Section 232 IPC: Counterfeiting Indian Coin
Section 232 of the Indian Penal Code, 1860 punished counterfeiting Indian coin and knowingly performing any part of the process of counterfeiting Indian coin. The provision carried a more severe punishment than the general offence of counterfeiting coin under Section 231 IPC.
This article explains Section 232 IPC as applicable before the Bharatiya Nyaya Sanhita, 2023 came into force. The expression "Indian coin" used in this provision was defined by Section 230 IPC.
Text of Section 232 IPC
Whoever counterfeits, or knowingly performs any part of the process of counterfeiting Indian coin, shall be punished with imprisonment for life, or with imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine.
Meaning of Indian coin under Section 230 IPC
For the relevant IPC Chapter, Section 230 defined "Indian coin" as metal stamped and issued by the authority of the Government of India in order to be used as money. It further provided that metal which had been so stamped and issued continued to be Indian coin for the purposes of the Chapter even if it had ceased to be used as money.
Essential ingredients of Section 232 IPC
The statutory language identifies two principal forms of prohibited conduct:
- counterfeiting Indian coin; or
- knowingly performing any part of the process of counterfeiting Indian coin.
Where liability is based on participation in only part of the process, the word "knowingly" is material. The required knowledge must be considered in light of the evidence and circumstances of the particular case.
Difference between Section 231 and Section 232 IPC
| Section 231 IPC | Applied generally to counterfeiting "coin" or knowingly performing any part of that process. The maximum imprisonment stated in Section 231 was seven years, with liability to fine. |
|---|---|
| Section 232 IPC | Specifically applied to counterfeiting "Indian coin" or knowingly performing any part of that process. It provided imprisonment for life or imprisonment of either description up to ten years, and liability to fine. |
Punishment under Section 232 IPC
The section provided alternative terms of imprisonment: imprisonment for life, or imprisonment of either description for a term which could extend to ten years. In addition, the offender was liable to fine. The words "shall also be liable to fine" made the fine component part of the statutory punishment structure.
Classification under the pre-BNS criminal procedure
| Offence | Counterfeiting Indian coin or knowingly performing any part of the process of counterfeiting Indian coin |
|---|---|
| Punishment | Imprisonment for life, or imprisonment of either description up to ten years, and liability to fine |
| Cognizable | Yes |
| Bailable | No - non-bailable |
| Triable by | Court of Session |
| Compoundable | No - non-compoundable |
Legislative history in the original IPC text
The historical notes attached to Section 232 record that the expression "Indian coin" replaced the earlier reference to "the Queen's coin." They also record that Act 26 of 1955 substituted "imprisonment for life" for the former expression "transportation for life," with effect from 1 January 1956. These amendments explain the modern pre-BNS wording of the provision.
Related counterfeiting provisions
Section 232 formed part of a connected group of IPC provisions. Section 231 dealt with counterfeiting coin generally, while Section 233 addressed making or selling instruments for counterfeiting coin and Section 234 dealt specifically with instruments for counterfeiting Indian coin.
Section 232 IPC at a glance
Section 232 IPC specifically punished counterfeiting Indian coin, including knowing participation in any part of the counterfeiting process. The offence carried imprisonment for life or imprisonment of either description for up to ten years, together with liability to fine.
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 and procedural law should be determined with reference to the relevant date and applicable saving or transition provisions.