Aznan Khan vs. State of U.P. and Another, 2025
It sends a cautionary note that SC/ST Act provisions meant to protect victims should not be exploited to obstruct justice.
Judgement Details
Court
Allahabad High Court
Date of Decision
10 December 2025
Judges
Justice Anil Kumar
Citation
Acts / Provisions
Facts of the Case
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Victim alleged that in 2016, Furkan Ilahi (appellant) met her, took her to a hotel and then to the residence of Aznan Khan (co-accused), where she alleged that Furkan raped her while Aznan bolted the door.
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Alleged repeated sexual relations under the pretext of promise of marriage, and she claimed she was forced to take pills that led to termination of pregnancy.
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FIR was lodged in 2025, nearly 9 years after the alleged incident.
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Some accused, including the victim herself, are practicing advocates.
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The accused moved the Allahabad High Court seeking bail, after their pleas were rejected by the Special Court (SC/ST Act).
Issues
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Whether the unexplained 9-year delay in lodging FIR affects the credibility of the prosecution case?
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Whether the conduct of the victim (a practicing advocate) in court proceedings was appropriate?
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Whether the rights under the SC/ST Act were being misused or abused in this matter?
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Whether the accused-appellants were entitled to bail?
Judgement
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The bench granted bail to the accused, Aznan Khan and Furkan Ilahi, noting the long delay in filing FIR and the conduct of the victim during court proceedings.
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The Court observed that the rights of victims under SC/ST Act “should not be misused or abused.”
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Specific observations were made regarding the victim’s conduct:
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She demanded video recording of the proceedings.
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Objected to other advocates in the courtroom.
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Claimed she had not filed vakalatnama and sought time to engage another advocate.
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Refused to accept service of notice and created obstructions during service.
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The Court did not comment on merits of the case to avoid prejudice but held that the facts, nature of offence, and evidence justified bail.
Held
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Accused-appellants were granted bail, and the bail rejection orders of the Special Judge (SC/ST Act), Bulandshahar, were set aside.
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Court emphasized that victim rights under SC/ST Act must not be misused.
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Noted the inappropriate conduct of the victim in court proceedings, despite her being a practicing advocate.
Analysis
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Balances victim protection with procedural fairness for accused.
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Emphasizes that long delays in filing FIRs and questionable conduct of complainants can impact bail decisions.
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Sends a cautionary note that SC/ST Act provisions meant to protect victims should not be exploited to obstruct justice.
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Highlights judicial discretion in granting bail, even in serious allegations, when procedural anomalies exist.
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Reinforces that courts can critically examine conduct of parties when it impacts administration of justice, without commenting on merits of the criminal case.