkar, AOR, Ms. Mrigna Shekhar, Adv.