Bombay High Court

SATISH SANJAY SHEDGEversusSTATE OF MAHARASHTRA

Decided: 27 March 2026
Disposal: Disposed Off
Bench: ASHWIN D BHOBE

Holding

The High Court held that the lower courts must dispose of the pending bail applications promptly, in compliance with the Supreme Court’s directive to avoid undue deprivation of liberty.

Summary

Four petitioners, all in custody for offences under the IPC, Arms Act, Maharashtra Police Act and the Maharashtra Control of Organized Crime Act, filed writ petitions alleging that their bail applications pending before the District Judge‑6 and Additional Sessions Judge, Pune, were unduly delayed. The sole grievance raised was the non‑disposal of these bail applications, which were posted for orders on 04‑04‑2026. The State counsel confirmed that the applications had been heard and were scheduled for orders, and the petitioners did not dispute this. The Court referred to the Supreme Court’s directions in Anna Waman Bhalerao v. State of Maharashtra, which mandate expeditious disposal of bail applications within two months. Accordingly, the High Court directed the lower courts to dispose of the bail applications on the scheduled date or at the earliest possible time and ordered the petitioners be informed. The writ petitions were consequently disposed of with these observations.

Issues considered

What is the appropriate time frame for disposal of bail applications under the Supreme Court’s directions?
Whether the delay in disposing bail applications violates the petitioners' fundamental right to liberty.

Legislation cited

Arms Act, 1959 — s. 25, 27, 3, 7
Indian Penal Code, 1860 — s. 120(b), 201, 202, 302, 307, 34
Maharashtra Control of Organized Crime Act, 1999 — s. 3(1)(i), 3(2), 3(4)
Maharashtra Police Act, 1951 — s. 135, 37(1), 37(3)

Subjects

bail
personal liberty
delay in justice
Supreme Court directions
criminal procedure
high court order

Judgment

14-WP-1391-2026 .doc

IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CRIMINAL APPELLATE JURISDICTION
WRIT PETITION NO. 1391 OF 2026
Satish Sanjay Shedge … Petitioner
V/S.
The State Of Maharashtra … Respondent
WRIT PETITION NO. 1395 OF 2026
Nitin Ananta Khaire … Petitioner
V/S.
The State Of Maharashtra … Respondent
WRIT PETITION NO. 1396 OF 2026
Aditya Vijay Gole … Petitioner
V/S.
The State Of Maharashtra … Respondent
WRIT PETITION NO. 1397 OF 2026
Abhijit Arun Mankar … Petitioner
V/S.
The State Of Maharashtra … Respondent
__________________________________________________________
Mr. Simran W., for the Petitioner in Writ Petition No. 1391 of 2026
through VC mode.

Ms. Priyanka Naik, for the Petitioner in Writ Petition No. 1395 of
2026.

Ms. Rui Danawala, for the Petitioner through VC in Writ Petition
1396 of 2026.

Mr. Dilip Shukla a/w Steve Fernandes h/f Davinder Sabharwal, for
the Petitioner in Writ Petition No. 1397 of 2026.

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Ms. Rajeshree Newton, APP for the Respondent – State in Writ
Petition No. 1391 of 2026 and Writ Petition No. 1396 of 2026.
Ms. Anuja Gotad, APP for the Respondent – State in Writ Petition
No. 1395 of 2026.
Mr. Sukanta Karmakar, APP for the Respondent – State in Writ
Petition No. 1397 of 2026.
API Dhavale, Unit-3, Pune City Police Station, is present.
__________________________________________________________

CORAM : ASHWIN D. BHOBE, J.
DATE : 27th March, 2026.
P.C. :

1. Heard.

2. These four Petitions are filed by the Petitioners, who are in

custody regarding an offence registered as Crime No. 2 of 2024

with Kothrud Police Station, for the offences punishable under

Sections 302, 307, 120(b), 201, 202, 34 of the Indian Penal Code,

1860, Sections 3, 7, 25, 27 of the Arms Act, 1959, and Sections

37(1), (3), r/w 135 of the Maharashtra Police Act, 1951, as well as

Sections 3(1)(i), 3(2), 3(4) of the Maharashtra Control of

Organized Crime Act, 1999.

3. The said crime is registered as Special Case (Sessions) No.
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616 of 2024 and remains pending before the District Judge-6 and

Additional Sessions Judge, Pune.

4. The Advocates representing the Petitioners (appointed

through the Legal Aid Scheme) submit that the solitary grievance

of the Petitioners in these Petitions, who are accused in Special

Case No. 4675 of 2024, is that their Bail Applications pending

before the Court are not being disposed of. They state that the

Petitioners grievance is limited to the delay in the disposal of their

Bail Applications.

5. Mr. Sukanta Karmakar and Ms. Anuja Gotad, learned APPs

for the Respondent – State, in all these four Petitions, on

instructions from the Investigation Officer, states that the

arguments in the Bail Applications filed by all these Petitioners

were heard by the District Judge – 6 and Additional Sessions

Judge, Pune, and the matters are now posted on 04.04.2026 for

orders. He submits that, in all probability, as the bail applications

are closed for orders, they will be disposed of on the date fixed.

6. The statement made by Mr. Sukanta Karmakar and Ms.

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Anuja Gotad, learned APPs is not disputed by the learned

Advocates appearing for the Petitioners in all these Writ Petitions.

7. Be that as it may, the Hon’ble Supreme Court in the case of

Anna Waman Bhalerao v. State of Maharashtra 1, in paragraph No.

18 has observed as follows:

18. We accordingly issue the following
directions:-

a) High Courts shall ensure that applications for bail
and anticipatory bail pending before them or before
the subordinate courts under their jurisdiction are
disposed of expeditiously, preferably within a period
of two months from the date of filing, except in cases
where delay is attributable to the parties themselves.

b) High Courts shall issue necessary administrative
directions to subordinate courts to prioritise matters
involving personal liberty and to avoid indefinite
adjournments.

c) Investigating agencies are expected to conclude
investigations in long-pending cases with
promptitude so that neither the complainant nor the
accused suffers prejudice on account of undue delay.

d) Being the highest constitutional fora in the States,
High Courts must devise suitable mechanisms and
procedures to avoid accumulation of pending
bail/anticipatory bail applications and ensure that the
liberty of citizens is not left in abeyance. In particular,
bail and anticipatory bail applications shall not be
1 (2025) SCC OnLine SC 1974

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kept pending for long durations without passing
orders either way, as such pendency directly impinges
upon the fundamental right to liberty.

18.1. The Registrar (Judicial) of this Court shall
circulate a copy of this judgment to all High Courts
for immediate compliance and prompt administrative
action.

8. In view of the above, it is expected that the District Judge - 6

and Additional Sessions Judge, Pune would dispose of the said Bail

Applications on 04.04.2026 or at the earliest convenient to the

Court.

9. The Registry of this Court is directed to communicate this

Order to the Petitioners who are presently lodged in the Jalna

District Prison Jalna, Maharashtra, through the Jail Authorities.

10. Mr. Sukanta Karmakar and Ms. Anuja Gotad, learned APPs

states that the Investigation Officer would place this Order before

the District Judge - 6 and Additional Sessions Judge, Pune on

04.04.2026.

11. In view of the above, learned Advocates for the Petitioners in

all these Petitions submit that these Petitions can be disposed of.

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12. Writ Petition Nos. 1391 of 2026, 1395 of 2026, 1396 of 2026

and 1397 of 2026 are disposed of with the above-mentioned

observations.

(ASHWIN D. BHOBE, J.)

Digitally
signed by
ARJUN
ARJUN KRISHNA
KRISHNA RODGE
RODGE Date:
2026.04.01
11:02:10
+0530

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