Successive anticipatory bail requires a real change in circumstances; evasive conduct and proclamation proceedings justified refusal.

Successive anticipatory bail can be considered only on a genuine and material change in circumstances; repeated pleas without new grounds do not justify renewed relief. Where the record shows non-cooperation with investigation, avoidance of notices, disputed explanation for absence, failed execution of warrants, and initiation of proclamation proceedings under Section 82 CrPC, the court may treat the applicant's conduct as a strong reason to refuse protection. The Delhi HC applied this principle to a third anticipatory bail plea, found no fresh basis for reconsideration, and rejected the application as not maintainable on the facts.

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Issues: Whether a successive anticipatory bail application deserved grant of relief in the absence of any material change in circumstances, particularly where the applicant's conduct showed non-cooperation with investigation and the process under proclamation had already been initiated.

Analysis: The application was the applicant's third anticipatory bail plea before the Court, after earlier applications had been dismissed or withdrawn, and one earlier grant of anticipatory bail had been made subject to a deposit condition that was not complied with. The record showed repeated notices, alleged avoidance of investigation, a disputed medical certificate, unsuccessful execution of warrants, and issuance of proclamation under Section 82 of the Code of Criminal Procedure, 1973. The Court held that successive anticipatory bail cannot be entertained without a real change in circumstances and relied on the applicant's conduct, the ongoing need for effective investigation, and the absence of any new ground justifying reconsideration.

Conclusion: The successive anticipatory bail application was not maintainable on the facts and was rejected against the applicant.

Ratio Decidendi: A successive anticipatory bail application can be entertained only on a genuine and material change in circumstances, and a court may refuse relief where the accused's conduct indicates evasion, non-cooperation, or suppression, especially after proclamation proceedings have commenced.

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