In a strong message on misuse of legal credentials, the Supreme Court has cancelled the bail granted to an accused who allegedly forged a law degree and projected himself as an advocate before courts, including the apex court itself.
The case, Zeba Khan v. State of U.P. & Others, arose from a challenge to an Allahabad High Court order that had granted bail to Mazahar Khan in connection with an FIR registered in Uttar Pradesh.
The top court held that the High Court’s order was “legally unsustainable” and suffered from serious flaws, including failure to consider the accused’s criminal history.
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Background of the Case
The controversy began with FIR No. 314 of 2024 lodged at Saray Khwaja Police Station in Jaunpur, Uttar Pradesh. The complainant alleged the existence of a large organised racket involved in fabricating and circulating forged academic degrees, particularly law qualifications.
According to the prosecution, the accused claimed to have obtained an LL.B. degree from Sarvodaya Group of Institutions, said to be affiliated with Veer Bahadur Singh Purvanchal University.
However, a letter from the University dated August 10, 2024, stated that the institution was not affiliated with it and that no such marksheet had been issued. Further communication from the college clarified that it did not even offer a law course.
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Investigators alleged that the accused used the purported degree to enrol as an advocate, secure bar memberships, and appear before courts. The FIR invoked offences under cheating and forgery provisions of the Indian Penal Code.
The accused was arrested in April 2025. Though his bail plea was rejected by the Sessions Court, the Allahabad High Court granted him bail in July 2025. That order was challenged before the Supreme Court.
Allegations of a Wider Racket
During the hearing, counsel for the appellant told the bench that the accused had nine criminal cases registered against him across different states, including Karnataka and Maharashtra.
The State supported the appeal, pointing to official communications confirming that the law degree relied upon by the accused was not genuine.
The prosecution also highlighted that the accused allegedly suppressed his criminal antecedents while seeking bail and made contradictory statements about his legal practice in different proceedings.
The bench took note of the tabulated list of multiple FIRs involving allegations of cheating, forgery and related offences.
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Court’s Observations on Bail Principles
The Supreme Court clarified the legal difference between cancelling bail due to later misconduct and setting aside a bail order that was flawed from the start.
The bench observed that appellate courts can interfere when a bail order is “perverse, illegal, or passed in disregard of material considerations.”
In this case, the Court found that the High Court had relied on documents whose authenticity was itself under investigation. It also failed to consider official letters denying the affiliation of the institution that allegedly issued the law degree.
Significantly, the Court noted that the accused appeared to have concealed multiple pending criminal cases.
“The suppression of criminal antecedents materially affects the exercise of judicial discretion,” the bench observed.
It further stated that allegations of impersonating a legal professional and using forged qualifications strike at the integrity of the legal system.
Transfer of Investigation: Court Declines
The appellant had also sought transfer of the investigation to a specialised agency, citing the seriousness of the allegations.
However, the Supreme Court refused this request. The bench pointed out that the investigation had already been completed, a chargesheet filed, and cognisance taken by the trial court.
Transfer of investigation after completion, the Court said, can be ordered only in rare and exceptional circumstances involving clear bias or mala fide conduct - none of which were established here.
The Court also referred to ongoing nationwide verification processes of law degrees being carried out under earlier Supreme Court directions.
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Final Decision
After analysing the material on record, the Supreme Court concluded that the High Court had failed to properly consider key evidence and the accused’s criminal background.
For these reasons, the Court set aside the bail order dated July 30, 2025, and cancelled the bail granted to the accused.
The appeal was accordingly allowed.
Case Title: Zeba Khan v. State of U.P. & Others
Case No.: Criminal Appeal No. 825 of 2026
Decision Date: 2026
