Allowed

Madhukar Pandurang Adling and Anr. v. State of Maharashtra and Anr.

Bombay HC17 Jan 2026APEAL/377/2024

Case brief

AI extract

What is this about?

Atrocities Act; SC/ST (Prevention of Atrocities) Act; Section 18 Atrocities Act; offence not committed in public view; FIR prima facie reading; investigation completed; charge-sheet filed; interim protection of liberty confirmed; order dated 10th April 2024; order dated 2nd April 2025; anticipatory-protection bar inapplicable; Bombay High Court Criminal Appeal No.377 of 2024; Madhukar Pandurang Ad

What did the court decide?

Appeal allowed; the interim order of 2nd April, 2025 protecting the Appellants' liberty confirmed; the appointed counsel to be paid fees as per rules by the High Court Legal-aid Services Committee.

Madhukar Pandurang Adling and Anr. Vs State of Maharashtra and Anr. — Bombay HC (2026) — LawSathi Research

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30 APEAL 377-24-CR.DOC

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Priya Soparkar

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IN THE HIGH COURT OF JUDICATURE AT BOMBAY CRIMINAL APPELLATE JURISDICTION

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CRIMINAL APPEAL NO.377 OF 2024

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Madhukar Pandurang Adling and anr. …Appellants Versus State of Maharashtra and anr. …Respondents

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Mr. Prashant S. Hagare i/by Ms. Ujjwala Khamane, for the Appellant/Applicant.

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Mr. Satyam Surana (Appointed through legal-aid) , for the Respondent No.2.

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Mr. A. S. Gawai, APP , for the State.

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CORAM: R. M. JOSHI, J. DATED: 17^th JANUARY, 2026.

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PC:-

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Heard.

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Learned counsel for the Appellants submits that the First Information Report ( FIR ) itself indicates that the offence under the Scheduled Caste and Scheduled Tribes (Prevention of Atrocities) Act ( Atrocities Act ) has not been committed in the public view. It is his further submission that liberty of the Appellants were protected by order dated 10^th April, 2024. According to him, having regard to the status of the proceedings, there is no propriety in not confirming the interim relief.

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PRIYA RAJESH SOPARKAR Digitally signed by PRIYA RAJESHSOPARKAR Date: 2026.01.20 10:24:03 +0530

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Page 1 of 2 17^th January, 2026.

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30 APEAL 377-24-CR.DOC

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Learned APP and learned counsel for the Respondent No.2 opposed the appeal.

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Learned APP, on instructions, makes statement that on conclusion of investigation charge-sheet has been filed.

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Prima facie perusal of the FIR indicates that the alleged incident of Appellants abusing the Informant over the cause has not been committed in the public view. As such, the embargo created by Section 18 of the Atrocities Act has no application to the present case.

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Undeniably investigation of the crime is completed. Appellants have participated in the investigation process.

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Pursuant to the order passed by this Court dated 2^nd April, 2025, this Court finds no reason not to confirm the said order.

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Appeal stands allowed.

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The appointed counsel be paid fees as per rules by the High Court Legal-aid Services Committee.

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Page 2 of 2

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17^th January, 2026.

Madhukar Pandurang Adling and Anr. v. State of Maharashtra and Anr.

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Madhukar Pandurang Adling and Anr. v. State of Maharashtra and Anr.

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