How hard is it to tamper with the odometer?

In the event that the mileage is inaccurate because the cluster was replaced, how would you replace it to show the correct mileage?
I believe the DMV has a form to document an odometer change.
Otherwise the only thing you can do is to document it and keep some sort of record with the vehicle.
This is pretty common on Harleys because people rebuild old bikes that are incomplete, or they want to upgrade to the fancy, white-faced, or metal faced (CVO) gauges.
Not in all cases. If you want to replace the cluster and have the mileage match the PCM, there is tampering involved.
I did exactly this. Had a faulty cluster, bought a replacement, took it to a place to reset the miles on the new cluster to match the miles on the one I took out.
In NY no mileage info shows on the title after 10 years. If this TJ is being sold at a low mileage price I would keep looking. That mileage inconsistency will follow that TJ for the rest of it's life.
Most states do not put mileage after ten years. Anyone can tell if a vehicle has 50,000 miles or 150,000 miles. I have a 20 year old jeep wrangler with 32,000 miles and you can clearly see the difference from one with 3 x that. I don't like the fact that the states no longer put mileage after ten years.
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I replaced odometer on 2006 JK and the place I bought it advertised rebuilt and they told me they all come with 130.000 on it. Do not why they picked that number but that is what it showed when I hooked it up. That should be close to what it had but the odometer quit working about 4 years ago. Everything worked but the odometer. The only clue I had was the last time my daughter got oil change the sticker had 89,000.
I recently replaced the Gauge cluster in my wife's Durango. I just stuck a post it note under the steering column with the mileage difference written on it so that I needed to I could figure the actual mileage.
Looking at a very low mileage Jeep. One problem is there are some inconsistencies with state inspections, title, and the odometer. One state inspection a few years ago says there was over 100,000 miles on it then the next year way less. How hard is it to tamper with the odometer in a TJ? The Jeep is several hours away so I cannot inspect easily myself.

Based on someone I knew, the odometer was easy.....but what happened in the prison shower was not.
This discussion brings back memories of when I started looking for a GMC motorhome. We looked at one that was advertised with only 9600 miles or something. It happens with RV's...Anyway, I was digging around in the glovebox and ran across an oil change receipt that showed the next change was due at 97653 miles (or something in the high 90,000 anyway). The seller was acting pretty sheepish at that the 70's, the odometer only had 5 digits, so they rolled over. This one had rolled over and he didn't know it (he was trying to sell it for his Grampa, I think).

We passed on that one, obviously.
On a 20+ year old vehicle, the most important consideration is condition.

As the years pass, there are less TJ's in good+ condition. If you are looking to buy one to keep, focus on options and condition. Mileage is not an indicator of condition.

On new vehicles, you cannot swap clusters in your driveway like you can with TJ's. Who knows how many of us bought Jeeps with cluster swaps?

I have no idea what the mileage is on my 65 and 67 Mustangs, those cars were bought to drive, not to be garage queens. I'm guessing at least 300k maybe 500k+.
If it's a TJ with a 4.0L, and you have an inspection that says around 100K miles, then it's still a low-mileage jeep.