The arson case relates to an attack on a church in Jabalpur in September last year. Kulkarni is one of the accused.
The judge ordered the police to produce Kulkarni on Wednesday, and also on February 12 at Mumbai's Arthur Road Jail for appearing in a Special Maharashtra Control of Organised Crime Act Court in the blast case, which is being probed by the Maharashtra Anti-Terrorism Squad.
Earlier, Kulkarni's advocates Deepak Panjwani and Narendra Nikhare alleged that police forced their client to give false statements and the same were recorded on mobile phones.
The police also forced him to sign on blank papers, they alleged. Taking cognisance of the allegations, the court issued a notice to the Cantonment police station in-charge, seeking a reply on the issue.