Making a false document is different from causing the making of a false document

Making a false document is different from causing the making of a false document;  Only those who make fake documents can be charged with fraud: Supreme Court [Read Judgment] https://drive.google.com/file/d/164yukU51jaN43VBzdMzEDwiDHbf3tyCT/view?usp=drivesdk

 The Supreme Court said in Sheela Sebastian vs. Jawaharraj case that making a fake document is different from causing the making of a fake document and action cannot be taken against a person who is not engaged in preparing this document.