Patna High Court Refuses to Quash FIR Against Politician With 23 Criminal Cases in Police Assault Case
Patna High Court declines to quash FIR against politician Naj Ahmad Khan.
The Patna High Court has refused to quash an FIR lodged against Bihar politician Naj Ahmad Khan alias Pappu Khan over allegations that he led a mob that assaulted police personnel who had arrived at his residence in connection with an investigation into an allegedly forged firearm licence verification report.
Naj Ahamad Khan contested the 2025 Bihar Assembly elections as a candidate of Prashant Kishor's Jan Suraaj Party (JSP).
A single-judge bench of Justice Arun Kumar Jha observed that the petitioner's allegation that the prosecution was acting with mala fide intent could not be sustained, particularly in view of his "long criminal history". Khan is accused in a total of 23 cases.
Court also noted that if a false police verification report showing that Khan had no criminal antecedents was indeed prepared for obtaining a second firearm licence, he would have been the "ultimate beneficiary" of such a report.
Khan had approached the high court seeking quashing of Kesariya P.S. Case No. 127 of 2026, registered under various provisions of the Bharatiya Nyaya Sanhita, alleging assault on police personnel, obstruction of public servants and related offences.
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The FIR stems from events that allegedly unfolded when a police team visited Khan's residence while investigating another case, Kesariya P.S. Case No. 126 of 2026. That case concerns allegations that a false police verification report was submitted during the processing of Khan's application for a second firearm licence.
According to the prosecution, the verification report falsely recorded that Khan had no criminal antecedents, despite him allegedly having 23 criminal cases to his name. Authorities subsequently initiated an investigation into how such a report came to be prepared.
What happened when police went to investigate?
According to the FIR, when police personnel reached Khan's residence as part of the investigation, he and several others became aggressive and gathered a mob at the spot.
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The prosecution alleged that the mob, acting at Khan's instigation, attacked the police team with lathis, wooden planks and iron rods, causing injuries to the officers. The petitioner allegedly managed to evade arrest. The State also told the court that videos and photographs of the incident had been collected during the investigation.
Opposing the plea, the State argued that Khan was a habitual offender with 23 criminal antecedents and that the allegations disclosed clear commission of cognizable offences requiring a full investigation.
Why did court reject the mala fide argument?
Khan argued that he was being targeted because of political rivalry. He told the court that he is an active politician, his wife is the Prakhand Pramukh of Kesariya Block, and that he had previously contested Assembly elections.
Rejecting the contention, Justice Jha noted that the petitioner stood to benefit from the allegedly false verification report.
"If the petitioner applied for a second firearm license and some report was being submitted showing nil criminal antecedent against the petitioner the ultimate beneficiary would have been the petitioner," court observed.
Court further remarked that merely claiming he had no role in the preparation of the report "would not cut much ice", since any such forgery would have been committed to benefit him.
"In these circumstances and considering the long criminal history of the petitioner, I do not think imputation of mala fide of prosecution is sustainable," the judge said.
Referring to the Supreme Court's decision in State of Haryana v. Bhajan Lal (1992), court held that the allegations in the FIR disclosed cognizable offences and that the case did not fall within any of the recognised categories warranting quashing of criminal proceedings.
Finding no merit in the petition, court dismissed the plea and allowed the investigation to proceed.
Case Title: Naj Ahmad Khan @ Pappu Khan v. State of Bihar & Ors
Judgment Date: June 19, 2026
Bench: Justice Arun Kumar Jha