Criminal record (4)
I believe the answer is:
form
'criminal record' is the definition.
(a repeat offender may be said to 'have form')
This is all the clue.
(Other definitions for form that I've seen before include "Hare's home - something to be filled in" , "'Shape, bench or school class (4)'" , "Establish" , "Make" , "Class - questionnaire" .)