The Supreme Court has prescribed a structured disclosure framework for courts while simultaneously cancelling the bail granted to an accused allegedly involved in forging law degrees and circulating fake academic credentials.
The bench of Justice Ahsanuddin Amanullah and Justice R. Mahadevan has directed that specific case-related disclosures should be placed before judges to ensure informed and reasoned bail decisions. The framework, described as a “facilitative guide,” has been circulated to High Courts and the district judiciary for possible adoption.
Mandatory Bail Disclosures Listed by the Supreme Court
The Court outlined a detailed checklist covering the following categories:
A. Case Details
- FIR number and date
- Police station, district, and state
- Sections invoked
- Maximum punishment prescribed
ZEBA KHAN
B. Custody & Procedural Compliance
- Date of arrest
- Total period of custody undergone
C. Status of Trial
- Stage of proceedings (investigation, chargesheet, cognizance, framing of charges, or trial)
- Total number of witnesses cited
- Number of prosecution witnesses examined
D. Criminal Antecedents
- FIR details and police station
- Sections involved
- Case status (pending, acquitted, or convicted)
E. Previous Bail Applications
- Court and case number
- Outcome of earlier applications
F. Coercive Processes
- Whether a non-bailable warrant was issued
- Whether the accused has been declared a proclaimed offender
The Court noted that the framework is intended to guide courts while leaving room for procedural adaptation based on individual judicial systems and case exigencies.
Bail Cancelled Over Suppression of Material Facts
The appeal was filed by Zeba Khan challenging the bail granted by the High Court of Judicature at Allahabad to the accused, Mazahar Khan.
The Supreme Court found that the High Court relied on documents whose genuineness was under investigation and overlooked serious criminal antecedents, rendering the bail order legally untenable.
It further observed that suppression of criminal history appeared to have materially influenced the grant of bail, thereby vitiating the exercise of judicial discretion.
Allegations of Organised Academic Fraud
The prosecution alleged a large-scale racket involving fabrication and circulation of forged legal qualifications in Uttar Pradesh, with individuals falsely projecting themselves as advocates before courts.
Verification from Veer Bahadur Singh Purvanchal University confirmed that the marksheet relied upon by the accused had never been issued and that the institution in question lacked affiliation to impart legal education.
The Court noted that the allegations disclose a systematic course of conduct affecting the integrity of the legal profession and the administration of justice.
Final Directions
Setting aside the High Court order, the Supreme Court cancelled the bail and directed the accused to surrender before the jurisdictional court within two weeks, failing which appropriate steps must be taken to secure custody.
The trial court has been instructed to proceed independently and conclude the trial expeditiously in accordance with law.
Case Details
Case Title: Zeba Khan Versus State Of U.P.
Case No.: Criminal Appeal No. 825 Of 2026
Date: 11/02/2026
