Summary and Analysis of Vandana vs The State of Maharashtra 2025 INSC 1098

1. Heading of the Judgment

Case Name: Vandana vs. The State of Maharashtra
Citation: 2025 INSC 1098
Court: Supreme Court of India
Criminal Appeal No.: Criminal Appeal No. 3977 of 2025 (@ SLP (Crl.) No. 9317 of 2025)
Judges: Justice Aravind Kumar and Justice Sandeep Mehta
Date of Judgment: September 11, 2025

2. Related Laws and Legal Sections

The judgment revolves around the interpretation and application of the following sections of the Indian Penal Code, 1860, and the Code of Criminal Procedure, 1973:

• Indian Penal Code, 1860 (IPC):
  Section 420: Cheating and dishonestly inducing delivery of property.
  Section 468: Forgery for the purpose of cheating.
  Section 471: Using as genuine a forged document.
  Section 511: Attempt to commit an offence punishable with imprisonment.
  Sections 463 & 464: Defining the offences of Forgery and Making a false document, which are essential to prove charges under Sections 468 and 471.

• Code of Criminal Procedure, 1973 (CrPC):
  Section 313: Power to examine the accused. The Court emphasized that this is a valuable right of the accused and not a mere formality.

3. Basic Judgment Details

• Parties:
  Appellant: Vandana (Accused No. 1, a former BSW student).
  Respondent: The State of Maharashtra (Prosecution).

• Subject Matter: A criminal appeal challenging the conviction of the appellant for forgery and cheating related to the tampering of a university mark-sheet and revaluation notification to secure admission.

• History of Litigation:
  Trial Court: Convicted Vandana and two college officials (the Principal and an Admission Clerk).
  Appellate Court: Modified the sentence but upheld the conviction.
  Revisional Court (High Court): Acquitted the college officials (Accused No. 2 & 3) but upheld Vandana's conviction.
  Supreme Court: Allowed Vandana's appeal and set aside her conviction and sentence.

4. Explanation of the Judgment

The Supreme Court, in Vandana vs. The State of Maharashtra (2025 INSC 1098), acquitted the appellant, highlighting critical lapses in the prosecution's case that failed to meet the stringent standard of proof "beyond reasonable doubt" required in criminal law.

A. Background of the Case:
The appellant, Vandana, was a student who failed her compulsory English paper. She applied for admission to the next year's course by submitting her original mark-sheet (showing 10 marks) and a revaluation notification (also showing 10 marks). The university later discovered that these documents had been tampered with; the marks were altered to 18 and 30, respectively. Based on this, an FIR was registered. After a trial, she was convicted for offences under Sections 420, 468, 471, and 511 of the IPC. The High Court acquitted the college officials but upheld her conviction, leading to this appeal.

B. The Core Legal Issues and the Supreme Court's Analysis:

The Supreme Court allowed the appeal based on multiple fundamental flaws in the prosecution's case:

1. Failure to Prove Authorship of Forgery (Chain of Custody):
   The Court noted that the allegedly forged documents passed through a "chain of custody"—from the appellant to the admission clerk, then to the principal, and finally to the university. The prosecution provided no evidence to prove that the tampering was done by Vandana while the documents were in her exclusive custody. The Court held that when a document is handled by multiple people, it is unsafe to conclusively pin the forgery on one person without direct proof. The possibility of tampering at any other stage in the chain remained uninvestigated.

2. Lack of Corroborative Forensic Evidence:
   The conviction by the lower courts was based solely on the visual inference of overwriting by the judges. The prosecution did not produce any handwriting expert or forensic report to scientifically prove that the alterations were made by Vandana. The Supreme Court cited its precedent in Fakhruddin v. State of Madhya Pradesh to reiterate that while expert opinion is not always mandatory, in cases where authorship is central to the crime, the absence of such scientific evidence creates a serious doubt. The Court held that "apparent overwriting" alone cannot replace legal proof beyond a reasonable doubt.

3. Failure to Prove Mens Rea (Guilty Mind):
   For charges of cheating (Section 420) and using a forged document (Section 471), the prosecution must prove the accused had a dishonest intention (mens rea). The Court found that the documents were stamped and verified by the college authorities. The appellant's act of submitting documents that were subsequently certified by officials weakened the prosecution's claim that she alone possessed a dishonest intention to deceive from the outset. The required mental element for the crimes was not established.

4. Procedural Lapse in Recording Statement of the Accused:
   The Court found a serious violation of Section 313 of the CrPC. The trial court had recorded the appellant's statement by putting compound and omnibus questions (multiple questions clubbed together), instead of putting each incriminating circumstance to her separately and distinctly. This deprived her of a fair chance to explain herself. The Supreme Court reiterated that Section 313 is a valuable right of the accused, and its improper application causes prejudice and vitiates the trial.

C. Supreme Court's Directions and Final Order:
The Supreme Court allowed the appeal and:

• Set aside the impugned order of the High Court dated May 8, 2025.

• Acquitted the appellant of all charges under Sections 420, 468, 471, and 511 of the IPC.

• Set aside all sentences and fines imposed on her.

In-depth Analysis:
This judgment is a classic example of the judiciary upholding the presumption of innocence and the standard of proof beyond reasonable doubt. The Supreme Court did not rule that the documents were genuine; it ruled that the prosecution failed to prove that the appellant was the one who forged them. The decision underscores several cardinal principles of criminal jurisprudence:

• Suspicion vs. Proof: The Court powerfully stated that "suspicion, however grave, cannot replace the standard of legal proof."

• Burden of Proof: The burden always lies on the prosecution to prove every ingredient of the offence, including authorship and intent, and this burden never shifts to the accused.

• Procedural Fairness: The judgment reinforces that fair trial procedures, like the proper recording of an accused's statement under Section 313 CrPC, are not empty technicalities but fundamental rights that ensure justice.

By acquitting the appellant, the Supreme Court corrected a miscarriage of justice that occurred due to a faulty investigation and an over-reliance on superficial evidence by the lower courts.