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Bombay High Court

SNEHAL RAJESH PAWARversusTHE STATE OF MAHARASHTRA

Decided
Disposal
Disposed Off

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

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/-




                                  Page 5 of 5
                                 27th July 2026


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