Bombay High Court

KAUSHALYA YUVRAJ NIKAMversusSTATE OF MAHARASHTRA AND ANR

Disposal: Allowed

Holding

The court granted anticipatory bail to the applicant, finding no material to justify denial.

Summary

The applicant, Kaushalya Yuvraj Nikam, sought anticipatory bail under Section 482 of the Bharatiya Nyaya Sanhita, 2023, fearing arrest in a case (Crime No. 0239 of 2026) concerning the suicide of her daughter‑in‑law, Kajal. The complaint alleged harassment by the husband, mother‑in‑law (the applicant), father‑in‑law and sister‑in‑law, but did not specify any concrete incidents involving the applicant. The applicant argued that the allegations were vague and that the other accused had already been granted bail. The State contended that the allegations did implicate the applicant and that the investigation was complete. The court found the complaint omnibus, noted the absence of material distinguishing the applicant, and held that custodial interrogation was unnecessary, thereby granting anticipatory bail with a bond and reporting conditions. The application was disposed with the bail order.

Issues considered

Whether the applicant is entitled to anticipatory bail under Section 482 of the Bharatiya Nyaya Sanhita, 2023 given the vague allegations of harassment in the suicide case.

Legislation cited

Bharatiya Nyaya Sanhita, 2023 — s. 108, 115(2), 3(5), 352, 482, 80

Subjects

anticipatory bail
Section 482
Bharatiya Nyaya Sanhita
suicide
harassment
bail conditions
criminal procedure

Judgment

902-ABA-506-2026 (CR).docx

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

CRIMINAL APPELLATE JURISDICTION

CR. ANTICIPATORY BAIL APPLN. NO. 506 OF 2026

Kaushalya Yuvraj Nikam … Applicant
Versus.
The State of Maharashtra & Anr. … Respondents

-----
Mr. Abhay A. Jadhavar i/b. Mr. Prashant Edake for the Applicant.
Mr. Nitin B. Patil, A.P.P. for the Respondents-State.
-------

Coram : ASHWIN D. BHOBE, J.

Date : 9th September 2026.

PER COURT :

1. Heard, Mr. Abhay Jadhavar, learned Advocate for the Applicant and Mr.

Nitin Patil, learned A.P.P. for the Respondents-State.

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

Applicant seeks pre-arrest bail, apprehending arrest in connection with Crime

No. 0239 of 2026, dated 11th April 2026, registered at the Tembhurni Police

Station, District Solapur Rural, for offences punishable under Sections 80,

108, 115(2), 352 and 3(5) of the Bharatiya Nyaya Sanhita, 2023 (BNS

2023).

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3. Mr. Abhay Jadhavar, learned Advocate for the Applicant, states that

there are four accused in Crime No. 0239 of 2026. He states that the

Applicant is accused No.2. He states that Crime No. 239 of 2026 is registered

as Sessions Case No. 82 of 2026.

4. The prosecution case is that Kajal (deceased) married Dhiraj Yuvraj

Nikam (accused No. 1) in 2020. She committed suicide on 10 th April 2026.

The Crime No. 239 of 2026 was registered based on the complaint lodged by

Kalpana Hiraman Antalkar (mother of the deceased). Kalpana Hiraman

Antalkar claims that the deceased was ill-treated by Dhiraj Nikam (husband -

accused No. 1), the Applicant (mother-in-law-accused No. 2), Yuvraj Nikam

(the father-in-law - accused No. 3), and Sakshi Nikam (the sister-in-law -

accused No. 4).

5. Mr. Abhay Jadhavar, learned Advocate for the Applicant, submits that

the allegations against the Applicant are vague. He submits that minor

quarrels between the deceased and the Applicant cannot be held to be the

ground that led the deceased to end her life. He submits that the Applicant

and her husband (accused No.3) have been implicated to cause harassment

to them. He submits that Dhiraj Nikam (husband -accused No. 1), has been

released on Regular bail by the Sessions Court by order below Exh.4 in

Sessions Case No. 82 of 2026 dated 18 th August 2026. He submits that Yuvraj

Nikam (the father-in-law - accused No. 3) and Sakshi Nikam (the sister-in-

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law - accused No. 4) have also been released on bail.

6. Mr. Nitin Patil, learned A.P.P. for the Respondents-State submits that the

allegations in Crime No. 239 of 2026 do refer to the Applicant being involved

in the harassment. He states that the investigation in Crime No. 239 of 2026

is complete.

7. Perused the record.

8. The complaint dated 11th April 2026, filed by the Informant, does not

refer to any specific instances or dates involving the Applicant in the context

of harassment or cruelty. P rima facie, the allegations against the Applicant

are omnibus. Based on these allegations in Crime No. 239 of 2026, accused

No. 1 (husband), accused No. 3 (father-in-law) and accused No. 4 (sister-in-

law) have been released on bail by the Sessions Court.

9. There is no material placed on record to demonstrate any

distinguishing circumstances that would warrant a different view in the

case of the present Applicant.

10. The Applicant is a woman. Mr. Abhay Jadhavar, learned Advocate for

the Applicant, states that the Applicant shall cooperate with the investigation

and appear before the Investigating Officer as and when required for the

investigation of Crime No. 239 of 2026.

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11. Considering the aforesaid circumstances and the nature of the

allegations against the Applicant, custodial interrogation of the Applicant is

not necessary in Crime No. 239 of 2026.

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

conditions:

(a) In the event of the arrest of the Applicant in Crime No. 0239 of

2026, dated 11th April 2026, registered with Tembhurni Police

Station, District Solapur Rural, 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, Tembhurni Police

Station, District Solapur Rural.

(b) The Applicant shall appear and report to the Investigating

Officer at Tembhurni Police Station, District Solapur Rural, on

10/09/2026, 11/09/2026, 16/09/2026 and 17/09/2026, from

10:00 a.m. to 12:00 p.m. and thereafter as and when required

by the Investigating Officer. The Applicant shall cooperate in the

investigation of Crime No. 0239 of 2026.

inducement, threat or promise to any person/s acquainted with

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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 Investigating Officer with her

residential address along with proof, her contact numbers, email

and must inform the Investigating Officer of any changes to this

information from time to time.

13. Anticipatory Bail Application No. 506 of 2026 is disposed.

[ ASHWIN D. BHOBE, J. ]

Digitally signed
by OMKAR
SHIVAHAR
OMKAR KUMBHAKARN
SHIVAHAR
KUMBHAKARN Date:
2026.09.10
10:28:42
+0530

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