Bombay High Court

Amritlal Devichand JainversusCentral Bureau of Investigation ACB,Mumbai

Decided: 17 February 2026
Disposal: Disposed Off
Bench: NEELA KEDAR GOKHALE

Holding

The High Court declined to relax the travel restriction, directing the trial court to decide any future application within seven days.

Summary

The applicant, Amritlal Devichand Jain, filed an application in the Bombay High Court seeking relaxation of Condition No. 4, which barred him from leaving India without court permission, imposed by the Additional Chief Metropolitan Magistrate in 2022. The respondents, CBI and ACB, opposed the relaxation in their reply affidavit. Justice Neela Gokhale, after considering the respondents’ submissions, declined to modify the travel restriction. However, the court directed that any future application for permission to travel abroad be filed before the trial court, which must expedite the matter and decide it within seven days of filing. The interim application was therefore disposed of without granting relief.

Issues considered

Whether the travel restriction condition imposed by the magistrate can be relaxed on the applicant’s behalf
What standard of proof or considerations govern the modification of a condition of release in a criminal case

Subjects

travel restriction
condition of release
bail
interim application
modification of magistrate order
criminal appellate jurisdiction

Judgment

                                                   906-APPLN-482-2024.DOC




Ajit Pathrikar



         IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                  CRIMINAL APPELLATE JURISDICTION
                 CRIMINAL APPLICATION NO. 482 OF 2024
Amritlal Devichand Jain                                   ...Applicant
     Versus
Central Bureau of Investigation
ACB, Mumbai and Anr.                                      ...Respondents

Mr. Shashvat Jariwala a/w Drishti Israni i/b Auroma Law, for
      the Applicant.
Mr. Amit Munde, a/w Jai Vohra, for Respondent-CBI,ACB.
Mr. Mayur Sonavane, APP for the State-Respondent.
PSI – M. R. Indrekar, Bhiwandi Taluka Police Station, is
      present.


                         CORAM            DR. NEELA GOKHALE, J.
                         DATED:           17th FEBRUARY 2026
PC:-

1.        This is an Application seeking relaxation of condition

No. 4 imposed in the order dated 28th January 2022 passed by

the Additional Chief Metropolitan Magistrate Court at

Esplanade, Mumbai. The said condition reads as thus:

            “Applicant/Accused shall not leave India without prior
            permission of the Court.”

2.        Considering the averments made by the Respondent in

its reply affidavit, I am not inclined to modify the said order.



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                              17 February 2026
                                             906-APPLN-482-2024.DOC




However, if such an application is made before the Trial Court

requesting for permission to travel abroad, the Trial Court is

requested to expedite the same and in any case, decide the

same in seven days from the date of the application.



3.   The present Interim Application is disposed of in the

aforesaid terms.



                                              (Dr. Neela Gokhale, J)




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                        17 February 2026

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