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Supreme Court of India, N.H. Bhagwati J;

Mahadeo Prasad v State of West Bengal (1954)

Citation: AIR 1954 SC 724. **Provision:** IPC s. 420 — now **BNS s. 318 (cheating)**; the authority on **intention to deceive at the time of the promise** as the line between cheating and mere breach of contract.. Covered in Unit 12 · Offences Against Property of Law of Crimes (Bharatiya Nyaya Sanhita, 2023).

Say the ratio out loud before you open Reasoning — recalling it unprompted is exactly what the exam pays for.

Why it matters

Cheating (Unit 12) is easy to confuse with a broken contract: both end with someone out of pocket. Mahadeo Prasad draws the line — the offence turns on the accused's intention at the moment he made the promise. It is the standard authority for the "cheating v breach of contract" question, and pairs with Akhil Kishore Ram.

Facts

The appellant agreed to buy 25 ingots of tin from the complainant, price payable cash against delivery. The complainant, to fulfil the order, bought 11 ingots on top of the 14 in his stock and had all 25 delivered to the appellant's guddi. The appellant took delivery, kept the complainant's man waiting, then left and never paid. He was convicted of cheating (IPC s. 420).

Issue

Whether the appellant's conduct was cheating — or merely a breach of the contract to pay, which would not be a criminal offence.

Held

Conviction affirmed. The decisive finding was that the appellant, at the time of the promise, had no intention whatsoever to pay and "merely promised to pay cash against delivery in order to induce the complainant to part with the goods which otherwise he would not have done." That dishonest intention existing at the moment of the promise — the inducement being false when made — turned the transaction from contract into cheating: the complainant was deceived into delivering property he would not otherwise have parted with.

Ratio

Cheating requires a dishonest or fraudulent intention at the time the inducement is made. If the accused meant to perform when he promised and later failed, it is breach of contract, not cheating; if he never intended to perform and used the promise as a lure to obtain the property, it is cheating. The intention is inferred from conduct — here, taking delivery and vanishing without payment.

Under the BNS

Cheating is s. 318; delivery of property induced by deception is the aggravated form in s. 318(4). The reasoning is unchanged. Pair it with Akhil Kishore Ram v Emperor (deception as to one's own powers/belief) as the two Unit-12 authorities on the mental element of cheating, and contrast it sharply with a bona fide contractual default.

In the app

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Related cases in this unit

Parts of the judgment

Precedents cited

  • Akhil Kishore Ram v Emperor