Successive bail applications require a real change in circumstances; mere compliance with interim conditions is not enough.

A successive bail application was treated as unsustainable where no material change in circumstances was shown. Mere compliance with interim bail conditions and timely surrender did not constitute a fresh ground for reconsideration, and repeated applications in close proximity were viewed as an abuse of process. The applicant's extensive criminal history, involvement in multiple serious cases, and prior convictions further weighed against relief. In these circumstances, the regular bail request was rejected and costs were imposed on counsel.

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Issues: Whether a successive bail application was maintainable in the absence of any material change in circumstances, and whether the applicant's compliance with interim bail conditions constituted a fresh ground for bail.

Analysis: The application was moved after two earlier bail applications had already been dismissed on merits. The only ground urged was that the applicant had complied with the conditions imposed while on interim bail and had surrendered on time. The Court held that mere compliance with the conditions of interim bail does not amount to a change in circumstances and cannot justify repeated bail applications in close proximity. The applicant's extensive criminal history, involvement in multiple serious cases, and prior convictions were also taken into account, along with the absence of any fresh ground warranting reconsideration.

Conclusion: The successive bail application was not maintainable on the facts presented and was dismissed. Costs of Rs. 10,000/- were imposed on counsel.

Final Conclusion: Repeated bail applications without any material change in circumstances were treated as an abuse of process, and the request for regular bail was rejected with costs.

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