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Bombay High Court

ADITYA RAVINDRA PAWARversusSTATE OF MAHARASHTRA AND ANR

Decided
Disposal
Disposed Off

Holding

The Court held that no prima facie case of abetment of suicide existed and therefore granted bail to the applicant.

Summary

The High Court of Bombay considered a bail application filed by Aditya Ravindra Pawar, who was arrested under FIR No.81 of 2026 for an alleged offence under Section 108 of the Bharatiya Nyaya Sanhita, 2023, relating to the suicide of a 19‑year‑old girl. The prosecution alleged that Pawar had entered into a sexual relationship with the deceased by falsely promising marriage, leading to her pregnancy and subsequent suicide after a quarrel triggered by a selfie posted on Instagram. The defence argued that there was no evidence of a false promise of marriage or abetment to suicide and that the selfie alone could not establish criminal intent. The Court examined whether the prosecution had established a prima facie case of abetment and found that the relationship appeared consensual and the selfie was insufficient to infer a false promise. Consequently, the Court held that no prima facie case existed and that the applicant was entitled to bail. The Court ordered his release on bail upon furnishing a bond and imposed standard conditions for attendance and non‑interference with evidence.

Issues considered

  • Whether the prosecution has established a prima facie case of abetment of suicide under Section 108 of the Bharatiya Nyaya Sanhita, 2023.
  • Whether the posting of a selfie on Instagram can be construed as evidence of a false promise of marriage to induce the victim.
  • Whether the alleged consensual relationship and pregnancy constitute sufficient grounds to deny bail.

Legislation cited

Subjects

  • bail
  • abetment of suicide
  • Section 108 BNS
  • false promise of marriage
  • Instagram selfie
  • consensual relationship
  • criminal law

Judgment

WAKLE                 MANOJ                                              912-BA-2324-2026.DOC
MANOJ
JANARDHAN

Digitally signed by
WAKLE MANOJ
                           IN THE HIGH COURT OF JUDICATURE AT BOMBAY
JANARDHAN
Date: 2026.08.19
                                CRIMINAL APPELLATE JURISDICTION
12:47:48 +0530
                           CRIMINAL BAIL APPLICATION NO.2324 OF 2026
                      Aditya Ravindra Pawar                               …Applicant
                            V/s.
                      The State of Maharashtra & Anr.                     …Respondents


                      Mr. Kuldeep S. Patil a/w Mr. Keshav Patil, for the Applicant.
                      Ms. A. A. Deshmukh, APP for the Respondent No.1-State.
                      Mr. Shubhash Rathod, API, Vasai Road Railway Police Station,
                      present.


                                                 CORAM: SHYAM C. CHANDAK, J.
                                                 DATED : 18th AUGUST, 2026
                      P.C. :-

                      1.      Heard learned Counsel for the parties. Perused the record.

                      2.      The Applicant seeks his release on bail in connection with
                      an FIR bearing CR No.81 of 2026, Registered with Vasai Road
                      Railway Police Station, for the offence punishable under Section
                      108 of the Bharatiya Nyaya Sanhita, 2023 (for short “BNS”), on
                      the report dated 25.02.2026 filed by XYX, mother of the deceased
                      girl then aged 19 years.

                      3.      The prosecution case is that, about six months prior to
                      lodging of the Report, love relationships were established between
                      the Applicant and the deceased. It is alleged that, on 08.11.2025 at
                      Pune and between 16.12.2025 to 18.12.2025          at Lonavala, the
                      Applicant had committed sexual intercourse with the deceased on
                      a false pretext that he will marry with her. Consequently, the
                      deceased got pregnant. It is alleged that on 21.01.2026 there was a
                      college day in the college of the Applicant. At that time, the
                      deceased had an argument with the Applicant on phone. Two days

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MANOJ                                             912-BA-2324-2026.DOC



thereafter, the deceased was quarreling with the Applicant on
phone. When her friend “M” inquired, the deceased told her that
the Applicant had a selfie photo with one girl and it was posted on
their Instagram account. That led to a quarrel between the two.
Further, the deceased told her friend “M” that the said girl may be
friend of the Applicant and therefore, she was disturbed. This
disturb mindset led the deceased to commit suicide on 29th
January, 2026. Therefore, the present crime came to be registered
and the Applicant was arrested. The Sessions Court refused the
Applicant’s prayer for bail.

4.      Mr. Patil, learned Counsel for the Applicant submits that
there is no evidence against the Applicant that he had made a false
promise of marriage to establish physical relationship with the
deceased. The sole incident of posting a selfie on the Instagram is
not sufficient to hold that the Applicant had falsely stated to the
victim that he would marry with her and therefore, the victim had
agreed to establish physical relationship with him. The case is
lacking the evidence of abetment to commit suicide. Therefore, the
Applicant deserves for bail.

5.      In reply, Ms. Deshmukh, learned APP submitted that there
is material against the Applicant which show that, immediately
after establishing physical relationship with the deceased, the
Applicant developed a friendship with another girl and further, he
made that relationship public by posting the selfie on Instagram.
This conduct clearly indicate that since beginning the Applicant
only wanted to establish physical relationship with the deceased,
making a false promise of marriage and consequently, she became
pregnant, which led her to commit suicide. Therefore, this is not a
fit case to grant bail.


                               Page 2 of 4
MANOJ                                              912-BA-2324-2026.DOC



6.      I have considered these submissions. To make out a case of
the alleged offence, the prosecution is required to show that, since
inception, the Applicant had intended to establish physical
relationship with the victim by making a false promise of marriage
but without any intention to marry with her. However, the record
prima facie show that       the physical relationship between the
Applicant and the victim was consensual. Consequently the victim
got pregnant. Secondly, the selfie is not sufficient to conclude that
the Applicant had made a false promise of marriage to induce the
deceased to consent for the physical relationship with him. It
usually happens in such cases, when two young persons are madly
in love, that they promise to each other several times that come
what may, they will get married. In the case in hand, having regard
to the facts and age of the Applicant as well as the deceased, it
appears that the alleged promise to marry was made by the
Applicant out of immaturity and unmindful of its consequences.

        The selfie indicates that there was friendship between the
Applicant and the girl seen in that selfie. However, the selfie was
misunderstood by the deceased and, it led to a quarrel between
her and the Applicant. Consequently, she committed suicide.

7.      In the wake of above, I am of the view that there is no prima
facie case of the alleged offence against the Applicant. Therefore,
the Applicant is entitled for bail. Hence, following Order:-

        (i)   Applicant – Aditya Ravindra Pawar shall be released
        on bail in connection with an FIR bearing CR No.81 of
        2026, Registered with Vasai Road Railway Police Station,
        on his furnishing P.R. Bond in the sum of Rs.50,000/- with
        one or two sureties in the like amount.


                               Page 3 of 4
MANOJ                                                912-BA-2324-2026.DOC



        (ii)   The Applicant shall mark his attendance at Vasai
        Road Railway Police Station, on the 1st day of each calendar
        month between 12:00 noon to 4:00 p.m., till the conclusion
        of the trial.

        (iii) The Applicant shall regularly attend the proceedings
        before the jurisdictional Court unless exempted by the said
        Court, for the reasons to be recorded in writing.

        (iv)   The Applicant shall not tamper with the prosecution
        evidence and shall not directly or indirectly influence upon
        the prosecution witness to prevent them from deposing
        against him.

        (v)    On being released from jail, the Applicant shall
        furnish his contact number and residential address to the
        Investigation Officer and shall keep him updated, in case
        there is any change.

        (vi)   It is clarified that any observation made in the present
        order are for the purpose of deciding the present Bail
        Application and should not influence the out come of the
        trial and also not be taken as an expression of opinion on
        the merits of the case.

        (vii) Application stands disposed of in the aforesaid terms.



                                   (SHYAM C. CHANDAK, J.)




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