Regular bail after charge-sheet filing granted where custody was prolonged, parity existed, and no special circumstances were shown.

After the charge-sheet was filed and investigation was complete, the Court treated the bail request on the basis that the applicant had remained in custody since 14.02.2023, charge had not yet been framed, and no special circumstances were shown against him. Parity with co-accused who had already obtained regular bail, the absence of any GST notice, and the applicant's willingness to cooperate all weighed in favour of release. Applying the usual principles governing bail, the Court found no need for a detailed examination of evidence at that stage and exercised discretion to grant regular bail.

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Issues: Whether the applicant was entitled to regular bail after filing of the charge-sheet in view of the period of custody, absence of special circumstances, parity with co-accused, and willingness to cooperate.

Analysis: The applicant had been in custody since 14.02.2023 and the investigation was complete with the charge-sheet filed, though charge had not yet been framed. No notice had been issued by the GST authority, and co-accused had already been granted regular bail. The Court also noted that the prosecution could not point out any special circumstances against the applicant. Relying on the principles governing bail, the Court found that the matter did not require detailed examination of evidence at that stage and that the discretion to grant bail could be exercised.

Conclusion: The applicant was held entitled to regular bail.

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