Documentary GST allegations and no need for custodial interrogation justified regular bail in a prosecution.

In a GST prosecution based mainly on alleged wrongful Input Tax Credit claims and bogus invoicing, regular bail was granted because the investigation had substantially progressed through seizure of documents and recording of statements. The Court noted that the material was primarily documentary, the applicant had remained in custody since 16/01/2026, and no further custodial interrogation appeared necessary. Without examining the merits of the prosecution, the decision reflects the approach that continued custody is not justified where the evidence is already on record and the case can proceed on existing documentary material.

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Issues: Whether the applicant was entitled to regular bail in a GST prosecution where the allegations primarily rested on documentary material and further custodial interrogation was claimed to be unnecessary.

Analysis: The allegations concerned wrongful availment of Input Tax Credit and bogus invoicing. The material on record showed that relevant documents had been seized and statements had been recorded, indicating that the investigation had substantially progressed. The applicant had been in custody since 16/01/2026, and the Court found no apparent need for further custodial interrogation. Without entering into the merits of the prosecution case, the Court treated the dispute as one that could proceed on the basis of the existing record.

Conclusion: Regular bail was granted to the applicant.

Ratio Decidendi: Where the accusations are primarily documentary, the investigation has substantially progressed, and further custodial interrogation is not , regular bail may be granted.

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