Pre-arrest bail granted where cooperation and completed investigation showed no need for further custodial interrogation.

Pre-arrest bail was justified where the applicant had cooperated with the Investigating Officer, his statement had already been recorded, and the material collected, including bank transactions and WhatsApp communication linked to the principal accused, showed substantial progress in the investigation. As no further custodial interrogation appeared necessary, the court accepted that anticipatory bail was warranted and made the interim protection absolute. The principle applied is that pre-arrest protection may be granted when investigation is substantially complete and custody is not shown to be required for inquiry.

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Issues: Whether the applicant was entitled to pre-arrest bail in view of the stage of investigation, his cooperation with the Investigating Officer, and the apparent absence of any need for further custodial interrogation.

Analysis: The applicant had already appeared before the Investigating Officer and his statement had been recorded. The record indicated that his statement corresponded with bank transactions and WhatsApp communication with the principal accused. The investigation had substantially progressed, the material already collected was sufficient for the purposes of inquiry, and no further custodial interrogation of the applicant appeared necessary. On this assessment, the request for pre-arrest protection was considered justified.

Conclusion: The applicant was held entitled to pre-arrest bail.

Final Conclusion: The application succeeded and the earlier interim protection was made absolute, resulting in the grant of anticipatory bail to the applicant.

Ratio Decidendi: Where an accused has cooperated with investigation, his statement has been recorded, and no further custodial interrogation is shown to be necessary, pre-arrest bail may be granted.

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