Bombay High Court
ANKUSH JAYWANT SATKARversusSTATE OF MAHARASHTRA
- Decided
- Disposal
- Allowed
Holding
Bail is granted to the applicant subject to the conditions specified by the court.
Summary
An application for bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 was filed by Ankush Jaywant Satkar, who is accused of offences under Sections 103(1) and 3(5) of the Bharatiya Nyaya Sanhita, 2023 and Section 4(25) of the Arms Act, 1959, relating to a family dispute that culminated in a fatal assault with a sickle on 1 April 2025. The prosecution’s case is based largely on circumstantial evidence and a neighbour’s statement implicating another accused, with no direct eyewitness to the applicant’s involvement. The applicant had been in custody for 16 months and argued that the motive stemmed from abusive video messages sent by the deceased victim to his family. The court examined the nature of the evidence, the seriousness of the offences, and the applicant’s right to liberty, concluding that bail could be granted subject to strict conditions. Accordingly, the court ordered the applicant’s release on bail with a bond of Rs.25,000 and a series of reporting and non‑interference conditions, while reserving the right to cancel bail for any breach.
Issues considered
- Whether bail should be granted to the accused under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 in a case involving offences under the Bharatiya Nyaya Sanhita and the Arms Act.
- Whether the circumstantial evidence and lack of direct eyewitnesses justify denial of bail.
Legislation cited
- Arms Act, 1959 — s. 4(25)
- Bharatiya Nagarik Suraksha Sanhita, 2023 — s. 483
- Bharatiya Nyaya Sanhita, 2023 — s. 103(1), 3(5)
Subjects
- bail
- criminal procedure
- circumstantial evidence
- assault with weapon
- family dispute
- Section 483 BNS Act
- Arms Act
- Maharashtra
Judgment
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rsk
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CRIMINAL APPELLATE JURISDICTION
BAIL APPLICATION NO.1765 OF 2026
Ankush Jaywant Satkar .. Applicant
Versus
The State of Maharashtra .. Respondent
....................
Mr. Niranjan Bhavake a/w. Mudra Bhayje a/w. Ms. Vaishnavi
Chore, Ms. Drishti Madhani and Mr. Aurag Ramkar i/b. Bhavake
and Associate for Applicant.
Mrs. Rajeshree V. Newton, APP for the Respondent-State.
...................
CORAM : MILIND N. JADHAV, J.
DATE : AUGUST 31, 2026
P.C.:
1. Mr. Niranjan Bhavake, learned counsel for Applicant and Mrs.
Rajeshree V. Newton, learned APP for the Respondent-State.
2. This is an Application under Section 483 of Bharatiya Nagarik
Suraksha Sanhita, 2023 seeking Bail in connection with C.R. No.125 of
2025 registered with Wadgaon Maval Police Station, Pune for offences
punishable under Sections103(1), 3(5) of the Bharatiya Nyaya
Sanhita, 2023 and 4(25) of the Arms Act, 1959. Date of the incident is
1 April 2025.
3. Applicant is indicted in crime No.125 of 2025 registered with
Wadgaon Maval PoliceStation, Pune, Maharashtra under Sections
103(1), 3 (5) of BNS Act and Section 4(25) of the Arms Act. Weapon
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in question is sickle (kyota). The applicant and the deceased victim’s
family are all relatives of each other . Though the incident has occurred
on 1 April 2025, the reason for that incident is a fight between the
parties in the year 2018 but that is not simply so. The said dispute
revived in March 2025 leading to the present incident in question. It is
prima facie seen that the applicant along with his wife , daughter,
father-in-law, mother-in-law and other relatives were working in the
field sometime in March 2025. In view of incident of 2018 the
deceased victim had started sending abusive video messages on
Whatsapp to the wife of the applicant who is arraigned as accused
No.1 at that time. The mother in law of the applicant and minor
daughter of the applicant on receiving such messages complained to
Applicant and he not knowing from which mobile phones the messages
were sent enquired upon which it was revealed that said messages
were sent by none other than the deceased victim to them. The
incident of 2018 pertains to a threat given by the deceased victim to
the applicant and his family members in view of certain previous
relationship between the victim’s wife and present applicant(accused
No.1). In the statement of the wife of the victim, which is appended
at page 88 she has referred to the incident of 2018. However the
statement of wife of the applicant which has been recorded and
appended at page 85 gives further details leading to the incident in
question. According to this statement, the deceased victim was
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repeatedly sending abusive and filthy video messages on Whatsapp to
the wife of the applicant and later on he started sending those
messages to the minor daughter and mother-in-law of the applicant
also. Once this happened there could have been some reason for the
applicant which triggered the incident in question. Insofar as the
incident is concerned , there is no direct eye witness to the incident
save and except the witness statement of a neighbour which
categorically states that it was the accused No. 2 who was instrumental
in inflicting the blow with the weapon i.e. koyta on the head of the
victim. The said neighbour has further stated that after the blow was
inflicted by accused No.2 on the victim, she hid herself inside her
room. Regarding precise role of accused No.1 is concerned, she has
stated that she heard the quarrel with the victim as there was some
scuffle going on between them. Insofar as the statement of Sangeeta,
who is mother of the victim is concerned the same is however a
complete improvisation, however it does not refer to the three accused
persons seen running away from the incident site. She has however
specifically referred to only one person having been seen running from
the incident site. No test identification parade has been either carried
out for identification of the person who was seen running by the
mother of the victim. The applicant has been incarcerated for 16
months. Accused No.2 has already been enlarged on anticipatory bail
by the Court. Since the case of the prosecution is based on
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circumstantial evidence and the motive of the crime will probably
prove the complicity of the applicant at the time of trial. Insofar as
prima facie material for grant of bail is concerned, applicant has
made out a case for grant of bail.
4. Considering the aforesaid, Applicant has made out case for grant
of bail subject to following conditions:-
I) Applicant is directed to be immediately released from
prison in connection with Crime No.125 of 2025
registered with Wadgaon Maval Police Station, Pune;
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 surety of the like amount;
iii) Applicant shall report to the Investigating Officer at
once every month on the first Monday of the month
between 10:00 a.m. to 12:00 p.m.;
iv) Applicant shall co-operate with the conduct of trial and
attend the Trial Court on all dates, unless specifically
exempted and will not take any unnecessary
adjournments, if he does so it will entitle the
prosecution to apply for revocation of this order;
v) Applicant shall not leave the State of Maharashtra
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without prior permission of the Trial Court;
vi) Applicant shall not influence with any of the witnesses
or tamper with the evidence in any manner;
vii) Applicant shall keep the Investigating Officer informed
of his current address and mobile contact number and /
or change of residence or mobile details, if any, from
time to time, as applicable; and
viii) Any infraction of the conditions shall entail cancellation
of bail granted to the Applicant.
5. 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.
6. Bail Application is allowed and disposed of in the above
terms.
rsk [ MILIND N. JADHAV, J. ]
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