Allowing Agrawal's prayer, Additional District Session Judge K S Patel today ordered the jail authorities to release him on parole till August 31.
According to sources, the former SP had submitted an application to the court to allow him to perform the last rites of his mother-in-law who expired recently in Jaipur.
Agrawal has been lodged in Palanpur sub-jail since 2010, when he was arrested by state crime branch along with other seven police officials in the Tulsiram Prajapati fake encounter case.
His bail application were rejected earlier.
The court has asked him to return by evening on August 31. The former SP had produced the death certificate of his mother-in-law, sources said.
Following the petition filed by Tulsi Prajapati's mother Narmada Bai, Supreme Court had on April 8, 2011 transferred the probe to Central Bureau of Investigation(CBI).
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Narmada Bai had alleged in her petition that her son was killed in a fake encounter by Gujarat police as he was a key eye-witness to the Sohrabuddin Shaikh encounter.
Shaikh was also killed in a fake encounter by Gujarat police and probe of that case was also carried out by CBI.
Prajapati, a close aide of Shaikh, was killed in an encounter near Chhapri village in Banaskantha on December 28, 2006.