“Human Life Is Not Less Important”: Bombay High Court Denies Anticipatory Bail To MD, Directors In Nagpur Factory Blast Case

The Bombay High Court on Monday (April 27) refused to grant anticipatory bail to the Managing Director, CEO and three Directors of the SBL Energy Limited, who apprehend arrest in connection with the First Information Report (FIR) lodged against them by the Nagpur Police after a massive explosion took place in the explosives manufacturing factory, killing 17 workers.

SBL Energy Limited, is a company specialised in manufacturing mining and industrial explosives. An explosion took place in its factory situated in Katol, Nagpur on March 1, 2026, in which 23 persons sustained injuries.

Single-judge Justice Rajnish Vyas denied anticipatory bail to - Sanjay Choudhari (Managing Director), Alok Choudhari (CEO/Director), Kedar Pachaputre Dy. Manager (Safety) and Directors - Alok Awadhiya and Shrawan Kumar.

The judge rejected the contention of the company that it was suffering from loses post the blast and also due to the investigations.

"The law prohibited handling hazardous substances without proper precautions and care. Thus, the manner in which the workers were given work who had absolutely no training shows they were exposed to danger. Just because the Company has also suffered losses does not mean human life is less important than anything else," Justice Vyas held.

In his 42-page order, Justice Vyas, further said, "The applicants were the Managing Director, Directors and Employees of a company that handled hazardous substances, and the blast occurred at the final stage, i.e. packaging. The non-appointment of safety officers and the non-removal of deficiencies would be enough to deny the applicants anticipatory bail. In hazardous industries, persistent statutory non-compliance, even after prior notice, transforms omission into culpable conduct, attracting criminal liability beyond mere negligence. Liability is not vicarious but arises from prima facie knowledge, statutory duty, and continued omission."

The judge noted that a similar blast had taken place in the very premises in the first half of 2024, injuring two workers. It noted that an FIR was lodged in that incident also and post that June 21, 2024 a notice was issued by the Directorate of Industrial Safety and Health (DISH) as well as the Petroleum and Explosives Safety Organisation (PESO) both of which highlighted the safety lapses on part of the company.

"All the accused persons named in the FIR, ignoring the directions given by the DISH and PESO did not comply with the same and though they had knowledge that due to non-compliance, a human life could be lost, the work in the company was allowed to be continued. It is considered that earlier also, the incident had taken place in which two workers were injured, and the FIR was registered, then it would reveal that the earlier FIR, though lodged against the Supervisor of the factory, was not seriously taken into consideration by the Managing Director, Directors and Safety Officers. Further, the communication issued by DISH, which pointed out several serious deficiencies, was also not addressed with the seriousness it deserved. The fact remains that the statements of the workers who worked in the Unit shows that they were never given any training to handle hazardous goods/substances," Justice Vyas noted.

These applicants turned a blind eye to the deficiencies, the judge underlined, while refusing the contention of the applicants that there were not aware of the DISH report and recommendations to rectify the deficiencies. He said whether the report was apprised to the applicants or not would be a matter of investigation.

"The applicant's contention that the incident didn't happen in their presence and they are not responsible overlooks the fact that when culpable homicide not amounting to murder is committed, the accused doesn't necessarily have to be present at the scene," the judge said.

With these observations, Justice Vyas denied pre-arrest bail to five Directors etc. However, the judge allowed the pre-arrest bail pleas filed by Satyavati Parashar, Ravindra Pokhara and Manoj Prasad - who were the Independent non-executive Directors on the ground that they were not responsible for the 'day-to-day' affairs of the company and also the fact that Satyavati was suffering from III Stage Cancer.

Appearance:

Senior Advocates Mahesh Jethmalani and Pranav Badheka assisted by Advcoates Aditya Chaudhari, Prafull Kumar and Amol Mardikar appeared for the 5 Directors.

Advocates Ravi Sharma, Aditya Chaudhari, Prafull Kumar and Anjali represented the Independent Directors.

Additional Public Prosecutor AM Ghogare represented the State.

Case Title: Sanjay Choudhari vs State of Maharashtra [Criminal Application (ABA) 275 of 2026]

Citation: 2026 LiveLaw (Bom) 216

Click Here To Read/Download Judgment