Justice Paresh Upadhyay held that the reason given by Asaram to perform last rites of his nephew is not sufficient enough to grant him temporary bail.
Asaram, 73, had yesterday moved the temporary bail application before the High Court, a day after his plea was rejected by a Gandhinagar court.
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Pagrani's body has been kept in a cold storage at city civil hospital.
The godman's plea said it was Pagrani's last wish that Asaram, who is his maternal uncle, should perform the last rites as his parents had already died.
The case of rape, sexual assault, illegal confinement and other offences was filed against Asaram by a Surat-based girl, who accused him of repeatedly sexually assaulting her between 2001 and 2006 when she was living in his ashram on the outskirts of Ahmedabad.
Her younger sister had lodged a separate complaint against Asaram's son Narayan Sai for alleged rape, sexual assault, illegal confinement and other offences.
Asaram is currently lodged in a Rajasthan jail since his arrest in September 2013 for allegedly sexually assaulting a minor girl at his Jodhpur ashram.
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