Valuable security is defined under Section 30 of the IPC as under:
“30. “Valuable security”.—The words “valuable security” denote a document which is, or purports to be, a document whereby any legal right is created, extended, transferred, restricted, extinguished or released, or whereby any person acknowledges that he lies under legal liability, or has not a certain legal right.”
The issue raised by you, i.e., whether a certificate forged to get admission in a college for education is a valuable security, is directly covered by the judgment of the Supreme Court in the case of Shriniwas Pandit Dharamadhikari v. State of Maharashtra, (1980) 4 SCC 551 : AIR 1981 SC 80, in which it was held that:
“…but as regards the offence under Section 471 read with Section 467 IPC we do not think that the two certificates the appellant has been found to have forged to get admission in the Arts and Commerce College affiliated to Poona University could be described as “valuable security” as the expression is defined in Section 30 of the Indian Penal Code. We therefore alter the conviction under the aforesaid sections to one under Section 471 read with Section 465 of the Indian Penal Code.”
Therefore, forgery of a certificate to get admission in a college will not be a valuable security forged for the purposes of Section 467 IPC and the application of such section in your case is wrong.
Dr. Ashok Dhamija is a New Delhi based Supreme Court Advocate and author of law books. Read more about him by clicking here. List of his Forum Replies. List of his other articles. List of his Quora Answers. List of his YouTube Videos.
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