Three men accused of enrolling with the Bar Council of Uttar Pradesh on allegedly forged degrees have been given interim anticipatory bail by the Allahabad High Court, which found prima facie merit in the plea that a marks-sheet or degree is not a “valuable security” under Section 338 of the BNS.
Prayagraj: Arrest has been held off for now for three applicants who face separate FIRs at Police Station Civil Lines, Prayagraj, alleging that they obtained enrolment as advocates with the Bar Council of Uttar Pradesh using forged educational certificates; the Allahabad High Court accepted, prima facie, their argument that the most serious charge, forgery of a valuable security, is not attracted [Shyam Singhal v. State of U.P. & 2 Others].
Justice Rajiv Lochan Shukla passed three orders on October 28, November 3 and November 4, 2026, in the anticipatory bail applications of Shyam Singhal, Harish Chandra and Ram Krishna Mishra, filed under Section 482 of the BNSS.
Is a degree a “valuable security”?
All three applicants argued that, even if the allegations were assumed to be true, a marks-sheet or degree is not a valuable security within Section 338 BNS (formerly Section 467 IPC), and that the remaining offences carry a maximum of seven years. In Singhal’s case, the Court noted his reliance on the Supreme Court’s decision in Shriniwas Pandit Dharamadhikari v. State of Maharashtra (1980) 4 SCC 551 and that he had surrendered his certificate of practice, and observed:
“The marks-sheet is not a valuable security and reliance has been placed by learned counsel for the applicant on a judgment of the Supreme Court in the case of Shriniwas Pandit Dharamadhikari vs. State of Maharashtra, reported in (1980) 4 SCC 551. Prima facie, the argument of the applicant appears to be sound.”
In Harish Chandra’s case, the Court also took note that the applicant is 65 years old. In Mishra’s case, it recorded that the police were trying to arrest him while the Bar Council sought time to produce his records.
What each FIR alleges
All three FIRs invoke Sections 318(4), 338, 336(3) and 340(2) of the Bharatiya Nyaya Sanhita. In Singhal’s case (Case Crime No. 0296 of 2026), the FIR was lodged pursuant to an earlier order of the High Court in a matter under Article 227. Counsel for the Bar Council told the Court that Singhal had claimed a BA degree from Thiruvalluvar University, Tamil Nadu, and that the University had informed in writing that the certificate was fake. The Bar Council urged that no indulgence be shown:
“…it is fake advocates like the applicant who give the entire profession a bad name.”
Harish Chandra (Case Crime No. 351 of 2026) is accused of enrolling on the basis of a fake law degree. In Ram Krishna Mishra’s case (Case Crime No. 0367 of 2026), the allegation is that his BA LLB degree from Glocal University, Saharanpur was found to be forged on verification; his counsel argued that the marks-sheet and other documents remain unverified but have not actually been found to be forged.
Protection only till the next dates
The State had not received instructions and the Bar Council sought time, so the Court did not decide the applications finally. It listed them on November 16, 19 and 25, 2026 respectively. Until then, each applicant is to be released on interim anticipatory bail on a personal bond and surety, on conditions that he joins interrogation when required, does not influence or intimidate witnesses and does not leave India without permission. Counsel for the Bar Council is to be shown as counsel for the informant or opposite party on the next dates.
The orders are interim and record only a prima facie view. The allegations against the three applicants are yet to be tested at trial, LawChakra expresses no view on the merits, and each of them is presumed innocent unless proven guilty.
The wider significance
Verification of advocates’ degrees has become a sharp issue for State Bar Councils, and criminal cases against those alleged to have enrolled on forged documents are now reaching the High Court in numbers. The orders flag a legal point that could shape how such cases are charged: whether a degree or marks-sheet is a “valuable security”, which decides whether the offence carries life imprisonment or a far lighter maximum.
For now, the Court has balanced the Bar Council’s concern for the profession’s integrity against personal liberty, granting short-term protection while the State and the Bar Council place their records before it.
Case Titles: Shyam Singhal v. State of U.P. & 2 Others; Harish Chandra v. State of U.P. & Another; Ram Krishna Mishra v. State of U.P. & Another
Case Nos.: Criminal Misc. Anticipatory Bail Application U/S 482 BNSS Nos. 11286, 11533 and 11025 of 2026
Bench: Justice Rajiv Lochan Shukla, High Court of Judicature at Allahabad
Dates of Orders: October 28, November 3 and November 4, 2026
Appearances: Advocates Devesh Kumar Sharma and Saurabh Pandey for Shyam Singhal; Advocates Rakesh Kumar Mishra and Vijay Kumar Ojha for Harish Chandra; Advocates Rahul Pandey and Rang Nath Pandey for Ram Krishna Mishra; Advocate Ashok Kumar Tiwari for the Bar Council of Uttar Pradesh; AGA for the State
READ ORDER (Shyam Singhal) | READ ORDER (Harish Chandra) | READ ORDER (Ram Krishna Mishra)