Bombay High Court
DOLLY JOSEPH PARRERAversusTHE STATE OF MAHARASHTRA
- Decided
- Disposal
- Allowed
Holding
Bail is granted to the applicant subject to the conditions specified in the order.
Summary
The High Court considered a bail application filed under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023, by Dolly Joseph Parrera, who is accused (Accused No. 6) of murder and related offences under Sections 302 and 201 read with Section 34 of the Indian Penal Code. The prosecution's case against her is based on circumstantial evidence and the confessional statements of co‑accused, while she has been in custody for nearly three years pending trial. The court noted that five co‑accused had already been released on bail and, considering the applicant’s gender and the length of incarceration, found a case for parity in granting bail. Consequently, the court ordered her release on bail with a cash bond of Rs. 25,000 and a surety of the same amount, imposing several reporting and conduct conditions. The order expressly limited its observations to bail and did not address the merits of the criminal case.
Issues considered
- Whether bail should be granted to the accused under Section 483 of the BNSS, 2023, given the nature of the offences and the evidentiary material.
- Whether the applicant’s prolonged pre‑trial detention and gender warrant bail on the ground of parity.
Legislation cited
- Bhartiya Nagarik Suraksha Sanhita, 2023 — s. 483
- Indian Penal Code — s. 201, 302, 34
Subjects
- bail
- murder
- circumstantial evidence
- gender parity
- pre‑trial detention
- BNSS
- Indian Penal Code
- criminal procedure
Judgment
10. BA 3764-2026.doc
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CRIMINAL APPELLATE JURISDICTION
BAIL APPLICATION NO. 3764 OF 2026
Dolly Joseph Parrera .Applicant
Vs.
The State of Maharashtra .Respondent
ANAND
SUDHAKAR Mr. Tanmay Kate i/b. Mr. Vipul Dushing, Advocates, for the Applicant
SUDAME Ms. Sangeeta E. Phad, APP, for the Respondent – State
Digitally signed by
ANAND SUDHAKAR
SUDAME
Date: 2026.10.07 CORAM : MILIND N. JADHAV, J.
20:33:44 +0530
DATE : 07.10.2026
P. C.
1. Heard Mr. Kate, learned Counsel for the Applicant and Ms. Phad,
learned APP for the Respondent – State.
2. This Application is filed under Section 483 of the Bhartiya
Nagarik Suraksha Sanhita, 2023 (for short “BNSS”) in connection with
C.R.No. 632 of 2023 registered with Paud Police Station, Pune for
offences punishable under Sections 302 and 201 r/w. 34 of the Indian
Penal Code, 1860 (for short “IPC”).
3. The Applicant is arraigned as Accused No. 6 in this crime, where
seven Accused persons have been arrested. She is alleged to have
conspired the murder of the victim, who used to harass her and had
also assaulted her. Case of the prosecution qua the Applicant insofar as
Anand 1 of 4
10. BA 3764-2026.doc
the incident in question is concerned is purely circumstantial. It is
prima facie based on the confessional statements of the other
co-accused persons which have been recorded. Applicant is
incarcerated close to three years pending trial. Five of the other
co-accused persons, who have actually committed the act have already
been enlarged on bail by this Court. In that view of the matter,
Applicant being a woman has made out a case on the ground of parity
as well as long incarceration to be released on bail.
4. 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 – Dolly Joseph Parrera is directed to be
immediately released from prison in connection with
CR. No. 632 of 2023;
(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
Paud Police Station, Pune, 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
Anand 2 of 4
10. BA 3764-2026.doc
attend all dates of hearing before the Trial Court;
(iv) Applicant shall co-operate 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 her current residential address and mobile telephone
number and shall forthwith inform the Investigating
Officer of any change in her residential address or
mobile telephone number, as and when such change
occurs; and
(viii)Any breach or infraction of any of the aforesaid
conditions shall entail cancellation of the bail granted to
the Applicant.
5. It is clarified that the observations made in this order are limited
Anand 3 of 4
10. BA 3764-2026.doc
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 in the above terms.
(MILIND N. JADHAV, J.)
Anand 4 of 4
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