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As per case facts, the appellant, accused of misappropriation, was granted regular bail by the High Court conditional upon depositing a certain amount, an undertaking which he later reneged on,
...arguing the condition was onerous. Consequently, the High Court cancelled his bail and directed him to surrender. The appellant challenged the cancellation of bail before the Supreme Court. The question arose whether the High Courts and Trial Courts can legally impose a financial deposit based on an accused's undertaking as a condition for granting regular or anticipatory bail. Finally, the Supreme Court dismissed the appeal and imposed a cost on the appellant for abuse of process. It issued a strong directive and held that henceforth, no Trial Court or High Court shall grant regular or anticipatory bail based on an accused's undertaking to deposit a sum. The plea for bail must be decided strictly on the merits of the case, and conditional orders for bail on financial undertakings are impermissible, as courts should not act as recovery agents.
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