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Bombay High Court

STATE OF MAHARASHTRAversusMOHITKUMAR BHISHANDAS BHAGAT AND ORS

Decided
Disposal
Disposed Off

Holding

The revision application is infructuous and is therefore disposed.

Summary

The State of Maharashtra filed a criminal revision seeking to set aside an order dated 25 April 2022 of the Additional Sessions Judge, Vasai, which had rejected the prosecution’s request to place certain documents on record. The trial in the underlying case had already concluded, resulting in the conviction of the accused on 16 January 2025, and a criminal appeal was pending before the High Court. The State argued that the revision was now moot because the trial was over and the appeal was pending. The Court examined whether a revision could still be entertained after the trial’s conclusion and found that the application had become infructuous. Consequently, the Court disposed of the revision application without further order.

Issues considered

  • What is the effect of a trial’s conclusion on the maintainability of a criminal revision seeking to admit evidence?

Subjects

  • criminal revision
  • evidence admission
  • procedural law
  • High Court jurisdiction
  • mootness

Judgment

NISHA   Digitally signed by
        NISHA SANDEEP
SANDEEP CHITNIS
        Date: 2026.08.24
CHITNIS 15:36:16 +0530                                                  18-revn.335.2022.doc


                           IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                                 CRIMINAL APPELLATE JURISDICTION

                           CRIMINAL REVISION APPLICATION NO.335 OF 2022

                  The State of Maharashtra                       ...Applicant
                       Versus
                  Mohitkumar Bhishandas Bhagat and Ors.          ...Respondents

                  Ms. Sangeeta D. Shinde, A.P.P for the Applicant-State.

                  None for the Respondents.

                                               CORAM: ASHISH S. CHAVAN, J.

                                               DATE    : 21st AUGUST 2026
                  P.C. :

                  1.           Learned A.P.P. submits that by way of this Revision

                  Application, the State has assailed the order dated 25 th April 2022

                  passed by the learned Additional Sessions Judge, Vasai, inter alia,

                  rejecting the application filed by the prosecution seeking permission of

                  the Court to place certain documents on record. She submits that the

                  trial in the aforesaid case has concluded. By a judgment dated 16 th

                  January 2025, the respondents/original accused stand convicted,

                  against which they have preferred a Criminal Appeal, which is pending

                  before this Court.



  N. S. Chitnis                                                                         1/2
                                                                      18-revn.335.2022.doc




                2.         In view thereof, she submits that the Revision Application

                has run its course and has been rendered infructuous. Consequently,

                nothing survives for consideration in the Revision Application.

                           Resultantly, the Revision Application stands disposed of.




                                                            ASHISH S. CHAVAN, J.




N. S. Chitnis                                                                          2/2


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