Anna Rajaram Bhokare vs the State of Maharashtra — Bombay HC (2026) — LawSathi Research

Anna Rajaram Bhokare vs the State of Maharashtra — Bombay HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Release of the applicant on regular bail in Crime No.10/2026 on furnishing P.B. and S.B. of Rs.50,000/-, subject to conditions: (a) not to tamper with prosecution evidence, (b) to attend each and every effective date before the Trial Court, (c) not to indulge in criminal activity; application disposed of.

Issue for consideration

Whether the applicant, in custody since 15.01.2026 in Crime No.10/2026 of Phulambri Police Station for offences punishable under Sections 108, 85 and 3(5) of the Bhartiya Nyaya Sanhita, 2023, should be granted regular bail after the Sessions Court rejected his earlier bail application on 09.02.2026. +1 more

Court's answer

The applicant had been behind bars for about seven weeks; the court held that further detention would not be necessary and that a case was made out for grant of bail subject to certain conditions.

Ratio / Principle

The allegations in the FIR against the applicant and the in-laws are omnibus and unspecific; nothing shows that soon before her death Sunita was subjected to ill-treatment or mental torture that led her to commit suicide.

Key takeaways

No link between the suicide and the acts of the applicant can be found on the material considered.ratio¶¶20
Invoking the notion of abetment under Section 107 IPC, the court holds that a person can be said to have abetted only when he commits such an act with design and intention to drive the victim to commit such act.ratio¶¶21
On prima facie consideration of the averments in the FIR, it is difficult to make out the offence of abetment to commit suicide under Section 108 of the Bhartiya Nyaya Sanhita against the applicant.ratio

Detailed headnote1 paragraphs

High Court of Judicature at Bombay, Bench at Aurangabad (S. G. Chapalgaonkar, J.), Bail Application No.298 of 2026, decided 06 March 2026: regular bail allowed to Anna s/o Rajaram Bhokare, husband of the deceased Sunita, in Crime No.10/2026 of Phulambri Police Station, Dist. Aurangabad, for offences punishable under Sections 108, 85, 3(5) of the Bhartiya Nyaya Sanhita, 2023. FIR (informant: Gajanan Shivaji Gawali, brother of the deceased) alleged harassment over money demands, including a demand of Rs.2,00,000/- for a JCB machine, an extra-marital relationship of the husband, the deceased leaving the matrimonial house on 13.01.2026 and her body being found in a well on 14.01.2026, the suicide being attributed to abetment by the in-laws; the applicant, arrested on 15.01.2026, had his earlier bail application (Criminal Bail Application No.229/2026) rejected by the Sessions Court on 09.02.2026. The Court found the FIR allegations 'omnibus and unspecific', observed that nothing showed that 'soon before death' Sunita was subjected to ill-treatment or mental torture leading to suicide, that 'no link between suicide and act of applicant can be found', recalled (with reference to Section 107 IPC) that a person abets only where he acts 'with design and intention to drive victim to commit such act', and concluded that on prima facie consideration it was 'difficult to make out offence of abetment to commit suicide under Section 108 of Bhartiya Nyaya Sanhita'. With the applicant about seven weeks in custody, further detention was deemed unnecessary; bail was granted on furnishing P.B. and S.B. of Rs.50,000/- with conditions (no tampering with prosecution evidence; attendance at every effective Trial Court date; no indulgence in criminal activity); the application was disposed of.

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2026:BHC-AUG:10500

IN THE HIGH COURT OF JUDICATURE AT BOMBAY BENCH AT AURANGABAD BAIL APPLICATION NO.298 OF 2026

Anna s/o Rajaram Bhokare Age:- 32 years, Occ. Agri., R/o. Wanegaon, Tq. Phulambrei Tq. & Dist. Aurangabad. ..Applicant

Versus

The State of Maharashtra, Through Phulambri Police Station, Taluka Phulambri District Aurangabad. ..Respondent

Mr. P. P. Giri a/w Mr. S. N. Ghodke, Advocate for Applicant. Ms. R. R. Tandle, APP for Respondent.

CORAM : S. G. CHAPALGAONKAR, J. DATED : 06^th MARCH, 2026

ORDER:-

The applicant seeks regular bail in connection with Crime

No.10/2026 registered with Phulambri Police Station, Dist. Aurangbad for offences punishable under Sections 108, 85, 3(5) of the Bhartiya Nyaya Sanhita, 2023.

The investigation was set in motion on the basis of information given by Gajanan Shivaji Gawali alleging that his sister Sunita married with applicant. After marriage, she was harassed on account of demand of money. She used to tell her

parents about demand and harassment mated to her. Her husband had developed illicit relationship, hence she was mentally depressed. Lastly, accused persons demanded amount of Rs.2,00,000/- for purchase of JCB Machine. On that count, she

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was mentally and physically harassed. On 13.01.2026 his sister left her matrimonial house. On 14.01.2026 her dead body was found in well infront of her house. It is alleged that she committed suicide due to abetment of in-laws.

The applicant/husband was arrested on 15.01.2026. Since then, he is behind bar. He moved before Sessions Court for grant of regular bail vide application below Exhibit-1 in Criminal Bail Application No.229/2026. However, his application came to be rejected vide order dated 09.02.2026. Hence, this Bail Application.

Heard learned Advocates appearing for respective parties.

Perused record tendered into service. Apparently, applicant had married with deceased Sunita about 12 years prior to her death. The allegations in FIR states about ill-treatment mated towards Sunita by her in-laws. The allegations are omnibus and unspecific. There is nothing to show that soon before death of Sunita, she was subjected to ill-treatment or mentally tortured that led her to commit suicide. No link between suicide and act of applicant can be found. Section 107 of Indian Penal Code deal with abetment. The person can be said to have abetted only when

he commits such an act with design and intention to drive victim to commit such act. In present case, on prima facie consideration

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of averments in FIR, it is difficult to make out offence of abetment to commit suicide under Section 108 of Bhartiya Nyaya Sanhita. The applicant is behind bar for about seven weeks. Further detention of applicant would not be necessary. Resultantly, case is made out for grant of bail subject to certain conditions. Hence, the following order:

ORDER

(i) Bail Application is allowed.

(ii) The applicant, Anna s/o Rajaram Bhokare be released on bail in Crime No. 10/2026 registered with Phulambri Police Station, Dist. Aurangbad for offences punishable under Sections 108, 85, 3(5) of the Bhartiya Nyaya Sanhita, 2023 on furnishing P.B. and S.B. of Rs.50,000/- (Rs.Fifty Thousand only) on following condition:

a. The applicant shall not tamper with prosecution evidence in any manner.

b. The applicant shall attend each and every effective date before the Trial Court.

c. The applicant shall not indulge in criminal activity.

(iii) Application is disposed of.

(S. G. CHAPALGAONKAR) JUDGE

Devendra/March-2026