Bail cancellation for ignoring prima facie material and passing a perverse, unreasoned order without supervening misconduct.

Cancellation of bail is justified not only by supervening conduct such as tampering with evidence or interference with justice, but also where the bail order itself is seriously infirm. If the granting court ignores relevant prima facie material, relies on irrelevant considerations, or passes a perverse order without adequate reasons, the discretion is vulnerable to cancellation even without post-release misconduct. Here, the court failed to deal with Section 164 statements and other material bearing on the accused's involvement, so the bail order was treated as arbitrary in a heinous crime and was liable to be quashed, with custody to follow.

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Issues: Whether the order granting bail to the accused was liable to be cancelled for ignoring relevant material and for being passed in an arbitrary and legally infirm manner.

Analysis: Cancellation of bail is justified not only when there are supervening circumstances such as tampering with evidence or interference with the due course of justice, but also where the order granting bail suffers from serious infirmity. If the court granting bail ignores material indicating prima facie involvement of the accused, relies on irrelevant considerations, or passes a perverse order without adequate reasons, the order becomes vulnerable to cancellation. In the present case, statements recorded under Section 164 of the Code and other material were relevant to the accused's involvement, yet the bail order did not deal with them in a reasoned manner. The order was therefore treated as an arbitrary exercise of discretion in a heinous crime.

Conclusion: The bail order was liable to be quashed and the accused was required to be taken into custody.

Ratio Decidendi: A bail order can be cancelled where the granting court ignores relevant prima facie material or takes irrelevant considerations into account, resulting in a perverse and unjustifiable exercise of discretion, even in the absence of supervening misconduct after release.

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