Regular bail in tax evasion cases may follow once investigation ends and the triple test is satisfied, despite economic allegations.

Regular bail may be granted in economic offence prosecutions once investigation is complete and challan has been filed, if the triple test of flight risk, tampering with evidence, and influencing witnesses is satisfied. The Court applied the settled principle that bail is the rule and detention the exception, and found no continuing custodial need after the investigative purpose was exhausted. Mere allegation of tax evasion and connected offences was not treated as a standalone reason to deny liberty. The petitioners were therefore entitled to regular bail on furnishing the required bonds and sureties, subject to conditions.

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Issues: Whether the petitioners, facing prosecution in cases arising out of alleged tax evasion and connected offences, were entitled to regular bail after completion of investigation and filing of challan.

Analysis: The petitions were considered on settled bail principles, including the nature and gravity of accusation, the triple test of flight risk, tampering with evidence, and influence over witnesses, and the principle that bail is ordinarily the rule while refusal is the exception. The investigation had concluded and challan had been presented. In these circumstances, further custodial detention was not shown to be necessary, and the Court found no reason to deny bail merely because the allegations involved economic offences. The order also proceeded on the settled approach that liberty must be balanced against the needs of fair investigation and trial.

Conclusion: The petitioners were held entitled to regular bail and were ordered to be released on bail on furnishing the requisite bonds and sureties, subject to the stated conditions.

Ratio Decidendi: Once investigation is complete and the custodial purpose is exhausted, regular bail may be granted in economic offence cases if the triple test is satisfied and continued detention is not necessary to secure trial or prevent misuse of liberty.

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