The Supreme Court recently dismissed the appeal filed by Gajanan Dattatray Gore and upheld the Bombay High Court’s decision to cancel his bail for failing to deposit ₹25 lakh, as promised in an undertaking. The apex court has issued clear directions to all Trial Courts and High Courts across the country, prohibiting the practice of granting bail based on monetary undertakings.
Case Background
Gajanan Dattatray Gore was arrested on 17 August 2023 in connection with a criminal case registered with Satara City Police Station (C.R. No. 652/2023). He was charged under IPC Sections 406, 408, 420, 467, 468, 471, 504, and 506, for allegedly siphoning ₹1.6 crore from Satara Advertising Company and I-Can Training Institute, where he worked as a business development manager.
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Following rejection of regular bail by the Trial Court, Gore approached the Bombay High Court, which granted bail on 1 April 2024, subject to the condition that he deposit ₹25 lakh within five months and abide by an affidavit-cum-undertaking stating:
“I undertake to deposit ₹25,00,000 (Twenty-Five Lakhs Only) within five months before this Hon’ble Court to show my bona fide.”
Despite securing bail, Gore failed to deposit the promised amount. This prompted the original complainant to file an interim application seeking cancellation of bail. The High Court, after hearing all parties and observing that the bail was granted solely on the strength of the affidavit, cancelled the bail and directed Gore to surrender before the Judicial Magistrate, Satara, by 31 July 2025.
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“The appellant got himself released on bail but failed to deposit the amount of ₹25 lakh as undertaken… Respondent No.1 is attempting to approbate and reprobate.” — High Court
Gore challenged the High Court’s decision, but the Supreme Court found no merit in his appeal. The Court condemned the misuse of judicial process and emphasized the unethical practice of offering monetary undertakings for bail, only to default later.
“This practice has to be stopped. Litigants are taking the courts for a ride and thereby undermining the dignity of the court.” — Supreme Court
The bench, comprising Justices J.B. Pardiwala and R. Mahadevan, dismissed the appeal and imposed a cost of ₹50,000 on the appellant for abuse of process.
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In a significant move, the Court directed all High Courts and Trial Courts:
“No bail order shall henceforth be passed on the basis of any monetary undertaking or statement by the accused. Bail must be granted or denied purely on merits.”
The Registry was also instructed to circulate the ruling to all High Courts.
Case Title: Gajanan Dattatray Gore vs. The State of Maharashtra & Anr.
Judgment Date: 28th July, 2025
Case Type: Criminal Appeal No. 3219/2025
(Arising out of SLP (Crl.) No. 10749/2025)