Summary and Analysis of Jupally Lakshmikantha Reddy vs State of Andhra Pradesh & Anr 2025 INSC 1096
1. Heading of the Judgment
Case Name: Jupally Lakshmikantha Reddy vs State of Andhra Pradesh & Anr.
Citation: Jupally Lakshmikantha Reddy vs State of Andhra Pradesh & Anr., 2025 INSC 1096 (Supreme Court of India, 2025).
Court: Supreme Court of India
Judges: Hon'ble Ms. Justice B.V. Nagarathna and Hon'ble Mr. Justice Joymalya Bagchi
Date of Judgment: September 10, 2025
2. Related Laws and Sections
The judgment primarily deals with the interpretation of the following sections of the Indian Penal Code, 1860 (IPC):
Section 415 & 420: Defines and prescribes punishment for the offence of Cheating.
Section 463, 465 & 468: Define and prescribe punishment for the offence of Forgery and Forgery for the purpose of cheating.
Section 471: Prescribes punishment for Using a forged document as genuine.
Section 24: Defines "Dishonestly" (intention of causing wrongful gain or wrongful loss).
Section 25: Defines "Fraudulently" (intent to defraud).
3. Basic Judgment Details
Parties:
Appellant: Jupally Lakshmikantha Reddy, representing JVRR Education Society which runs a college.
Respondents: The State of Andhra Pradesh and the complainant (District Fire Officer).Background: A criminal case was registered against the appellant alleging that he submitted a forged No-Objection Certificate (NOC) from the Fire Department to the Education Department to obtain recognition for his college.
The Allegation: The District Fire Officer, Kurnool, complained that the NOC submitted was forged, as his office had never issued it. Based on this, an FIR was registered for offences under Sections 420, 465, 468, and 471 IPC. After investigation, a chargesheet was filed specifically under Section 420 IPC (Cheating).
High Court's Decision: The appellant approached the Andhra Pradesh High Court to quash the criminal proceedings. The High Court refused, stating that the issue of whether an NOC was needed could not be decided at a preliminary stage.
Appeal to Supreme Court: Aggrieved by the High Court's order, the appellant appealed to the Supreme Court.
4. Explanation of the Judgment
The Supreme Court allowed the appeal and quashed the entire criminal proceedings against the appellant. The Court's reasoning was based on a fundamental legal principle: for an action to be a crime, all essential ingredients of the offence must be present. The Court found that the allegations, even if taken at face value, failed to establish these essential ingredients.
Core Issues and the Supreme Court's In-Depth Analysis:
A. The Missing Ingredient of "Dishonest Inducement" in Cheating (Section 420 IPC):
The Court performed a detailed analysis of what constitutes the offence of cheating. It broke down Section 415 IPC, which defines cheating, into two parts:
Dishonestly inducing a person to deliver any property. For this, the inducement must be dishonest (with intention of wrongful gain/loss).
Intentionally inducing a person to do an act or omission which causes harm. For this, the inducement need only be intentional.
The Court emphasized that intention is the gist of the offence. It referred to its own precedent in Dr. Sharma’s Nursing Home v. Delhi Admn. (1998), which held that mere deception is not enough; there must be a "dishonest inducement"—a deliberate intention to cause wrongful gain or loss.
Applying this to the facts, the Court found a fatal flaw in the prosecution's case:
The National Building Code of India, 2016, stated that a Fire NOC was not required for educational buildings below 15 meters in height.
The appellant's building was 14.20 meters tall. Therefore, an NOC was not legally necessary to obtain recognition from the Education Department.
This fact was already established and confirmed by the Andhra Pradesh High Court's order in a separate writ petition (WP No. 14542/2018), which had directed the Education Department to renew affiliations without insisting on a fire NOC.
The Supreme Court's crucial conclusion: Since the NOC was not a mandatory requirement, the Education Department was not induced to grant recognition based on its submission. The recognition was granted because the appellant's college met the actual legal criteria (building height). Therefore, the essential link between the alleged false representation (submitting the NOC) and the official action (granting recognition) was completely missing. There was no question of the Department being deceived into doing something it otherwise would not have done.
B. The Missing Ingredient of "Dishonest Intent" for Forgery-related Offences:
The counsel for the State argued that even if Section 420 was not made out, offences of forgery (Sections 465, 468, 471 IPC) were evident.
The Supreme Court rejected this argument for two key reasons:
No Evidence of Creation: The chargesheet itself admitted that the original fabricated document was never recovered. There was no material to show that the appellant himself had made the forged document, which is a essential requirement for forgery under Section 463/465 IPC. The Court cited Sheila Sebastian v. R. Jawaharaj (2018) to reinforce this point.
No Wrongful Gain/Loss: The core of forgery offences also requires a dishonest or fraudulent intention (mens rea). Since the appellant was legally entitled to the recognition regardless of the NOC, he did not gain anything unlawfully (no wrongful gain), and the Education Department did not lose anything it was legally entitled to (no wrongful loss). Therefore, the necessary criminal intent was absent.
Supreme Court's Final Directions and Conclusion
The Supreme Court held that the High Court had failed to consider these vital legal issues. The uncontroverted facts, especially the building height rule confirmed by the High Court's own writ order, demonstrated that the essential ingredients of cheating or forgery were not disclosed by the allegations in the chargesheet.
Allowing such a case to continue would be an abuse of the process of the law. The Court strongly suggested that the FIR appeared to be a "counter-blast" or retaliatory action initiated by the Fire Department after it was held in contempt for wrongly insisting on the NOC.
Final Order:
The impugned order of the Andhra Pradesh High Court dated April 18, 2024, was set aside.
All proceedings in Criminal Case (CC) No. 303 of 2020 pending before the Judicial Magistrate, Nandyal, were quashed.
Blog Posts
