Anticipatory bail in GST investigation granted where cooperation, secured evidence, and no flight risk made custodial interrogation unnecessary.

Anticipatory bail may be granted in a GST investigation where the accused has cooperated, joined the investigation on multiple occasions, and the relevant material is already secured by the department. Because the documents were in departmental custody, the premises had been searched, bank accounts were frozen, and there was no material showing antecedents, flight risk, or likelihood of tampering with evidence, custodial interrogation was not shown to be necessary. Protection of personal liberty therefore favoured bail, and anticipatory bail was granted.

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Issues: Whether the petitioners were entitled to anticipatory bail in connection with the GST investigation.

Analysis: The petitioners had joined the investigation on multiple occasions, their statements had been recorded, the premises had been searched, the relevant documents were already in the custody of the department, and the bank accounts had been frozen. There was no material showing prior criminal antecedents, likelihood of absconding, or any risk of inducement, threat, or tampering with evidence. In these circumstances, custodial interrogation was not shown to be necessary, and the protection of personal liberty weighed in favour of bail.

Conclusion: The petitioners were entitled to anticipatory bail.

Ratio Decidendi: Anticipatory bail may be granted where the accused has cooperated in the investigation, the material evidence is already secured with the department, and no credible basis exists to show flight risk, tampering with evidence, or the necessity of custodial interrogation.

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