Anticipatory bail refused in alleged GST evasion case where custodial interrogation was found necessary for effective investigation.

Anticipatory bail was refused in allegations of forgery, fake invoices and GST evasion because the Court treated the matter as a serious economic offence affecting the public exchequer and found custodial interrogation necessary for effective investigation. The alleged use of fabricated entities and invoices, together with the need to confront documents, witness statements and recover diverted material, justified denial of pre-arrest protection. Earlier interim protection, granted only to facilitate possible settlement, did not create a right to bail on merits. Interim protection was vacated and investigation was allowed to continue without restraint on custodial interrogation.

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Issues: Whether anticipatory bail should be granted in a case involving allegations of forgery, fake invoices, and GST evasion, where custodial interrogation was stated to be necessary.

Analysis: The application was examined against the background of repeated bail filings, withdrawal of an earlier anticipatory bail petition, unsuccessful mediation, and the allegation that the accused had used fabricated entities and invoices to facilitate GST evasion. The Court treated the alleged conduct as an economic offence affecting the public exchequer and noted that the investigation required confrontation with documents, witness statements, and recovery of allegedly diverted . It held that custodial interrogation would be materially useful and that interim protection had been granted earlier only in aid of possible settlement, not on merits.

Conclusion: Anticipatory bail was declined, as no ground for pre-arrest protection was made out.

Final Conclusion: The proceedings ended with refusal of pre-arrest bail and vacation of interim protection, leaving the investigation to continue without restraint on custodial interrogation.

Ratio Decidendi: Anticipatory bail may be refused where the allegations disclose a serious economic offence and custodial interrogation is necessary for effective investigation, especially when interim protection was earlier granted only to facilitate settlement.

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