Anticipatory bail travel restrictions can be modified only for exceptional later circumstances, not previously known factors.

A condition in anticipatory bail restraining foreign travel can be relaxed only on exceptional, cogent and subsequent circumstances not existing when the condition was imposed. Here, the applicant knew of his overseas business dealings when bail was granted and raised no objection then; alleged investigation abroad and the risk of witness influence or evidence tampering also weighed against modification. The request to travel to Dubai and obtain release of the passport was therefore held unjustified, and the foreign-travel relaxation was set aside.

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Issues: Whether the condition imposed while granting anticipatory bail, restraining the respondent from leaving India without permission, could be modified to permit travel to Dubai and release of the passport.

Analysis: The condition attached to anticipatory bail was treated as binding and capable of modification only in rare cases on showing cogent and convincing reasons based on circumstances not available when the order was made. The respondent was aware of his business dealings abroad when bail was granted and did not object to the restriction at that stage. The alleged investigation abroad and the possibility of influencing witnesses or tampering with evidence were also relevant factors against relaxation of the condition.

Conclusion: The permission to travel abroad was not justified and the bail condition could not be modified in the absence of any new or exceptional circumstance.

Final Conclusion: The revision was accepted and the order permitting foreign and release of the passport was set aside.

Ratio Decidendi: A condition imposed while granting anticipatory bail can be altered only on a showing of exceptional, cogent, and subsequent circumstances not existing when the condition was first imposed.

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