A) ABSTRACT / HEADNOTE
Surinder Dogra v. State Through Director CBI, Criminal Appeal No. 1020 of 2022, concerns concurrent convictions under Sections 420, 468, 471 of the Ranbir Penal Code, 1989 and Section 5(1)(d) read with Section 5(2) of the Prevention of Corruption Act, 1988. The accused, a Traffic Superintendent of Indian Airlines, Jammu, was found to have issued an infant ticket in the fictitious name Master Azim on 19.11.1997, deposited Rs. 102/-, and thereafter forged and tampered with the flight coupon to create an adult ticket in the name of Vikram, changing the sector from Jammu–Srinagar to Jammu–Delhi and enabling travel on flight no. 422.
The Trial Court convicted the appellant after admission of documentary evidence, oral testimony of airline personnel acquainted with the accused’s handwriting and duties, and the expert opinion of the Deputy Government Examiner of Questioned Documents. The High Court upheld the conviction on reappreciation, holding that the coupons were in the appellant’s handwriting and that he alone had physical control of the subject coupons on the relevant date.
On appeal, the Supreme Court, after considering relevant precedent concerning forgery, proof of manipulation and the weight of expert and ocular testimony, found no infirmity in the concurrent findings and dismissed the appeal. The authorities relied upon include Sait Tarajee Khimchand v. Yelamarti Satyam, Ram Narain v. State of Uttar Pradesh, Kale & Ors. v. Deputy Director of Consolidation & Ors., Sharad Birdhichand Sarda v. State of Maharashtra, State of Rajasthan v. Islam and V.C. Shukla v. State Through CBI, considered in the context of handwriting opinion, possession of documents and control over ticketing coupons.
Keywords: Concurrent conviction; Traffic Superintendent; Infant ticket; Forgery; Auditor coupon; Flight coupon; Handwriting opinion; Prevention of Corruption; Pecuniary advantage.
B) CASE DETAILS
i) Judgment Cause Title
Surinder Dogra v. State Through Director CBI.
ii) Case Number
Criminal Appeal No. 1020 of 2022.
iii) Judgment Date
21 February 2025.
iv) Court
Supreme Court of India (Bench of JJ. Sudhanshu Dhulia and Prashant Kumar Mishra).
v) Quorum
Two-Judge Bench.
vi) Author
Hon’ble Prashant Kumar Mishra, J.
vii) Citation
[2025] 2 S.C.R. 696 : 2025 INSC 258.
viii) Legal Provisions Involved
Sections 420, 468, 471, Ranbir Penal Code, 1989; Section 5(1)(d) read with Section 5(2), Prevention of Corruption Act, 1988; Criminal Procedure Code (s.313 referenced procedurally).
ix) Judgments overruled by the Case (if any)
None indicated in the judgment.
x) Related Law Subjects
Criminal Law; Anti-corruption Law; Evidence Law (documentary, expert handwriting); Administrative/Service Law (officer duties); Forensic Science.
C) INTRODUCTION AND BACKGROUND OF JUDGMENT
The prosecution case originates from a vigilance complaint dated 27.12.1997 by the Manager (Vigilance), Indian Airlines, alleging systemic misuse of infant tickets by travel agents and certain airline officials at Jammu. The complaint narrated that infant coupons were procured and illicitly transformed into adult, longer-distance coupons and sold for adult fares. The specific incident involved a ticket whose auditor coupon reflected Master Azim for Jammu–Srinagar and an associated flight coupon altered to show Mr. Vikram for Jammu–Delhi on 19.11.1997.
The Central Bureau of Investigation registered the case and investigated physical custody, handwriting and ticket transactions. The accused was a Traffic Superintendent at Indian Airlines, assigned to issue tickets at the Jammu counter; evidence established the system of multi-leaf tickets (auditor, flight, office coupons), the carbon transfer mechanism, and that the person issuing the auditor coupon would, effectively, be the person whose writing would appear on the flight coupon. The trial focused on establishing that the appellant prepared the infant ticket, deposited Rs. 102/-, retained and tampered with coupons and thereby enabled another to travel by paying the lesser infant fare while causing loss and obtaining pecuniary advantage.
The Trial Court convicted on documentary proof, ocular evidence from airline staff acquainted with the accused’s handwriting and official duties, and expert opinion by the Deputy Government Examiner of Questioned Documents. The High Court affirmed after reappreciation. The Supreme Court was tasked with scrutinising whether the evidence met the standard to sustain concurrent convictions under forgery and cheating provisions alongside anti-corruption charges.
D) FACTS OF THE CASE
On 19.11.1997, within the operational set-up of Indian Airlines at Jammu, tickets were issued in a multipart format: the auditor coupon (first leaf), the flight coupon (second leaf) and the office coupon (third leaf). Cashier records show a pay-in-slip dated 19.11.1997 for Rs. 102/-, linked to a ticket ostensibly issued for Master Azim (infant) for the sector Jammu–Srinagar. The investigating officer discovered that the associated flight coupon in use for travel bore the name Vikram and a different sector Jammu–Delhi with adult fare indicated. The appellant, being on duty manning the ticket counter, was identified through station records and witnesses as the person who prepared and issued the coupons that day.
Prosecution witnesses included the Airport Manager (PW-1), the Cashier (PW-2), the Vigilance Manager (PW-3), the Sr. Assistant from Vigilance (PW-4) and the Station Manager (PW-5) who was personally acquainted with the appellant’s handwriting. Forensic examination by PW-8 (Deputy Government Examiner of Questioned Documents) reported handwriting correspondence between the questioned coupons and the appellant’s writing. The net factual matrix is that an infant ticket was created and paid for at Rs. 102/-, then the flight coupon was altered by forgery to permit adult travel at no corresponding payment, thereby procuring unauthorised pecuniary advantage and causing loss to Indian Airlines. The accused denied guilt and did not lead defence evidence after examination under Section 313 Cr.P.C.
E) LEGAL ISSUES RAISED
i. Whether the evidence establishes beyond reasonable doubt that the appellant forged and tampered with the flight coupon to convert an infant ticket into an adult ticket?
ii. Whether possession and control of the ticket coupons by the appellant on the date of offence, coupled with handwriting opinion, suffice to prove the charge of forgery and cheating?
iii. Whether the conduct of issuing a forged document by a public servant attracts liability under Section 5(1)(d) read with Section 5(2) of the Prevention of Corruption Act, 1988?
iv. Whether the concurrent conviction by Trial and High Court can be interfered with in exercise of appellate jurisdiction by the Supreme Court?
F) PETITIONER / APPELLANT’S ARGUMENTS
The counsel for the appellant contended that the prosecution failed to produce admissible, unimpeachable evidence to prove that the appellant manipulated the ticket or committed forgery. Reliance was placed on precedents such as Sait Tarajee Khimchand v. Yelamarti Satyam and Ram Narain v. State of Uttar Pradesh to argue that opinion evidence and circumstantial inferences cannot substitute for direct proof and that gaps in chain of custody, possibility of third-party access, or alternate modes of manipulation introduced reasonable doubt.
It was urged that mere presence on duty and contemporaneous pay-in slips do not conclusively tie the accused to the act of tampering, and that expert opinion should be treated with caution in absence of corroboration.
G) RESPONDENT’S ARGUMENTS
The prosecution urged that documentary exhibits, cashier entries and the testimony of airline personnel acquainted with both the ticketing procedure and the appellant’s handwriting form a coherent, consistent narrative of direct guilt. The handwriting expert’s report (PW-8) and evidence of PW-5 who was personally familiar with the appellant’s writing were relied upon to show that both the auditor and flight coupons bore the appellant’s hand.
It was submitted that the appellant had exclusive custody and control over the ticket coupons on the relevant date, and that the resulting pecuniary advantage and loss to the airline were direct consequences of the forgery and cheating. The prosecution referred to established principles that where the accused alone had opportunity and physical control, concurrent inference of guilt is permissible.
H) JUDGMENT
The Supreme Court, through Prashant Kumar Mishra, J., reviewed the material produced at trial: oral testimony of airline officers, cashier pay-in records, the multi-leaf structure of tickets (carbon-backed auditor coupons), the opportunity and duty of the appellant as Traffic Superintendent to prepare and issue tickets, and the expert handwriting report. The Trial Court’s narrative factually found that the appellant first prepared an infant ticket in the fictitious name Master Azim, deposited Rs. 102/-, and thereafter forged the flight coupon to show Vikram for Jammu–Delhi.
The High Court affirmed this on reappreciation. The Supreme Court emphasised two strands:
(i) possession/control and duty the appellant was on duty and the person operating the counter, hence had custody of coupons; and
(ii) handwriting and expert corroboration PW-8’s expert opinion together with PW-5’s ocular familiarity established that the questioned auditor and flight coupons carried the appellant’s handwriting and signature.
The Bench examined precedent cited by the appellant regarding the quality of evidence required to prove forgery and manipulation; but found the present case distinguishable since the prosecution produced both direct (witnesses acquainted with handwriting and duty) and expert evidence, and the coupons themselves were in the accused’s possession on the relevant date.
On that basis, the Court held that the ingredients of Sections 420, 468 and 471 of the RPC were proved and that the appellant, being a public servant, committed an offence under Section 5(1)(d) r/w Section 5(2) of the Prevention of Corruption Act, 1988. The Bench found no legal or factual infirmity in the concurrent findings and dismissed the appeal as sans substance.
a. RATIO DECIDENDI
The decisive legal principle is that where a public servant entrusted with the issuance and custody of multipart tickets is shown to have had exclusive opportunity and physical control, and where both expert opinion and witnesses acquainted with his handwriting identify the questioned documents as his, the evidence suffices to sustain convictions for forgery (s.468, 471) and cheating (s.420) and to attract anti-corruption charges under Section 5(1)(d) read with Section 5(2) of the Prevention of Corruption Act, 1988.
Concurrent findings based on such combined documentary, ocular and expert evidence are entitled to high respect and will not be upset unless shown to be perverse or unsupported by material.
b. OBITER DICTA
The Court observed, implicitly, that expert opinion carries weight when corroborated by witnesses acquainted with the accused’s handwriting and when placed within a chain of custody demonstrating custody and opportunity. The judgment signals caution against substituting pure conjecture for proof but confirms that combined, consistent strands of evidence may be sufficient even in absence of eyewitness to the precise moment of tampering.
c. GUIDELINES
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Proof of possession and duty is material: establish who had custody of multi-leaf tickets and whether exclusive control existed.
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Handwriting expert opinion should be treated as corroborative when combined with ocular evidence from persons familiar with the accused’s hand.
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Chain of custody for ticket coupons and contemporaneous cashier records must be maintained to negate third-party access.
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Concurrent findings of Trial and High Courts deserve deference; appellate interference requires demonstrable perversity or legal error.
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Anti-corruption liability of public servants arises where forgery or manipulation results in pecuniary advantage and loss to the institution.
I) CONCLUSION & COMMENTS
The conviction was sustained on a balanced appraisal of documentary, expert and eyewitness evidence that linked the appellant to the preparation and tampering of the ticket coupons. The Courts applied settled principles that do not demand direct proof of the exact moment of forgery where custody, duty, handwriting opinion and supporting records create an ineluctable inference of culpability. The decision underscores the evidentiary synergy between forensic opinion and familiar-hand testimony in cases involving document manipulation.
For prosecuting agencies, the case reiterates the importance of preserving physical documents, maintaining cashier records and producing witnesses who can speak to system practices and personnel duties. For defence, the judgment highlights the limited traction of general denials when forensic and contemporaneous documentary evidence point cogently to guilt. The appellate restraint exercised by the Supreme Court in maintaining concurrent findings reflects the doctrine that appellate courts should not lightly disturb factual findings grounded in acceptable evaluation of the evidence.
J) REFERENCES
a. Important Cases Referred
i. Sait Tarajee Khimchand v. Yelamarti Satyam, AIR 1971 SC 1865.
ii. Ram Narain v. State of Uttar Pradesh, (1973) SC 2200.
iii. Kale & Ors. v. Deputy Director of Consolidation & Ors., AIR 1976 SC 807.
iv. Sharad Birdhichand Sarda v. State of Maharashtra, AIR 1984 SC 1622.
v. State of Rajasthan v. Islam, AIR 2011 SCW 1748.
vi. V.C. Shukla v. State Through CBI, AIR 1980 SC 962.
vii. Surinder Dogra v. State Through Director CBI, [2025] 2 S.C.R. 696 : 2025 INSC 258.
b. Important Statutes Referred
i. Ranbir Penal Code, 1989 — Sections 420, 468, 471.
ii. Prevention of Corruption Act, 1988 — Section 5(1)(d) read with Section 5(2).
iii. Code of Criminal Procedure, 1973 — Section 313 (procedure reference).
