Pre-trial detention and documentary evidence justified bail under the CGST Act after completion of investigation.

Bail was granted to a person arrested for alleged offences under the CGST Act because the investigation had been completed, the custody period was long, and the case substantially depended on documentary evidence. The Court treated further pre-trial detention as serving no useful purpose, noting the petitioner's age and permanent residence as supporting factors. Bail was therefore allowed under Section 439 CrPC on terms and conditions, with liberty to cancel it if any condition was breached.

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Issues: Whether the petitioner, arrested in connection with an offence under Section 132(1)(b)(c)(f)(i) of the Central Goods and Services Tax Act, 2017, was entitled to bail under Section 439 of the Code of Criminal Procedure, 1973.

Analysis: The petitioner had undergone a long period of custody, the investigation had been completed, the alleged offence carried the prescribed punishment, the petitioner was stated to be a permanent resident of Rourkela and aged about 71 years, and the case substantially rested on documentary evidence. In these circumstances, further detention was found to serve no useful purpose.

Conclusion: Bail was granted to the petitioner on terms and conditions imposed by the Court, with liberty to cancel bail upon violation of any condition.

Ratio Decidendi: When investigation is complete and the case mainly rests on documentary evidence, prolonged custody may not be justified for the purpose of pre-trial detention, and bail can be granted on appropriate conditions.

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