Regular bail after completed investigation was upheld where custody was no longer needed and tampering risk was not shown.

Regular bail was held to be justified after completion of investigation and filing of the challan because continued custody required a concrete necessity. The court found no material showing that the petitioner would abscond or misuse liberty, and the fact that bail had already been granted in a connected matter weighed against further detention. The apprehension of tampering with evidence was rejected because the petitioner no longer had access to the bank records and documents forming the core evidence. Prolonged pre-trial custody cannot be treated as punishment once investigation is substantially complete.

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Issues: Whether the petitioner was entitled to regular bail in view of completion of investigation and filing of the challan; whether further custody was necessary having regard to the risk of absconding or tampering with evidence.

Analysis: The allegations related to fraudulent withdrawal of bank funds and forgery, but the investigation had substantially progressed and the challan had already been filed. The petitioner had earlier been granted bail in a connected matter and there was nothing to show misuse of liberty or any attempt to flee from justice. The petitioner was no longer in a position to access the bank records and documents that formed the core evidence, so the apprehension of tampering with evidence was not made out. In bail matters, continued detention after completion of investigation must be justified by concrete necessity, and prolonged pre-trial custody cannot be used as punishment.

Conclusion: The petitioner was held entitled to regular bail.

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