Bombay High Court

APARNA SALIANversusSTATE OF MAHARASHTRA

Decided: 29 August 2026
Disposal: Disposed off as Withdrawn

Holding

The anticipatory bail application may be withdrawn with liberty to re‑file after full disclosure of criminal antecedents.

Summary

Smt. Aparna Salian filed an anticipatory bail application before the Bombay High Court. The learned court observed that the applicant had failed to disclose all her criminal antecedents, contrary to the Supreme Court's directive in Zeba Khan v. State of U.P. The applicant's counsel sought permission to withdraw the pending application and to file a fresh one after full disclosure. The court allowed the withdrawal, granting liberty to re‑file the application with complete antecedent details. No order on the merits of bail was pronounced.

Issues considered

Whether non‑disclosure of criminal antecedents defeats an anticipatory bail application.
Whether the applicant may be permitted to withdraw the application and re‑file after compliance.

Subjects

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

Judgment

                                                   905-ABA-2409-2026.ODT




             IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                   CRIMINAL APPELLATE JURISDICTION

            ANTICIPATORY BAIL APPLICATION NO. 2409 OF 2026

Smt. Aparna Salian                                     …Applicant
      Versus
The State of Maharashtra                               …Respondent


Adv. Bhanudas Jagtap i/b Adv. Ashish B. Jagtap, for the Applicant.
Mr. Arfan Sait, A.P. P., for the Respondent – State.
Adv. Shaila R. Pandey, for the Orig. Complainant / Intervenor.
PI Sandeep Chavan, Powai Police Station, Mumbai, is present.


                          CORAM :       PRAFULLA S. KHUBALKAR, J.
                          DATE      :    29TH AUGUST 2026
P. C:-

1.          After the learned APP pointed out that, the applicant has
not disclosed all the criminal antecedents as required by the
judgment of Hon’ble Supreme Court in the matter of Zeba Khan
Vs. State of U.P. and Ors., reported at 2026 SCC Online SC 188,
learned counsel for applicant seeks permission to withdraw the
application with liberty to file fresh application after disclosing
all the criminal antecedents.


2.          Application is permitted to be withdrawn with liberty as
prayed for.


                                         (PRAFULLA S. KHUBALKAR, J.)
VDMokal/-



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