Bombay High Court

SANGITA VILAS SALAVADEversusTHE STATE OF MAHARASHTRA

Disposal: Allowed
Bench: MEHROZ ASHRAF KHAN PATHAN

Holding

The court allowed the anticipatory bail application, subject to stringent conditions.

Summary

The applicant, Sangita Vilas Salavade, sought anticipatory bail in a case where the complainant allegedly set herself on fire after a family dispute, with the applicant accused of pouring petrol on her. The victim’s initial statements recorded on 22 and 25 April 2025 described the fire as accidental and did not implicate the applicant, while a later statement on 8 May 2025 alleged the applicant’s involvement. The prosecution argued the offence was serious, punishable with life imprisonment, and cited the FIR and forensic evidence of petrol. The court noted the discrepancy in the victim’s statements, the completion of the investigation, and the applicant’s lack of criminal antecedents, and decided to protect the applicant by granting anticipatory bail with strict conditions. The order required the applicant to attend the police station regularly, refrain from tampering with evidence or contacting the complainant, and provide identification documents, with bail cancellable upon any violation.

Issues considered

Whether anticipatory bail should be granted to the applicant under the Bharatiya Nyaya Sanhita in view of the seriousness of the alleged offences
Whether the contradictory statements of the complainant affect the likelihood of the applicant’s involvement
Whether the risk of tampering with evidence or influencing witnesses warrants denial of bail

Legislation cited

Bharatiya Nyaya Sanhita, 2023 — s. 109, 115(2), 183, 3(5), 352

Subjects

anticipatory bail
Bharatiya Nyaya Sanhita
attempt to murder
family dispute
contradictory statements
bail conditions
criminal procedure

Judgment

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913-ABA-26-2026 (CR).DOC

IN THE HIGH COURT OF JUDICATURE AT BOMBAY
HARISH
VITHAL
CHAUDHARI
CIRCUIT BENCH AT KOLHAPUR
CRIMINAL APPELLATE JURISDICTION
Digitally signed
by HARISH
VITHAL
CHAUDHARI CR. ANTICIPATORY BAIL APPLICATION NO. 26 OF 2026
Date:
2026.06.16
15:05:55 +0530
Sangita Vilas Salavade ...Applicant
VERSUS
The State Of Maharashtra ...Respondent

-----
Mr. Jaydeep Mane a/w Mihir Mondkar for Applicant.
Mr. Nitin. B. Patil, APP for the Respondent-State.
-----

CORAM : MEHROZ K. PATHAN, J.
DATE : 12th JUNE, 2026.
P.C.

1. Heard the learned Counsel for the Applicant and the learned

APP for the State.

2. The Applicant has approached this Court, seeking

anticipatory bail in connection with Crime No. 530/2025 registered

with Mohol Police Station, District Solapur Rural for the offences

punishable under Sections 352, 3(5), 115(2) and 109 of the

Bharatiya Nyaya Sanhita, 2023.

3. The case of the prosecution is that on 21.04.2025 at around

11.30 pm on account of some trivial family dispute, the Complainant

after being throttled by her husband, who then left the room, she

poured petrol upon her and set herself on fire.

Harish
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913-ABA-26-2026 (CR).DOC

4. The learned counsel for the Applicant submits that the

Applicant is falsely implicated in the present crime only with an

intention to rope in the entire family members of the husband against

whom, the complainant wife is having some issues. The complainant

wife was admitted in the hospital on 21.04.2025 for treatment of her

injuries and during her admission in the hospital, there were two

statements recorded of the victim. However, in those statements, the

victim did not attribute any role to the present applicant of setting her

on fire. The victim had rather stated that the fire was caused

accidentally while she was cooking. The Applicant is an aged mother

of the husband of the victim. The victim had rather stated that the

fire was caused accidentally while she was cooking. The husband of

the victim i.e. son of the present Applicant was already released on

anticipatory bail vide order dated 06.11.2025 passed in ABA

No.2391/2025. The Applicant is not having any criminal antecedents.

The Applicant is ready to abide by any condition that may be imposed

by this Court. Hence, the Applicant woman may be protected.

5. As against this, learned APP strongly opposes the

application on the ground that the Applicant is involved in the serious

offence of attempt to commit murder. There are direct allegations in

the FIR wherein the Applicant is attributed to the role of pouring

petrol upon the complainant/victim and setting her on fire due to

Harish
3
913-ABA-26-2026 (CR).DOC

family dispute. The allegations are serious in nature. The anticipatory

bail granted to the son of the present Applicant may not give benefit

of parity to the present Applicant as this Court has observed that the

allegation about setting the victim on fire is against the present

Applicant and hence, on that ground, the son of the present Applicant

Sachin Salavade was granted anticipatory bail by this Court. The

statement of the complainant is recorded under Section 183 of

Bharatiya Nyaya Sanhita, 2023. The presence of petrol, as found

during the spot panchanama, clearly indicates the common intention

of the applicant and his family members to bring petrol and set the

complainant on fire. The offence is serious in nature and is

punishable with life imprisonment. Hence, this is not a fit case to

release the Applicant on anticipatory bail.

6. I have gone through the investigation papers made available

by the learned APP. The investigation appears to have been

completed. The investigation papers contains the statement of the

victim recorded immediately on the next date of the incident i.e. on

22.04.2025 wherein, she specifically states about accidental fire being

caught while she was cooking. The said statement do not attribute

any role either to the Applicant or her family members for setting her

on fire. The said statement is recorded in the presence of the doctor,

who has certified the fitness of the complainant while recording the

Harish
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913-ABA-26-2026 (CR).DOC

statement. The other statement dated 25.04.2025, which was also

recorded in the presence of the Medical Officer, does not attribute any

specific overt act to the present Applicant of setting the complainant

on fire. The present FIR came to be lodged on 09.05.2025 solely on

the basis of the third statement dated 08.05.2025, which is materially

at variance with the earlier two statements of the prosecution. In the

said statement, for the first time, a specific role has been attributed to

the present Applicant, namely that she poured petrol on the

complainant. Since, the Applicant is the mother-in-law of the

complainant, the submission of the learned counsel for the Applicant

that the Applicant is falsely implicated in the present crime cannot be

ruled out at this stage.

7. Taking into consideration the discrepancy in the statements

of the complainant and that the investigation is almost completed and

the chargesheet is submitted for approval of the higher officer,

nothing remains to be investigated or recovered at the instance of the

present Applicant. Hence, I am inclined to protect the Applicant. The

apprehension of the learned APP can be taken care of by imposing

conditions upon the Applicant. However these observations are prima

facie in nature and are made only with purpose to decide the

application and the same may not influence the trial Court. Hence the

following order :

Harish
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913-ABA-26-2026 (CR).DOC

ORDER

(i) In the event of arrest of the Applicant - Sangita Vilas
Salavade in connection with Crime No. 530/2025 registered with
Mohol Police Station, District Solapur Rural for the offences
punishable under Sections 352, 3(5), 115(2) and 109 of the
Bharatiya Nyaya Sanhita, 2023, she be released on bail on furnishing
P.R. bond of Rs.50,000/- (Rupees Fifty Thousand) with two solvent
sureties in the like amount, on the following conditions :

(a) The Applicant shall attend Mohol Police Station,
District Solapur Rural on every Tuesday and Wednesday
between 11:00 am. to 01:00 pm. and thereafter as when
called by the Investigating Officer, till filing of the charge-
sheet, if any.

(b) The Applicant shall not tamper with the prosecution
evidence and shall not influence the witnesses.

(d) The Applicant shall submit her Aadhar and PAN Cards
to the Investigating Officer and detailed addresses and
phone numbers of herself and two of the near relatives.

(e) A single violation by the Applicant, such as making an
attempt to contact or threaten the complainant, shall entitle
the prosecution to seek cancellation of the Applicant’s bail.

(ii) The application is allowed in the above terms and stands
disposed of.

( MEHROZ K. PATHAN, J.)

Harish

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