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BNS Section 28: Counterfeit under Bharatiya Nyaya Sanhita,

Adv. Kuldeep Kumar June 22, 2026 5 min read

Section Overview

Section Number

28

Section Title

Counterfeit

Act

Bharatiya Nyaya Sanhita, 2023 (BNS)

Status

Active

Applicability

Applicable throughout India wherever the Bharatiya Nyaya Sanhita, 2023 is in force.

BNS Section 28 is an interpretative provision that explains the legal meaning of the word "Counterfeit." The concept is important because many criminal offences involve the creation of fake items designed to resemble genuine ones.

Counterfeiting may relate to:

  • Currency notes

  • Official seals

  • Government documents

  • Educational certificates

  • Identity cards

  • Electronic records

  • Trademarks

  • Valuable securities

  • Digital assets

The provision establishes the legal test for determining when an imitation becomes a counterfeit item under criminal law.

BNS Section 28 substantially corresponds to Section 28 of the Indian Penal Code, 1860 and continues the same legal principle.

Section Explanation

Simple Explanation (Plain English / Hinglish)

BNS Section 28 batata hai ki "Counterfeit" ka kya matlab hota hai.

Simple language mein, agar koi vyakti kisi asli cheez jaisi nakli cheez banata hai taaki log use asli samjhen, to use counterfeiting kaha ja sakta hai.

Counterfeit karne ka matlab sirf exact copy banana nahi hota.

Agar nakli cheez itni milti-julti ho ki kisi ko dhokha ho sakta hai, to law use counterfeit maan sakta hai.

Examples:

  • Fake currency note banana.

  • Nakli Aadhaar card banana.

  • Fake university degree banana.

  • Duplicate branded product banana.

  • Forged digital certificate create karna.

Legal Definition (Original Law Text)

The section provides in substance:

"A person is said to counterfeit who causes one thing to resemble another thing intending by means of that resemblance to practice deception, or knowing it to be likely that deception will thereby be practiced."

The section further clarifies that exact imitation is not necessary.

Even partial resemblance may amount to counterfeiting if deception is intended.

Practical Interpretation

To establish counterfeiting, courts generally examine:

  • Whether one item was made to resemble another.

  • Whether the resemblance was intentional.

  • Whether deception was intended.

  • Whether a reasonable person could be misled.

The prosecution is not required to prove that the imitation is perfect.

The focus is on the intention and likelihood of deception.

Essential Ingredients of Counterfeiting

Resemblance

One object must resemble another object.

Intention

There must be an intention to deceive.

Knowledge

The accused knew deception was likely.

Capability of Deception

The resemblance must be capable of misleading people.

Exact Copy Not Necessary

A common misconception is that a counterfeit item must be identical to the original.

The law does not require perfect duplication.

Even a substantially similar imitation may qualify as counterfeit if it is likely to deceive.

Punishment & Legal Classification

Punishment

BNS Section 28 itself does not prescribe punishment.

It merely defines the term "Counterfeit."

Punishment arises under other provisions dealing with:

  • Counterfeit currency

  • Forgery

  • Fake seals

  • Counterfeit trademarks

  • Forged documents

  • Fake government instruments

Bailable / Non-Bailable

Not Applicable.

Cognizable / Non-Cognizable

Not Applicable.

Compoundable

Not Applicable.

Triable By

Not Applicable.

Since Section 28 is a definition clause, procedural classifications do not apply.

IPC ↔ BNS Mapping

IPC Section

Section 28 IPC

BNS Equivalent

Section 28 BNS

Status

Replaced with substantially identical provision.

Comparison Between IPC and BNS

The legal meaning of counterfeiting remains substantially unchanged.

Both provisions emphasize:

  • Resemblance.

  • Deception.

  • Intention.

  • Likelihood of misleading others.

Judicial precedents under IPC continue to provide guidance under BNS.

Real-Life Examples

Example 1

A person prints fake ₹500 notes that resemble genuine currency notes and circulates them in the market.

The notes may constitute counterfeit currency.

Example 2

An individual creates a forged university degree certificate resembling an original degree and uses it to obtain employment.

The certificate may be considered counterfeit.

Example 3

A seller manufactures shoes carrying a famous brand logo and packaging to make buyers believe the products are genuine.

The goods may amount to counterfeit products.

Additional Practical Examples

Digital Counterfeiting

Creating fake digital certificates that resemble authentic certificates.

Government Documents

Producing forged passports, driving licenses, or voter identification cards.

Business Sector

Printing counterfeit invoices and financial documents.

Banking Industry

Creating fake cheques resembling genuine bank instruments.

Landmark Judgments

Case Name

Mobarik Ali Ahmed v. State of Bombay

Court

Supreme Court of India

Key Takeaway

Criminal intent and deceptive conduct are essential elements in offences involving false representations.

Case Name

State of Maharashtra v. Mayer Hans George

Court

Supreme Court of India

Key Takeaway

Knowledge and surrounding circumstances play a significant role in establishing criminal liability.

Case Name

Dr. Vimla v. Delhi Administration

Court

Supreme Court of India

Key Takeaway

Deception and fraudulent intention are central considerations in offences involving counterfeit or fraudulent representations.

Legal Insights

When is this Section Applied?

Section 28 is commonly applied in cases involving:

  • Counterfeit currency.

  • Fake government documents.

  • Forged certificates.

  • Counterfeit trademarks.

  • Identity fraud.

  • Cyber fraud.

  • Electronic record manipulation.

The provision helps courts determine whether an imitation amounts to a counterfeit item.

Common Misuse Scenarios

 Assuming Exact Copies Are Necessary

The law does not require exact duplication.

 Ignoring Intention

Similarity alone is insufficient.

Intent to deceive must generally be established.

Treating Every Duplicate Item as Counterfeit

Not every copy is criminal.

The element of deception is essential.

Confusing Civil and Criminal Liability

Trademark disputes may sometimes involve civil remedies unless criminal elements exist.

Overlooking Digital Counterfeiting

Modern counterfeit activities frequently occur through digital platforms and electronic records.

Defenses Available

Common defenses include:

Lack of Intention

No intention to deceive existed.

Absence of Resemblance

The alleged counterfeit item was clearly distinguishable.

Good Faith Conduct

The accused acted without fraudulent intent.

Lack of Knowledge

The accused was unaware that the item was counterfeit.

Insufficient Evidence

The prosecution failed to prove resemblance and deceptive intent.

Importance of BNS Section 28

Section 28 is vital because it provides the legal framework for identifying counterfeit items.

It helps:

  • Protect consumers.

  • Safeguard government institutions.

  • Preserve trust in financial systems.

  • Prevent fraud.

  • Combat identity theft.

  • Strengthen cybercrime enforcement.

Without a clear definition of counterfeiting, many fraud-related offences would become difficult to prosecute.

Modern Relevance

Counterfeiting has evolved significantly in the digital age.

Modern forms include:

  • Fake QR codes.

  • Counterfeit websites.

  • Fake mobile applications.

  • Digital identity fraud.

  • Forged electronic signatures.

  • Counterfeit digital certificates.

Although technology has changed, the underlying principle remains the same: creating a resemblance with the intention to deceive.

Disclaimer: This article is for general informational purposes only and does not constitute legal advice. Please consult a qualified advocate for your specific legal matter.
Adv. Kuldeep Kumar
Verified Advocate
Bar Council Reg: BR/196/2015

Frequently Asked Questions

BNS Section 28 defines the legal meaning of "Counterfeit" under the Bharatiya Nyaya Sanhita, 2023.

No classification applies because it does not create an offence.

No punishment is prescribed because it only defines a legal term.

BNS Section 28 corresponds to IPC Section 28.

It means making one thing resemble another with the intention of practicing deception.

No. Exact duplication is not required.

Yes. Electronic records and digital documents can be counterfeit.

Yes. Intent to deceive is a key element.

No. It only defines a legal expression.

It forms the foundation of offences involving fake documents, counterfeit currency, forged records, and deceptive imitations.
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