Bombay High Court
ANMOL GOVINDRAM SEKHRIversusTHE STATE OF MAHARASHTRA
- Decided
- Disposal
- Disposed Off
Holding
The death of the accused results in the abatement of the criminal case, and the revision application is consequently disposed.
Summary
The applicant, originally accused No.4, filed a criminal revision seeking discharge from offences under Sections 120B, 420, 468, 471 of the IPC and Sections 13(2) and 13(1)(d) of the Prevention of Corruption Act. The revision challenged the order of the CBI Special Judge that had rejected his discharge plea. During the pendency of the revision, the applicant died, as evidenced by a judgment and order dated 10 March 2026 in CBI Special Case No.24 of 2009, which recorded the abatement of the case against him. The CBI counsel submitted the death certificate and the judgment, urging the court to dispose of the proceedings. The High Court held that the death of the accused extinguishes the criminal liability, rendering the case abated and there being no purpose to continue the revision. Consequently, the revision application was disposed of.
Issues considered
- Whether criminal proceedings may continue against an accused who has died during the pendency of the case
- Whether the revision application seeking discharge should be dismissed on the ground of abatement
Legislation cited
- Indian Penal Code — s. 120B, 420, 468, 471
- Prevention of Corruption Act — s. 13(1)(d), 13(2)
Subjects
- criminal procedure
- abatement
- death of accused
- revision
- IPC
- Prevention of Corruption Act
Judgment
NISHA Digitally signed by
NISHA SANDEEP
SANDEEP CHITNIS
Date: 2026.09.21
CHITNIS 12:04:20 +0530 901-REVN.292.2018.doc
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CRIMINAL APPELLATE JURISDICTION
CRIMINAL REVISION APPLICATION NO.292 OF 2018
Anmol Govindram Sekhri ...Applicant
Versus
The State of Maharashtra
through the Central Bureau of Investigation ...Respondent
None for the Applicant.
Mr. Tanveer Khan, A.P.P for the Respondent–State.
Mr. Digvijay S. Kachare with Mr. Kuldeep Patil for the Respondent-
Central Bureau of Investigation (CBI).
CORAM: ASHISH S. CHAVAN, J.
DATE : 17th SEPTEMBER 2026
P.C. :
1. Heard learned counsel for the Central Bureau of
Investigation (CBI), Mr. Kachare.
2. By way of this Revision Application, the applicant, who
was the original accused No.4, has challenged the order rejecting his
prayer for discharge from the offences punishable under Sections
120B, 420, 468, 471 of the Indian Penal Code, read with Sections
13(2) and 13(1)(d) of the Prevention of Corruption Act, passed by the
N. S. Chitnis 1/3
901-REVN.292.2018.doc
learned CBI Special Judge, Greater Mumbai, on 6th March 2018. On
6th December 2019, this Court had recorded that the learned counsel
for the applicant had filed an application for withdrawal of
Vakalatnama. The subsequent orders indicate that none has appeared
on behalf of the applicant and no appearance has been entered on his
behalf.
3. Today, the learned counsel for the CBI has tendered a
Judgment and Order dated 10 th March 2026, passed by the learned
Special Judge (CBI), City Civil and Sessions Court, Greater Mumbai,
in CBI Special Case No.24 of 2009. He has invited my attention to
the details of the accused set out in the said Judgment and Order,
wherein the name of the applicant is reflected as accused No.4. The
Judgment and Order further reflects that the case has abated against
accused No.4, who was charge-sheeted by the CBI for entering into a
criminal conspiracy and cheating Syndicate Bank, following orders
dated 3rd January 2023 and 16th April 2025, respectively.
N. S. Chitnis 2/3
901-REVN.292.2018.doc
4. The learned counsel for the CBI, on instructions, also
states that the applicant (accused No.4) has expired, during the
pendency of the Revision Application. A copy of the said Judgment
and Order is taken on record.
5. In view of the submissions made by the learned counsel for
the CBI and the aforesaid Judgment and Order, it is evident that the
case against the present applicant has abated. No purpose would,
therefore, be served by continuing the present proceedings.
Consequently, Criminal Revision Application No.292 of 2018 stands
disposed of.
ASHISH S. CHAVAN, J.
N. S. Chitnis 3/3
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