The court reinforced the principle of timely trials, finding entitlement to bail under Section 480(6) of B.N.S.S. due to significant delay not attributable to the accused, thus safeguarding individual liberty.

ORDER :

ANAND SHARMA, J.

1. This third bail application has been filed by the petitioner for seeking bail in respect of Criminal Complaint No.DGGI/INT/ARM/5/2024-0/OADG/DGGI/JZU-Jaipur dated 03.06.2024, registered at office of DGGI, JZU, Jaipur for offences punishable under Section 132 (1) (b) (c) (f) & (l) of Central Goods and Services Tax Act, 2017 (for short, 'the Act of 2017').

2. First bail application filed by the petitioner was dismissed by this Court vide order dated 18.06.2025. However, while deciding the first bail application, following directions were given by this Court:

"Since while rejecting the Bail Application, custody of the accused-petitioner is resultantly continued, the Trial Court is expected to conclude the Trial within a reasonable time, ensuring right of the accused petitioner regarding speedy trial as guaranteed by Article 21 of the Constitution of India."

3. Aggrieved by rejection of bail vide order dated 18.06.2025, the petitioner approached Hon'ble Supreme Court by way of filing Special Leave Petition (Criminal), however, the same was withdrawn with the contention that one clarification application has already been filed by the petitioner in order to seek clarification of order dated 18.06.2025 passed by this Court in first bail application.

4. The clarification application filed by the petitioner was also withdrawn by the petitioner and on account of withdrawing the application, the same was dismissed vide order dated 20.08.2025. Thereafter, without approaching the learned Court below, directly second bail application was filed by the petitioner before this Court, however, the same was withdrawn by the petitioner on 16.09.2025 with liberty to approach the learned trial Court.

5. Thereafter, bail application was filed before the learned trial Court by the petitioner with specific plea that although from the first date fixed for taking evidence in the instant matter, more than 90 days have expired, yet the learned trial Court has not concluded it and under such circumstances, in view of Section 480 (6) of Bharatiya Nagarik Suraksha Sanhita, 2023 (for short, 'B.N.S.S.'), the petitioner is entitled to be released on bail.

6. Learned Senior Counsel appearing for the petitioner submits that the cognizance on the complaint filed by the respondent was taken by the learned trial Court on 01.02.2025. Thereafter, first time complainant's witness PW-1 Rakesh Kumar Meena appeared before the learned trial Court, however, even his chief examination could not be concluded for the reason that he wanted to cite relevant register which was not available with him. Thereafter, on subsequent so many dates i.e., 07.08.2025, 12.08.2025 & 18.08.2025 and even today, the matter was fixed for completion of examination of PW-1, yet till date even his statements have not been completed.

7. Learned Senior Counsel appearing for the petitioner further submits that in the meanwhile, other two witnesses PW-2 (Meenu Verma) and PW-3 were examined, however, only PW-2 has completed her statements and even the statements of PW-3 are still incomplete.

8. Learned Senior Counsel for the petitioner also submits that as per list of witnesses, there are ten witnesses, who are to be examined before the learned Trial Court and from the first date on which PW-1 appeared before the learned trial Court, more than 90 days have expired and even PW-1 has not completed his deposition. Under these circumstances, as pe