Successive bail applications need changed circumstances; absent fresh grounds, a fourth bail plea was dismissed as not entertainable.

Successive bail applications require a material change in circumstances before the same request can be reconsidered. In a bail matter under Section 439 CrPC arising from alleged offences under the CGST Act, the earlier third bail application had already been rejected on merits, and no fresh circumstance was shown apart from continued custody. On that basis, the fourth bail application was treated as not entertainable and was dismissed. The note applies the principle that mere passage of time or custody period, without a new factual basis, does not justify re-agitation of a rejected bail plea.

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Issues: Whether the fourth bail application deserved to be entertained in the absence of any change in circumstances after rejection of the earlier bail application.

Analysis: The petitioner sought bail under Section 439 of the Code of Criminal Procedure, 1973 in a case registered for offences under the Central Goods and Services Tax Act, 2017. The earlier third bail application had already been rejected on merits. Apart from the period of custody, no fresh circumstance was shown to justify reconsideration of the matter. In successive bail proceedings, absence of a material change in circumstances weighs against re-agitation of the same request.

Conclusion: The fourth bail application was not entertainable and was dismissed.

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