Anticipatory bail granted after completion of investigation where custodial interrogation and evidence tampering were not shown.

Anticipatory bail was considered appropriate because the investigation was complete, the prosecution report had been filed, and cognizance had been taken. The court noted that the petitioner had not been arrested during investigation, no warrant of arrest had been sought, and there was no material showing any likelihood of custodial interrogation or tampering with evidence. As the alleged evidence was documentary and already in the prosecution's possession, custodial interrogation was found unnecessary. Anticipatory bail was therefore granted, subject to surrender and release on the specified terms and conditions.

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Issues: Whether anticipatory bail should be granted where investigation is complete, prosecution report has been filed, cognizance has been taken, and there is no material suggesting likelihood of custodial interrogation or tampering with evidence.

Analysis: The allegations related to creation of fake firms, issuance of fake GST bills, and wrongful passing of ineligible input tax credit. The investigation had already concluded, the prosecution report was filed, and cognizance had been taken. The petitioner had not been taken into custody during investigation and no warrant of arrest had been sought. The record did not indicate any real possibility of tampering with evidence, which was stated to be documentary in nature and in the possession of the prosecution. In these circumstances, custodial interrogation was found unnecessary.

Conclusion: Anticipatory bail was granted in favour of the petitioner, with directions to surrender and to be enlarged on bail on the specified terms and conditions.

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