Successive bail applications require substantial change in circumstances; prima facie conspiracy evidence and non-cooperation justified continued custody.

A successive bail application can be considered only on a showing of substantial change in circumstances. In this corruption case, the Court found no such change after the earlier rejection on merits and held that the investigation record prima facie supported continued custody. CCTV footage, witness identification and voice-related material indicated the applicant's alleged role in impersonating a senior GST officer and acting in conspiracy for illegal gratification. The Court also relied on alleged non-cooperation during investigation, including evasion of notices and refusal to give a voice sample. Bail was therefore refused and custody was maintained.

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Issues: Whether the second bail application deserved to be allowed in the absence of any substantial change in circumstances, and whether the material collected during investigation prima facie justified continued custody.

Analysis: The applicant sought regular bail in a corruption case alleging that he impersonated a senior GST and acted in conspiracy with co-accused persons in the demand of illegal gratification. The Court noted that the earlier bail application had already been rejected on merits and that a successive bail application could be entertained only on a showing of substantial change in circumstances. It further noted that the investigation had been completed, the charge sheet and supplementary charge sheet were filed, and the material on record, including CCTV footage, identification by witnesses, and voice-related material, prima facie indicated the applicant's presence and active role in the alleged conspiracy. The Court also relied on the applicant's alleged non-cooperation during investigation, including evasion of notices and reluctance to give voice sample.

Conclusion: No substantial change in circumstances was shown, and the material on record prima facie supported the prosecution case; the second bail application was therefore not fit to be granted.

Final Conclusion: The applicant was not entitled to bail on the facts and material placed before the Court, and the custody order was maintained.

Ratio Decidendi: A successive bail application can be entertained only on proof of a substantial change in circumstances, and where the record discloses a prima facie active role in a serious offence together with non-cooperation in investigation, bail may be refused.

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