Facts / Background:
An FIR was registered alleging an organised racket involving forged LL.B. degrees and fake academic certificates used to impersonate advocates. 
Respondent No. 2 allegedly procured and used a forged law degree to practice as an advocate and facilitate similar fraud for others. 
The Sessions Court rejected bail, but the High Court granted bail relying on disputed documents and claims of innocence. 
The appellant challenged the bail order citing suppression of multiple FIRs, serious criminal antecedents, and reliance on forged material. 

Court Decision:
The Supreme Court set aside the High Court’s order granting bail, holding it to be perverse and legally unsustainable. 
It held that the High Court relied on disputed and prima facie forged documents, ignored material evidence, and failed to consider criminal antecedents and gravity of offences. 
The Court emphasized that suppression of material facts, including multiple FIRs, vitiates the exercise of judicial discretion in granting bail. 
It clarified that appellate courts can annul bail where the order suffers from illegality, perversity, or non-consideration of relevant factors, irrespective of post-bail conduct. 
The prayer for transfer of investigation to a special agency was rejected as investigation was complete and no exceptional circumstances were shown. 

Cases Referred by Court:
•    State of Karnataka v. Sri Darshan 
•    Yogendra Pal Singh v. Raghvendra Singh 
•    Manik Madhukar Sarve v. Vitthal Damuji Meher 
•    Ajwar v. Waseem 
•    Mahipal v. Rajesh Kumar 
•    P v. State of Madhya Pradesh 
•    Dolat Ram v. State of Haryana 
•    Prasanta Kumar Sarkar v. Ashis Chatterjee 
•    Ash Mohammad v. Shiv Raj Singh 
•    Neeru Yadav v. State of Uttar Pradesh 
•    Brijmani Devi v. Pappu Kumar 
•    Disha v. State of Gujarat 
•    K.V. Rajendran v. Superintendent of Police 
•    Kusha Duruka v. State of Odisha