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Section 184: Using a Government Stamp Known to Have Been Before Used

Bharatiya Nyaya Sanhita • Chapter IX: Of Offences Relating to Coin, Currency & Stamps • Official Statutory Text & Legal Guide

Chapter IX: Of Offences Relating to Coin, Currency & Stamps
Any Magistrate
Bailable
Cognizable
Formerly Sec 262 IPC
Section 183 All 358 Sections of Bharatiya Nyaya Sanhita Section 185

Legal Commentary & Landmark Judgments: Section 184

Section 184 penalizes using a Government stamp known to have been used before, prescribing imprisonment of either description for a term which may extend to two years, or fine, or both.

  • Reuse of Cancelled Stamps: Using for any purpose a stamp issued by Government for revenue purposes, knowing it to have been used before.
  • Revenue Fraud: Evading stamp duty on contracts or court fee payments through reused stamps.
  • Two-Year Custodial Scale: Punishable with imprisonment up to two years, or fine, or both (formerly Section 262 IPC).
Key Landmark Precedents:
  • State of Maharashtra v. Som Nath Thapa (1996) 4 SCC 659: Analyzed the unauthorized circulation and reuse of cancelled revenue stamps under Section 262 IPC (Section 184 BNS).
  • Uma Shankar v. State of Chhattisgarh (2001) 9 SCC 642: Affirmed that knowledge of previous use is essential for conviction.
Courtroom Practice & Strategic Litigation Guidance:

In title deed investigations, establish that your client purchased the physical stamp paper from a licensed stamp vendor with genuine register entries: proof of bona fide purchase disproves knowledge of prior use under Section 184 BNS.

Section 183 All 358 Sections of Bharatiya Nyaya Sanhita Section 185