1. Applicability of Forgery Laws to Electronic Records
Section 464 IPC (Making a False Document/Electronic Record):
Explicitly covers dishonest alteration of electronic records, including scanned documents.
Rina’s act of editing her marksheet to inflate grades qualifies as creating a "false electronic record" with intent to deceive.
Section 470 IPC (Forged Document):
A forged document includes any electronic record altered via forgery.
The edited marksheet becomes a "forged document" under this provision.
2. Using a Forged Document as Genuine
Section 471 IPC:
Submitting the forged marksheet for employment constitutes fraudulent use of a forged document.
Punishment aligns with forgery charges: imprisonment up to 7 years + fine.
Mens Rea Established:
Intent to cheat is inferred from Rina’s act of submitting the document to gain employment.
3. Judicial Precedents
In State of Karnataka v. Praveen Kumar (Case Study 2 in ), using a forged educational certificate led to 3 years’ imprisonment.
The Supreme Court in Sushil Suri v. CBI (2011) emphasized that fraudulent intent is critical for forgery convictions.
4. Penalties Under IPC
Forgery (Section 468 IPC): Up to 7 years’ imprisonment + fine if forgery is for cheating.
Using Forged Document (Section 471 IPC): Same punishment as forgery.
Key Takeaway
Rina’s actions satisfy both actus reus (altering the marksheet) and mens rea (intent to deceive). She would face charges under Sections 468 and 471 IPC, with potential imprisonment and fines. Courts treat such forgery harshly due to its impact on institutional trust
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