Prior permission for foreign travel under anticipatory bail can be retained absent changed circumstances, despite personal liberty concerns.

A prior-permission condition for overseas travel, imposed while granting anticipatory bail, could not be deleted absent any material change in circumstances. The filing of the charge-sheet and the absence of fresh facts meant the earlier safeguard remained justified, and inconvenience in approaching the court was insufficient to remove it. While the right to travel abroad forms part of personal liberty, the condition could at most be regulated, not eliminated, and requests for permission had to be considered expeditiously. The modification order was therefore unsustainable, and the original condition was restored.

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Issues: Whether the condition requiring prior permission before travelling abroad, imposed while granting anticipatory bail, could be deleted or relaxed in the absence of a material change in circumstances.

Analysis: The charge-sheet had already been filed and no significant alteration in the factual matrix was shown to justify dilution of the earlier bail condition. The right to travel abroad is part of personal liberty, but where a prior permission condition was specifically engrafted while granting anticipatory bail, mere inconvenience in approaching the court was not enough to delete that safeguard altogether. In the absence of fresh material, the condition could at most be regulated, not removed. The trial court was, however, required to consider any request for permission expeditiously.

Conclusion: The modification order was unsustainable. The original condition requiring prior permission before travelling abroad was restored, and the appeal was allowed.

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