Bombay High Court

DWARKA KRISHNA SATPUTEversusTHE STATE OF MAHARASHTRA AND ANR.

Disposal: Allowed

Holding

Anticipatory bail is granted to the applicant with specified conditions.

Summary

Dwarka Krishna Satpute, a 72‑year‑old woman, applied for anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in connection with Crime No. 340 of 2026 alleging assault on an informant. The prosecution alleged that she, along with her husband, assaulted the informant during a property dispute, causing injury. The defence argued that the allegations against her were exaggerated, that she did not use any weapon, and that custodial interrogation was unnecessary given her age and gender. The court found that the probability of her committing the assault was remote and that there was no need for her detention. Consequently, the court granted anticipatory bail with conditions including a personal bond, reporting to the investigating officer, and non‑interference with evidence.

Issues considered

Whether anticipatory bail can be granted under Section 482 of the BNSS, 2023 for the alleged offences.
Whether custodial interrogation of a 72‑year‑old woman is necessary in the present case.

Legislation cited

Bharatiya Nagarik Suraksha Sanhita, 2023 — s. 482
Bharatiya Nyaya Sanhita, 2023 — s. 109, 115(2), 118(1), 3(5), 351(2), 351(3), 352

Subjects

anticipatory bail
Section 482
assault
age and gender considerations
bail conditions
BNSS 2023
BNS 2023
criminal procedure

Judgment

Digitally signed
by LAXMIKANT
LAXMIKANT GOPAL
GOPAL CHANDAN (3) ABA-463.26.DOCX
CHANDAN Date:
2026.08.19
12:23:55 +0530
lgc
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CIRCUIT BENCH AT KOLHAPUR
CRIMINAL APPELLATE JURISDICTION

CRIMINAL ANTICIPATORY BAIL APPLICATION NO.463 OF 2026

Dwarka Krishna Satpute : Applicant
Versus.
The State of Maharashtra & anr. : Respondents
-----

Ms. Vishakha Patil i/by Talekar and Associates for the Applicant.
Dr. A. A. Takalkar, APP for the Respondents – State.
-------

CORAM : ASHWIN D. BHOBE, J.

DATED : 18 AUGUST 2026
PC:-

1. Heard Ms. Vishakha Patil, learned Advocate for the Applicant
and Dr. A. A. Takalkar, learned APP for the Respondents – State.

2. By this Application filed under Section 482 of the Bharatiya
Nagarik Suraksha Sanhita, 2023 (“BNSS, 2023”), the Applicant
seeks pre-arrest bail in connection with Crime No. 340 of 2026,
dated 12 July 2026, registered with Malshiras Police Station,
Solapur Rural, for offences punishable under Sections 109, 115(2),
118(1), 3(5), 351(2), 351(3) and 352 of the Bharatiya Nyaya
Sanhita, 2023 (“BNS, 2023”).

3. Ms. Vishakha Patil, learned Advocate for the Applicant,
states that there are two accused in Crime No. 340 of 2026. The

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Applicant is Accused No. 2, whereas her husband, Krishna
Sahebrao Satpute, is Accused No. 1.

4. In brief, the case of the prosecution is that a dispute over the
property between the Informant, the brother of Accused No.1
(Krishna Sahebrao Satpute) and the brother-in-law of the
Applicant, led to an altercation and a fight. The Informant is said
to have been injured in the said fight.

5. Ms. Vishakha Patil, learned Advocate for the Applicant,
submits that the allegations against the Applicant are of abuse and
assault on the Informant with fists and kicks. She further submits
that the Informant has falsely implicated the 72-year-old Applicant
in the crime. She, on instructions, submits that the Applicant will
cooperate with the investigation in Crime No. 340 of 2026.

6. Dr. A. A. Takalkar, learned APP for the Respondents – State,
submits that the Informant sustained a fracture due to the assault
by Accused No.1. She submits that the weapon used by Accused
No.1 to assault the Informant was a wooden stick.

7. Perused the records.

8. The Applicant’s involvement in Crime No. 340 of 2026 is
verbal abuse and assault by fist and kick on the Informant. Prima
facie, the probability of the Applicant, a 72-year-old woman,
assaulting a 54-year-old person is remote and appears to be an
overstatement.

9. The FIR makes no reference to the Applicant using any
weapon in the alleged assault on the Informant.

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10. Considering the Applicant (a woman) and her age, custodial
interrogation of the Applicant is not necessary in Crime No.340 of
2026.

11. In view of the above, this Anticipatory Bail Application is
allowed on the following conditions :-

(a) In the event of arrest of the Applicant in
the Crime No.340 of 2026, registered with
Malshiras Police Station, Solapur Rural, Applicant
shall be released on bail upon Applicant
furnishing a PR bond in the sum of Rs. 20,000/-
(Rupees Twenty Thousand only), with one or
two sureties in the like amount to the satisfaction
of the Investigating Officer, Malshiras Police
Station, Solapur Rural.

(b) The Applicant shall appear and report to
the Investigation Officer, Malshiras Police
Station, Solapur Rural, on 24 August 2026 from
10.00 a.m. to 11.00 a.m. and as and when
required by the Investigating Officer. Applicant
shall cooperate with the Investigating Officer in
the process of investigation of Crime No.340 of
2026.

(c) The Applicant shall not directly or
indirectly make any inducement, threat or
promise to the Intervenor or any person/s
acquainted with the facts of the case to dissuade
such person/s from disclosing the facts to the

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(3) ABA-463.26.DOCX

Court or any police officer.

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

(e) The Applicant shall provide the
Investigation Officer, Malshiras Police Station,
Solapur Rural 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.

12. Criminal Anticipatory Bail Application No.463 of 2026 is
disposed of.

(ASHWIN D. BHOBE, J.)

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