Supreme Court Upholds Conviction in Ticket Forgery Case: Surinder Dogra vs. State (2025)

Date of the Judgment: February 21, 2025

Judges: Prashant Kumar Mishra, J., Sudhanshu Dhulia, J.

Can an airline employee be convicted for forging flight tickets and causing financial loss to the company? The Supreme Court of India recently addressed this question in a case involving an employee of Indian Airlines who was accused of tampering with infant tickets to create adult tickets for personal gain. The Court upheld the concurrent conviction of the employee by the Trial Court and the High Court.

Case Background

The case revolves around Surinder Dogra, who was working as a Traffic Superintendent at Indian Airlines, Jammu. On November 19, 1997, Dogra was manning the ticket sale counter at Jammu Airport. It was alleged that he prepared an infant ticket under a fictitious name and then forged the flight coupon to convert it into an adult ticket. This act allowed him to gain financially while causing a loss to the airline.

The complaint was lodged by Romesh Malhotra, Manager (Vigilance) of Indian Airlines, on December 27, 1997, which led to the CBI registering the case. The complaint stated that M/s. Blue Bird Tours & Travel, in collaboration with Rattan Chand and some unidentified officials of Indian Airlines, Jammu, were involved in procuring infant tickets and tampering with them to convert them into adult tickets for longer distances and higher fares, which were then sold to various individuals.

Specifically, a flight coupon in the name of Mr. Vikram for the Jammu to Delhi sector, issued by Indian Airlines for travel on November 19, 1997, was found to be suspicious. Upon checking the auditor coupon of the same ticket number, it was discovered that the original ticket was in favor of Master Azim (an infant) for the Jammu to Srinagar sector. Investigations revealed that Dogra was on duty at the ticket counter on that day and had prepared the infant ticket in the name of Master Azim, depositing Rs. 102/- with the Cashier.

Later, Dogra allegedly tampered with the flight coupon, changing it to an adult ticket in the name of Vikram and altering the sector to Jammu-Delhi with a fare of Rs. 3105/-. This allowed Mr. Vikram to travel to Delhi on flight no. 422 on November 19, 1997, using the forged ticket.

Timeline

Course of Proceedings

Following the investigation, a chargesheet was filed. During the trial, the prosecution presented nine witnesses. The appellant/accused, Surinder Dogra, pleaded not guilty and was examined under Section 313 of the Criminal Procedure Code (Cr.P.C.). However, he did not present any evidence in his defense.

Legal Framework

The appellant was charged under several sections of the Ranbir Penal Code (RPC) of 1989 and the Prevention of Corruption Act, 1988. These include:

✓ Section 420, RPC: This section deals with cheating and dishonestly inducing delivery of property.
✓ Section 468, RPC: This section pertains to forgery for the purpose of cheating.
✓ Section 471, RPC: This section addresses using as genuine a forged document or electronic record.
✓ Section 5(1)(d) read with Section 5(2) of the Prevention of Corruption Act, 1988: These sections relate to a public servant abusing their position to obtain pecuniary advantage and the punishment for such acts.

Arguments

The defense argued that there was a lack of admissible evidence to prove that the appellant had committed forgery by manipulating the ticket. The appellant’s counsel referred to several judgments to support their claim, including:

✓ Sait Tarajee Khimchand vs. Yelamarti Satyam [AIR (1971) SC 1865]
✓ Ram Narain vs. State of Uttar Pradesh [AIR (1973) SC 2200]
✓ Kale & Ors. vs. Deputy Director of Consolidation & Ors. [AIR (1976) SC 807]
✓ Sharad Birdhichand Sarda vs. State of Maharashtra [AIR (1984) SC 1622]
✓ State of Rajasthan vs. Islam [AIR (2011) SCW 1748]
✓ V.C. Shukla vs. State Through CBI [AIR (1980) SC 962]

However, the prosecution presented the handwriting expert’s report (H.M. Saxena/ PW-8) and the testimony of J.P. Jaiswar (PW-5), which proved that the appellant was on duty at the Jammu Airport on the day of the offense and that the questioned auditor coupon and flight coupon were issued under his handwriting.

Issues Framed by the Supreme Court

1. Whether the Trial Court and the High Court erred in holding the appellant guilty of the offences under Sections 420, 468, and 471 of the Ranbir Penal Code of 1989 and Section 5(1)(d) read with Section 5(2) of the Prevention of Corruption Act, 1988.

Treatment of the Issue by the Court: “The following table demonstrates as to how the Court decided the issues”

Authorities

The court considered the following authorities:

✓ Sait Tarajee Khimchand vs. Yelamarti Satyam [AIR (1971) SC 1865] – Cited by the defense to argue the lack of admissible evidence.
✓ Ram Narain vs. State of Uttar Pradesh [AIR (1973) SC 2200] – Cited by the defense to argue the lack of admissible evidence.
✓ Kale & Ors. vs. Deputy Director of Consolidation & Ors. [AIR (1976) SC 807] – Cited by the defense to argue the lack of admissible evidence.
✓ Sharad Birdhichand Sarda vs. State of Maharashtra [AIR (1984) SC 1622] – Cited by the defense to argue the lack of admissible evidence.
✓ State of Rajasthan vs. Islam [AIR (2011) SCW 1748] – Cited by the defense to argue the lack of admissible evidence.
✓ V.C. Shukla vs. State Through CBI [AIR (1980) SC 962] – Cited by the defense to argue the lack of admissible evidence.

The court also considered the reports of the handwriting expert (H.M. Saxena/ PW-8) and the testimony of J.P. Jaiswar (PW-5).

Judgment

What weighed in the mind of the Court?

The court’s decision was primarily influenced by the conclusive evidence presented by the prosecution, particularly the handwriting expert’s report and the testimony of witnesses who identified the appellant’s handwriting on the forged tickets. The court emphasized that the appellant was in a position to manipulate the documents, as the coupons were in his possession on the relevant date.

Fact:Law Ratio

Logical Reasoning

The Supreme Court found no grounds to interfere with the High Court’s judgment. The appeal was dismissed due to lack of substance.

The court stated:

“…we are in full agreement with the finding recorded by the Trial Court and affirmed by the High Court that it was the appellant alone who could have manipulated the document because the subject coupons were in his possession on the relevant date.”

Key Takeaways

✓ Airline employees in positions of trust can be held accountable for fraudulent activities such as ticket forgery.
✓ Handwriting analysis and expert testimony can be crucial in proving forgery cases.
✓ Courts will consider the access and opportunity an individual has to commit the alleged offense.

Development of Law

The ratio decidendi of the case is that an employee can be convicted for forgery and corruption based on handwriting evidence and their position of access to the manipulated documents. This case reinforces the existing legal principles regarding fraud and corruption in public service.

Conclusion

The Supreme Court’s decision in Surinder Dogra vs. State reaffirms the importance of integrity and accountability in public service. By upholding the conviction, the Court sends a strong message that fraudulent activities, such as ticket forgery, will not be tolerated, and those found guilty will be held accountable under the law.

Category

Parent category: Criminal Law

Child categories: Forgery, Corruption, Prevention of Corruption Act, 1988, Section 5, Ranbir Penal Code, 1989, Sections 420, 468, 471

FAQ

Q: Can an airline employee be convicted for forging flight tickets?

A: Yes, if there is sufficient evidence to prove that the employee manipulated the tickets for personal gain, as demonstrated in the Surinder Dogra vs. State case.

Q: What type of evidence is crucial in proving forgery cases?

A: Handwriting analysis and expert testimony are often critical in proving forgery cases, as they can establish that the accused person was responsible for altering the documents.

Q: What factors do courts consider when determining guilt in forgery cases?

A: Courts consider factors such as the accused person’s access to the documents, their opportunity to commit the offense, and any evidence linking them to the forgery, such as handwriting analysis or witness testimony.