Bail cancellation upheld where later grant ignored settled factors and relied only on filing of the charge-sheet.

Cancellation of bail was upheld because the later grant of bail ignored settled bail parameters and relied mainly on filing of the charge-sheet, which by itself does not weaken the prosecution case or amount to a sufficient change in circumstance. The court held that bail cannot be granted mechanically on general notions of liberty or presumption of innocence without considering the nature and gravity of the accusation, supporting evidence, possible influence on witnesses, and the interests of justice. Where earlier bail refusals had been made on the same factual basis, the subsequent order was found unsustainable for relying on irrelevant considerations and omitting relevant material.

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Issues: Whether the order cancelling bail was justified in the facts where the grant of bail was made after earlier bail refusals and without due regard to the governing parameters for bail.

Analysis: The appellants had earlier been denied bail, including by the Supreme Court, and the later grant of bail was made chiefly on the ground that the charge-sheet had been filed. Filing of the charge-sheet, by itself, does not dilute the prosecution case or constitute a sufficient change in circumstance. Bail cannot be granted mechanically by relying on general observations about the presumption of innocence or liberty without applying the settled factors governing bail, such as the nature and gravity of the accusation, the supporting evidence, the possibility of influencing witnesses, and the larger interests of justice. The order granting bail was found to have ignored relevant material and to have proceeded on irrelevant considerations, making it vulnerable to interference.

Conclusion: The cancellation of bail was upheld and the grant of bail was held to be unsustainable.

Ratio Decidendi: An order granting bail is liable to be set aside where the court ignores relevant considerations, relies on irrelevant factors, and grants liberty without proper application of the settled bail parameters, particularly after earlier refusals on the same factual basis.

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