Bail in non-bailable offences depends on prima facie evidence, tampering risk, and trial attendance, especially during further investigation.

Bail in non-bailable offences is assessed on the nature and seriousness of the accusation, the prima facie character of the evidence, the risk of tampering with evidence, and the likelihood of the accused securing presence at trial. Allegations of criminal conspiracy may be established through circumstantial evidence. Where comprehensive further investigation is directed by the CBI, it may be inappropriate to finally determine bail on the material then available. No final opinion was expressed on entitlement to bail, and liberty was left to seek bail afresh after the further investigation.

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Issues: Whether bail should be granted on the material then available in view of the pending investigation and the direction for further investigation by the Central Bureau of Investigation.

Analysis: The Court reviewed the settled principles governing bail in non-bailable offences, including the nature and seriousness of the accusation, the prima facie character of the evidence, the possibility of tampering with evidence, and the likelihood of the accused securing presence at trial. It also noted that allegations of criminal conspiracy may be proved by circumstantial evidence. However, after the order was reserved, the Court was informed of the High Court's direction for comprehensive further investigation by the CBI. In that backdrop, the Court considered it inappropriate to finally determine entitlement to bail at that stage.

Conclusion: No final opinion was expressed on the appellant's entitlement to bail, and the matter was disposed of leaving liberty to seek bail afresh depending on the outcome of the further investigation.

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