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2026 Supreme(Online)(MP) 1017

HIGH COURT OF MADHYA PRADESH
Salman Khan Alias Salman Lala – Appellant
Versus
The State Of Madhya Pradesh – Respondent
MCRC 52250/2025



Advocates:
Ashutosh Surana[P-1],Advocate General[R-1]

Judgement Key Points

Key Points: - The applicant, Salman Khan Alias Salman Lala, sought bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, for offenses including forgery and Passport Act violations (!) . - The applicant's first bail application was previously dismissed (!) . - The applicant claims false implication and argues that the prosecution for forgery and Passport Act offenses was added without sufficient evidence from the issuing authority (!) . - The State opposed the bail application citing the gravity of the alleged offense and the applicant's criminal antecedents (18 criminal antecedents and 4 prohibitory proceedings) (!) . - The court noted that the investigation officer could not show documents from the issuing authority verifying the forgery of the voter ID card or passport (!) . - The applicant has been acquitted in some cases and convicted with sentences of imprisonment and fine in others, but has not been convicted for any major offense (!) (!) . - The court found prima-facie merit in the applicant's contentions and stated that the veracity of the prosecution and the applicant's complicity would be considered on merit after evidence (!) . - Considering the applicant's family responsibilities, lack of previous conviction for major offenses, and the proposed prosecution, the court found no likelihood of fleeing justice, tampering with evidence, or influencing witnesses (!) (!) . - The court allowed the bail application on stringent conditions due to the applicant's criminal antecedents (!) . - Bail was granted upon furnishing a personal bond of Rs. 1,00,000/- with one surety of the same amount, subject to several conditions including presence on hearing dates, not committing further offenses, not tampering with evidence, depositing the passport, and marking presence monthly (!) (!) (!) (!) (!) (!) (!) .

What are the conditions for granting bail in cases involving alleged forgery and passport offenses?

How to determine the veracity of prosecution and complicity of an applicant in a criminal case for bail purposes?

What are the implications of criminal antecedents on bail applications?


IN THE HIGH COURT OF MADHYA PRADESH AT INDORE BEFORE HON'BLE SHRI JUSTICE SANJEEV S KALGAONKAR st ON THE 21 OF JANUARY, 2026 MISC. CRIMINAL CASE No. 52250 of 2025 SALMAN KHAN ALIAS SALMAN LALA Versus THE STATE OF MADHYA PRADESH Appearance:

Shri Ashutosh Surana advocate for the applicant.

Shri Ayushyaman Choudhary public prosecutor for State.

Mr. Virendra Singh Chouhan, Sub Inspector Police Station Nagda present in person.

ORDER

1. This second application has been filed by applicant under 483 of Bharatiya Nagarik Suraksha Sanhita, 2023 for grant of bail in connection with Crime No. 43/2023 registered at Police Station - Nagda, District Ujjain(M.P.) for offence punishable under Sections 294, 448, 465, 467, 468, 120-B, 216, 34 of IPC and Section 12 of Passport Act. The applicant is in judicial custody since 28.3.2025. His first bail application was dismissed vide order dated 19.6.2025 passed in MCRC No. 25138/2025.

2. Heard the arguments.

3. Perused the grounds for grant of bail stated in the application, case diary and the relevant material on record.

4. Learned counsel for the applicant, in addition to the grounds mentioned in the application, submits that the applicant has been falsely implicated in this matter. No offence, as alleged, is committed by the applicant. The applicant was in custody of the Police Station Nagda since 31.1.2025 in relation to crime No. 55 of 2025, still he was arrested in present matter on 26.3.2025 deliberately to ensure his incarceration. The primary allegation in this prosecution relates to unauthorised use of school ground, but to increase the gravity and to ensure incarceration of the applicant, the prosecution for offence punishable under Sections 465, 467, 468 of IPC and Section 12 of Passport Act was added without there being any evidence of the Issuing Authority to the effect that the alleged Voter ID card or Passport is false or forged document. These documents were issued in year 2021 and have never been cancelled by the Appropriate Authority. The prosecution against the applicant is malafide. Jail incarceration on false allegation is causing hardship to the applicant. The trial would take time to conclude. There is no likelihood of tampering with evidence by the applicant as the prosecution is based on documentary evidence and verification of it by the Government officials. The trial would take time to conclude. Applicant is ready to co-operate in the trial.

5 . Per contra, learned counsel for the State opposes the application on the ground of gravity of alleged offence. Learned counsel further refers to 18 criminal antecedents and 4 prohibitory proceedings against the applicant, as mentioned in the case diary.

Learned counsel for the State, at the instruction of the Investigation Officer, submits that the address of Salman Lala was verified from the local sources. It was found that he has secured ration card and the passport using address of Rajiv Colony Nagda and Sardar Patel Marg, Thandla. It was informed by the Chief Municipal Officer, Thandla that no ration card was issued in favour of Salman Khan as resident of Nagda. Therefore, the ration card and the passport appear to be forged. However, the Investigation Officer was at loss to explain on what basis the voter ID Card and the Passport were found to have been forged. He could not show any document of the Issuing Authority verifying forgery of the voter ID Card or the Passport.

6. In reply, learned counsel for the applicant submits that the applicant was acquitted vide order dated 2.12.2021 passed in RCT No. 23/2010 in relation to crime No. 264/2010, the applicant stands acquitted in other offences relating to crime Nos. 509/2008, 205/2009, 66/2010, 264/2010. The applicant has been sentenced to imprisonment of TRC and fine in crime Nos. 342/2019 and 69/2023. Other matters are pending for trial.

The applicant has never been convicted for any major offence.

7. As per the accusation on case diary, Kalpna Bhati, Principal of Government Boys Higher

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