Forged Law Degrees | Fabrication, Procurement: Supreme Court Cancels Bail of Accused Issuing Fake Certificates

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Today, On 11th February, The Supreme Court has cancelled the bail granted to Mazahar Khan, accused of issuing counterfeit degree certificates to lawyers. The Court said the allegations indicate an organised pattern of fabricating and procuring false qualifications, undermining the integrity of the legal profession.

The Supreme Court revoked the bail previously granted by the Allahabad High Court to Mazahar Khan, who is accused of issuing counterfeit degree certificates to lawyers.

A Bench comprising Justice Ahsanuddin Amanullah and R. Mahadevan cancelled the High Court’s decision made on July 30, 2025.

The apex court observed that the allegations against Khan are not merely isolated instances of forgery; rather, they hint at a pattern of organized misconduct involving the fabrication, procurement, and use of false educational qualifications, especially law degrees, which significantly impacts the integrity of the legal profession.

The Bench stated,

“The case against Respondent No. 2 is not confined to an isolated instance of forgery. It prima facie discloses a systematic and organised course of conduct involving the fabrication, procurement, and use of false educational qualifications, particularly law degrees, which has a direct bearing on the integrity of the legal profession,”

The Court further remarked that the accused misused his freedom to stalk and intimidate the complainant following his release on bail.

The Court added while set-a-siding the bail order,

“The submission that Respondent No. 2 has not misused the liberty granted to him cannot be considered in isolation. There are prima facie allegations of stalking and intimidating the appellants after the grant of bail. The existence of a family or property dispute does not dilute the gravity of allegations involving impersonation as a legal professional and the use of such credentials before courts, which have serious public and institutional ramifications,”

Nonetheless, the Court declined to initiate an investigation by the Central Bureau of Investigation (CBI) into the case.

Khan was apprehended by Bengaluru police in Maharashtra for his role in a case involving a forged BHMS degree associated with an institution in Karnataka, following a complaint lodged by a law practitioner, Zeba Khan.

Khan had been operating an educational institution in Chhatrapati Sambhajinagar. It was revealed that he was also wanted by the Uttar Pradesh Police for issuing forged degree certificates to lawyers and was facing prosecution at the Jaunpur District Court in UP.

In challenging the bail, the complainant also called for a CBI investigation. While the Court cancelled Khan’s bail, it refused to mandate a CBI probe, citing,

“No specific or substantial material has been placed on record to demonstrate that the investigation conducted by the State Police was vitiated by mala fides, bias or extraneous influence.”

Producing or using counterfeit degree certificates to become a lawyer is a serious offence under Indian law.

Such acts attract multiple provisions of the Indian Penal Code, including Sections 420 (cheating), 465 (forgery), 468 (forgery for the purpose of cheating), 471 (using a forged document as genuine), and 474 (possession of forged documents), all of which carry significant prison terms and fines.

Under the Advocates Act, 1961, a person must hold a genuine law degree for enrolment, and any enrolment obtained through fraud can be cancelled under Sections 24 and 26.

Overall, using counterfeit degrees in the legal profession leads to criminal liability, disqualification, and permanent debarment.

Case Title: Zeba Khan v. State of Uttar Pradesh





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