Anticipatory bail in corruption cases may be refused where prima facie material indicates involvement and trial prejudice is likely.

Anticipatory bail was refused in a bribery prosecution under the Prevention of Corruption Act because the record prima facie indicated involvement in demand and acceptance of illegal gratification. The Court relied on surrounding material, including the visitors' register entry, recorded conversation and inventory prepared during investigation, and noted the prosecution version that the petitioner fled through a secret passage. It held that further discussion at the pre-arrest stage could prejudice the trial, so no ground existed for anticipatory bail.

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Issues: Whether the petitioner was entitled to anticipatory bail in a bribery-related prosecution under the Prevention of Corruption Act.

Analysis: The complaint alleged demand and acceptance of illegal gratification by a GST Inspector, and the surrounding material, including the visitors' register entry, the recorded conversation, and the inventory prepared by the investigating officer, prima facie supported the allegation of involvement. The Court also noted the prosecution case that the petitioner fled through a secret passage and that further discussion at the bail stage could prejudice the trial. On these facts, the Court found no ground to grant pre-arrest bail.

Conclusion: The petitioner was not entitled to anticipatory bail.

Ratio Decidendi: Anticipatory bail may be refused where the material on record prima facie indicates involvement in corruption and the circumstances do not justify pre-arrest protection.

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