Karan Jitendra Virwani vs the State of Maharashtra — Bombay HC (2026) — LawSathi Research

Karan Jitendra Virwani vs the State of Maharashtra — Bombay HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Interim Application partly allowed and disposed of: the travel-restriction condition (iv) was NOT relaxed, but the Trial Court may dispense with the Applicant's personal appearance when he seeks permission to travel abroad, and any such application is to be decided within seven days of first listing. Rest of the order remains as it is.

Issue for consideration

Whether condition (iv) of the bail order - that the Applicant is not permitted to leave India without permission of the Trial Court - should be relaxed or modified. +1 more

Court's answer

The court was not inclined to relax condition (iv) of the bail order; the bar on leaving India without Trial Court permission stands.

Ratio / Principle

Considering the hardship faced by the Applicant in conducting his business activities, the Trial Court may not insist on the Applicant's personal appearance at the time of seeking permission to travel abroad.

Key takeaways

The Trial Court is requested to decide any application made by the Applicant (for permission to travel abroad) within a period of seven days from the date it is first listed before the Trial Court.ratio¶5

Detailed headnote1 paragraphs

Bombay High Court (Dr. Neela Gokhale, J.), Criminal Application No. 406 of 2025 - Karan Jitendra Virwani v. The State of Maharashtra (with an organisational complainant as Intervenor; decision dated 26th February 2026). The Applicant sought modification of condition (iv) of his bail order dated 15th January 2026 (modified by order dated 18th July 2025), which barred him from leaving India without permission of the Trial Court. Counsel argued the Applicant, a businessman required to travel frequently, was frustrated by delays in travel-permission approvals, and that charges were not yet framed; the State and the Intervenor resisted, deeming the condition imperative to secure attendance before the Trial Court. The court declined to relax the condition, but, acknowledging business hardship, held that the Trial Court may not insist on the Applicant's personal appearance at the time of seeking permission to travel abroad, and requested the Trial Court to decide any such application within seven days of first listing. The Interim Application was partly allowed and disposed of; the rest of the bail order remains unchanged.

918-APPLN-406-2025.DOC

Ajit Pathrikar

IN THE HIGH COURT OF JUDICATURE AT BOMBAY CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPLICATION NO. 406 OF 2025

Karan Jitendra Virwani ...Applicant Versus The State Of Maharashtra ...Respondent

Mr. Satish Maneshinde, Senior Advocate a/w Namita Maneshinde, Yuvraj, for the Applicant.

Ms. Gauri S. Rao , APP for the State-Respondent.

Mr. Pranav Badheka, Senior Advocate a/w Pradeep Mane and Nayan Mahar i/b Desai and Diwanji, for the Intervenor/Org. Complainant.

PI – Anita Varade , EOW, Mumbai, is present.

CORAM DR. NEELA GOKHALE, J. DATED: 26^th FEBRUARY 2026

PC:-

1. The Applicant seeks modification of condition (iv) of the

bail order dated 15^th January 2026, which was modified by the order dated 18^th July 2025, to the extent that the Applicant is not permitted to leave India without permission of the Trial Court.

2. Heard Mr. Satish Maneshinde, learned senior counsel for

the Applicant and Ms. Gauri Rao, learned APP and Mr. Pranav

Badheka, learned senior counsel for the Intervenor.

Page 1 of 3 26^th February 2026

918-APPLN-406-2025.DOC

3. Mr. Maneshinde submits that the Applicant is a businessman and is required to travel frequently outside India. He further submits that every time the Applicant makes an application for prior permission to travel, the purpose of the application is rendered infructuous because of the time taken in deciding the same. He also submits that the charges are not yet framed.

4. Mr. Badheka strenuously resists the Application. Ms. Rao submits that the original order granting bail is already modified to a large extent and this condition is imperative to secure the Applicant’s attendance before the Trial Court.

5. For the reasons mentioned in the Application and on consideration of the contentions advanced by the learned counsel appearing for the respective parties, I am not inclined to relax the said condition. However, considering the hardship faced by the Applicant in conducting his business activities, the Trial Court may not insist on the personal appearance of the Applicant at the time of seeking permission to travel

Page 2 of 3

26^th February 2026

918-APPLN-406-2025.DOC

abroad. The Trial Court is requested to decide an application if any made by the Applicant, within a period of seven days

from the date it is first listed before the Trial Court.

6. Rest of the order remains as it is.

7. The Interim Application is partly allowed and disposed of in the aforesaid terms.

(Dr. Neela Gokhale, J)

Page 3 of 3

26^th February 2026