Charge-sheet filing can justify fresh bail consideration on merits after investigation is complete.

Filing of the charge-sheet constitutes a substantial change of circumstance in a bail matter because investigation is complete, the accused becomes entitled to the prosecution papers, and the court's focus shifts to the merits of continued custody. An earlier refusal of bail does not prevent a later application from being examined afresh where the case has progressed to that stage. A post-charge-sheet bail plea therefore cannot be rejected only for want of a further change; it must be considered on the available material after hearing the accused on the charge-sheet documents.

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Issues: Whether filing of the charge-sheet constituted a substantial change of circumstance so as to require fresh consideration of the bail application on merits and permit reliance on the documents supplied with the charge-sheet.

Analysis: An earlier rejection of bail does not bar a later application where there are further developments or different considerations. Filing of the charge-sheet alters the stage of the case because investigation is complete, the accused becomes entitled to the prosecution papers under Section 207 of the Code of Criminal Procedure, 1973, and the Court's focus shifts from the impact of release on investigation to the merits of continued custody. A post-charge-sheet application therefore cannot be rejected merely on the ground that no substantial change has occurred; it must be examined afresh on the available material.

Conclusion: Filing of the charge-sheet is a substantial change of circumstance for considering a fresh bail application, and the application had to be decided on merits after hearing the accused on the charge-sheet material.

Ratio Decidendi: A bail application filed after the charge-sheet must be considered afresh on merits, because completion of investigation and supply of papers under Section 207 of the Code of Criminal Procedure, 1973 constitute a substantial change of circumstance.

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