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Bombay High Court

SAGAR BABA SINGHversusTHE STATE OF MAHARASHTRA

Decided
Disposal
Disposed Off

Holding

Anticipatory bail is granted subject to stringent conditions of cooperation, reporting, and non‑tampering with evidence.

Summary

The applicant, Sagar Baba Singh, filed an anticipatory bail application under Section 482 of the Bharatiya Nyaya Sanhita, 2023, fearing arrest in FIR No. 68 of 2026 for alleged offences under Sections 3(5), 316(2) and 318(4). The applicant contended that the complaint stemmed from a commercial dispute with the second respondent and offered to cooperate fully with the investigating officer. The State argued that the applicant’s cooperation would obviate the need for custodial interrogation. The Court held that anticipatory bail could be granted provided the applicant complied with strict conditions, including regular reporting, surrender of passport, and non‑interference with evidence. Accordingly, the bail was ordered on a personal bond of Rs. 25,000 with local sureties and a series of conditions, and the application was disposed.

Issues considered

  • The appropriateness of granting anticipatory bail under Section 482, BNSS 2023 for offences under Sections 3(5), 316(2) and 318(4).
  • Whether the applicant’s willingness to cooperate and the commercial nature of the dispute justify bail without custodial interrogation.

Legislation cited

Subjects

  • anticipatory bail
  • Section 482
  • Bharatiya Nyaya Sanhita
  • commercial dispute
  • cooperation with investigation
  • bail conditions

Judgment

                                                       27-ABA-1100-2026.doc


       IN THE HIGH COURT OF JUDICATURE AT BOMBAY
              CRIMINAL APPELLATE JURISDICTION
       ANTICIPATORY BAIL APPLICATION NO. 1100 OF 2026
Sagar Baba Singh                                  … Applicant
      Versus.
The State Of Maharashtra                         … Respondent
                               -----
Mr. Rishabh Singh a/w Leepika Basant, Vikram Sutaria, for the
Applicant.
Mr. Sukanta Karmakar, APP for the Respondent – State.
API Sandip Mane, CBD Police Station, is present.
                              ------

                               CORAM : ASHWIN D. BHOBE, J.
                                DATE : 28th April, 2026.
P.C. :


1.       Heard, Mr. Rishabh Singh learned Advocate for the Applicant

and Mr. Sukanta Karmakar learned APP for the Respondent –

State.



2.       By the present Application filed under Section 482 of the

BNSS 2023, the Applicant is before this Court seeking pre-arrest

bail, apprehending arrest in Crime No. 68 of 2026, dated

24.03.2026, registered with the C.B.D. Belapur Police Station, Navi

Mumbai (hereinafter “impugned FIR”), for offences punishable

under Sections 3(5), 316(2), and 318(4) of the Bharatiya Nyaya


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                                                     27-ABA-1100-2026.doc


Sanhita, 2023.



3.      Mr. Rishabh Singh learned Advocate for the Applicant,

submits that the subject matter of the complaint filed by the First

Informant is a commercial dispute between the Applicant and

Respondent No. 2.



4.      Mr. Sukanta Karmakar, learned APP for the Respondent –

State, on instructions from the Investigation Officer investigating

the impugned FIR, states that if the Applicant undertakes to

remain present before the Investigation Officer for the purpose of

investigation as and when required and cooperates with the

investigation, the Respondent No. 1 does not require the Applicant

for custodial interrogation.



5.      Mr. Rishabh Singh, learned Advocate for the Applicant, on

instructions from the Applicant, states that the Applicant shall

appear before and remain present before the Investigation Officer

at the C.B.D. Belapur Police Station, as and when required by the

Investigation Officer for the investigation of the impugned FIR. He

further states that the Applicant will cooperate with the

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                                                       27-ABA-1100-2026.doc


investigation of the impugned FIR. The statements made by Mr.

Rishabh Singh before this Court, on instructions from the

Applicant, are accepted.



6.      In view of the above, this Application is allowed on the

following terms:-


           (a)    In the event of arrest of the Applicant in
           C.R. No. 68 of 2026 dated 24.03.2026, registered
           with C.B.D. Belapur Police Station, the Applicant
           shall be released on bail upon furnishing a PR
           bond in the sum of Rs. 25,000/- (Rupees Twenty-
           Five Thousand only) with one or two local sureties
           in like amount.


           (b)   Applicant shall report to the Investigation
           Officer, C.B.D. Belapur Police Station, on the 2 nd
           and 4th Saturday of every month between 10.00
           am to 12.00 pm., commencing from the month of
           May 2026. In the event the Applicant is required
           on any other day, by the Investigating Officer,
           C.B.D. Belapur Police Station, the Applicant shall
           ensure his presence before the Investigating
           Officer.



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                                                                                27-ABA-1100-2026.doc


                                (c)   Applicant shall not directly or indirectly
                                make any inducement, threat or promise to any
                                person/s acquainted with the facts of the case to
                                dissuade such person/s from disclosing the facts to
                                the Court or any police officer.


                                (d) Applicant shall not tamper with evidence in
                                any manner.


                                (e)   Applicant shall provide the Investigation
                                Officer with his residential address along with
                                proof, his contact number, email and must inform
                                the Investigating Officer of any changes to this
                                information from time to time.


                                (f)   Applicant    shall    cooperate    with       the
                                Investigating Officer in the process of investigation
                                of the present Crime.


                                (g)   The Applicant shall hand over his Passport, if
                                any, to the Investigation Officer, C.B.D. Belapur
                                Police Station, within 15 days from today.


                     7.      Anticipatory Bail Application No. 1100 of 2026 is disposed

                     of.



                                                                   (ASHWIN D. BHOBE, J.)

        Digitally
        signed by
                     Arjun                              4
        ARJUN
ARJUN   KRISHNA
KRISHNA RODGE
RODGE   Date:
        2026.04.29
        22:30:26
        +0530


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