The Bombay High Court on February 9, 2026, granted bail to Akashdeep Karaj Singh, an accused in the murder case of former Maharashtra minister Ziauddin Abdul Rahim Siddiqui alias Baba Siddiqui, holding that the material placed by the prosecution did not disclose reasonable grounds to believe that the accusations against him under the Maharashtra Control of Organised Crime Act were prima facie true.
Case Details
- Case Title: Akashdeep Karaj Singh v. State of Maharashtra
- Court: High Court of Judicature at Bombay
- Jurisdiction: Criminal Appellate Jurisdiction
- Bench: Justice Dr. Neela Gokhale
- Case Number: Bail Application No. 3679 of 2025
- Date Reserved: February 3, 2026
- Date Pronounced: February 9, 2026
- Citation: 2026:BHC-AS:6589
Background of the Case
The bail application arose from C.R. No. 589 of 2024 registered at Nirmalnagar Police Station, Brihanmumbai City, in connection with the fatal shooting of Baba Siddiqui on October 12, 2024.
Siddiqui, a former minister of the State of Maharashtra, was under police protection when he was shot near his son’s office at Khernagar, Bandra (East), Mumbai. He later succumbed to gunshot injuries, while several others at the spot were also injured.
Two alleged shooters were apprehended at the scene and arrested the following day.
Subsequent investigation led the police to invoke provisions of the Bharatiya Nyaya Sanhita, the Arms Act, the Maharashtra Police Act, and later, the Maharashtra Control of Organised Crime Act, 1999 (MCOCA), on the allegation that the offence was committed by an organised crime syndicate allegedly headed by Anmol Bishnoi.
The present applicant, Akashdeep Karaj Singh, was arrested as Accused No. 24 after the investigation claimed the involvement of 27 persons in the conspiracy.
His earlier bail application had been rejected by the Special MCOCA Court on July 19, 2025.
Prosecution Allegations Against the Applicant
According to the prosecution, Singh was an active member of the organised crime syndicate run by the Bishnoi brothers.
The case against him primarily rested on alleged call data analysis showing that he made two phone calls on October 7, 2024 to a co-accused, Sujit Singh (Accused No. 15), using the internet hotspot of another person in his village in Punjab.
The State also alleged that the applicant had made international calls to coordinate with syndicate members abroad, possessed photographs with firearms on his mobile phone, and had deposited money in an ATM in Punjab that was later credited to the account of an associate of a co-accused in Mumbai.
The prosecution argued that releasing the applicant on bail would impede further investigation, particularly as the alleged gang leader had recently been extradited and was yet to be interrogated in the case.
Defence Submissions
The defence contended that the applicant had been falsely implicated and that there was no incriminating material connecting him to the murder or to the organised crime syndicate.
It was argued that the applicant was not named in the FIR, nor in any confessional statements recorded by other accused.
The defence highlighted that the alleged international calls were made to relatives in Canada and that the prosecution had failed to identify the recipients of such calls.
It was further submitted that Singh had no criminal antecedents and that mere phone contact with a co-accused, without evidence of knowledge or participation in organised crime, could not justify continued incarceration under MCOCA.
Court’s Analysis of MCOCA Bail Bar
Justice Dr. Neela Gokhale examined the stringent bail conditions under Section 21(4) of MCOCA, which require the court to be satisfied that there are reasonable grounds for believing that the accused is not guilty of the offence and that he is not likely to commit any offence while on bail.
The court noted that the entire prosecution case against the applicant hinged on two phone calls allegedly made to Accused No. 15. While call data extraction showed that such calls were made, the court observed that
“merely putting through a call to the mobile phone of A-15 prima facie does not connect the Applicant with the organised crime syndicate, unless it is demonstrated that the Applicant had knowledge of A-15 being engaged in assisting in any manner, an organised crime syndicate.”
On the allegation of international calls, the court found that the prosecution had failed to identify the recipients or produce material linking such calls to members of the crime syndicate.
It held that “a bare allegation unsupported by any material” could not establish complicity under MCOCA.
Confessional Statements and Other Material
The court undertook a detailed examination of the confessional statements of Accused Nos. 5 and 15, which extensively described the planning, recruitment, and execution of the crime.
Significantly, neither confession mentioned the applicant or attributed any role to him in the conspiracy or the murder.
On the recovery of photographs showing the applicant holding a firearm, the court held that this did not advance the prosecution’s case, particularly when there was no material linking the weapon to the offence and when the prosecution itself claimed that the firearms used in the murder were procured from Rajasthan.
The allegation regarding the deposit of money in an ATM in Punjab was also rejected, with the court noting the absence of any affidavit or documentary material establishing that the applicant had made such a deposit or that it constituted financial assistance to the syndicate.
Reliance on Supreme Court Precedents
The High Court relied on settled principles laid down by the Supreme Court on bail under special statutes, including the interpretation of Section 21(4) of MCOCA.
The court reiterated that while the threshold under MCOCA is higher than under ordinary criminal law, the provision does not require a positive finding of innocence at the bail stage.
The court emphasised that its duty at this stage was to assess broad probabilities and determine whether the material collected could reasonably justify a conviction, while making it clear that any findings were only prima facie and would not prejudice the trial.
Grant of Bail and Conditions Imposed
Considering that the applicant was 22 years old, had no criminal antecedents, and that his alleged connection with the co-accused was limited to phone calls, the court held that it was unlikely he would commit an offence if released on bail.
It concluded that the embargo under Section 21(4) of MCOCA would not apply in his case.
The court accordingly granted bail, directing the applicant to execute a personal recognisance bond of ₹1 lakh with local sureties.
Strict conditions were imposed, including regular attendance before the trial court, periodic reporting to the DCB/CID, surrender of passport, restrictions on travel, and a prohibition on contacting or influencing witnesses.
Any breach of conditions would entail cancellation of bail.
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