Valuable Security under the Indian Penal Code, 1860

Section 30 in The Indian Penal Code
30. “Valuable security” – The words “valuable security” denote a document which is, or purports to be, a document whereby any legal right is created, extended, transferred, restricted, extin­guished or released, or where by any person acknowledges that he lies under legal liability, or has not a certain legal right.

Illustration: A writes his name on the back of a bill of exchange. As the effect of this endorsement is transfer the right to the bill to any person who may become the lawful holder of it, the endorse­ment is a “valuable security”.

• Document must be ‘valuable security -Validity or otherwise does not matter. Document need not be legally effective and valid. = AIR 1918 MADRAS 150 ::(1918) 43 Ind Cas 593

Examples of what is a Valuable Security

• A Rent Receipt given by Landlord to a Tenant.
• Hundi is a valuable security = (1910) Pun LR(149) 194 ::1910 Punj Rec 31
• Executing forged power of attorney = AIROnline 2021 MP 1013
• A Postal Acknolwedgement signed by the accused impersonating the complainant and illegally receiving money = AIR 1976 SC 1139
• Even an illegal or void order rendering earlier order of suspension of Principal of College to be non est continues to be valuable security = 1971 CRI. L. J. 708
• Income-tax assessment order is a valuable security. = (1969) 1 S C J 16 ::71 Bom L R 52
• Appointment letter is both “property” and “valuable security” = (1987) All WC 282 ::1987 (2) Crimes 831
• Even an unstamped or insufficiently stamped document can be considered a valuable security = AIR 1916 ALLAHABAD 197(2)
• A discharge receipt purporting to have been signed by a fictitious nominee in an insurance policy is on the face of it a valuable security = 1956 CRI. L. J. 1246
• Passport creates a legal right and is a valuable security = 1968 CRI. L. J. 1282
• Import License is a valuable security = AIR 1955 BOMBAY 82 ::56 Bom LR 188
• Counterfoil of paying in slip of bank, is valuable security. A counterfoil of a paying in slip purporting to be an acknowledgment of receipt of a sum of money by the bank is a document within the definition of valuable security = AIR 1926 CALCUTTA 425 ::1925 (29) Cal WN 868
• Account paper acknowledging liability is valuable security. An account paper which purports to he a document whereby a person acknowledges that he lies under a legal liability is a valuable security within the definition. = AIR 1918 PATNA 274 ::(1918) 46 Ind Cas 293
• Even if a man has a legal claim or title to property, he is guilty of forgery if he counterfeits documents in order to support it. A rent note is a valuable security. where A, although entitled to possession of his house from B. sues ‘B’ for arrears of rent basing his claim on a rent note which is found to be not genuine, ‘A’, not being entitled to rent at a rate fixed by the rent note, clearly intends to cause wrongful gain. = 1953 CRI. L. J. 979
• Certificate in ‘K’ form prescribed u/S. 9, Bombay Sales Tax Act is valuable security – Accused using as genuine forged ‘K’ form for purchasing cloth free of sales tax is an offence under section 467. = AIR 1960 BOMBAY 146 ::61 Bom LR 1161 
• Admission Card / Exam Hall Ticket used for purpose of competitive examination, is capable of getting the candidate a job, which in turn would give him salary and, therefore, may amount to ‘valuable security’  = 2021 (2) ABR (Cri) 430
• Signature of attesting witness for forged agreement to sell – Although no direct inducement to complainant for delivery of any property, the witness signing on the bogus document can also be made accused. = AIROnline 2019 P and H 1879
  but similarly
  Attestor to valuable security which is forged can plead that he signed it believing in representation of others. There is no estoppel which bars an accused per son in any case from pleading that he had no dishonest or criminal intention. Hence, it is open to an attestor to a valuable security, which is forged, to plead that he signed believing in the representation of others arid therefore had no criminal intention. In other words, there is nothing to prevent the attestors from pleading that they were only foolish and not criminal in what they did. = AIR 1939 MADRAS 730
• Fabricated income tax payment challans, blank Income Tax Returns bearing fake machine receipt No. as well as fake stamp of income tax office, Blank intimation slips u/s 143 (1) (a) Income Tax Act bearing fake stamp of ITO and fabricated Sales Tax Challans are Valuable Security. = Vinod Kumar Ahuja vs State (Govt Of Nct Of Delhi)
• Incomplete document unsigned by some of executants is still a valuable security as the execution of it by them is complete and the document would be binding on them when it is completed by the other intending executants affixing their signatures. = AIR 1918 MADRAS 150 ::(1918) 43 Ind Cas 593

Examples of what is NOT a Valuable Security

• Application filed by defendant admitting that complaint filed by him was false and agreeing to pay damages to plaintiff = 1963 AllCriR 115 ::1963 (1) CRI. L. J. 279
• Certificates which the accused was found to have forged to get admission in a college could not be described as valuable security = 1980 CRI. L. J. 1312
• Administrative order of Court is not valuable security. = AIR 1933 BOMBAY 494 
• Mere endorsement calling a person for an interview does not give him any legal right to be considered for the post and is as such not a valuable security. = 1973 CRI. L. J. 1640
• Deed of agreement for purchase of shares – It is not valuable security. = (1992) 1 CalLT 77 ::1992 CalCriLR 68
• Acknowledgment of receipt of cheque – Such writing is neither a valuable security nor is it a thing which is capable of being converted into a valuable security. = 1977 CRI. L. J. 531
• Forgery of copy of valuable security. There can be no conviction under S.467 for forging a copy of a document which is a valuable security. = AIR 1962 CALCUTTA 174
• Account books are not valuable security ordinarily. = 1963 (1) CRI. L. J. 180
• Decree is not valuable security = AIR 1924 CALCUTTA 502 ::1924 (39) Cal LJ 122
• Postal acknowledgment receipt of parcel is not valuable security. An acknowledgment of receipt of an insured parcel is not valuable security. = AIR 1917 PATNA 699 ::1916 Cri LJ(2) 272 (PAT)
• Signing plea of not guilty by impersonating someone – Plea of Guilt is not a valuable security as it does not create any right in favour of accused = 2018 (1) ABR (Cri) 490
• Fake PhD Certificate being used to practice as a doctor in a hospital – Fake PhD Certificate is not a valuable security – certifcates testifying the educational qualifcation, could not be described as valuable security = Cri. WP  NO. 2281 OF 2021 Dr. Swapna Patker v. State of Maharashtra /  Shriniwas Pandit Dharamadhikari (1980) 4 SCC 551