Attempt to cheat includes deceptive acts beyond preparation, and an admission card can qualify as property under criminal law.

An attempt to cheat arises when, with intent to deceive, the goes beyond mere preparation and takes a step in the course of the deception. Here, false statements to the university, followed by submission of fees and photographs, were held sufficient to induce issue of an admission card, so the conduct amounted to attempt under Section 420 read with Section 511 IPC. The admission card was treated as property because, although it had no intrinsic pecuniary value, it had value as the means of securing entry to the examination hall. The conviction was therefore upheld.

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Issues: Whether the appellant's false representations and subsequent acts constituted an attempt to cheat punishable under Section 420 read with Section 511 of the Indian Penal Code, 1860, and whether the university admission card amounted to property for the purpose of the offence.

Analysis: A person commits an attempt to commit a particular offence when he intends to commit that offence and, after making preparation, does an act towards its commission during the course of the offence. The dividing line between preparation and attempt is factual and depends on the nature of the offence. In a cheating case, the attempt begins when the accused takes a step to deceive the person sought to be cheated. The appellant had knowingly made false statements to the University, followed up the application by sending the fees and photographs, and thereby induced the University to issue the admission card. The card had no pecuniary value in itself, but it had value as the means of obtaining entry to the examination hall and was therefore property.

Conclusion: The appellant's conduct went beyond preparation and amounted to an attempt to cheat. The admission card was property. The conviction under Section 420 read with Section 511 of the Indian Penal Code, 1860, was upheld.

Ratio Decidendi: An attempt to commit cheating is made when, with the intention to deceive, the accused does an act in the course of the offence that advances the deception beyond mere preparation; a document or instrument valuable for securing a legal benefit may constitute property.

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