Prolonged pre-trial custody and speedy-trial rights justified regular bail in GST-related criminal proceedings.

Prolonged pre-trial custody, slow progress of trial and the constitutional right to a speedy trial justified regular bail to an accused facing offences under the Haryana Goods and Services Tax Act and the IPC. The Court noted that the petitioner had remained in custody for more than three years, the challan had been filed, charges framed, and only a limited number of witnesses examined, while co-accused had already been granted bail. Applying the principles that bail is the rule and jail the exception, and that an accused is presumed innocent until proved guilty, the Court held continued detention unwarranted and ordered release on bail.

---

---

Issues: Whether regular bail should be granted to the petitioner accused of offences under the Haryana Goods and Services Tax Act, 2017 and the Indian Penal Code.

Analysis: The petitioner had remained in custody for more than three years, the challan had already been presented, charges had been framed, and only a limited number of witnesses had been examined out of the total cited witnesses. Co-accused had already been granted bail. The Court applied the principles that bail is the rule and jail is the exception, that an accused is presumed innocent until proved guilty, and that the right to speedy trial forms part of Article 21 of the Constitution of India. The pendency of other cases was noted, but it was not treated as decisive in the facts of the case.

Conclusion: Regular bail was granted to the petitioner.

Final Conclusion: The petitioner was ordered to be released on bail, as continued custody was found unwarranted in view of the stage of trial and the constitutional and criminal jurisprudence governing bail.

Ratio Decidendi: In a bail matter, prolonged pre-trial incarceration, slow progress of trial, and the constitutional mandate of speedy trial may justify release on regular bail even where allegations involve economic or GST offences.

---