Bombay High Court
PRANAV RAJENDRA SALVIversusSTATE OF MAHARASHTRA
- Decided
- Disposal
- Allowed
Holding
Bail is granted to the applicant subject to the conditions specified in the order.
Summary
The applicant, Pranav Rajendra Salvi, has been in custody for three years and eight months as an under‑trial accused of offences under Sections 302, 120B, 279, 337, 338, 304A of the IPC and Sections 184, 134 and 187 of the Motor Vehicle Act. The prosecution’s case is based solely on circumstantial evidence with no eye‑witnesses, and the co‑accused have already been released on bail. The applicant argued that his prolonged pre‑trial detention violates the principle of parity and that the trial is unlikely to conclude soon. The Court, noting the long incarceration, the lack of direct evidence, and the bail granted to co‑accused, allowed the bail application subject to strict conditions. The order expressly limited its observations to bail and declined to comment on the merits of the case.
Issues considered
- Whether bail should be granted to an under‑trial accused charged with serious offences when the pre‑trial detention has been lengthy
- Whether the circumstantial nature of the evidence and lack of eye‑witnesses justify bail
- Whether parity with co‑accused who are on bail mandates release of the applicant
Legislation cited
- Code of Criminal Procedure, 1973 — s. 439
- Indian Penal Code — s. 120B, 279, 302, 304A, 337, 338
- Motor Vehicle Act — s. 134, 184, 187
Subjects
- bail
- under‑trial detention
- circumstantial evidence
- parity
- Section 439 CrPC
- IPC offences
- Motor Vehicle Act
- pre‑trial delay
Judgment
69. BA 1555-2026.doc
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CRIMINAL APPELLATE JURISDICTION
BAIL APPLICATION NO. 1555 OF 2026
Pranav Rajendra Salvi .Applicant
Vs.
The State of Maharashtra .Respondent
Mr. Aniket Vagal a/w. Ms. Juhi Kadu & Ms. Savvy Kolhekar, Advocates,
Digitally
signed by for the Applicant
ANAND
ANAND SUDHAKAR
SUDHAKAR SUDAME Ms. R. V. Newton, APP, for the Respondent – State
SUDAME Date:
2026.09.23
19:55:32
+0530
CORAM : MILIND N. JADHAV, J.
DATE : 22.09.2026
P. C.
1. Heard Mr. Vagal, learned Counsel for the Applicant and Ms.
Newton, learned APP for the Respondent – State.
2. This Application is filed under Section 439 of the Code of
Criminal Procedure, 1973 (for short “CRPC”) in connection with
C.R.No. I-198 of 2021 registered with Mumbai Naka Police Station for
offences punishable under Sections 302, 120B, 279, 337, 338 and 304A
of the Indian Penal Code, 1860 (for short “IPC”) and under Sections
184, 134/187 of the Motor Vehicle Act.
3. The Applicant is incarcerated for the past three years and eight
months pending trial as an under trial. The co-accused persons have all
been released on bail. It is prima facie seen that the case of the
Anand 1 of 4
69. BA 1555-2026.doc
prosecution is entirely based on circumstantial evidence. FIR is
registered against unknown persons and there are no eye witnesses to
the alleged crime either. The case against the Applicant on further
investigation is that he has received an amount of Rs.1,68,000/- in a
transaction relatable to his car dealership business which is attributed
as the reason of he having received proceeds of crime. The Applicant
claims parity. Trial has begun and evidence of PW.1 is part-heard. There
is no likelihood that the trial will be completed in the near foreseeable
future.
4. Considering the aforesaid period of long incarceration of the
Applicant and on parity, the Applicant is directed to be released on bail.
5. Hence, in view of above prima facie observations and finding,
Bail Application of Applicant is allowed subject to the following terms
and conditions:-
(i) Applicant – Pranav Rajendra Salvi is directed to be
immediately released from prison in connection with
CR. No. I-198 of 2021;
(ii) Applicant is directed to be released on bail on furnishing
P.R. Bond of Rs.25,000/- (Rs. Twenty Five Thousand
only) with one or two sureties of the like amount;
(iii) Applicant shall report to the Investigating Officer at
Anand 2 of 4
69. BA 1555-2026.doc
Mumbai Naka Police Station, once every month, on the
first Monday of the month between 10:00 a.m. to 12:00
p.m. until commencement of trial and thereafter shall
attend all dates of hearing before the Trial Court;
(iv) Applicant shall cooperate with the conduct of the trial
and remain present before the Trial Court on all dates,
unless specifically exempted. Applicant shall not seek
unnecessary adjournments. Any such conduct shall
entitle the prosecution to apply for cancellation of bail;
(v) Applicant shall not leave the State of Maharashtra
without prior permission of the Trial Court;
(vi) Applicant shall not influence any of the witnesses or
tamper with the evidence in any manner;
(vii) Applicant shall keep the Investigating Officer informed
of his current residential address and mobile telephone
number and shall forthwith inform the Investigating
Officer of any change in his residential address or
mobile telephone number, as and when such change
occurs; and
(viii)Any breach or infraction of any of the aforesaid
Anand 3 of 4
69. BA 1555-2026.doc
conditions shall entail cancellation of the bail granted to
the Applicant.
6. It is clarified that the observations made in this order are limited
for the purpose of granting bail only and I have not made any
observations on merits of the case. The trial shall be adjudicated on
the strength of the evidence led and strictly on its own merits being
uninfluenced with any of the prima facie observations made
hereinabove in this order.
7. Bail Application is allowed and disposed in the above terms.
(MILIND N. JADHAV, J.)
Anand 4 of 4
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