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Bombay High Court

SANSKAR ABASO PATOLEversusTHE STATE OF MAHARASHTRA

Decided
Disposal
Disposed Off

Holding

Bail is granted to the applicant with a personal bond and sureties, subject to conditions.

Summary

Sanskar Abaso Patole applied for regular bail in a murder case (Crime No. 690 of 2025) under Sections 103(1) and 238 r/w 3(5) of the Bharatiya Nyaya Sanhita, 2023. The prosecution alleges that Patole and a co‑accused conspired to murder the deceased, who was Patole's father, while the defence argues that the case is based solely on circumstantial evidence and that the death was initially recorded as accidental. The co‑accused has already been released on anticipatory bail, and Patole has been in custody for six months with no prior criminal record. The court examined the chargesheet, noted the lack of direct evidence, and considered the risk of absconding and witness tampering. It granted bail on the condition of a Rs. 30,000 personal bond, one or two sureties of the same amount, and strict compliance with directions not to tamper with evidence or influence witnesses. The order emphasized that the trial court will decide the case on its merits.

Issues considered

  • Whether bail should be granted in a murder case under the Bharatiya Nyaya Sanhita when the prosecution's case is based on circumstantial evidence
  • Whether the applicant poses a risk of absconding or tampering with evidence or influencing witnesses

Legislation cited

Subjects

  • bail
  • murder
  • circumstantial evidence
  • anticipatory bail
  • Bharatiya Nyaya Sanhita
  • personal bond
  • surety
  • witness tampering

Judgment

                                                                                  62-BA-1522-2026 (CR).doc


                             S.S.Kilaje


                                          IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                                                CRIMINAL APPELLATE JURISDICTION

                                           CRIMINAL BAIL APPLICATION NO. 1522 OF 2026

                             Sanskar Abaso Patole                                    … Applicant

                             VERSUS

                             The State Of Maharashtra                        … Respondent
                             _________________________________________________________________

          Digitally signed
SONALI SATISH
       by SONALI
                             Mr. Shreekrishna More i/b. Mr. Mayur Mali, Mr. Ajinkya Jadhav and Mr.
               KILAJE
SATISH Date:
       2026.05.05
KILAJE 12:49:21
       +0700
                             Rahul Jamdar, Advocate for Applicant.
                             Mr. P. P. Jadhav, APP for the Respondent-State.
                             _________________________________________________________________

                                                                  CORAM      :   SHIVKUMAR DIGE, J.
                                                                  DATE       :   30th APRIL, 2026.
                             P.C. :

                             1.           By this application, the Applicant is seeking regular bail in

                             Crime No. 690 of 2025 registered with Daund Police Station, Pune, for the

                             offences punishable under Sections 103(1), 238 r/w 3(5) of Bharatiya

                             Nyaya Sanhita, 2023 (for short “BNS Act”).

                             2.           It is prosecution’s case that applicant and co-accused murdered

                             the deceased on the ground that he was addicted to drinking liquor.

                             3.           It is contention of learned counsel for the applicant that

                             applicant’s case is based on circumstantial evidence. Initially, accidental

                             death was registered and thereafter, applicant and co-accused were

                             arrested.    The co-accused has been released on anticipatory bail.      The



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S.S.Kilaje


applicant is behind the bars for six months. Investigation is completed.

Chargesheet has been filed and requested to allow the application.

4.           It is contention of learned APP      the applicant that and co-

accused hatched conspiracy and murdered the deceased, who was father of

the applicant.       They showed his death as accidental death but in

postmortem report, it revealed that the deceased had injuries on his body.

If applicant is released on bail, he may abscond and may threaten

prosecution witnesses and requested to reject the application.

5.           I have heard both the learned counsel. Perused chargesheet

and documents produced on record. The prosecution’s case is based on

circumstantial evidence. To prove the case against the applicant, trial is

required.    The co-accused has been released on anticipatory bail.        The

applicant has no antecedents. Considering these facts, I pass following

order.

                                          ORDER

               i.      The applicant be enlarged on bail in Crime No. 690 of

                       2025 registered with Daund Police Station, Pune, on

                       executing P.R.Bond of Rs. 30,000/- on furnishing one

                       or two sureties in the like amount.

               ii.     The applicant shall attend the concerned police station

                       as and when required.


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                                                      62-BA-1522-2026 (CR).doc


S.S.Kilaje


                iii.   The applicant shall not tamper with the evidence or

                       attempt to influence or contact the complainant,

                       witnesses or any person concerned with the case.

6.           The application is allowed in the aforesaid terms and is

accordingly disposed of. All pending applications, if any, disposed of.

7.           It is made clear that the above observations are made only for

the purpose of granting bail and the Trial Court shall decide the case on its

own merits in accordance with law and uninfluenced by the observations

made in this order.

8.           All concerned to act on the authenticated copy of this order.



                                                (SHIVKUMAR DIGE, J.)




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