Bombay High Court

ARUN VINOD JAISWARversusSTATE OF MAHARASHTRA

Decided: 7 October 2026
Disposal: Disposed off as Withdrawn

Holding

The anticipatory bail application was withdrawn, with liberty to file a fresh application after full disclosure of criminal antecedents.

Summary

The applicant, Vasant Anandrao Idhol, filed an anticipatory bail application but failed to disclose a pending criminal case registered at Charkop Police Station (Crime No. 171). The learned counsel highlighted this omission and sought leave to withdraw the application, requesting liberty to file a fresh application after full disclosure, citing the Supreme Court’s decision in Zeba Khan v. State of Uttar Pradesh (2026). The Court examined the requirement of full disclosure of antecedent offences as mandated by the Supreme Court precedent. It held that the application could not proceed in its present form. Consequently, the Court disposed of the application as withdrawn, granting the applicant permission to re‑file a fresh application with complete disclosure of all criminal antecedents.

Issues considered

Whether anticipatory bail can be granted when the applicant fails to disclose pending criminal antecedents.
Whether the applicant may withdraw the anticipatory bail application and re‑file after complying with the disclosure requirement as per Supreme Court precedent.

Subjects

anticipatory bail
disclosure of criminal antecedents
withdrawal of application
Supreme Court precedent
criminal procedure

Judgment

                                                                            911-aba2202-26.doc

       vai

                             IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                                    CRIMINAL APPELLATE JURISDICTION

                             ANTICIPATORY BAIL APPLICATION NO.2202 OF 2026

VASANT             Arun Vinod Jaiswar                                       ...Applicant
ANANDRAO
IDHOL                         V/s.
                   State of Maharashtra                                     ...Respondent
Digitally signed
by VASANT
ANANDRAO           Mr.Karim Pathan with Mr.Fazlur Rahiman Shaikh, Mr.Shane Illahi
IDHOL
Date: 2026.10.07   Turkej , Mr.Fardeen Shaikh and Mr.Shoaib Shaikh for the Applicant.
18:35:51 +0530

                   Ms.Megha S. Bajoria, APP for the Respondent – State.

                                     CORAM : PRAFULLA S. KHUBALKAR, J.
                                     DATE  : 7TH OCTOBER, 2026.
                   P.C. :-

                   1.           After learned APP pointed out that the applicant has not

                   disclosed the criminal antecedents being an offence registered with

                   Charkop Police Station, at Crime no. 171,           learned counsel for

                   applicant seeks leave to withdraw the instant application with liberty

                   to file fresh application after disclosing all the criminal antecedents in

                   accordance with the judgment of the Supreme Court in Zeba Khan vs.

                   State of Uttar Pradesh 2026 SCC OnLine SC 188.
                   2.           Accordingly, the instant application is disposed of as

                   withdrawn with liberty to file fresh application.



                                                            (PRAFULLA S. KHUBALKAR, J.)


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