Advocate Devkrishna Bhambri, convener of the Gen-Z Lawyers Association, has filed a detailed complaint with the Chief Justice of the Bombay High Court, demanding serious action against Special Judge Chakor S. Baviskar, who granted bail to former police officer Sachin Vaze, accused in the Antilia-Mansukh Hiren case.
The complaint alleges that the September 29, 2026, order granting Sachin Vaze bail contradicts binding decisions of the Supreme Court and the Bombay High Court, as well as the findings recorded by the same judge shortly before.
The most serious ground of the complaint is the contradictory findings recorded by the same judge within a span of just two and a half months.
On July 15, 2026, while rejecting Sachin Vaze’s discharge application, the judge cited numerous witness statements, mobile contact details, CDRs, tower locations, CCTV footage, and other electronic and forensic material, stating that there was “huge evidence” on record.
Most importantly, in paragraph 20 of the same order, the judge had clearly stated—
“I do not have any hesitation or even the slightest doubt that more than sufficient material exists on record to frame the charge…”
This means that the judge did not have “the slightest doubt” about the existence of sufficient material to frame charges; rather, in his opinion, there was “more than sufficient material” on record.
Subsequently, on August 1, 2026, the same judge framed charges against Sachin Vaze.
But in paragraph 49 of the September 29 bail order, the same judge took a completely opposite stance, stating that there was no direct evidence against Sachin Vaze; the charges were framed to at least give the prosecution an opportunity to prove its case, and otherwise the case could have been closed “at the threshold.”
This comment is in stark contrast to the same judge’s clear conclusion of “huge evidence” and “more than sufficient material” on July 15. According to the complaint, the law does not permit a judge to adopt such contradictory positions; rather, such conduct is an offense under Sections 256 and 257 of the IPC, which carry a punishment of three to seven years for the offenses.
The question is profound and straightforward—what has changed in just two and a half months? On July 15th, the same judge saw “huge evidence,” “more than sufficient material,” and had “not even the slightest doubt” about the adequacy of the evidence. How did the case weaken so much by September 29th that the judge had to declare that the case could otherwise be “shut at the threshold”?
This question becomes even more serious because on August 1st, the same judge had framed charges against Sachin Vaze. After framing charges, the trial court would not have been in a position to go back on its initial order and discharge the accused in this manner.
Another serious fact has been raised in the complaint. Sachin Vaze had previously approached the Bombay High Court seeking several reliefs, including quashing of the charge and cognizance of the offence. The High Court had dismissed that petition.
Recording this fact in his July 15 order, the Special Judge himself stated, ”
“certainly this Court cannot at all grant those reliefs to him.”
Not only this, he also stated that the outcome of Vaze’s discharge petition could not have been anything other than dismissal.
In such a situation, the completely opposite approach adopted by the same judge in the subsequent bail order is a matter of serious investigation.
In paragraph 6 of the bail order, the judge himself recorded that both the accused’s lawyer and the NIA’s Special Public Prosecutor had relied on various High Court and Supreme Court judgments.
The judge himself wrote—
“I always feel honored to be happily abided by each and every precedent…”
But the complaint alleges that the entire 33-page order does not discuss the key decisions given by the NIA, their ratio, and the reasons for their application or setting aside.
The complaint raises another serious question regarding the 33-page order granting bail to Sachin Vaze—when the NIA placed before the court important binding decisions of the Supreme Court and the High Court, where is the consideration of those decisions, their ratio, and their applicability to the present case in the final bail order?
In paragraph 6 of the bail order, the judge himself recorded that both the accused’s lawyer and the NIA’s Special Public Prosecutor had relied on various decisions of the High Court and the Supreme Court. Moreover, the judge himself wrote—
“I always feel honored to be happily abided by each and every precedent…”
But the complaint alleges that despite this clear declaration, the entire 33-page order lacks any effective discussion of the proportion of important and binding precedents presented by the NIA. The order also fails to explain why the precedents cited by the prosecution are inapplicable to the present case, on what facts they were distinguishable, or what the legal basis was for not accepting them.
The complaint contends that this is not simply a case of a citation being omitted. When a binding precedent is specifically brought to the court’s attention by a party, the court cannot simply ignore it. It is essential to consider its applicable proportions, and if it is inapplicable, to provide the legal justification for it.
Recording reasons is an essential part of judicial discipline. The complaint cites several judgments, including Ratilal Jhaverbhai Parmar, Yogesh Waman Athavale, Legrand (India), and Garware Polyester, to support this proposition.
The Bombay High Court’s judgment in Yogesh Waman Athavale v. Vikram Abasaheb Jadhav has been cited as particularly significant on this issue. In that case, the High Court observed that the relevant order was silent on the cited authorities and it was unclear whether those judgments had been considered. The High Court also stated that merely citing judgments is not sufficient; the judicial officer must understand their ratio and clarify whether they apply to the current case. Instructions were even given to monitor the functioning of the concerned judicial officer.
The complaint cited Baradakant Mishra v. Citing Registrar of Orissa High Court, (1973) 1 SCC 374, the Supreme Court held that deliberate non-compliance with a prior High Court judgment was conduct that created confusion in the administration of justice and undermined the High Court’s constitutional authority. The Supreme Court clarified that deliberate and mala fide disregard of binding law could fall within the scope of the principles of contempt.
The complaint also cites New Delhi Municipal Council v. Prominent Hotels Limited, stating that judicial discipline is one of the fundamental pillars of the judicial system and that “conscious disregard” of binding judgments placed before the court cannot be dismissed as mere oversight.
The complaint’s allegations are further exaggerated because the matter is not limited to mere silence on the NIA’s precedents. According to the complaint, on the one hand, binding authorities specifically presented by the prosecution were not considered, while on the other hand, materially inconsistent reasoning was adopted in the subsequent bail order from the judge’s earlier clear findings regarding the same accused and the same prosecution material. The complaint cites this cumulative conduct as the basis for seeking contempt, criminal, and disciplinary scrutiny.
The complaint states that the Supreme Court has already laid down particularly stringent principles regarding the granting of bail to police officers accused of serious crimes.
In Prakash Kadam v. Ramprasad Vishwanath Gupta, the Supreme Court made a scathing remark regarding accused police officers—
“Thus, the protectors have become the predators.”
In that case, the order cancelling bail granted to police officers was upheld. Edited complaint against NIA Ju…
Similarly, in State of Jharkhand v. Sandeep Kumar, the Supreme Court held that when the accused is themselves an investigating officer or a police officer and is accused of abuse of office, the same considerations as those applicable to ordinary accused cannot be applied. Even after the officer is suspended and a charge sheet is filed, his ability to influence witnesses and evidence may remain significant.
The complaint cites the 2026 cases of State of Maharashtra v. Rahul Datta Bhosale and Jitendra Singh v. State of U.P. has also been invoked.
According to the complaint, Sachin Vaze is facing prosecution in the Mansukh Hiren murder and alleged cover-up case and is also accused in the Khwaja Yunus case.
Furthermore, the complaint states that a new FIR filed by the CBI on September 13, 2026, also names Vaze in several murders and cover-up cases, including the alleged murder of Disha Salian.
The complaint specifically cites S. Nirki, Principal District Judge, Wardha v. R. A. Khan, Magistrate, Wardha, 1993 Cri LJ 816.
In that case, contempt proceedings were initiated against the judicial officer who granted relief to the accused despite the higher courts having already denied relief to him.
The principle is clear—a subordinate court cannot nullify an order of a higher court through any other means. The complaint argues that the same principle applies to the present case.
There are several other judicial decisions in which judges who act against binding precedents have been held guilty of contempt.
Deliberately disregarding binding judicial precedents and passing judicial orders directly contrary to them is considered corrupt practice, malice in law, fraud on power, judicial adventurism, breach of judicial oath, and gross judicial misconduct.
The established principles of law thus recognize deliberate disobedience of binding law as “the grossest form of judicial dishonesty,” “legal malice,” “fraud on power,” and “fraud on the Constitution.” It may also be considered corruption in the exercise of judicial or quasi-judicial power, even if there is no separate or additional evidence of extraneous consideration, if the judicial order itself and the manner in which the power was exercised provide sufficient material to demonstrate such misconduct.
The law also recognizes that conduct of this nature is a manifestation of incompetence, incapacity, or proven misbehavior on the part of the authority concerned.
This could reflect misconduct and result in stringent constitutional, disciplinary, and, where applicable, punitive action.
An important aspect of this complaint for the common man is that judicial office itself is not a blanket shield from criminal or departmental investigation. However, the mere fact that an order is erroneous does not automatically prove corruption; it requires an examination of the necessary elements and evidence prescribed by law.
In this context, the complaint cites the example of the 2012 Gali Janardhana Reddy cash-for-bail case.
The then CBI Special Judge T. Pattabhi Rama Rao granted bail to Janardhana Reddy. Following allegations of alleged illegal financial transactions in exchange for the bail order, the judge concerned was suspended, arrested by the Anti-Corruption Bureau, and departmental proceedings initiated against him, the complaint states.
Section 257 of the IPC has also been invoked in the complaint. According to the provision cited in the complaint, a public servant who corruptly or maliciously gives an order, decision, or verdict in a judicial proceeding that they know to be contrary to law is punishable with imprisonment up to seven years.
The complaint demands that the Chief Justice examine the September 29th bail order and the entire judicial record related to it; that the written arguments and decisions submitted by the NIA be summoned; that the discharge order of July 15th, the charge-framing order of August 1st, and the September 29th bail order be examined together.
Where did the binding judgments submitted by the NIA go? What happened to the reliefs previously denied by the High Court? What happened to the stringent standards set by the Supreme Court when the accused is a police officer? And the biggest question: how could the same judge reach two diametrically opposed conclusions based on the same record?
The complaint seeking answers to these questions has now reached the Chief Justice of the Bombay High Court. The matter is no longer just about bail for an accused, but also about judicial discipline, accountability, and the common citizen’s faith in the justice system.

