Section 230 IPC: Coin and Indian Coin Defined
Section 230 of the Indian Penal Code, 1860 defined the expressions "coin" and "Indian coin" for the IPC chapter dealing with offences relating to coin and Government stamps. The provision focused on metal stamped and issued under sovereign or governmental authority for use as money.
This article explains Section 230 IPC and its statutory illustrations as they stood before the Bharatiya Nyaya Sanhita, 2023 came into force. It is retained as a reference for matters governed by the earlier Indian Penal Code.
Definition of "coin" under Section 230 IPC
Coin is metal used for the time being as money, and stamped and issued by the authority of some State or Sovereign Power in order to be so used.
The definition contains three central features: the object must be metal; it must be stamped and issued under the authority of a State or Sovereign Power; and it must be intended to be used as money. Merely using an object as a medium of exchange does not, by itself, make it "coin" within this statutory definition.
Definition of "Indian coin"
Indian coin is metal stamped and issued by the authority of the Government of India in order to be used as money. Metal which has been so stamped and issued continues to be Indian coin for the purposes of this Chapter even if it has ceased to be used as money.
The second part of the definition is important for the IPC provisions dealing with coin offences. Once qualifying metal had been stamped and issued by the authority of the Government of India for use as money, it continued to be treated as "Indian coin" for the purposes of the Chapter even after it ceased to circulate as money.
Essential elements of the statutory definitions
| Coin | Metal used for the time being as money and stamped and issued by the authority of a State or Sovereign Power for that purpose. |
|---|---|
| Indian coin | Metal stamped and issued by the authority of the Government of India to be used as money. |
| Former Indian coin | Qualifying metal continues to be Indian coin for this IPC Chapter even after it has ceased to be used as money. |
| Purpose of Section 230 | To supply definitions used by the provisions in the IPC Chapter dealing with offences relating to coin and Government stamps. |
Statutory illustrations to Section 230 IPC
The illustrations included with Section 230 clarify what does and does not fall within the definition:
- (a) Cowries are not coin.
- (b) Lumps of unstamped copper, although used as money, are not coin.
- (c) Medals are not coin because they are not intended to be used as money.
- (d) The coin denominated as the Company's rupee is Indian coin.
- (e) The "Farukhabad rupee", formerly used as money under the authority of the Government of India, is Indian coin although it is no longer so used.
Why cowries, unstamped copper and medals are excluded
The illustrations show that use as a medium of exchange is not the only requirement. Cowries fail the statutory requirement that coin be metal. Unstamped copper lacks the required official stamping and issue. Medals, although metallic and stamped, are excluded because they are not issued for use as money.
Importance of official authority
Section 230 tied the concept of coin to official issuance. For the general definition, the metal had to be stamped and issued by the authority of a State or Sovereign Power. For "Indian coin," the relevant authority was the Government of India. This distinction supported the operation of the succeeding IPC provisions dealing with counterfeiting, possession, import, export and delivery of counterfeit coin.
Legislative history reflected in the original provision
The text carried historical amendment notes. The first paragraph was substituted by Act 19 of 1872. The definition of Indian coin and related terminology were later adapted, including through the Adaptation of Laws Order, 1950. Illustration (e) was added by Act 6 of 1896. These notes explain the historical wording preserved in older editions of the Indian Penal Code.
Section 230 IPC at a glance
Under Section 230 IPC, "coin" meant metal officially stamped and issued for use as money by a State or Sovereign Power. "Indian coin" meant metal stamped and issued by the Government of India for use as money and, for the purposes of the relevant IPC Chapter, continued to retain that character even after it ceased to be used as money.
Legal note: This page is deliberately framed around the Indian Penal Code position before implementation of the Bharatiya Nyaya Sanhita, 2023. For a particular historical or pending matter, the applicable substantive law should be determined by reference to the relevant date and applicable saving or transition provisions.