Anticipatory bail travel condition modified after charge-sheet; prior permission shifted to the Trial Court and limited foreign travel allowed.

After filing of the charge-sheet, the High Court modified the anticipatory bail travel condition that had required prior permission of the Investigating Officer, directing instead that future permission be sought from the Trial Court. It further noted that the petitioner had earlier travelled abroad twice without misuse of liberty and, on that basis, permitted travel to Dubai, UAE, for two months on the same terms and conditions previously imposed. The operative effect was a modification of the bail condition in favour of the petitioner together with limited foreign travel permission.

---

---

Issues: Whether the condition in the anticipatory bail order requiring prior permission from the Investigating Officer for foreign could be modified to require prior permission of the Trial Court, and whether the petitioner could be permitted to travel abroad.

Analysis: The application was moved under Section 482 of the Code of Criminal Procedure, 1973 for modification of the travel condition imposed in the anticipatory bail order. Since the charge-sheet had been filed, the Court modified the earlier condition by substituting prior permission of the Investigating Officer with prior permission of the Trial Court. The Court also noted that the petitioner had earlier been permitted to travel abroad on two occasions without misuse of liberty, and granted permission to travel to Dubai, UAE, for two months on the same terms and conditions as earlier imposed by the Trial Court.

Conclusion: The travel condition was modified in favour of the petitioner, and permission to travel abroad was granted.

Final Conclusion: The petition succeeded with modification of the bail condition and grant of limited foreign travel permission.

Ratio Decidendi: Where circumstances have changed after filing of the charge-sheet and the accused has not misused earlier travel permissions, the Court may modify an anticipatory bail travel condition and direct that future permission be sought from the Trial Court instead of the Investigating Officer.

---