Modification of bail conditions remains available where changed circumstances make a financial restraint unjust and recovery-oriented.

Section 362 CrPC does not prevent the High Court from modifying or revoking conditions in an earlier bail order because a bail order is interlocutory and does not finally dispose of the criminal case. The High Court may use inherent jurisdiction under Section 482 CrPC, read with its constitutional status as a court of record, where changed circumstances require intervention to prevent injustice. A bail condition requiring a substantial fixed deposit without a prima facie finding of guilt was treated as unreasonably onerous and impermissibly recovery-oriented. In view of stalled proceedings and the absence of an early trial conclusion, the condition was revoked and the deposit with accrued interest was directed to be released.

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Issues: (i) Whether Section 362 of the Code of Criminal Procedure, 1973 bars the High Court from modifying a condition imposed in its earlier bail order; (ii) Whether the condition requiring deposit of Rs. 64,00,000 in fixed deposit as a prerequisite to bail warranted revocation.

Issue (i): Whether Section 362 of the Code of Criminal Procedure, 1973 bars the High Court from modifying a condition imposed in its earlier bail order.

Analysis: Section 362 applies only to a judgment or final order disposing of a case. A bail order is interlocutory in nature and does not finally determine the criminal case; bail conditions may be varied where changed circumstances justify such variation. The inherent jurisdiction preserved by Section 482, read with the High Court's status as a constitutional court of record under Article 215, may be exercised to prevent injustice and secure the ends of justice. The contrary coordinate-bench view was treated as per incuriam because it did not consider the statutory meaning of judgment and the binding authorities treating bail orders as interlocutory.

Conclusion: Section 362 does not bar modification or revocation of a condition imposed in a bail order; the High Court may exercise inherent jurisdiction under Section 482 where the circumstances warrant it.

Issue (ii): Whether the condition requiring deposit of Rs. 64,00,000 in fixed deposit as a prerequisite to bail warranted revocation.

Analysis: A bail condition requiring deposit of money without prima facie determination of guilt is unreasonably onerous and cannot convert criminal proceedings into a mechanism for recovery of alleged dues. The prosecution sanction against co-accused had been quashed, the trial proceedings had been closed and records consigned, and there was no prospect of an early conclusion of trial. The continuing restraint on the petitioner's funds, deposited only until conclusion of trial, caused failure of justice in the materially changed circumstances.

Conclusion: The deposit condition was revoked, and the fixed-deposit amount with accrued interest was directed to be released to the petitioner.

Final Conclusion: The inherent jurisdiction was invoked to remove an unjustified continuing bail condition in light of the stalled criminal proceedings and the unreasonable financial restraint.

Ratio Decidendi: A bail order is interlocutory and is not protected from variation by the bar under Section 362; the High Court may, under its inherent jurisdiction, modify or revoke an onerous bail condition when changed circumstances make its continuance unjust.

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