How is it possible for Android to receive Bluetooth pair requests when Bluetooth is turned off

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I have an issue where an Android app is sending users pair requests even though Bluetooth is turned off on their devices.

How is this possible? Has anyone ever come across something like this before? I thought it was the users device but they've managed to replicate it somehow on multiple devices (can't replicate it myself) so maybe it's something set in the app code

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With a current Android phone, a user application cannot disable Bluetooth. Only a few special applications, including the system application, are allowed to do so.

The background to this is probably that many applications use Bluetooth technology today and therefore a single application could take this function away from all other applications.