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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

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

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                                                        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
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                                                     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

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                                                          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.)




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