Santosh Madhukar Manjare vs State of Maharashtra — Murder and Culpable Homicide | Bombay HC (2026)

Santosh Madhukar Manjare vs State of Maharashtra — Murder and Culpable Homicide | Bombay HC (2026)

What the court decided

AI extract

Outcome

Regular bail granted in C.R. No. 578 of 2021 (Chakan Police Station, Pune) on execution of a P.R. Bond of Rs. 30,000/- with one or two sureties in the like amount, subject to conditions that the applicant shall attend the concerned police station as and when required, and shall not tamper with the evidence or attempt to influence or contact the complainant, witnesses or any person concerned with the case.

Issue for consideration

Whether the Applicant — in custody for almost five years as an accused in C.R.No. 578 of 2021 (Chakan Police Station, Pune) for murder, attempt to murder, conspiracy and allied IPC offences together with Indian Arms Act, Criminal Law Amendment Act and MCOCA provisions — should be enlarged on regular bail, notwithstanding the prosecution's allegations that he actively conspired in the killing and, if released, might abscond or threaten prosecution witnesses.

Court's answer

The court observed that the allegations against the applicant are of conspiracy and that evidence would be required to prove them, taking this evidentiary burden into account in assessing bail.

Ratio / Principle

The applicant's almost five years in custody and the fact that a co-accused having similar allegations had already been released on bail were treated as grounds favouring his enlargement on bail.

Key takeaways

The court ordered that the applicant be enlarged on bail in C.R.No. 578 of 2021 registered with Chakan Police Station, Pune, on executing a P.R.Bond of Rs. 30,000/- with one or two sureties in the like amount.ratio¶19
The court clarified that its observations were made only for the purpose of granting bail and that the Trial Court is to decide the case on its own merits in accordance with law.ratio¶26

Detailed headnote1 paragraphs

Bombay High Court, Criminal Appellate Jurisdiction (Shivkumar Dige, J.) — Bail Application No. 3886 of 2025, decided 08-04-2026. REGULAR BAIL GRANTED. Santosh Madhukar Manjare, applicant in C.R. No. 578 of 2021 (Chakan P.S., Pune), charged under Ss. 302, 307, 120-B, 201, 216, 143, 147, 148, 149 IPC, S. 4(25) and S. 27 Indian Arms Act, Ss. 37(1)(3) and 135 Criminal Law Amendment Act, and Ss. 3(1)(i)(ii) and 3(4) Maharashtra Control of Organized Crime Act, 1999. Prosecution case: co-accused murdered the deceased on 14.05.2021 over an old dispute and the applicant was one of the main conspirators; APP urged risk of absconding and witness intimidation. Defence contentions: applicant's name absent from the FIR, he was not present at the incident spot, Accused Nos. 10 and 12 already enlarged on bail, and custody approaching five years with the trial likely to take time. Court's grounds for grant: conspiracy allegations would require evidence to prove; applicant behind bars for almost five years; co-accused with similar allegations already released on bail. Order: release on P.R. Bond of Rs. 30,000/- with one or two sureties of the like amount; attendance at the concerned police station as and when required; no tampering with evidence or influencing/contacting complainant or witnesses. Observations expressly confined to the purpose of granting bail; Trial Court to decide the case independently on its own merits.

11-BA-3886-2025 (CR).doc

S.S.Kilaje

IN THE HIGH COURT OF JUDICATURE AT BOMBAY CRIMINAL APPELLATE JURISDICTION BAIL APPLICATION NO. 3886 OF 2025

Santosh Madhukar Manjare … Applicant Versus The State of Maharashtra … Respondent

Digitally signed SONALI by SONALISATISH KILAJE SATISH Date:2026.04.10 KILAJE 11:13:15+0700

_________________________________________________________________ Mr. Vaibhav Kulkarni, Advocate for the Applicant. Mr. S.R.Agarkar, APP for the Respondent-State.

PSI – Pinjari S.N., South Mahalunge Police Station, Pimpri Chinchwad, present.

_________________________________________________________________ CORAM : SHIVKUMAR DIGE, J. DATE : 8^th APRIL, 2026.

P.C. :

By this application, the Applicant is seeking regular bail in C.R.No. 578 of 2021 registered with Chakan Police Station, Pune, for the offences punishable under Sections 302, 307, 120-B, 201, 216, 143, 147, 148, 149 of Indian Penal Code, 1860 (for short “IPC”), Section 4(25) and 27 of Indian Arms Act, Sections 37(1)(3) and 135 of Criminal Law Amendment Act and Sections 3(1)(i)(ii), 3(4) of Maharashtra Control of Organized Crime Act, 1999.

It is prosecution’s case that on 14.05.2021, co-accused murdered the deceased on the ground of old dispute. It is alleged that the applicant was one of the main conspirators of the present crime.

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11-BA-3886-2025 (CR).doc

S.S.Kilaje

It is contention of learned counsel for the applicant that applicant’s name is not mentioned in FIR. Accused Nos. 10 and 12 have been enlarged on bail. The applicant is behind bars for almost five years. The applicant was not present at the incident spot. It may take time to conclude the trial. Hence, requested to allow the application.

It is contention of learned APP that the applicant conspired with the co-accused to kill the deceased on the ground of old dispute. Accordingly, deceased was murdered by the co-accused. The applicant was actually involved in the commission of crime. If the applicant is released on bail, he may abscond or threaten prosecution witnesses. Hence, requested to reject the application.

I have heard both the learned counsel. Perused chargesheet and documents produced on record. The allegations against the applicant are of conspiracy. To prove it, evidence required. The applicant is behind bars for almost five years. The co-accused having similar allegations has been released on bail. Considering these facts, I pass following order.

ORDER

i. The applicant be enlarged on bail inC.R.No. 578 of 2021 registered with Chakan Police Station, Pune, on executing P.R.Bond of Rs. 30,000/- on furnishing one or two sureties in the like amount.

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11-BA-3886-2025 (CR).doc

S.S.Kilaje

ii. The applicant shall attend the concerned police station as and when required.

iii. The applicant shall not tamper with the evidence or attempt to influence or contact the complainant, witnesses or any person concerned with the case.

The application is allowed in the aforesaid terms and is accordingly disposed of. All pending applications, if any, disposed of.

It is made clear that the above observations are made only for the purpose of granting bail and the Trial Court shall decide the case on its own merits in accordance with law and uninfluenced by the observations made in this order.

All concerned to act on the authenticated copy of this order.

(SHIVKUMAR DIGE, J.)

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