Revision becomes infructuous after compliance with bail deposit condition, leaving the pending appeal to proceed independently.

Compliance with the 20% deposit condition imposed while suspending sentence in the pending appeal removed the live controversy over the earlier refusal of bail. As the petitioner had already been enlarged on bail on that basis and the criminal appeal remained pending, the revision no longer required adjudication on merits. The Gujarat High Court therefore treated the revision application as infructuous and disposed of it, leaving the pending appeal to be decided independently.

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Issues: Whether the revision application challenging refusal of bail could survive after the petitioner complied with the deposit condition imposed in the appeal proceedings.

Analysis: The condition for deposit of 20% of the compensation amount, imposed while suspending the sentence in the pending appeal, was subsequently complied with by depositing the balance amount. The petitioner had already been enlarged on bail on that basis, and the main criminal appeal was still pending. In these circumstances, nothing further remained for adjudication in the revision, and the challenge to the earlier order refusing bail no longer required consideration on merits.

Conclusion: The revision application was held to have become infructuous and was disposed of accordingly.

Final Conclusion: The proceeding was terminated without further adjudication, leaving the pending criminal appeal to be decided independently.

Ratio Decidendi: Where the condition underlying the interim controversy is fully complied with during pendency and no further live issue survives, the proceeding becomes infructuous and is liable to be disposed of.

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