Regular bail in GST evasion matter granted where case rested on documents, investigation was complete, and custody was no longer necessary.

In alleged GST evasion proceedings, the High Court treated the case as one resting mainly on documentary evidence, noted that investigation was complete and the petitioner had cooperated, and found that continued custody was unnecessary where substantial pre-trial detention had already occurred, the trial remained at the pre-charge stage, and the likely sentence was limited. Regular bail was therefore granted subject to conditions, including appearance before the CJM/Duty Magistrate and deposit of any valid passport.

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Issues: Whether the petitioner was entitled to regular bail in proceedings arising from alleged GST evasion offences.

Analysis: The allegations were based substantially on documentary material. Investigation had been completed and there was no indication that the petitioner had not cooperated during investigation. The petitioner had already undergone substantial custody, the maximum punishment was stated to be limited, and the trial was still at the pre-charge stage with a large number of witnesses remaining. In these circumstances, continued custody was not considered necessary for the purpose of the case.

Conclusion: Regular bail was granted subject to conditions, including satisfaction of the CJM/Duty Magistrate and deposit of the valid passport, if any.

Ratio Decidendi: In a case resting mainly on documentary evidence, where investigation is complete, custody is substantial, and the likely sentence is limited, regular bail may be granted if further detention is not for the progress of the trial.

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