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Bombay High Court

PRAFUL PRATAPRAI TRIVEDIversusTHE STATE OF MAHARASHTRA

Decided
Disposal
Disposed Off

Holding

The revision application is abated because the sole applicant has died.

Summary

The applicant, Praful Prataprai Trivedi, was convicted under IPC Sections 467, 468, 471 and 420 and sentenced to two years' rigorous imprisonment with a fine of Rs.5,000, which was later confirmed by the Additional Sessions Judge. He filed a criminal revision seeking relief, but his wife submitted an affidavit with a death certificate showing that he died on 30 October 2025. The fine of Rs.5,000 had already been paid. The High Court examined whether the revision could continue after the death of the sole applicant. It held that the death of the applicant extinguishes the pending revision. Consequently, the revision application was disposed of as abated.

Issues considered

  • Whether a criminal revision application can proceed after the death of the sole applicant
  • Effect of the death of an accused on pending criminal proceedings

Legislation cited

Subjects

  • criminal revision
  • abated proceedings
  • death of accused
  • IPC sections 467, 468, 471, 420
  • fine payment

Judgment

       Digitally
       signed by                                                        1.cri.revn.369.2002.doc
       VINA
VINA   ARVIND
ARVIND KHADPE
KHADPE Date:
       2026.08.20
       18:20:27
       +0530
                               IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                                     CRIMINAL APPELLATE JURISDICTION

                              CRIMINAL REVISION APPLICATION NO.369 OF 2002

                    Praful Prataprai Trivedi                    … Applicant
                          Versus
                    The State of Maharashtra                     … Respondent

                                                     ***
                    Mr. Shashikant Chaudhari (appointed through Legal Aid), a/w Ms.
                    Snehal S. Chaudhari, Ms. Ananya Thakoor, Mr. Pranav Thakare for
                    the Applicant.
                    Ms. M. R. Tidke, APP for Respondent- State.
                    Mrs. Mamta Praful Trivedi – wife of the Applicant is present.
                    PSI K. N. Dhaware, L.T. Marg Police Station present.
                                                     ***

                                                        CORAM : M.M. SATHAYE, J.
                                                        DATE     : 20 AUGUST, 2026
                    P.C. :

                    1.       The Applicant is accused no.1 who was convicted for the
                    offences punishable under Sections 467, 468, 471 and 420 of the
                    Indian Penal Code, 1860, and was sentenced to suffer rigorous
                    imprisonment for two years and to pay a fine of Rs.5,000/- and in
                    default to suffer further rigorous imprisonment for three months. The
                    conviction and sentence were confirmed in the appeal by the learned
                    Additional Sessions Judge, Mumbai, against which the the present
                    Revision Application is filed.

                    2.       Learned counsel for the Applicant has placed on record an
                    affidavit sworn by the wife of the Applicant (who is present in Court,
                    and is duly identified by the advocate for the Applicant) wherein it is


                    Vina Khadpe                          1
                                                   1.cri.revn.369.2002.doc




stated that the sole Applicant expired on 30.10.2025. His death
certificate is annexed to the Affidavit. A copy of the Affidavit along
with documents (Page Nos. 1 to 6) is taken on record and marked ‘X’
for identification.

3.     Learned APP confirms that the amount of fine of Rs.5000/- has
been paid.

4.     Considering that the sole Applicant has expired, the Revision
Application is disposed of as abated.

                                             (M.M. SATHAYE, J.)




Vina Khadpe                             2


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