Penal Code, 1860–Sec. 420–Scope–It is necessary to show that a person had the fraudulent or dishonest intention at the time of making promise to say that he committed an act of cheating–Mere failure to keep up a promise subsequently cannot be presumed as an act of cheating, but at the same
time, the subsequent conduct of accused is also relevant factor to infer whether he had the fraudulent or dishonest intention at the inception.
