Bombay High Court
SHRIRAM LALUJI MUGAL AND ANRversusSTATE OF MAHARASHTRA
- Decided
- Disposal
- Disposed Off
Holding
The court granted anticipatory bail to the applicants subject to specified conditions.
Summary
The applicants, Pawan Shriramji Mugal, Shriram Laluji Mugal and Varsha Nikhil Yokar, filed anticipatory bail applications in connection with CR No. 391 of 2026, alleging offences under the Maharashtra Prevention and Eradication of Human Sacrifice Act, 2013 and several sections of the Bharatiya Nyaya Sanhita, 2023. The first informant, the wife of the first accused, submitted a statement on 19 September 2026 indicating that the underlying dispute was matrimonial, had been settled, and that no complaint was being pursued. The learned counsel argued that, given the settlement and the applicants’ clean antecedent, custodial interrogation was unnecessary. The court accepted that the dispute was essentially matrimonial and that the informant’s statement negated the need for further detention, finding the applicants eligible for anticipatory bail. Consequently, the court ordered that the applicants be released on bail upon furnishing a cash surety and complying with several conditions, including cooperation with the investigation and non‑interference with witnesses.
Issues considered
- Whether anticipatory bail should be granted when the complainant states that the matrimonial dispute is settled and no complaint is being pursued.
- Whether custodial interrogation is necessary in light of the informant’s statement and the nature of the dispute.
- Whether the offences alleged under the Maharashtra Human Sacrifice Act and the Bharatiya Nyaya Sanhita warrant denial of bail.
Legislation cited
- Bharatiya Nyaya Sanhita (B.N.S) of 2023 — s. 109, 115(2), 316(2), 318(4), 3(5), 351(2), 352, 85
- Maharashtra Prevention and Eradication of Human Sacrifice, other Inhuman and Aghori Practices and Black Magic Act, 2013 — s. 3(3)
Subjects
- anticipatory bail
- matrimonial dispute
- human sacrifice act
- bail conditions
- criminal procedure
- Maharashtra
- Bharatiya Nyaya Sanhita
Judgment
926-ABA-2684-2026.DOC
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CRIMINAL APPELLATE JURISDICTION
ANTICIPATORY BAIL APPLICATION NO. 2684 OF 2026
Pawan Shriramji Mugal …Applicant
Vs.
State of Maharashtra …Respondent
WITH
ANTICIPATORY BAIL APPLICATION NO. 2194 OF 2026
Shriram Laluji Mugal & Anr. …Applicants
Vs.
State of Maharashtra & Anr. …Respondents
Ms. Nikita Kaur i/b Mr. Mihir Sharma, for the applicant in ABA No.
2684 of 2026.
Mr. Pravin Desai, for the applicants in ABA No. 2194 of 2026.
Ms. Dhanalakshmi Krishna Iyer, APP for the Respondent-State.
API Samadhan Hire, Panchvati, Nashik City.
CORAM: MADHAV J. JAMDAR, J.
DATE : 30th SEPTEMBER, 2026
P. C.:
1. Heard, Ms. Kaur and Mr. Desai, learned counsel appearing
for the applicants in respective Applications and Ms. Iyer, learned
APP appearing for the State.
2. By this Anticipatory Bail Applications the Applicants are
seeking Anticipatory Bail in connection with C.R. No. 391 of 2026
registered with Panchvati Police Station, Nashik City, Under
Aftab S.
Page 1 of 4
30th September, 2026
926-ABA-2684-2026.DOC
Section 3(3) of the Maharashtra Prevention and Eradication of
Human Sacrifice, other Inhuman and Aghori Practices and Black
Magic Act, 2013 and Sections 109, 115(2), 3(5), 316(2), 318(4),
351(2), 352 and 85 of Bharatiya Nyaya Sanhita(B.N.S) of 2023.
The Applicant – Pawan Shriramji Mugal is Accused No. 1,
Applicant - Shriram Laluji Mugal and Varsha Nikhil Yeokar are
Accused Nos. 2 and 3. The First Informant is the wife of Accused
No. 1, Daughter-in-law of Accused No.2 and Sister-in-law of
Accused No.3.
3. It is the submission of the learned counsel appearing for the
applicants that the dispute is of matrimonial nature and the
dispute is settled. Accordingly, statement is recorded by the
Investigating Officer of the First Informant dated 19 th September
2026 wherein she has stated that how there is no complaint
against the applicants.
4. The prosecution case is set out in paragraph no. 2 to 5 of
order dated 28th July, 2026 passed by the learned Additional
Sessions Judge, Nashik in Criminal Bail Application no. 1414 of
2026. Although, there are several allegations, however, the dispute
is mainly of matrimonial nature.
Aftab S.
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30th September, 2026
926-ABA-2684-2026.DOC
5. In view of the statement dated 19 th September, 2026 of the
First Informant wherein she has stated that the dispute is settled,
the custodial interrogation is not necessary. The Applicants have no
other antecedents.
6. Accordingly, the case is made out for grant of anticipatory
bail. In view thereof, the following order is passed:
ORDER
(a) In the event of arrest of the Applicants - Pawan
Shriramji Mugal, Shriram Laluji Mugal and Varsha Nikhil
Yokar in connection with C.R. No. 391 of 2026 registered
with the Panchvati Police Station, Nashik City, Nashik,
be released on bail on their furnishing sum of Rs.
10,000/- each with one or two solvent sureties each in
the like amount.
(b) The Applicants shall attend the concerned Police
Station as and when called by the Investigating Officer
and shall cooperate with the investigation.
Aftab S.
Page 3 of 4
30th September, 2026
926-ABA-2684-2026.DOC
(c) The Applicants shall furnish their cell phone
numbers and residential address to the Investigating
Officer and shall keep the same updated, in case of any
change thereto.
(d) The Applicants shall not directly or indirectly
make any inducement, threat, or promise to any person
acquainted with the facts of the case so as to dissuade
such a person from disclosing the facts to the Court or to
any Police personnel.
(e) The Applicant shall not tamper with the
prosecution evidence and shall not contact or influence
the Complainant or any witness in any manner.
7. The Anticipatory Bail Application is disposed of accordingly.
[MADHAV J. JAMDAR, J.]
Aftab S.
Page 4 of 4
30th September, 2026
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