An accused whose anticipatory bail plea was successively rejected by the Sessions Court, the Punjab and Haryana High Court, and the Supreme Court has still not been arrested.Taking note, the High Court has directed the Punjab Director-General of Police (DGP) to examine why the accused continues to remain beyond the reach of the investigating agency.Among other things, the Bench observed that the situation prima facie raised serious concerns regarding the manner in which the investigation was conducted and the effectiveness of efforts to secure his presence.The court added, “Appropriate corrective measures, if warranted, shall be taken in accordance with law to ensure that judicial orders are implemented in their true letter and spirit and that public confidence in the administration of criminal justice is not undermined.”The directions came as Justice Deepak Gupta dismissed with Rs 50,000 costs the second anticipatory bail petition filed by the accused. The Bench held that completion of the investigation and presentation of the final report did not constitute a substantial change in circumstances warranting reconsideration of a prayer already rejected at three judicial forums.The Bench, during the course of the hearing, was told that the petitioner is seeking pre-arrest bail in an FIR registered on November 30, 2024, at the Economic Offences Wing, Vigilance Bureau, Ludhiana, for cheating and other offences under Sections 384, 420, 465, 467, 468 and 120-B of the IPC.Justice Gupta observed that the petition was a second attempt to secure the extraordinary relief of anticipatory bail. His earlier plea had been dismissed by the Sessions Court on December 16, 2024. A subsequent petition before the High Court was dismissed by a detailed order on January 16, 2025, following which his Special Leave Petition was dismissed by the Supreme Court on July 28, 2025. The petitioner had thereafter filed a petition seeking quashing of the FIR, which he withdrew on January 30, 2026.The only circumstance now projected before the court as a change justifying reconsideration of anticipatory bail was that the investigation had been completed and the final report had been presented before the competent court.Rejecting the submission, Justice Gupta observed: “It is a settled principle that a second or successive petition for anticipatory bail is maintainable only upon the disclosure of a substantial and genuine change in circumstances occurring after the rejection of the earlier petition. Such a change must be of a nature which materially alters the factual or legal position considered while declining the earlier relief.”The court added that mere progression of the investigation to its logical conclusion or presentation of the challan could not, by itself, be treated as a “fresh circumstance entitling an accused to re-agitate a prayer which has already been declined by the Sessions Court, this Court and even the Supreme Court. Acceptance of such a contention would render the doctrine governing successive bail petitions wholly otiose and would permit repeated litigation on identical grounds.”Justice Gupta then expressed concern over the petitioner’s continued absence despite repeated judicial orders declining him pre-arrest protection. “Rather, what is striking in the present case is that despite rejection of the petitioner’s prayer for anticipatory bail at three successive judicial forums, including the Supreme Court, the petitioner continues to remain beyond the reach of the investigating agency,” the Bench observed.Noting that the FIR had been registered in November 2024 and that more than one and a half years had elapsed thereafter, the Bench asserted satisfactory explanation was not forthcoming as to why the petitioner had not been taken into custody if his custodial interrogation or arrest was considered necessary by the investigating agency.“Such a state of affairs prima facie raises serious concerns regarding the manner in which the investigation has been conducted and the effectiveness of the efforts undertaken for securing the presence of the accused.”The court also denounced the growing practice of filing consecutive anticipatory bail petitions without any real change in conditions. “This Court has repeatedly deprecated the growing tendency of litigants to file successive petitions seeking anticipatory bail without any real or substantial change in circumstances. Such repeated attempts not only amount to an abuse of the process of law but also result in unnecessary consumption of valuable judicial time,” Justice Gupta asserted.The Bench added that judicial discipline and the principle of finality attached to earlier orders require that “successive petitions be entertained only in exceptional circumstances, which are conspicuously absent in the present case.”Finding no merit in the petition, the High Court dismissed it with costs of Rs 50,000 and directed the petitioner to deposit the amount with the District Legal Services Authority, Ludhiana, within two weeks. The authority was given the liberty to initiate appropriate recovery proceedings in accordance with the law in the event of default.Considering the “peculiar facts” of the case, the Bench directed the forwarding of the order to the Punjab DGP, who “shall examine the matter and ascertain the reasons for the apparent inaction in securing the petitioner.”