Anticipatory bail refused where forgery allegations required custodial interrogation to verify disputed documents and assess the accused's role.

Anticipatory bail under Section 438 CrPC was refused because the allegations involved forgery, alterations in documents and false representations before public authorities, and custodial interrogation was considered necessary to recover and verify the disputed documents and determine the appellant's role in the alleged fabrication. The prior refusal of anticipatory bail was therefore held justified in the circumstances, and the appeal was dismissed.

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Issues: Whether the appellant was entitled to anticipatory bail under Section 438 of the Code of Criminal Procedure, 1973.

Analysis: The materials showed allegations of forgery, alterations in documents, and false representations before public authorities. The need to recover and verify the disputed documents and to ascertain the role of the appellant in the alleged fabrication made custodial interrogation necessary. The prior refusal of anticipatory bail by the courts below was found to be justified in the circumstances.

Conclusion: Anticipatory bail was not granted and the appeal was dismissed.

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