Bombay High Court

SALIMUDDIN ABDUL MAJID KHANversusSTATE OF MAHARASHTRA

Decided: 17 September 2026
Disposal: Allowed

Holding

The court held that an intervention by the complainant is permissible and the informant's name may be added as respondent No.2.

Summary

The complainant, Ratnamala P. Patil, filed an application for intervention in an anticipatory bail proceeding (ABA No.1916 of 2026) seeking to be added as respondent No.2, since the FIR was registered on her complaint. The State opposed the intervention, but the court noted that the application originated from the informant whose FIR underlies the case. The court allowed the intervention, directing that the informant's name be added as respondent No.2 and that the necessary amendment be filed within one week. The interim relief granted earlier was ordered to continue until the next hearing. The anticipatory bail application was listed for further consideration on 6 October 2026.

Issues considered

Whether an application for intervention by the complainant in an anticipatory bail proceeding can be allowed
Whether the informant can be added as a respondent in the anticipatory bail application

Subjects

anticipatory bail
intervention
FIR
criminal procedure
amendment

Judgment

                                                                                929-aba1916-26.doc



       vai

                                IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                                     CRIMINAL APPELLATE JURISDICTION
VASANT
ANANDRAO
IDHOL                           ANTICIPATORY BAIL APPLICATION NO.1916 OF 2026
                                                    WITH
Digitally signed by
VASANT
                                     INTERIM APPLICATION NO.2746 OF 2026
ANANDRAO
IDHOL
Date: 2026.09.17
19:14:39 +0530
                      Smt.Ratnamala P. Patil (Yenare)                           ...Applicant
                                 V/s.
                      State of Maharashtra                                      ...Respondent


                      Mr.Aditya Vijay Sawant for the Applicant in ABA No.1916 of 2026.

                      Mr.Sandeep Singh for the Intervenor.

                      Mr.Bapu V. Holambe Patil, APP for the Respondent – State.

                      Mr.Shahaji Narale, API,Shil-Dighar Police Station is present in
                      Court.


                                        CORAM : PRAFULLA S. KHUBALKAR, J.
                                        DATE : 17TH SEPTEMBER, 2026.
                      P.C. :-

                                              INTERIM APPLICATION NO.2746 OF 2026

                      1.           This is an application for intervention filed on behalf of the

                      complainant.

                      2.           Heard learned counsel for the applicant as well as learned

                      APP for respondent – State and learned counsel for accused.


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                                                         929-aba1916-26.doc

3.         Although, the application is opposed by learned counsel for

accused, considering the fact that it is filed by the complainant at

whose instance the FIR is registered, the intervention application is

allowed. The name of the informant be added as respondent no.2 in

the application for anticipatory bail.

4.         Necessary amendment be carried out within a period of one

week from today.

5.         The interim application is allowed in aforesaid terms.


        ANTICIPATORY BAIL APPLICATION NO.1916 OF 2026



1.         List the application for further consideration on 6th October,

2026. Interim protection granted earlier shall continue till next date.


                                         (PRAFULLA S. KHUBALKAR, J.)




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