New Delhi, Sept 11: In a significant ruling, the Supreme Court set aside the conviction of Vandana, a social work student accused of forging her university mark sheet. The bench of Justices Aravind Kumar and Sandeep Mehta sharply criticised the lower courts for relying only on “visual inference of overwriting” without expert analysis.
Background
Vandana had appeared for the 1998 BSW Part-I exams under Nagpur University and failed in the compulsory English paper, even after revaluation. To move to the final year, she submitted her mark sheet and revaluation notification to her college. University staff later claimed the marks were altered from 10 to 18 and 30, leading to a police case under cheating and forgery sections of the Indian Penal Code. The trial court sentenced her to multiple jail terms, which were partly reduced on appeal but otherwise upheld by the Bombay High Court’s Nagpur bench.
The Supreme Court questioned every key step of the prosecution. “Suspicion, however grave, cannot replace the standard of legal proof,” the bench observed. No handwriting or forensic expert was ever called, and several university officials who handled the documents were not examined. The judges noted that the papers passed through several institutional hands before the alleged forgery was detected, weakening the claim that Vandana alone could have tampered with them.
The bench also pointed out lapses in the accused’s questioning under Section 313 of the Criminal Procedure Code. Compound and confusing questions, it said, denied Vandana a fair chance to defend herself. “Such an approach causes prejudice and vitiates reliance on those statements,” the court remarked.
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Decision
Finding that the prosecution failed to prove authorship of the forgery or any dishonest intent, the Supreme Court allowed the appeal. It set aside Vandana’s convictions under Sections 420 (cheating), 468 (forgery for cheating), 471 (using forged documents), and 420 read with 511 (attempt to cheat) of the IPC.
Case: Vandana vs. State of Maharashtra
Appeal No.: Criminal Appeal No. 3977 of 2025 (arising out of SLP (Crl.) No. 9317 of 2025)
Date of Judgment: 11 September 2025