Bombay High Court
SNEHAL RAJESH PAWARversusTHE STATE OF MAHARASHTRA
- Decided
- Disposal
- Disposed Off
- Bench
- PRAFULLA S KHUBALKAR
Holding
The court denied anticipatory bail to the applicant, finding a strong prima facie case against her.
Summary
The applicant, Snehal Rajesh Pawar, sought anticipatory bail in a murder case (Crime No.189 of 2025) filed under Sections 103(1), 238 and 3(5) of the Bharatiya Nyaya Sanhita, 2023. The FIR alleged that she, along with two others, concealed the dead body of her handicapped daughter after the alleged murder on 19‑20 February 2025. The applicant contended that the death was natural, the complaint was false, and the CCTV footage showing a white sheet in a car was insufficient to establish her involvement. The State relied on the same CCTV panchnama and a taxi driver’s statement to argue that the applicant was seen placing the body in a car, indicating prima facie participation. The court found the material sufficient to establish a strong prima facie case, noting serious allegations of possible poisoning and the need for custodial interrogation, and consequently rejected the anticipatory bail application.
Issues considered
- Whether anticipatory bail can be granted in a murder case where prima facie evidence of involvement exists.
- Whether the CCTV footage and the taxi driver’s statement constitute sufficient material to deny bail.
- Whether the seriousness of the alleged offences, including alleged poisoning, justifies custodial interrogation and denial of bail.
Legislation cited
- Bharatiya Nyaya Sanhita, 2023 — s. 103(1), 238, 3(5)
Subjects
- anticipatory bail
- murder
- prima facie case
- CCTV evidence
- custodial interrogation
- serious offence
Judgment
18-ABA-3609-2025.ODT
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CRIMINAL APPELLATE JURISDICTION
ANTICIPATORY BAIL APPLICATION NO. 3609 OF 2025
Smt. Snehal Rajesh Pawar …Applicants
Versus
The State of Maharashtra …Respondents
Adv. Chintan Shah a/w Adv. Rohan Chaughule, for Applicant.
Ms. Poonam Bhosale, A.P. P., for the Respondent – State.
PSI Ravindra Deelip Ranbhire, Naupada Police Station, Thane,
is present.
CORAM : PRAFULLA S. KHUBALKAR, J.
DATE : 27TH JULY 2026
P.C:-
1. Heard learned counsel for the applicant as well as learned
APP for the respondent - State.
2. The applicant has filed the instant application seeking pre-
arrest bail in Crime No.189 of 2025 dated 24.02.2025, registered
with Naupada Police Station, Thane, under Section 103(1), 238
and 3 (5) of the Bharatiya Nyaya Sanhita, 2023.
3. The offence is registered on the basis of a report lodged by
Varsha Shobhit Raghunandan alleging that on 19 th February 2025,
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the daughter of her maternal cousin brother, by name Yashaswi
who was handicapped, deaf and dumb and who was suffering
from serious ailments, was murdered by somebody and on
20th February 2025 at about 1:30 a.m. in the night time, the three
accused persons had carried her dead body from a four wheeler.
On the basis of this report, the FIR came to be registered against
the three accused persons, including this applicant who is mother
of the deceased.
4. Advocate Shah, learned counsel for applicant submitted
that, the allegations about commission of murder are imaginary
and without any basis. It is submitted that the deceased girl had
died naturally on account of her illness and her body was being
carried to her native place for funeral purposes. It is also
submitted that, the complainant has lodged the false report in the
background of a long standing dispute in between the
complainant and the accused. It is also submitted that on the basis
of CCTV footage, showing that something in white bed sheet was
being kept in the Maruti car nothing can be concluded. Such a
video is not sufficient to show involvement of these persons in the
alleged offence of murder.
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5. As against this, learned APP for the respondent - State
opposed the application and submitted that the offence of murder
is a serious offence and there are specific allegations about
involvement of this applicant. By relying on the Panchanama of
the CCTV footage ( at page 59 of the application) she submitted
that the involvement of the applicant is clear in view of her
activities recorded in the night of 20th February 2025, in which she
along with two other accused persons is seen while placing the
body covered in white cloth in a car. Apart from this, by inviting
attention to the statement of the Taxi driver, Mr Vinod Nishad
recorded during investigation, she submitted that the suspicious
behaviour of the accused persons was noticed and involvement of
this applicant is clear. She submitted that although chargesheet is
filed, the investigation in the matter against this applicant needs
to be made and considering the seriousness of the offence, the
custodial interrogation of the applicant is necessary.
6. Perused the FIR and the documents filed on record. It
appears that the complainant has specifically alleged that this
applicant was seen actively involved in the video footage which
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was received on her mobile. The conduct of this applicant along
with the other accused persons in taking away the dead body
during night time of 20th February 2025, without disclosing the
death of her daughter to anybody, clearly shows their suspicious
conduct. A perusal of the Panchnama of CCTV footage also
corroborates the contentions about involvement of the applicant
along with other accused persons. Apart from this, the statement
of taxi driver, Mr Vinod, who is an independent person also shows
involvement of the applicant in the process of secretly carrying
away the dead body.
7. In view of all these aspects, there is material to show a
strong prima facie case against this applicant. There are serious
allegations about administration of poison by this applicant who
was in direct touch with the deceased and was daily giving food to
her. These allegations are serious in nature. There are many
aspects about which investigation is required to be done.
Considering the prima facie involvement of this applicant in the
serious offence of murder, at this stage, the custodial interrogation
of this applicant appears to be very much necessary.
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8. Having regard to the serious nature of offence and the
material against this applicant in the CCTV footage showing her
involvement in the offence, I am not inclined to grant anticipatory
bail to this applicant. Hence, the instant application for
anticipatory bail is rejected.
(PRAFULLA S. KHUBALKAR, J.)
VDMokal/-
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