Regular bail in GST prosecution granted where investigation was complete and continued detention was not justified.

Regular bail may be granted in a prosecution under the Central Goods and Services Tax Act, 2017 where investigation is complete, the complaint has been filed, the accused has already spent a substantial period in custody, and no special circumstance justifies continued detention. The Court applied a prima facie assessment and noted that further incarceration was not warranted in the absence of any concrete reason to keep the applicant confined. On those facts, the applicant was found entitled to regular bail.

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Issues: Whether the applicant accused in a prosecution under the Central Goods and Services Tax Act, 2017 should be enlarged on regular bail under Section 439 of the Code of Criminal Procedure, 1973.

Analysis: The complaint had already been filed, the applicant had remained in custody for a substantial period, the maximum punishment for the alleged offences was five years, and the record did not disclose any special circumstance justifying continued detention. The Court also took note of the principle that bail can be granted where further incarceration is not warranted, and considered the matter fit for exercise of discretion on a prima facie assessment without entering into detailed evidence.

Conclusion: The applicant was entitled to regular bail.

Ratio Decidendi: Where investigation is complete and no special circumstances justify further detention, regular bail may be granted even in a prosecution under the Central Goods and Services Tax Act, 2017, on a prima facie assessment of the case.

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