Section 178 punishes counterfeiting, or knowingly performing any part of the process of counterfeiting, any coin, any stamp issued by Government for the purpose of revenue, or any currency-note or bank-note, with imprisonment for life, or imprisonment of either description up to ten years, and fine. This is the opening section of Chapter X (Of Offences Relating to Coin, Currency-Notes, Bank-Notes, and Government Stamps), and it also carries the Explanation defining several terms used throughout this Chapter.
Verified against the National Crime Records Bureau's official BNS–IPC concordance (Sankalan Portal), which maps Section 178 to a cluster of old IPC provisions, and cross-checked directly against the bare text of each.
| BNS section | IPC, 1860 equivalent | Category |
|---|---|---|
| 178 | 231, 255, 489A (offence-creating provisions); Explanation drawing on 230, 246, 248 (definitional provisions) | Merged |
Merged: The old IPC scattered this subject across several separate sections — Section 231 (counterfeiting coin, punishable with imprisonment up to seven years and fine), Section 255 (counterfeiting a Government revenue stamp, punishable with imprisonment for life or up to ten years, and fine), and Section 489A (counterfeiting currency-notes or bank-notes, punishable with imprisonment for life or up to ten years, and fine). Section 178 consolidates all three offences into one provision and adopts the higher punishment (imprisonment for life, or imprisonment of either description up to ten years, and fine) uniformly across all three subject matters, rather than retaining Section 231's separate seven-year cap for coin alone. Section 178's own Explanation, in turn, draws its five defined terms from four separate old-law sources: Explanation (1) ("bank-note") reproduces the Explanation to old Section 489A; Explanation (2) ("coin") reproduces old Section 230's definition (dropping the separate "Indian coin" definition and its illustrations, which are not carried into the BNS Explanation); Explanation (3) ("counterfeiting Government stamp") reproduces the Explanation to old Section 255; Explanation (4) ("counterfeiting coin") reproduces the Explanation to old Section 231; and Explanation (5) ("counterfeiting coin" — diminishing weight/altering composition/appearance) draws on old Sections 246 and 248, which were themselves separate standalone offences under the old law (each independently punishable with imprisonment up to three years and fine) and are folded here into a definitional clause rather than retained as separate offences.
Whoever counterfeits, or knowingly performs any part of the process of counterfeiting, any coin, stamp issued by Government for the purpose of revenue, currency-note or bank-note, 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.
Explanation.—For the purposes of this Chapter,—
(1) the expression “bank-note” means a promissory note or engagement for the payment of money to bearer on demand issued by any person carrying on the business of banking in any part of the world, or issued by or under the authority of any State or Sovereign Power, and intended to be used as equivalent to, or as a substitute for money;
(2) “coin” shall have the same meaning as assigned to it in section 2 of the Coinage Act, 2011 and includes metal used for the time being as money and is stamped and issued by or under the authority of any State or Sovereign Power intended to be so used;
(3) a person commits the offence of “counterfeiting Government stamp” who counterfeits by causing a genuine stamp of one denomination to appear like a genuine stamp of a different denomination;
(4) a person commits the offence of counterfeiting coin who intending to practise deception, or knowing it to be likely that deception will thereby be practised, causes a genuine coin to appear like a different coin; and
(5) the offence of “counterfeiting coin” includes diminishing the weight or alteration of the composition, or alteration of the appearance of the coin.
Source: Bharatiya Nyaya Sanhita, 2023 (Act No. 45 of 2023), as published in the Gazette of India Extraordinary.
This section brings together, in one place, what the old law spread across separate sections for coin, Government revenue stamps, and currency-notes/bank-notes, and sets a single, uniformly high punishment ceiling for all three. Merely performing "any part of the process" of counterfeiting is enough — a person need not complete a finished forged coin, stamp, or note to fall within this section. The accompanying Explanation supplies the working definitions (bank-note, coin, counterfeiting Government stamp, counterfeiting coin, and the forms diminishing/altering a coin can take) that apply throughout this Chapter.
These judgment(s) relate to Section 178 as a whole rather than to one specific sub-section, and so are presented together here rather than alongside a particular clause above.
Six accused were charged with conspiring to forge and counterfeit American 20-dollar notes by printing 2000 of them, and two of them were also alleged to hold 148 forged notes knowing them to be forged. The Sessions Court discharged them at the threshold, accepting their argument that a charge for counterfeiting or possessing counterfeit currency notes could lie only for Indian notes, not foreign ones. The Kerala High Court confirmed the discharge, and the State appealed to the Supreme Court.
The Supreme Court reversed that view. It held that the expression ‘currency note’ in these provisions is wide enough to cover the currency notes of any country, because the legislature did not say ‘Indian currency note’ and a court cannot re-write the section to narrow it. So counterfeiting foreign notes such as dollar bills, or possessing counterfeit ones, falls within the offence.
Currency check: decided November 1986, a foundational authority on the scope of this offence; no adverse subsequent history found.
Yes. Section 178 consolidates what the old law treated as three separate offences (counterfeiting coin, counterfeiting a Government revenue stamp, and counterfeiting currency-notes or bank-notes) into a single provision with one punishment.
Yes. The section punishes "knowingly performs any part of the process of counterfeiting," not only a completed counterfeit.
Imprisonment for life, or imprisonment of either description up to ten years, along with fine.