Anticipatory bail refused where cheating and forgery allegations, non-cooperation, and custodial interrogation needs justified denial.

Anticipatory bail under Section 438 CrPC was declined where allegations of cheating and forgery disclosed prima facie participation in a racket involving forged property documents and receipt of money. The applicant was named by the complainant and public witnesses, appeared in video footage counting money, and had not joined or cooperated with the investigation. In view of the non-cooperation, issuance of non-bailable warrants and proceedings under Section 82 CrPC, the Court treated custodial interrogation as necessary and held that anticipatory bail could not be granted as a matter of course. The request was rejected.

---

---

Issues: Whether the applicant was entitled to anticipatory bail under Section 438 of the Code of Criminal Procedure, 1973 in view of the allegations of cheating and forgery, the need for custodial interrogation, and the applicant's non-cooperation with the investigation.

Analysis: The allegations disclosed prima facie participation in a cheating and forgery racket involving forged property documents and receipt of money from the complainant. The applicant was specifically named by the complainant and public witnesses, was shown in video footage counting money, and had not joined or cooperated in the investigation, resulting in issuance of non-bailable warrants and initiation of proceedings under Section 82 of the Code of Criminal Procedure, 1973. In these circumstances, the Court found that custodial interrogation was still required and that anticipatory bail could not be granted as a matter of course.

Conclusion: The applicant was not entitled to anticipatory bail and the request was rejected.

---