Successive bail requires changed circumstances; ongoing investigation and tampering risk justified refusal in a grave case.

A successive bail application will not be entertained without material changed circumstances after an earlier rejection on merits. The Court noted a prima facie role in the post-incident disposal of the deceased's body, continuing investigation under Section 173(8) CrPC, and the gravity of the allegations. In that setting, the risk of influencing witnesses or obstructing the investigation remained real, so discretionary bail was refused.

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Issues: Whether the applicant was entitled to bail in a successive bail application in view of the nature of accusations, the ongoing further investigation, and the apprehension of tampering with evidence.

Analysis: The application was considered under the discretionary bail jurisdiction. The Court noted that the earlier bail request had been rejected on merits and that there were no material changed circumstances warranting a different view. The supplementary charge-sheet and further investigation disclosed a prima facie role of the applicant in the post-incident conduct relating to the disposal of Kausarbi's dead body, and the investigation under Section 173(8) of the Code of Criminal Procedure, 1973 was still in progress. The Court found that, in a serious case involving grave accusations and a continuing inquiry, the possibility of influencing witnesses or obstructing the investigation could not be ignored.

Conclusion: The applicant was not entitled to bail and the application was rejected.

Ratio Decidendi: In a successive bail application, bail should not be granted in the absence of changed circumstances where a prima facie case exists, the offence is grave, and further investigation is continuing with a real apprehension of tampering with evidence or witnesses.

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