In Jupally Lakshmikantha Reddy v. State of Andhra Pradesh (Supreme Court, Sept 10, 2025), the appellant, running a college under JVRR Education Society, was accused of submitting a forged Fire NOC to obtain educational recognition. The FIR charged him under Sections 420, 465, 468, and 471 IPC, though the final chargesheet was only under Section 420 (cheating). The Supreme Court examined whether using a fake NOC could constitute cheating when the document was not legally required, as the college building was 14.20 metres tall (below the 15-metre threshold under the National Building Code 2016). The Court held that for Section 420 IPC, a false representation must induce the victim to act or grant a benefit. Since the Fire NOC was unnecessary, no material inducement occurred. Additionally, there was no proof that the appellant created the forged document, negating forgery charges. Consequently, the Court allowed the appeal and quashed the criminal proceedings under Section 420, emphasizing the necessity of materiality and causation in cheating cases.