Section 201 BNS: Public Servant Framing Incorrect Document to Cause Injury (Formerly Section 167 IPC)

Section 201 of Bharatiya Nyaya Sanhita: Public Servant Framing Incorrect Document to Cause Injury

Official Bare Act Text

Override / Mandate Mens Rea (Intent) Actus Reus (Conduct) Punishment Limitation Monetary

Whoever, being a public servant, and being, as such public servant, charged with the preparation or translation of any document or electronic record, frames, prepares or translates that document or electronic record in a manner which he knows or believes to be incorrect, intending thereby to cause or knowing it to be likely that he may thereby cause injury to any person, shall be punished with imprisonment of either description for a term which may extend to three years, or with fine, or with both.

Legal Commentary & Landmark Judgments: Section 201

Section 201 criminalises the deliberate framing or translation of incorrect official documents or electronic records by a public servant with the intention to cause injury to any person.

Custody and Duty: The public servant must be charged with the statutory duty of preparing, signing, or translating official records or electronic data.
Incorrect Framing: The document or digital entry must be drawn up incorrectly in a manner known to be false by the public servant.
Injurious Intent: The falsification must be executed with intent or knowledge that it will cause injury, wrongful loss, or judicial prejudice to a person.

Key Landmark Precedents:

State of Orissa v. Ganesh Chandra Jew (2004) 8 SCC 40: The Supreme Court reiterated that when a public servant dishonestly alters case diaries or official panchnamas, sanction under Section 197 CrPC does not shield acts unrelated to lawful duty.
Prabhu Dayal v. State of Rajasthan (2018) 8 SCC 127: Affirmed that fabrication of revenue records or mutation registers by patwaris with intention to deprive rightful owners constitutes a completed offence under this provision.

Courtroom Practice & Strategic Litigation Guidance:

Prosecutors must present the original draft alongside the distorted final record with forensic handwriting or digital metadata stamps. The defence should contest mens rea, highlighting clerical error, lack of unlawful gain, or reliance on subordinate data.

Section 201: Public Servant Framing Incorrect Document to Cause Injury

Section 201 of Bharatiya Nyaya Sanhita: Public Servant Framing Incorrect Document to Cause Injury

Legal Commentary & Landmark Judgments: Section 201