Successive bail application requires a substantial change in circumstances when GST investigation remains ongoing.

A successive regular bail application was refused because no substantial change in circumstances was shown after the earlier rejection. The Court noted that the GST investigation was still in progress, scrutiny of beneficiary firms was continuing, and recovery proceedings had not concluded. On that basis, release at that stage was considered capable of prejudicing the investigation, so the renewed bail request failed.

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Issues: Whether a successive application for regular bail could be granted in the absence of any substantial change in circumstances, where investigation in a GST offence was still in progress.

Analysis: The application was a second request for regular bail after rejection of the earlier bail plea. The material placed before the Court did not disclose any substantial change after the earlier refusal. The investigation had not concluded, scrutiny of beneficiary firms was continuing, and recovery proceedings were still underway. In these circumstances, release at that stage was considered capable of interfering with the investigation.

Conclusion: Bail was not granted.

Final Conclusion: The successive bail request failed because the applicant did not establish any new circumstance justifying reconsideration, and the pending investigation weighed against release.

Ratio Decidendi: A successive bail application is not maintainable on the same material unless a substantial change in circumstances is shown, especially where release may prejudice an ongoing investigation.

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