Regular bail under the CGST Act granted where investigation was complete and documentary evidence reduced custodial interrogation needs.

Regular bail under the CGST Act was granted because the investigation had been completed, the final report had been filed, and the case rested largely on documentary and electronic evidence, reducing any need for further custodial interrogation. The Court also noted that the alleged offences carried a maximum punishment of five years, the petitioner had remained in custody for more than four months, and no pressing necessity for continued detention was shown. Concerns about the gravity of the allegation and possible misuse of liberty were addressed by imposing stringent conditions, which were considered sufficient to protect the investigation and trial.

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Issues: Whether the petitioner was entitled to regular bail in a prosecution under the Central Goods and Services Tax Act, 2017, considering the stage of investigation, nature of evidence, alleged role in the offence, and the asserted risk of interference with the trial.

Analysis: The maximum punishment for the alleged offences was up to five years. The petitioner had been in custody for more than four months, the investigation had been completed, and the final report had been submitted. The case was substantially based on documentary and electronic material, reducing the need for further custodial interrogation. The Court also considered the principles governing arrest and bail, the absence of any pressing necessity for continued detention, and the fact that stringent conditions could adequately safeguard the investigation and trial. In these circumstances, the gravity of the allegation and the apprehension of misuse of liberty did not outweigh the factors favouring release on bail.

Conclusion: The petitioner was entitled to bail on stringent conditions.

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