Bombay High Court

PALLAVI SATISH MHAMUNIversusTHE STATE OF MAHARASHTRA AND ANR.

Disposal: Allowed

Holding

The court granted anticipatory bail to the applicant with conditions, finding no necessity for custodial interrogation.

Summary

The applicant, Pallavi Satish Mhamuni, sought anticipatory bail under Section 482 of the Bharatiya Nyaya Sanhita, 2023, fearing arrest in a fraud case (Crime No. 0620 of 2025) involving alleged promises of forest department jobs in exchange for money. The prosecution alleged that the applicant and her husband conspired to receive Rs. 13.10 lakh from informants, with the applicant receiving Rs. 3.10 lakh in her bank account. The applicant contended she was a housewife with no involvement in her husband’s affairs and that custodial interrogation was unnecessary. The court examined the allegations, noted that the applicant’s alleged participation was limited to receiving money through banking channels, and found no justification for detention. Consequently, the court granted anticipatory bail on specified conditions, including a bond, reporting requirements, and prohibitions on tampering with evidence, and disposed of the application.

Issues considered

Whether anticipatory bail can be granted to the applicant under Section 482 of the Bharatiya Nyaya Sanhita, 2023.
Whether the allegations against the applicant justify custodial interrogation or denial of bail.
Whether the applicant’s alleged receipt of money through a bank account constitutes sufficient participation in the alleged offences.

Legislation cited

Bharatiya Nyaya Sanhita, 2023 — s. 318(4), 336(3), 338, 340(2), 3(5), 482

Subjects

anticipatory bail
Section 482
Bharatiya Nyaya Sanhita
criminal procedure
fraud
job scam
banking transaction
bail conditions

Judgment

2-ABA-455-2026 (CR).docx

IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CIRCUIT BENCH AT KOLHAPUR

CRIMINAL APPELLATE JURISDICTION

CR. ANTICIPATORY BAIL APPLN. NO. 455 OF 2026

Pallavi Satish Mhamuni … Applicant
Versus.
The State Of Maharashtra And Anr. … Respondents

-----
Mr. Saurabh P. Tandale for the Applicant.
Mr. Shrikant H. Yadav, A.P.P. for the Respondents-State.
-------

Coram : ASHWIN D. BHOBE, J.

Date : 17th August 2026.

PER COURT :

1. Heard Mr. Saurabh Tandale, learned Advocate for the Applicant and

Mr. Shrikant Yadav, learned A.P.P. for the Respondents-State.

2. By the present Application under Section 482 of the BNSS 2023, the

Applicant seeks anticipatory bail, apprehending arrest in connection with

Crime No. 0620 of 2025, dated 07.08.2025, registered at Mangalwedha

Police Station, District Solapur Rural, for offences punishable under Sections

318(4), 338, 336(3), 340(2) and 3(5) of the Bharatiya Nyaya Sanhita, 2023.

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3. Mr. Saurabh Tandale, learned Advocate for the Applicant states that

there are three (3) accused in Crime No. 0620 of 2025, with the Applicant

being accused No.2.

4. The prosecution case is that the accused in Crime No. 0620 of 2025

gave false assurances to the Informant and the witnesses, promising a job in

the Forest Department in exchange for money. Based on these false

assurances, the accused received Rs. 13,10,000/- from the Informant and the

witnesses to secure the job. Neither the job was given nor the amount was

repaid, resulting in the Informant and the witnesses being cheated.

5. Mr. Saurabh Tandale, learned Advocate for the Applicant, submits that

the allegations against the Applicant are that she and her husband Satish

Mhamuni (Accused No. 1) conspired to receive amounts from the Informant

in exchange for securing a job. He submits that the Applicant is a housewife

and is not connected with her husband's affairs. He submits that the husband

instructed the payment of the amount into the Applicant's account.

6. Mr. Shrikant Yadav, learned A.P.P. for the Respondents-State, submits

that the Applicant is involved in the crime along with her husband. He

further submits that the Applicant and Satish Mhamuni (Accused No. 1) have

lured job seekers and cheated them.

7. Perused the records.

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8. The Applicant is the wife of Satish Mhamuni (Accused No. 1).

9. Accused No. 1, against whom it is alleged that he promised the

Informant and the witnesses a job in exchange for money, actively

participated in Crime No. 0620 of 2025 was released on bail by the Sessions

Court in Criminal Bail Application No. 685 of 2025 on 17th October 2025.

10. The Applicant's involvement in Crime No. 0620 of 2025 is limited to

receiving Rs. 3,10,000/- in her bank account.

11. Considering the allegations against the Applicant, a woman, the

amount the Applicant is alleged to have received was through the banking

channel. Custodial interrogation of the Applicant is not required.

12. In view of the above, this Application is allowed on following terms :-

(a) In the event of the arrest of the Applicants in the Crime No.
0620 of 2025, dated 07/08/2025, registered with Mangalwedha
Police Station, District Solapur Rural, for the offences punishable
under Sections 318(4), 338, 336(3), 340(2), 3(5) of the
Bharatiya Nyaya Sanhita, 2023, the Applicant shall be released
on bail upon furnishing a P.R. bond of Rs. 50,000/- (Rupees Fifty
Thousand only), with one or two sureties in the like amount to
the satisfaction of the Investigation Officer, Mangalwedha Police
Station, District Solapur Rural.

(b) The Applicant shall report to the Investigating Officer at
Mangalwedha Police Station, District Solapur Rural, on

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20/08/2026, 21/08/2026, 24/08/2026 and 25/08/2026, from
10:00 am to 11:00 am, and thereafter as and when required by
the Investigating Officer.

(c) 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.

(d) The Applicant shall not tamper with evidence in any manner.

(e) The Applicant shall provide the Investigation Officer with her
residential address along with proof, her contact numbers and
must inform the Investigating Officer of any changes to this
information from time to time.

(f) The Applicant shall cooperate with the Investigating Officer in
the process of investigation of the present Crime.

13. Anticipatory Bail Application No. 455 of 2026 is disposed off.

[ ASHWIN D. BHOBE, J. ]
Digitally signed
by OMKAR
SHIVAHAR
OMKAR KUMBHAKARN
SHIVAHAR
KUMBHAKARN Date:
2026.08.18
11:00:32
+0530

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