Connecticut General Statutes

Conn. Gen. Stat. § 52-565 (2026)

Double damages for forgery

✓ current as of May 2026
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Any person who falsely makes, alters, forges or counterfeits any document, or knowingly utters, as true, any document falsely made, altered, forged or counterfeited, shall pay double damages to any party injured thereby.

(1949 Rev., S. 8306.)

See Secs. 53a-137 to 53a-140, inclusive, re forgery.

Not a penal statute. 1 D. 100; 74 C. 136; 87 C. 468. Is constitutional. 82 C. 5. Cited. 205 C. 93; 236 C. 582.

Cited. 11 CA 161; 41 CA 659; 43 CA 1.

An agent may commit forgery by making or signing an instrument in disobedience of his instructions or by exceeding his authority. 24 CS 498.

Notes of Decisions
Cited in 17 cases (5 in the last 5 years), 1987–2025 · leading case: Aksomitas v. Aksomitas, 529 A.2d 1314 (Conn. 1987).
Aksomitas v. Aksomitas, 529 A.2d 1314 (Conn. 1987). · cites it 11× “This matter involves an action brought against the administratrix of an estate by an heir who sought double damages under General Statutes § 52-565 based on allegations of fraudulent concealment and forgery.”
Lauder v. Peck, 526 A.2d 539 (Conn. App. Ct. 1987). · cites it 9× “” The court, therefore, borrowed the criminal offense definition of “falsely makes” and used it in the civil context of General Statutes § 52-565. The second count of the complaint repeated the essential allegations of the first count, and added the allegation that “[t]he making…”
Treglia v. Zanesky, 788 A.2d 1263 (Conn. App. Ct. 2001). · cites it 4× “The plaintiff further asserts that, pursuant to General Statutes § 52-565, the jury should have been charged on double damages related to forgery.”
Criscuolo v. Shaheen, 736 A.2d 947 (Conn. Super. Ct. 1999). · cites it 8× “The second count claims that Shaheen is hable for double damages pursuant to General Statutes § 52-565. The third count alleges a CUTPA violation pursuant to General Statutes § 42-110a et seq.”
Delahunty v. Massachusetts Mut. Life Ins., 674 A.2d 1290 (Conn. 1996). · cites it 2× “General Statutes § 52-564 provides: “Treble damages fortheft.”
Chien v. Skystar Bio Pharm. Co., 623 F. Supp. 2d 255 (D. Conn. 2009). · cites it 2× “See Conn. Gen.Stat. § 52-565 ("Any person who falsely makes, alters, forges or counterfeits any document or knowingly utters, as true, any document falsely made, altered, forged or counterfeited, shall pay double damages to any party injured thereby.”
Koennicke v. Maiorano, 682 A.2d 1046 (Conn. App. Ct. 1996). · cites it 2× “Such statutes include General Statutes §§ 52-565, 52-566, 52-567, 52-568, 52-569, 52-560 and 47a-46.”
Fair Cadillac Oldsmobile Corp. v. Allard, 677 A.2d 462 (Conn. App. Ct. 1996). · cites it 2× “The plaintiff asks us to conclude that, in addition to his statutory duty to serve an execution, a sheriff is responsible for ascertaining any possible legal defects in a facially valid execution. The law does not require or expect sheriffs to have the education and training to…”
Fed. Deposit Ins. Corp. v. Roberti (In Re Roberti), 201 B.R. 614 (Bankr. D. Conn. 1996). “16 in the New London Action, included punitive damages for fraud, treble damages for theft pursuant to Conn.”
Maguire v. Ameriprise Fin. Servs., LLC (D. Conn. 2022). · cites it 6× “Stat § 52-564 (Second Count); aiding and abetting statutory theft (Third Count); forgery, in violation of Connecticut’s civil forgery statute, Conn. Gen. Stat § 52-565 (Fourth Count); conspiracy to commit forgery (Fifth Count); aiding and abetting forgery (Sixth Count); common-…”
Li v. Peck (D. Conn. 2022). · cites it 5× “” Conn. Gen. Stat. § 52-565 . Although Ms. Li alleges that certain statements in the Fairfield Police Department reports and AMR medical reports are false, she does not identify any document that was allegedly forged.”
Cartagena-Cordero v. Five Star Cars, LLC (D. Conn. 2020). · cites it 3× “” Conn. Gen. Stat. § 52-565 . Civil forgery is “a species of fraud.”
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