Bombay High Court

ANITA DASHARATH JADHAVversusSTATE OF MAHARASHTRA AND ANR.

Disposal: Allowed

Holding

The applicant is entitled to bail on the ground of parity and under Section 480 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Summary

Anita Dasharath Jadhav, accused No.5 in Crime No. 940 of 2024, sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, for offences under multiple IPC sections and Section 66C of the IT Act. The applicant argued that co‑accused Kashmira Sandip Pawar (Accused No.1) and Radha Yuvraj Zalke (Accused No.4) had already been released on bail by the Supreme Court and this Court respectively, invoking the principle of parity. The State contended that the allegations against the applicant were similar to those against the other accused, thereby allowing consideration of parity. The Court examined the Supreme Court order (Criminal Appeal No. 3723‑3724/2026) and this Court’s order (Criminal Bail Application No. 601 of 2026) and noted that the applicant, being a woman, is entitled to the benefit of Section 480 of the Bharatiya Nagarik Suraksha Sanhita. Applying the parity principle and the statutory benefit, the Court granted bail with standard conditions and disposed of the bail application.

Issues considered

The applicability of the parity principle for granting bail to the applicant in view of bail granted to co‑accused.
Whether Section 480 of the Bharatiya Nagarik Suraksha Sanhita, 2023, confers a right to bail on a female accused.
The adequacy of the charges to justify continued detention.

Legislation cited

Bharatiya Nagarik Suraksha Sanhita, 2023 — s. 480, 483
Indian Penal Code, 1860 — s. 120(1), 120B, 170, 420, 465, 467, 468, 469, 470, 471, 472, 473
Information Technology Act, 2000 — s. 66C

Subjects

bail
parity
women's rights
Section 480
Bharatiya Nagarik Suraksha Sanhita
Indian Penal Code
Information Technology Act
criminal procedure

Judgment

70-BA-530-2026.odt

IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CIRCUIT BENCH AT KOLHAPUR
CRIMINAL APPELLATE JURISDICTION
BAIL APPLICATION NO. 530 OF 2026
Anita Dasharath Jadhav … Applicant
Versus.
State of Maharashtra And Anr. … Respondents
-----
Mr. Ramanik Pawar i/b S. V. Mahamulkar, Advocate for the Applicant.
Mr. N. B. Patil, APP for the Respondent – State.
PSI A. S. Jaypatre, Satara City Police Station, is present.
-------

CORAM : ASHWIN D. BHOBE, J.
DATE : 24th August, 2026.
P.C. :

1. Heard Mr. Ramanik Pawar, learned Advocate for the Applicant

and Mr. N. B. Patil, learned APP for the Respondent – State.

2. By this Application, filed under Section 483 of the Bharatiya

Nagarik Suraksha Sanhita, 2023, the Applicant seeks Regular Bail in

connection with Crime No. 940 of 2024, dated 21.10.2024, registered

with Satara City Police Station, District Satara, for offences punishable

under Sections 170, 420, 465, 467, 468, 469, 470, 471, 472, 473, 120B

and 120(1) of the Indian Penal Code, 1860 and Section 66(C) of the

Information Technology Act, 2000.

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70-BA-530-2026.odt

3. Mr. Ramanik Pawar, learned Advocate for the Applicant, states

that the Applicant is Accused No. 5 in Crime No. 940 of 2024, registered

as R.C.C. No. 60 of 2025, which is pending before the Judicial

Magistrate First Class (Court No. 2), Satara. He states that the

Applicant was arrested on 21.10.2024.

4. Mr. Ramanik Pawar, learned Advocate for the Applicant submits

that the Applicant seeks bail in Crime No. 940 of 2024 on the ground of

parity. He submits that Kashmira Sandip Pawar (Accused No. 1) in

Crime No. 940 of 2024, against whom the allegations are more serious

and graver than those against the Applicant, has been released on bail

by the Hon’ble Supreme Court in Criminal Appeal No. 3723-3724/2026

on 07.08.2026. He states that Radha Yuvraj Zalke (Accused No. 4), who

has allegations similar to the Applicant has been released on bail by this

Court vide order dated 20.08.2026 passed in Criminal Bail Application

No. 601 of 2026. He tenders a photostat copy of the order dated

20.08.2026 passed in Criminal Bail Application No. 601 of 2026, which

is taken on record and marked as “X” for identification.

5. Mr. Ramanik Pawar, learned Advocate for the Applicant, relying

on the orders granting bail to Accused Nos. 1 and 4, submits that the

Applicant is entitled on the ground of parity.

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6. Mr. N. B. Patil, learned APP for the Respondent – State, in all

fairness, submits that the allegations against the Applicant are almost

similar to those against Accused Nos. 1 and 4 in Crime No. 940 of 2024.

Therefore, the Applicant's request for bail can be considered on the

ground of parity.

7. Perused the records, the order dated 07.08.2026 passed by the

Hon’ble Supreme Court in Criminal Appeal No. 3723-3724/2026 and

the order dated 20.08.2026 passed by this Court in Criminal Bail

Application No. 601 of 2026.

8. The Hon’ble Supreme Court, in paragraph Nos. 4 to 9 of the order

dated 07.08.2026, has observed as follows :

"4. We have heard learned counsel for the parties.

5. The charge-sheet in respect of FIR No. 940 of
2024 was filed on 18th January 2025 while the charge-sheet in
respect of FIR No. 1059 of 2024 was filed on 17th February
2025.

6. Learned counsel appearing for the respondent-
State of Maharashtra submits that the prosecution proposes to
examine eight witnesses in support of the charges against the
appellant in respect of FIR No. 940 of 2024. In respect of FIR
No. 1059 of 2024, the application for discharge filed by the
appellant is pending; consequently, charges have not yet been
framed.

7. As the matter stands now, the trial will take some
time to conclude. Appellant has been in custody for a little less
than two years. In any event, the appellant is a woman entitled

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to the benefit of Section 480 of the Bharatiya Nagarik Suraksha
Sanhita, 2023.

8. Taking an overall view of the matter and
particularly in view of seizure of incriminating documents, we
find that further detention of the appellant in custody may not
serve any useful purpose; hence, we are inclined to accept the
appeal and grant relief as prayed by admitting the appellant to
an order for grant of bail.

9. Accordingly, we set aside the impugned judgment
and order.”

9. Mr. Ramanik Pawar, learned Advocate for the Applicant, has

submitted that the allegations against Kashmira Sandip Pawar (Accused

No. 1) are more serious than those against the Applicant. On the

allegations in Crime No. 940 of 2024, Kashmira Sandip Pawar (Accused

No. 1) has been released on bail by the Hon’ble Supreme Court. Radha

Yuvraj Zalke (Accused No. 4) has been released on bail by this Court

vide order dated 20.08.2026 passed in Criminal Bail Application No.

601 of 2026. The Applicant is a woman and as such, would be entitled

to the benefit of Section 480 of the Bharatiya Nagarik Suraksha Sanhita,

2023. No material has been placed on record to demonstrate any

distinguishing circumstances that would warrant a different view in the

case of the Applicant. The principle of parity applies to the case of the

Applicant.

10. Mr. Ramanik Pawar, learned Advocate for the Applicant, is

therefore justified in seeking bail for the Applicant on the ground of

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parity.

11. In view of the above, the Applicant is entitled to bail on the

following conditions :-

(a) The Applicant - Anita Dasharath Jadhav in the

Crime No. 940 of 2024, dated 21.10.2024, registered

with Satara City Police Station, District Satara, shall be

released on bail upon furnishing a PR bond of Rs.

50,000/- (Rupees Fifty Thousand only), with one or

two sureties in the like amount to the satisfaction of

the Judicial Magistrate First Class, Satara.

(b) The Applicant shall report to the Investigating

Officer on the 2nd Monday of each month from 10:00

a.m. to 11:00 a.m., till further orders from the Trial

Court.

indirectly make any inducement, threat or promise to

any person/s acquainted with the facts of the case to

dissuade such person/s from disclosing the facts to the

Court or any police officer.
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(d) The Applicant shall not tamper with the

evidence in any manner.

(e) The Applicant shall provide the Investigating

Officer, with her residential address along with the

proof, her contact numbers and must inform the

Investigating Officer of any changes to this information

from time to time.

(f) The Applicant shall regularly appear

before the Trial Court in R.C.C. No. 60 of 2025, unless

specifically exempted. If the Applicant fails to appear

before the Trial Court on the date fixed, the same

would be considered a breach of condition and the

Trial Court would be at liberty to pass appropriate

orders.

12. Criminal Bail Application No. 530 of 2026 is disposed of.

(ASHWIN D. BHOBE, J.)

Digitally
signed by
ARJUN
ARJUN KRISHNA
KRISHNA RODGE
RODGE Date:
2026.08.25
10:38:56 Arjun 6
+0530

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