Bombay High Court

KRUSHNA @ GOTYA RAVINDRA SANAPversusSTATE OF MAHARASHTRA

Decided: 7 September 2026
Disposal: Allowed

Holding

The Court granted anticipatory bail to the applicant with stringent conditions.

Summary

The High Court considered an anticipatory bail application filed under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 by Krushna @ Gotya Ravindra Sanap, who was alleged to have participated in an assault on 4 July 2026 involving weapons offences under the Arms Act, 1959 and other statutes. The prosecution alleged a financial dispute and a group attack on the complainant, but no injury certificate was produced and the FIR was lodged after a ten‑hour delay. The applicant argued lack of injuries, willingness to cooperate, and that he would reside outside Nashik, while the State highlighted four prior antecedents and his habitual offender status. The Court examined whether the circumstances warranted bail and, finding the lack of medical evidence and the delay significant, granted anticipatory bail subject to stringent conditions, including a bond, residence restrictions, regular reporting, and non‑interference with witnesses. The order disposes of the application by granting bail with the stipulated conditions.

Issues considered

Whether anticipatory bail should be granted to the applicant under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 despite allegations of assault and habitual offending
Whether the absence of an injury certificate and delay in FIR registration justify bail
What conditions, if any, should be imposed to safeguard the investigation and trial

Legislation cited

Arms Act, 1959 — s. 25, 4
Bharatiya Nagarik Suraksha Sanhita, 2023 — s. 482
Bharatiya Nyaya Sanhita, 2023 — s. 109, 115(2), 3(5), 351(2), 351(3), 352
Maharashtra Police Act, 1951 — s. 135

Subjects

anticipatory bail
Section 482
habitual offender
arms offence
injury certificate
FIR delay
bail conditions
cooperation with investigation

Judgment

25-ABA-2462-2026.DOC

IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CRIMINAL APPELLATE JURISDICTION
ANTICIPATORY BAIL APPLICATION NO.2462 OF 2026

Digitally
signed by
Krushna @ Gotya Ravindra Sanap …Applicant
ARJUN
ARJUN
VITTHAL
VITTHAL
KUDHEKAR
KUDHEKAR Date:
Versus
2026.09.09
20:15:59
+0530
The State of Maharashtra …Respondent

Mr. Akshay Bankapur, for the Applicant.
Mrs. M. R. Tidke, APP, for the Respondent-State.
Ms. Kalyani Najan, PSI, attached to Bhadrakali Police Station,
Nashik City, Nashik, present.

CORAM: MADHAV J. JAMDAR, J.
DATED : 7th SEPTEMBER 2026
PC:-

1. Heard Mr. Bankapur, learned Counsel appearing for the

Applicant and Mrs. Tidke, learned APP appearing for the

Respondent-State.

2. This application is filed under Section 482 of the Bharatiya

Nagarik Suraksha Sanhita, 2023 seeking pre-arrest bail in

connection with C.R. No.285 of 2026 registered with Bhadrakali

Police Station, Nashik City, Nashik, for the offences punishable

under Sections 25 and 4 of the Arms Act, 1959, Section 135 of the

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25-ABA-2462-2026.DOC

Maharashtra Police Act, 1951, Sections 109, 115(2), 3(5), 351(2),

351(3) and 352 of the Bharatiya Nyaya Sanhita, 2023.

3. As per the prosecution case, a financial dispute is there

between the First Informant and the Applicant and other accused.

It is alleged that on the night of 4 th July 2026, the Applicant along

with other co-accused visited the First Informant’s residence and

abused and assaulted him and allegedly attempted to attack him.

4. It is the submission of Mr. Bankapur, learned Counsel

appearing for the Applicant that although as per the prosecution

case, total four persons attacked the First Informant, there is no

Injury Certificate and even the simple injuries are not there. The

offence is registered after a period of 10 hours. He submits that the

Applicant will completely co-operate with the investigation. He

submits that there are total four accused persons, out of which,

one accused has been granted regular bail and one accused has

been granted Anticipatory Bail.

5. On the other hand, learned APP strongly opposes the

Anticipatory Bail Application. She submits that there are about

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25-ABA-2462-2026.DOC

four antecedents against the Applicant and the Applicant is

habitual offender.

6. Mr. Bankapur, learned Counsel appearing for the Applicant

states the Applicant will not reside within District – Nashik and

that the Applicant will reside at C/o. Rajesh Rokade, 207, Ward

No.6, Mahatma Phule Nagar, Kasara, Mokhavane, District-Thane

421602.

7. Although as per the prosecution case, total four persons

attacked the First Informant, there is no Injury Certificate and even

the simple injuries are not there. There is delay of 10 hours while

registering the offence.

8. Accordingly, in the facts and circumstances, the case is made

out for grant of Anticipatory Bail. However, the stringent

conditions are required to be imposed as the Applicant is habitual

offender. In view thereof, the following order is passed:

ORDER

(a) In the event of arrest of the Applicant-Krushna @

Gotya Ravindra Sanap in connection with C.R. No.285

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25-ABA-2462-2026.DOC

of 2026 registered with the Bhadrakali Police Station,

Nashik City, Nashik, the Applicant is directed to be

released on bail on his furnishing P.R. Bond in the sum

of Rs.50,000/- with one or two solvent sureties in the

like amount.

(b) The Applicant shall not enter Nashik district, except

for reporting to the Investigating Officer, if called, and

for attending the trial.

Station, Nashik City, Nashik on 10th September 2026

and 11th September 2026 between 11:00 a.m. to

02:00 p.m.

(d) The Applicant shall report to the Kasara Police Station,

District – Thane, once every week, on every Monday

between 11:00 a.m. and 02:00 p.m. till the conclusion

of the trial. The Police Inspector of Kasara Police

Station, District - Thane, to communicate details

thereof to the Investigating Officer.

(e) The Applicant shall furnish his cell phone number and

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residential address to the Investigating Officer and

shall keep the same updated, in case of any change

thereto.

(f) The Applicant 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.

(g) The Applicant shall not tamper with the prosecution

evidence and shall not contact or influence the

Complainant or any witness in any manner.

(h) The Applicant shall not leave India without prior

permission of the learned Trial Court.

9. The Anticipatory Bail Application is disposed of accordingly.

[MADHAV J. JAMDAR, J.]

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