Bombay High Court
SARIKA RAJENDRA SALUNKHEversusTHE STATE OF MAHARASHTRA AND ANR.
- Disposal
- Allowed
Holding
The Court allowed the anticipatory bail application, granting bail with specified conditions.
Summary
The applicant, Sarika Rajendra Salunkhe, wife of the main accused in Crime No. 817 of 2023, sought anticipatory bail for alleged offences under Sections 420 and 406 of the IPC. The High Court, noting the nature of the allegations and the applicant's cooperation with the investigating officer, initially granted conditional bail on 10 June 2026. Both counsel for the applicant and the State confirmed that the applicant had appeared before the investigating officer and cooperated with the investigation. On further hearing, the Court affirmed the bail order, modifying the attendance condition and adding stricter prohibitions against influencing witnesses and requiring the applicant to furnish her residential details. The bail conditions were made absolute, and the anticipatory bail application was disposed.
Issues considered
- Whether anticipatory bail should be granted to the applicant despite allegations under Sections 420 and 406 IPC.
- Whether the conditions imposed are adequate to prevent interference with the investigation and witnesses.
Legislation cited
- Indian Penal Code, 1860 — s. 406, 420
Subjects
- anticipatory bail
- IPC 420
- IPC 406
- bail conditions
- witness tampering
- cooperation with investigation
Judgment
23-ABA-310-2026.doc
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CIRCUIT BENCH AT KOLHAPUR
CRIMINAL APPELLATE JURISDICTION
ANTICIPATORY BAIL APPLICATION NO. 310 OF 2026
Sarika Rajendra Salunkhe … Applicant
Versus.
The State of Maharashtra and Anr. … Respondents
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Mr. Yash Fadtare i/b Sairaj Suryavanshi, for the Applicant.
Mr. N. B. Patil, APP for the Respondent – State.
API S. V. Bile, Satara City Police Station, is present.
-------
CORAM : ASHWIN D. BHOBE, J.
DATE : 19th August, 2026.
P.C. :
1. Heard Mr. Yash Fadtare, learned Advocate for the Applicant,
and Mr. N. B. Patil, learned APP for the Respondent – State.
2. On 10.06.2026, the following order was passed:-
1. Heard learned counsel for the Applicant and
learned APP for the Respondent – State.
2. Issue notice to the Respondents, returnable
on 29th June, 2026. Learned APP waives service of notice
on behalf of the Respondent – State.
3. Taking into consideration, the nature of the
allegations against the Applicant who is wife of Rajendra
Salunkhe (main accused), who is already arrested and
released on bail, I am inclined to protect the Applicant till
the next date of hearing, however upon certain conditions.
Arjun 1
23-ABA-310-2026.doc
Hence, the following order :-
ORDER
I) In the event of arrest of the Applicant -
Sarika Rajendra Salunkhe in connection with Crime
No.817 of 2023 registered with Satara City Police Station,
Satara, for the offences punishable under Sections 420 and
406 of the Indian Penal Code, 1860, she be released on
bail on furnishing P.R. Bond of Rs.50,000/- (Rupees Fifty
Thousands) with one or two solvent sureties in the like, on
the following conditions:
A) The Applicant shall attend the concerned police
station on every Monday and Tuesday between 11:00 a.m.
to 1:00 p.m. and co-operate with the Investigating Officer
until further orders.
B) The Applicant shall not tamper with the evidence
and shall not pressurize the prosecution witnesses, in any
manner.
C) The Investigating Officer shall make the
investigation papers available on the next date for perusal
of this Court.
4. Needless to say, violation of any of the
aforesaid conditions may entitle the prosecution to seek
vacation of the interim relief granted herein above.
5. Stand over to 29th June, 2026.
3. Mr. Yash Fadtare, learned Advocate for the Applicants, states
that the Applicant has appeared before the Investigating Officer at
Satara City Police Station and has co-operated with the
investigation in Crime No. 817 of 2023. He, on instructions from
the Applicant, submits that the Applicant will continue to co-
operate with the investigation in the said crime and will appear
Arjun 2
23-ABA-310-2026.doc
before the Investigating Officer as and when required.
4. Mr. N. B. Patil, learned APP for the Respondent – State, on
instructions from the Investigating Officer, Satara City Police
Station, states that the Applicant has appeared before the
Investigating Officer and has cooperated with the investigation in
Crime No. 817 of 2023.
5. In view of the statements made by Mr. Yash Fadtare, learned
Advocate for the Applicant and Mr. N. B. Patil, learned APP, this
Application is allowed, confirming the order dated 10.06.2026.
The bail conditions imposed therein are made absolute, with the
following modification to the bail condition in clause I(A) and the
following additional conditions, which shall read as follows:-
(i) The Applicant shall appear before the
Investigating Officer at Satara City Police Station,
Satara, on the 2nd and 4th Mondays of each month
from 11:00 am to 1:00 p.m., or as and when
required by the Investigating Officer in Crime No.
817 of 2023.
Arjun 3
23-ABA-310-2026.doc
(ii) The Applicant shall not directly or indirectly
make any inducement, threat or promise to any
person/s acquainted with the facts of the case to
dissuade such person/s from disclosing the facts to
the Court or any police officer.
(iii) The Applicant shall provide the Investigating
Officer, Satara City Police Station, Satara, with her
residential address along with proof, her contact
number and must inform the Investigating Officer
of any changes to this information from time to
time.
6. Criminal Anticipatory Bail Application No. 310 of 2026 is
disposed.
(ASHWIN D. BHOBE, J.)
Digitally
signed by
ARJUN
ARJUN KRISHNA
KRISHNA RODGE
RODGE Date:
2026.08.20
21:57:44
+0530
Arjun 4
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