Madhya Pradesh High Court Grants Anticipatory Bail to Journalist Amid Allegations of Video Manipulation

Court acknowledges professional duty and clean past; imposes conditions for cooperation and non-indulgence in similar offences.

Indore, November 17, 2025: In a significant judgment, the Madhya Pradesh High Court has granted anticipatory bail to Rafiq Khan, a 42-year-old news reporter, who was facing arrest in connection with allegations of video manipulation aimed at tarnishing the reputation of a police official. The case, registered under Sections 336(3) and 336(4) of the Bharatiya Nyaya Sanhita, 2023, involves accusations that Khan edited and circulated a video falsely accusing Head Constable Mahendra Tiwari of accepting bribes.

Justice Sanjeev S Kalgaonkar presided over the proceedings, wherein Khan's legal counsel argued that the video was recorded as part of Khan's professional duties and was not manipulated. The defense highlighted Khan's clean past, social standing, and the absence of any criminal intent or antecedents.

The court acknowledged these factors, noting Khan's age, profession, and responsibilities, which collectively diminished the likelihood of his fleeing from justice or engaging in further criminal activities. The court emphasized the importance of adhering to legal guidelines, referencing Supreme Court precedents such as Amesh Kumar v. State of Bihar (2014) 8 SCC 273 and Satender Kumar Antil v. Central Bureau of Investigation (2022) 10 SCC 51, which advocate for notice issuance rather than immediate arrest for offenses punishable by less than seven years of imprisonment.

In granting anticipatory bail, the court imposed several conditions on Khan, including cooperation with the investigation, abstention from similar offenses, and non-tampering with evidence. Khan is required to furnish a personal bond of Rs. 50,000/- along with a solvent surety of the same amount. The court stipulated that the bail conditions be explained to Khan and his surety, ensuring compliance throughout the trial.

The judgment underscores the balance between safeguarding individual rights and facilitating a fair investigation. It reflects the judiciary's role in considering the broader implications of incarceration, particularly for individuals with a clean past and significant social responsibilities.

The court's decision will remain effective until the conclusion of the trial, with provisions for bail cancellation if any conditions are breached. The case serves as a reminder of the legal system's duty to uphold justice while recognizing the complexities inherent in professional and personal conduct.

Bottom Line:

Anticipatory bail granted under Section 482 of Bharatiya Nagarik Suraksha Sanhita, 2023 considering the clean past, status, and profession of the applicant despite allegations of manipulation and forgery of video evidence.

Statutory provision(s): Section 482 of Bharatiya Nagarik Suraksha Sanhita, 2023; Sections 336(3), 336(4) of Bharatiya Nyaya Sanhita, 2023

Rafiq Khan v. State of Madhya Pradesh, (Madhya Pradesh)(Indore) : Law Finder Doc Id # 2810115