Regular bail after completed investigation: custody without further recovery or interrogation was found unnecessary in a CGST prosecution.

Regular bail was granted in a CGST prosecution after the investigation was completed and the challan filed, because the accused was no longer required for custodial interrogation or further recovery. The Court noted that the laptop and material documents had already been recovered, the trial had not begun, and continued incarceration would serve no useful purpose. While considering the gravity of the alleged economic offence, the Court applied the settled principle that bail is the rule and jail is the exception, and found that detention could not be justified without concrete necessity. Bail was allowed subject to conditions to secure attendance and protect the trial process.

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Issues: Whether the petitioner, arraigned in a prosecution under the Central Goods and Services Tax Act, 2017, was entitled to regular bail after completion of investigation and filing of the challan.

Analysis: The investigation had been completed and the challan had been presented. The petitioner had remained in custody since the date of arrest, the material documents and laptop had already been recovered, and nothing further was required to be recovered from him. The trial had not commenced, the prosecution case involved a large number of witnesses, and continued incarceration was found to serve no useful purpose. The Court applied the settled principles that bail is the rule and jail is the exception, while also keeping in view the gravity of the alleged economic offence and the stage of investigation.

Conclusion: The petitioner was held entitled to regular bail.

Final Conclusion: Regular bail was granted subject to conditions intended to secure the petitioner's during trial, prevent interference with evidence, and safeguard the prosecution process.

Ratio Decidendi: Once investigation is complete and the accused is no longer required for custodial interrogation or further recovery, continued detention in a bail matter must be justified by concrete necessity and cannot be ordered merely because the case involves an economic offence.

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