New Delhi, September 10: In a relief for Andhra Pradesh educationist Jupally Lakshmikantha Reddy, the Supreme Court on Tuesday set aside a cheating case that had lingered for years. The bench of Justices B.V. Nagarathna and Joymalya Bagchi ruled that the criminal proceedings lacked the basic ingredients of fraud or forgery.
Background
Reddy’s JVRR Education Society runs a college in Kurnool district from a building just 14.2 metres high. Back in 2018, the District Fire Officer complained that the college had used a forged fire safety No-Objection Certificate (NOC) to obtain recognition from the School Education Department. Police registered a case under Section 420 of the Indian Penal Code, which deals with cheating, and later filed a chargesheet.
But the National Building Code of India, 2016 clearly states that institutions operating from buildings under 15 metres do not need a fire NOC. In fact, Reddy and other institutions had already won a High Court order in April 2018 directing education authorities to renew affiliation without insisting on such clearance.
“The representation of the appellant that he possessed a valid NOC cannot be said to have induced the Education Department to grant recognition,” the bench observed. It noted that the college’s height was below the threshold and therefore no NOC was legally required.
The judges carefully explained the offence of cheating, stressing that deception alone is not enough. “To attract penal consequences, it must be shown that the false representation was of a material fact which induced the victim to act differently,” the court said. Since recognition was never dependent on the NOC, there was no dishonest inducement or wrongful gain.
The bench also dismissed arguments of forgery. The prosecution had not produced the alleged fake document or any proof that Reddy created it. “No material connecting the appellant to the making of the fake document has been adduced,” the order stated.
Decision
Concluding that the High Court had overlooked these crucial aspects, the Supreme Court quashed the proceedings in CC No. 303/2020 under Section 420 IPC. “We set aside the impugned order of the High Court and allow the appeal,” the bench declared, bringing the seven-year-old case to a close.
Case: Jupally Lakshmikantha Reddy vs. State of Andhra Pradesh & Anr.
Court & Date: Supreme Court of India, Judgment delivered on 10 September 2025
