The Supreme Court of India has partly allowed an appeal, ruling that while the use of forged documents in court is a serious offence, sentencing must remain proportionate and not reduce to a purely retributive exercise. A two-judge bench comprising Justice Prashant Kumar Mishra and Justice N.V. Anjaria maintained the conviction of the appellant, Israfil alias Pappu alias Naimuddin Khan, under Sections 420, 467, 468, and 471 of the Indian Penal Code, 1860. However, citing mitigating circumstances—including a decade-long legal battle, the absence of criminal antecedents, and the lack of permanent economic harm—the Court reduced his five-year rigorous imprisonment sentence to the period of over two years already undergone.
Background of the Case
The criminal proceedings originated on September 15, 2014, during a bail hearing in Criminal Case No. 07 of 2014 before the Court of the Judicial Magistrate First Class in Rewa, Madhya Pradesh. The appellant appeared before the court to furnish surety on behalf of an accused person named Mukesh Dahiya. In support of the surety, the appellant produced a “Bhu Adhikar Rin Pustika” (Land Rights and Loan Book) bearing No. 943/0124451, purportedly issued on January 31, 2013, for agricultural land in Village Amirati, Tehsil Gurh, District Rewa.
During scrutiny, the Judicial Magistrate noticed physical irregularities in the booklet, specifically that page 10 appeared immediately after page 2. Suspecting the document’s authenticity, the Magistrate questioned the appellant, who failed to provide a satisfactory explanation. The matter was referred to the Civil Lines Police Station in Rewa, leading to the registration of FIR No. 562 of 2014 under Sections 420, 466, 467, 468, and 471 of the IPC.
Revenue authorities subsequently verified that the booklet was forged. Following an investigation where the appellant’s identity was recorded under multiple aliases, the case was committed to trial. On January 6, 2024, the Fifth Additional Sessions Judge, Rewa, acquitted co-accused Ashish Garg but convicted the appellant, sentencing him to five years of rigorous imprisonment on each count, to run concurrently, alongside a fine of Rs. 1,000 under each head. The High Court of Madhya Pradesh at Jabalpur dismissed the appellant’s appeal on April 30, 2025, affirming the trial court’s verdict. The appellant then approached the Supreme Court, which issued notice on November 21, 2025, restricted strictly to the quantum of sentence.
Arguments of the Parties
The counsel representing the appellant did not challenge the conviction but urged a reconsideration of the five-year sentence. The counsel highlighted that the incident occurred in 2014 and the appellant had endured criminal proceedings for more than ten years. Additionally, it was argued that the appellant had no subsequent criminal antecedents, was not a habitual offender, and had already completed over two years of actual custody.
Conversely, the counsel for the State of Madhya Pradesh strongly opposed any leniency, emphasizing the gravity of the offence. The State argued that using a forged revenue document in a court of law to obtain bail directly strikes at the purity of the administration of justice and therefore does not warrant a reduction in sentence.
The Court’s Analysis
In evaluating the case, the Supreme Court strongly condemned the manipulation of judicial files. The bench observed:
“There can be no manner of doubt that offences involving forgery and use of forged documents in judicial proceedings are serious in nature. Sections 467, 468 and 471 of the IPC deal with the offences which undermine the authenticity and sanctity attached to public and legal documents. Use of forged documents before a Court of law cannot be viewed lightly.”
However, the Court emphasised that the judiciary must balance the gravity of the offence with mitigating circumstances and the overarching principles of sentencing jurisprudence:
“At the same time, while considering the question of sentence, the Court is required to balance the nature of the offence with the attendant facts and circumstances of the case, the role attributed to the accused, the period of incarceration undergone, the passage of time and other mitigating circumstances relevant to sentencing jurisprudence. The principle of proportionality remains central to the sentencing process. Sentencing cannot be reduced to a purely retributive exercise divorced from the factual matrix of the case and the overall circumstances of the offender.”
The Court identified several mitigating elements in the appellant’s favour. Notably, the forgery was detected at the threshold stage of the bail proceedings, meaning the act did not result in irreversible pecuniary or proprietary damage. The bench distinguished this case from systematic or larger white-collar crimes, noting:
“The present case is not one involving organized criminal activity, large-scale economic fraud, systematic forgery affecting public institutions, or recurring acts of deception causing widespread financial loss. While the offence cannot be treated lightly, sentencing must ultimately remain proportionate to the overall factual matrix and the degree of criminality reflected in the case.”
The bench drew support from the precedent Padum Kumar vs. State of Uttar Pradesh (2020) 3 SCC 35, where the apex court had reduced a sentence under Sections 467 and 468 of the IPC by taking into account the age of the litigation, time already served, and the lack of recurring criminal conduct. Looking at the custody certificate, the Court noted the appellant was jailed from September 19, 2014, to December 1, 2014, and again from January 6, 2024, representing more than two years of actual incarceration under the shadow of a decade-long trial.
The Decision
The Supreme Court concluded that the ends of justice would be adequately met by modifying the substantive sentence while maintaining the conviction. The bench reduced the appellant’s five-year rigorous imprisonment term under Sections 420, 467, 468, and 471 of the IPC to the period of custody already undergone.
The fines of Rs. 1,000 imposed on each count were left unaltered. The Court ordered the immediate release of the appellant, provided he is not required in any other case, subject to the deposit of the outstanding fine amounts.
Case Details
Case Title: Israfil @ Pappu @ Naimuddin Khan v. State of Madhya Pradesh
Case No.: Criminal Appeal No. 3081 of 2026 (Arising out of S.L.P. (Criminal) No. 19486 of 2025)
Bench: Justice Prashant Kumar Mishra, Justice N.V. Anjaria
Date: June 23, 2026
