In Brief
The appellant sought review of a trial court's grant of regular bail, which the court appeared to have granted solely on the basis of anticipatory bail protection previously granted by the Supreme Court under Section 438 CrPC. The Supreme Court declined to decide the substantive issue, referring it to a larger bench. However, it clarified that the de facto complainant could approach the trial court to modify bail conditions and that courts need not treat Supreme Court anticipatory bail as the sole basis for granting regular bail. The appeal was disposed without prejudice to the complainant's right to seek modifications."
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