Pre-arrest bail refused where fraudulent GST registration documents and false NOC showed a prima facie role in forgery and cheating.

Allegations of forgery, cheating, criminal conspiracy and GST offences involved use of fraudulent documents and a false NOC at the registration stage itself, not merely non-payment of tax or falsification of records. The investigation also linked the applicant to the formation and functioning of the entity through the chartered accountant's statement and surrounding circumstances. On that material, the HC found no ground to exercise discretion for pre-arrest protection, and anticipatory bail was refused.

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Issues: Whether the applicant was entitled to pre-arrest bail in connection with allegations of forgery, cheating, criminal conspiracy, and offences under the goods and services tax law.

Analysis: The allegations were not confined to non-payment of tax or falsification of records. The material showed use of fraudulent documents and a false NOC at the stage of obtaining registration itself under the goods and services tax regime. The investigation also linked the applicant to the formation and functioning of the concerned entity through the statement of the chartered accountant and surrounding circumstances. In view of the nature of the accusations, the Court found no ground to exercise discretion in favour of pre-arrest bail.

Conclusion: The applicant was not entitled to anticipatory bail.

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