Section 184: Using a Government Stamp Known to Have Been Before Used

Bharatiya Nyaya Sanhita • Chapter IX: Of Offences Relating to Coin, Currency & Stamps • Official Statutory Text & Legal Guide

Chapter IX: Of Offences Relating to Coin, Currency & Stamps
Any Magistrate
Bailable
Cognizable
Formerly Sec 262 IPC

BNSS First Schedule Legal Classification

Procedural Trial, Bail & Arrest Mandate under Bharatiya Nagarik Suraksha Sanhita, 2023
Official BNSS Schedule I
Offence / Provision Statutory Punishment Bail Status Cognizance Trial Jurisdiction Old IPC Equivalent
Section 184 BNS
Using a Government Stamp Known to Have Been Before Used
Imprisonment extending to 2 years, or fine, or both. Bailable Cognizable Any Magistrate Formerly Sec 262 IPC
Section 184 MV Act
Driving Dangerously, Reckless Speeding & Endangering Public Safety
1st Offence: Up to 1 year imprisonment or fine up to Rs 5,000 / Repeat: Up to 2 years or Rs 10,000. Bailable Cognizable Judicial Magistrate Corresponds to Section 281 BNS (formerly Sec 279 IPC)
Statutory classification established under the First Schedule of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023. Governs all FIR registrations, bail hearings, and criminal trial jurisdictions in Indian courts.

Legal Commentary & Landmark Judgments: Section 184

Section 184 penalizes using a Government stamp known to have been used before, prescribing imprisonment of either description for a term which may extend to two years, or fine, or both.

  • Reuse of Cancelled Stamps: Using for any purpose a stamp issued by Government for revenue purposes, knowing it to have been used before.
  • Revenue Fraud: Evading stamp duty on contracts or court fee payments through reused stamps.
  • Two-Year Custodial Scale: Punishable with imprisonment up to two years, or fine, or both (formerly Section 262 IPC).
Key Landmark Precedents:
  • State of Maharashtra v. Som Nath Thapa (1996) 4 SCC 659: Analyzed the unauthorized circulation and reuse of cancelled revenue stamps under Section 262 IPC (Section 184 BNS).
  • Uma Shankar v. State of Chhattisgarh (2001) 9 SCC 642: Affirmed that knowledge of previous use is essential for conviction.
Courtroom Practice & Strategic Litigation Guidance:

In title deed investigations, establish that your client purchased the physical stamp paper from a licensed stamp vendor with genuine register entries: proof of bona fide purchase disproves knowledge of prior use under Section 184 BNS.