- Published on
KembaraXtra - Bharatiya Nyaya Sanhita - Section 228: Fabricating False Evidence
Introduction
Section 228 of the Bharatiya Nyaya Sanhita, 2023 (BNS) defines what amounts to fabricating false evidence.
The provision is aimed not merely at a person who tells a lie, but at a person who manufactures a false evidentiary situation with the specific intention that it will appear in a judicial or other legally recognised proceeding and mislead the person deciding the matter on a material point.
Fabrication may take the form of:
- Creating a false circumstance;
- Making a false entry in a book or record;
- Making a false entry in an electronic record;
- Making a document containing a false statement; or
- Making an electronic record containing a false statement.
The central formula is:
FALSE CREATION + INTENDED APPEARANCE IN EVIDENCE + INTENT TO CAUSE ERRONEOUS OPINION ON MATERIAL POINT = FABRICATING FALSE EVIDENCE
Q1. What does Section 228 define?
Answer:
Section 228 defines:
FABRICATING FALSE EVIDENCE
It explains the circumstances in which the creation of false circumstances, entries, documents or electronic records becomes false evidence in the legal sense.
Q2. Which IPC provision corresponds to Section 228 BNS?
Answer:
According to the supplied comments:
Section 228 BNS = Section 192 IPC
Q3. What change has been made under the BNS?
Answer:
According to the supplied comments, the language remains unchanged except that:
“COURT OF JUSTICE” → “COURT”
Q4. What is the central idea behind Section 228?
Answer:
The section targets the deliberate manufacture of false evidence.
The accused creates something false intending that it will later appear as evidence and cause the decision-maker to form an incorrect opinion concerning a material issue.
Memory
CREATE FALSE → MAKE IT APPEAR AS EVIDENCE → MISLEAD ON MATERIAL POINT
Q5. What are the essential ingredients of fabricating false evidence?
Answer:
The essential ingredients emerging from the supplied provision and comments are:
- The accused creates a false circumstance, entry, document, electronic record or false statement;
- He intends that the fabricated matter may appear in evidence;
- The intended proceeding is one recognised by Section 228;
- He intends that the fabricated matter, when appearing in evidence, will cause a person forming an opinion upon the evidence to entertain an erroneous opinion;
- That erroneous opinion must touch a point material to the result of the proceeding.
Formula
FABRICATION + EVIDENTIARY INTENT + RECOGNISED PROCEEDING + INTENT TO MISLEAD + MATERIAL POINT = SECTION 228
Q6. What are the principal methods of fabricating false evidence?
Answer:
Section 228 covers three broad methods:
First — Creating a False Circumstance
The accused:
CAUSES ANY CIRCUMSTANCE TO EXIST
Second — Making a False Entry
The accused makes a false entry in:
- A book;
- A record; or
- An electronic record.
Third — Making a False Document or Electronic Record
The accused makes:
- A document; or
- An electronic record;
containing a false statement.
Memory
CIRCUMSTANCE – ENTRY – DOCUMENT/ELECTRONIC RECORD
Q7. What does “causing any circumstance to exist” mean?
Answer:
It refers to deliberately creating or arranging a factual situation so that it falsely appears to support a particular conclusion.
The accused is effectively manufacturing a circumstance capable of being treated as evidence.
Q8. Does Section 228 apply only to documents?
Answer:
No.
This is an important examination point.
The provision expressly extends beyond documents to:
ANY CIRCUMSTANCE
Therefore, physical situations may also be fabricated.
Q9. Can physical evidence be fabricated?
Answer:
Yes.
Illustration (a) demonstrates this.
A places jewels into Z’s box intending that they be discovered there and that the circumstance cause Z to be convicted of theft.
The jewels and their placement create a false evidentiary circumstance.
Q10. Can a false entry in a book amount to fabrication?
Answer:
Yes.
A false entry in a book or record is expressly covered.
Q11. Are electronic records covered?
Answer:
Yes.
Section 228 expressly refers to:
ELECTRONIC RECORD
Thus, the provision is not restricted to paper records.
Q12. Can a document containing a false statement constitute fabricated evidence?
Answer:
Yes.
Making a document containing a false statement is expressly included where the other statutory ingredients are satisfied.
Q13. Does every false document amount to fabricated false evidence?
Answer:
No.
This is a crucial distinction.
According to the supplied comments:
MERE GENERATION OF FALSE EVIDENCE IS NOT ENOUGH
The required intention concerning its appearance in evidence and misleading effect must also exist.
Q14. Why is intention so important under Section 228?
Answer:
Because fabrication is not established merely by showing that something false was created.
The accused must have the specific evidentiary intention required by Section 228.
Memory
FALSE CREATION ALONE ≠ SECTION 228
Q15. What is the first specific intention required?
Answer:
The accused must intend that the false circumstance, entry or statement:
MAY APPEAR IN EVIDENCE
in one of the proceedings specified by the section.
Q16. What is the second specific intention involved?
Answer:
The accused must intend that the false material, when appearing in evidence, may cause the person forming an opinion upon that evidence:
TO ENTERTAIN AN ERRONEOUS OPINION
Q17. What must that erroneous opinion concern?
Answer:
It must touch:
A POINT MATERIAL TO THE RESULT OF THE PROCEEDING
Materiality is therefore a central ingredient.
Q18. What does “material point” mean in the context of Section 228?
Answer:
It refers to a point important to the result of the proceeding.
According to the supplied comments, examples include matters bearing upon:
- Guilt;
- Innocence;
- Liability; or
- Another important issue affecting the outcome.
Q19. Is an irrelevant falsehood sufficient?
Answer:
Not merely because it is false.
The statutory structure requires the intended erroneous opinion to touch a:
MATERIAL POINT
Q20. Who must the accused intend to mislead?
Answer:
The provision refers broadly to:
ANY PERSON WHO IN SUCH PROCEEDING IS TO FORM AN OPINION UPON THE EVIDENCE
The focus is therefore on the person who must evaluate the evidence in the proceeding.
Q21. Is a Judge the only person who can be misled for Section 228?
Answer:
No.
The wording is broader than merely referring to a Judge.
The relevant person is one who, in the proceeding, is to form an opinion upon the evidence.
Q22. In what proceedings may the fabricated evidence be intended to appear?
Answer:
Section 228 identifies three settings:
- A judicial proceeding;
- A proceeding taken by law before a public servant as such;
- A proceeding before an arbitrator.
Memory
COURT/JUDICIAL – PUBLIC SERVANT – ARBITRATOR
Q23. Is fabrication restricted to judicial proceedings?
Answer:
No.
The statutory definition is wider.
It also covers the relevant legally taken proceedings before:
- A public servant; and
- An arbitrator.
Q24. Why is the reference to an arbitrator important?
Answer:
It shows that fabricated false evidence is not restricted to ordinary Court litigation.
The provision expressly recognises proceedings before an arbitrator.
Q25. What is meant by a proceeding before a public servant?
Answer:
The provision refers specifically to:
A PROCEEDING TAKEN BY LAW BEFORE A PUBLIC SERVANT AS SUCH
Therefore, the proceeding must have the required legal character.
Q26. Is any informal conversation with a public servant enough?
Answer:
Not merely because a public servant is involved.
The supplied statutory wording requires a:
PROCEEDING TAKEN BY LAW
before the public servant acting as such.
Q27. Must fabricated evidence actually be produced before the Court or authority?
Answer:
No.
According to the supplied comments:
MERE PREPARATION WITH THE REQUIRED INTENT MAY SUFFICE
The fabricated material need not actually be used.
Q28. Why is actual use unnecessary?
Answer:
Because Section 228 focuses on the intention that the false circumstance, entry or statement:
“MAY APPEAR IN EVIDENCE”
Once fabrication is completed with the required intention, subsequent actual use is not necessary according to the supplied comments.
Q29. Must a judicial proceeding already have commenced?
Answer:
No.
According to the supplied comments:
COMMENCEMENT OF THE JUDICIAL PROCEEDING IS NOT MANDATORY
The evidence may be fabricated in advance.
Q30. When is the offence complete?
Answer:
According to the supplied comments, once the fabrication has been completed with the necessary statutory intention, the offence is established.
Memory
FABRICATION COMPLETE + REQUIRED INTENTION = OFFENCE COMPLETE
Q31. Can evidence therefore be fabricated before litigation begins?
Answer:
Yes.
For example, a person may manufacture a false document today intending to produce it in proceedings that are expected later.
If the statutory intentions are established, the fact that proceedings have not yet commenced does not by itself prevent Section 228 from applying.
Q32. What does Illustration (a) provide?
Answer:
A puts jewels into a box belonging to Z.
A intends:
- That the jewels will be found in Z’s box; and
- That this circumstance will cause Z to be convicted of theft.
A has fabricated false evidence.
Q33. What principle does Illustration (a) demonstrate?
Answer:
It demonstrates:
FABRICATION OF A PHYSICAL CIRCUMSTANCE
No false document is necessary.
A deliberately creates a misleading physical situation.
Q34. Why is placing the jewels in Z’s box more than mere possession of stolen property?
Answer:
For the purpose of Section 228, the important point is A’s deliberate creation of a false evidentiary circumstance intended to appear as evidence against Z and lead to an erroneous conclusion regarding Z’s guilt.
Q35. What does Illustration (b) provide?
Answer:
A makes a false entry in his shop-book for the purpose of using it as corroborative evidence in a Court.
A has fabricated false evidence.
Q36. What principle does Illustration (b) demonstrate?
Answer:
It demonstrates:
FALSE ENTRY + INTENDED COURT USE = FABRICATION
provided the other statutory requirements are satisfied.
Q37. Does the false shop-book entry have to be actually produced in Court?
Answer:
No.
The Illustration focuses on the purpose for which the entry was created.
The supplied comments similarly state that actual use is unnecessary.
Q38. What does Illustration (c) provide?
Answer:
A intends to cause Z to be convicted of criminal conspiracy.
A:
- Writes a letter imitating Z’s handwriting;
- Makes it appear that the letter was addressed to an accomplice;
- Places the letter somewhere police officers are likely to search.
A has fabricated false evidence.
Q39. What principle does Illustration (c) demonstrate?
Answer:
It demonstrates deliberate manufacture and strategic placement of false documentary evidence.
Sequence
FALSE LETTER → IMITATE HANDWRITING → PLANT LETTER → EXPECT DISCOVERY → FALSE INFERENCE OF GUILT
Q40. Why is Illustration (c) particularly useful?
Answer:
Because it shows that fabrication may involve more than merely writing something false.
The accused may deliberately arrange for the false material to be discovered so that it appears naturally as genuine evidence.
Q41. What example is given in the supplied comments concerning a loan dispute?
Answer:
A forges a letter purporting to have been written by B in which B admits liability in a loan dispute.
A then produces the letter in Court as evidence.
According to the supplied comments, A has fabricated false evidence.
Q42. What does the loan-letter example demonstrate?
Answer:
It illustrates:
FALSE DOCUMENT + FALSE ADMISSION + INTENDED EVIDENTIARY USE + MATERIAL LIABILITY ISSUE
The false admission is intended to mislead the Court regarding B’s liability.
Q43. What example is given concerning a forged medical report?
Answer:
A bribes a doctor to prepare a fake medical certificate stating that A was in hospital on the day a crime was committed.
A plans to produce it in Court as an alibi.
According to the supplied comments, this constitutes fabricating false evidence.
Q44. Why is the fake medical report material?
Answer:
Because it is intended to support an alibi and therefore influence the decision-maker’s opinion regarding A’s possible involvement in the offence.
The false evidence concerns a matter material to guilt or innocence.
Q45. What if A prepares the false medical report but is arrested before producing it?
Answer:
According to the supplied comments, actual production is unnecessary.
If fabrication was completed with the required evidentiary intention:
SECTION 228 MAY ALREADY BE COMPLETE
Q46. What if a false document is created merely as a joke with no intention of using it as evidence?
Answer:
The mere falsity would not, by itself, satisfy Section 228.
The required evidentiary intention is essential.
Q47. What if a false record is made for an unrelated private purpose?
Answer:
Again, falsity alone does not automatically establish fabrication of false evidence.
There must be the required intention connecting the false material to its appearance in evidence and its misleading effect on a material point.
Q48. Is actual deception of the Court necessary?
Answer:
No.
The statutory definition focuses on the accused’s intention that the false material may cause the person considering the evidence to entertain an erroneous opinion.
Actual success is not expressly required.
Q49. Must the Judge actually believe the fabricated evidence?
Answer:
No.
The offence does not depend upon whether the intended decision-maker is actually fooled.
Q50. Must the fabricated evidence actually alter the result of the proceeding?
Answer:
No.
The statutory focus is on the intention that it may cause an erroneous opinion touching a point material to the result.
Actual alteration of the final result is not expressly required.
Q51. Is financial gain an ingredient?
Answer:
No.
The provision does not require financial benefit.
Q52. Is actual injury to another person required?
Answer:
No separate requirement of actual injury is stated.
The offence concerns the deliberate corruption of the evidentiary process.
Q53. Is dishonest intention expressly required?
Answer:
The provision does not use “dishonestly” as the central mens rea.
Instead, it specifies the particular intention concerning:
- Appearance of the fabricated matter in evidence; and
- Creation of an erroneous opinion on a material point.
Q54. Is malicious intention expressly required?
Answer:
No.
The specific evidentiary intention described by Section 228 is the controlling requirement.
Q55. Why is intention described in the comments as a “prime ingredient”?
Answer:
Because discrepancies, contradictions or inaccuracies do not automatically establish deliberate fabrication.
There must be evidence of the particular intention required by the section.
Q56. Does every discrepancy in evidence amount to fabrication?
Answer:
No.
According to the supplied comments, discrepancies or contradictions in evidence do not automatically amount to intentional deception or fabrication.
Important Principle
CONTRADICTION ≠ AUTOMATIC FABRICATION
Q57. Why is this distinction important?
Answer:
Witnesses and records may contain inconsistencies for many reasons.
Section 228 targets deliberate manufacture of false evidence with a specific evidentiary purpose, not every mistake or inconsistency.
Q58. What is the relationship between Section 228 and Section 229?
Answer:
Section 228:
DEFINES FABRICATING FALSE EVIDENCE
Section 229:
PRESCRIBES PUNISHMENT FOR GIVING OR FABRICATING FALSE EVIDENCE
Memory
228 = DEFINITION
229 = PUNISHMENT
Q59. What punishment does Section 229 provide for fabrication connected with a judicial proceeding?
Answer:
According to the supplied comments and Section 229(1):
IMPRISONMENT OF EITHER DESCRIPTION UP TO 7 YEARS + FINE UP TO ₹10,000
where the false evidence is fabricated for the purpose of being used at any stage of a judicial proceeding.
Q60. What punishment applies in cases other than those under Section 229(1)?
Answer:
According to Section 229(2):
IMPRISONMENT OF EITHER DESCRIPTION UP TO 3 YEARS + FINE UP TO ₹5,000
Q61. Why does Section 229 impose a higher punishment for judicial proceedings?
Answer:
According to the supplied comments, the seven-year punishment demonstrates the legislative intention to treat false evidence affecting judicial proceedings as a serious offence.
Q62. What is a “judicial proceeding” according to the supplied comments?
Answer:
The supplied comments refer to Section 2(m) of the BNSS, under which:
“JUDICIAL PROCEEDING” INCLUDES ANY PROCEEDING IN THE COURSE OF WHICH EVIDENCE IS OR MAY BE LEGALLY TAKEN ON OATH
Q63. What does Section 229 Explanation 1 add?
Answer:
It provides that:
A TRIAL BEFORE A COURT-MARTIAL IS A JUDICIAL PROCEEDING
Q64. What does Section 229 Explanation 2 add?
Answer:
An investigation:
- Directed by law;
- Preliminary to a proceeding before a Court;
is treated as a stage of a judicial proceeding even if the investigation itself does not occur before the Court.
Q65. What does Section 229 Explanation 3 add?
Answer:
An investigation:
- Directed by a Court according to law; and
- Conducted under the authority of a Court;
is a stage of a judicial proceeding even though it takes place outside the Court.
Q66. Can an officer deputed by a Court conduct a proceeding relevant to these provisions?
Answer:
Yes.
According to the supplied comments, officers deputed by Courts to enquire into evidence, whether concerning a statement or document, may conduct proceedings falling within this extended concept of judicial proceeding.
Q67. How does Section 228 differ from Section 227?
Answer:
The distinction can be expressed in note form.
Section 227 — Giving False Evidence
The central wrong is:
MAKING A FALSE STATEMENT WHILE LEGALLY BOUND TO STATE THE TRUTH
Section 228 — Fabricating False Evidence
The central wrong is:
CREATING FALSE EVIDENTIARY MATERIAL OR CIRCUMSTANCES WITH SPECIFIC INTENT TO MISLEAD ON A MATERIAL POINT
Shortest Memory
227 = LIE
228 = MANUFACTURE
Q68. Is being bound by oath essential under Section 228?
Answer:
No.
Unlike giving false evidence, fabrication does not depend on the fabricator being under an oath or equivalent obligation to state the truth.
Q69. Is an existing proceeding essential under Section 228?
Answer:
No.
This is one of its most important characteristics.
Evidence can be fabricated in anticipation of later proceedings.
Q70. What is the best examination formula for Section 228?
Answer:
Use this five-stage test:
1. CREATE SOMETHING FALSE
2. INTEND IT TO APPEAR IN EVIDENCE
3. IN A RECOGNISED LEGAL PROCEEDING
4. INTEND IT TO CAUSE AN ERRONEOUS OPINION
5. ON A MATERIAL POINT
If these requirements are established:
FABRICATING FALSE EVIDENCE = SECTION 228
Key Provisions (Study Notes)
1. Nature of the Offence
Section 228 is primarily a:
DEFINITION PROVISION
It defines what it means to:
FABRICATE FALSE EVIDENCE
The punishment is principally dealt with under Section 229.
2. Three Forms of Fabrication
The accused may:
(a) Cause a False Circumstance to Exist
Example:
PLANT JEWELS
(b) Make a False Entry
Example:
FALSE SHOP-BOOK ENTRY
(c) Make a False Document/Electronic Record
Example:
FORGED LETTER OR FALSE MEDICAL RECORD
Memory
CIRCUMSTANCE – ENTRY – DOCUMENT
3. Required Evidentiary Intention
The accused must intend that the fabricated matter:
MAY APPEAR IN EVIDENCE
This is indispensable.
4. Recognised Proceedings
The intended evidence may appear in:
JUDICIAL PROCEEDING
PROCEEDING TAKEN BY LAW BEFORE PUBLIC SERVANT
PROCEEDING BEFORE ARBITRATOR
5. Intended Effect
The fabricated evidence must be intended to cause the decision-maker:
TO ENTERTAIN AN ERRONEOUS OPINION
6. Materiality
The erroneous opinion must concern:
A POINT MATERIAL TO THE RESULT
7. Actual Use Not Necessary
According to the supplied comments:
FABRICATION + REQUIRED INTENTION IS SUFFICIENT
Actual production of the evidence is unnecessary.
8. Existing Judicial Proceeding Not Necessary
The evidence may be fabricated before the proceeding commences.
Memory
PREPARE NOW → USE LATER
The Three Statutory Illustrations
Illustration (a) — Planting Jewels
FALSE PHYSICAL CIRCUMSTANCE
A plants jewels in Z’s box to make Z appear guilty of theft.
Illustration (b) — False Shop-Book Entry
FALSE RECORD ENTRY
A creates a false entry intending to use it as corroborative evidence in Court.
Illustration (c) — Forged Letter
FALSE DOCUMENT + PLANTING
A imitates Z’s handwriting, creates a false conspiracy letter and places it where police are likely to discover it.
Illustration Memory Formula
JEWELS = CIRCUMSTANCE
SHOP-BOOK = ENTRY
LETTER = DOCUMENT
These three illustrations neatly correspond to the major methods of fabrication.
Section 227 vs Section 228
Section 227 — Giving False Evidence
Think:
FALSE STATEMENT
The person is legally bound to state the truth and nevertheless makes the false statement with the required mental state.
Section 228 — Fabricating False Evidence
Think:
FALSE CREATION
The person manufactures a circumstance, entry, document or electronic record with the specific evidentiary intention required by the provision.
Best Distinction
227 = PERSON LIES
228 = PERSON CREATES THE LIE AS EVIDENCE
Section 228 vs Section 233
This distinction is also important.
Section 228
FABRICATE FALSE EVIDENCE
The emphasis is on creation.
Section 233
CORRUPTLY USE OR ATTEMPT TO USE FALSE/FABRICATED EVIDENCE
The emphasis is on subsequent use.
Memory
228 = MAKE
233 = USE
Quick Revision Notes
Section
228 BNS
Title
Fabricating false evidence
IPC Equivalent
Section 192 IPC
Nature
Definition of fabricating false evidence.
Acts
Create false circumstance, false entry, false document or false electronic record.
First Intention
Fabricated matter may appear in evidence.
Proceedings
Judicial proceeding; proceeding taken by law before public servant; proceeding before arbitrator.
Second Intention
Cause person forming opinion on evidence to entertain an erroneous opinion.
Materiality
Erroneous opinion must touch a point material to the result.
Actual Use
Not necessary according to supplied comments.
Existing Proceeding
Not necessary according to supplied comments.
Punishment
Governed by Section 229 according to the nature of the proceeding.
BNS Change
“Court of Justice” replaced with “Court.”
Exam Traps
Trap 1 — Thinking every false document is fabricated false evidence
Incorrect.
FALSE DOCUMENT + NO EVIDENTIARY INTENT ≠ AUTOMATIC SECTION 228
Trap 2 — Requiring actual production in Court
Incorrect.
According to the supplied comments, fabrication may be complete before actual use.
Trap 3 — Requiring proceedings already to have commenced
Incorrect.
Evidence may be manufactured in anticipation of proceedings.
Trap 4 — Limiting fabrication to documents
Incorrect.
Section 228 includes:
CIRCUMSTANCES
ENTRIES
DOCUMENTS
ELECTRONIC RECORDS
Trap 5 — Forgetting materiality
The intended erroneous opinion must touch:
A MATERIAL POINT
Trap 6 — Forgetting the second intention
It is not enough that the material is intended to appear in evidence.
It must also be intended to cause an erroneous opinion on a material point.
Trap 7 — Thinking only Courts are covered
Incorrect.
The section also expressly covers proceedings before:
PUBLIC SERVANT AS SUCH
and
ARBITRATOR
Trap 8 — Requiring the fabricator to be under oath
Incorrect.
That distinction belongs to the concept of giving false evidence.
Trap 9 — Treating ordinary contradictions as fabrication
Incorrect.
According to the supplied comments:
MERE DISCREPANCY OR CONTRADICTION ≠ INTENTIONAL FABRICATION
The required intention must be established.
Trap 10 — Confusing creation with use
Remember:
228 = FABRICATE
233 = USE
Rapid Revision Chain: Sections 227–237
227 = GIVE FALSE EVIDENCE
228 = FABRICATE FALSE EVIDENCE
229 = PUNISH FALSE EVIDENCE
230 = FALSE EVIDENCE FOR CAPITAL CONVICTION
231 = FALSE EVIDENCE FOR LIFE / 7+ CONVICTION
232 = THREAT FOR FALSE EVIDENCE
233 = USE FALSE EVIDENCE
234 = ISSUE/SIGN FALSE CERTIFICATE
235 = USE FALSE CERTIFICATE
236 = MAKE FALSE DECLARATION
237 = USE FALSE DECLARATION
Best Memory Sequence
227 = GIVE
228 = FABRICATE
229 = PUNISH
230 = CAPITAL
231 = SERIOUS NON-CAPITAL
232 = THREAT
233 = USE
234 = ISSUE CERTIFICATE
235 = USE CERTIFICATE
236 = MAKE DECLARATION
237 = USE DECLARATION
Ultimate Memory Formula
SECTION 228
CREATE
a false:
CIRCUMSTANCE / ENTRY / DOCUMENT / ELECTRONIC RECORD
+
INTEND IT TO APPEAR IN EVIDENCE
before a:
JUDICIAL PROCEEDING / PUBLIC SERVANT / ARBITRATOR
+
INTEND TO CAUSE AN ERRONEOUS OPINION
+
MATERIAL POINT
= FABRICATING FALSE EVIDENCE
Key Takeaway
Section 228 BNS is fundamentally about:
MANUFACTURING EVIDENCE RATHER THAN MERELY TELLING A LIE
The accused must create a false circumstance, entry, document or electronic record with the specific intention that it may appear as evidence in a legally recognised proceeding and cause the person evaluating that evidence to form an erroneous opinion on a matter material to the result.
Actual use is not necessary according to the supplied comments, and the proceeding need not already have commenced. The critical element is the specific evidentiary intention at the time of fabrication.
The statutory illustrations provide the easiest memory device:
PLANTED JEWELS = FALSE CIRCUMSTANCE
FALSE SHOP-BOOK = FALSE ENTRY
FORGED CONSPIRACY LETTER = FALSE DOCUMENT
According to the supplied comments:
Section 228 BNS = Section 192 IPC
with:
“COURT OF JUSTICE” → “COURT”
The punishment is then governed by Section 229, with the more serious punishment applying to fabrication intended for use in a judicial proceeding.
Final Memory Line
“228 = CREATE FALSE EVIDENCE + INTEND IT TO APPEAR IN A LEGAL PROCEEDING + INTEND IT TO MISLEAD ON A MATERIAL POINT.”
