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Issues: Whether the petitioner was entitled to bail in a successive application on the basis of parity with a co-accused and the asserted change in circumstances, in a case involving alleged GST evasion and fabrication of invoices and e-way bills.
Analysis: The earlier bail rejection was based on the nature of the allegations, the material collected during investigation, and the specific role attributed to the petitioner. A successive bail application requires a substantial change in circumstances having a direct bearing on the merits. Parity is not a standalone or mechanical ground for bail; the individual role of the accused, the gravity of the allegations, and the prima facie material must be independently assessed. On the material noticed, the petitioner was alleged to be the principal architect of a fraudulent syndicate involving fictitious firms, fake invoices, bogus e-way bills, and substantial tax evasion, supported by documentary and electronic material and statements recorded during investigation. The co-accused's grant of bail did not place the petitioner on the same footing.
Conclusion: The petitioner was not entitled to bail on the ground of parity or any substantial change in circumstances, and the second bail application was liable to be rejected.
Ratio Decidendi: Parity is not a sole or mechanical basis for bail in economic offences, and a successive bail plea can succeed only on a substantial change in circumstances supported by an independent assessment of the accused's individual role and the prima facie material.