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Issues: Whether the applicant was entitled to bail in the second application under Section 439 of the Code of Criminal Procedure, 1973 in view of the alleged absence of change in circumstances and the seriousness of the offence under the Prevention of Money Laundering Act, 2002.
Analysis: The application was a second bail request after an earlier bail application had already been rejected on merits. The Court noted that no material change in circumstances had been shown after the earlier rejection. It also relied on the settled approach that economic offences involving deep-rooted conspiracy and alleged laundering of crime proceeds are grave in nature and require serious consideration. On the record, the Court found no basis to depart from the earlier view, notwithstanding the allegations of long custody and medical condition.
Conclusion: The second bail application was rejected.
Ratio Decidendi: A subsequent bail application will not be allowed in the absence of a material change in circumstances, and allegations of grave economic offences under the Prevention of Money Laundering Act, 2002 justify refusal of bail.