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Vimalakka Ramappa Koli @ Talwar vs. State of Karnataka (SC)

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Penal Code, 1860–Sec. 198–Using as true a certificate known to be false–Essential ingredient of offence–Men’s rea is an essential ingredient of the offence–Merely because the appellant could not establish her caste claim before the Committee, it can not be concluded that she corruptly used the caste certificate–The allegation that the certificate is false to the knowledge of the accused must be proved by the prosecution–Caste certificate was issued by the Authority who was competent to issue the same and it was issued after following due procedure–Subsequently it was invalidated because the appellant could not prove her caste–It cannot be said that the caste certificate was false–Offence u/s. 198 has not been made out.