completed and charge-sheet is filed. The applicant is behind bar almost for one year. As far as the guidelines issued by this Court in Freedom Firm Vs. Commissioner of Police, Pune and ors. (supra) are concerned it shows that (a) The fundamental right of the victim not to be trafficked. (b) The antecedents of the accused - the trafficker would be easily seen to have been earlier apprehended and arrested. Such accused are habitual offenders. (c) The repetitiveness of the offence - since it is a career in crime, it is bound to be repeated upon the accused being released on bail thus trafficking further similar victims which is the State''s duty to prevent. (d) The intimidation and threat that accompanies the relationship between the accused and the victim. The victim is the helpless chattel of the accused, the accused being in a position to threaten her to lie and coerce her to turn hostile and thus tamper with evidence. (e) The economic position of the accused, if a trafficker, (f) The violence involved in the case and keeping in mind these diverse ways to frustrate justice, the application of the bail to be considered. It is further held that bail should also be denied if the victim is a minor except in case of any extraordinary, compelling or special circumstances to be explained in the order itself and upon the most stringent conditions. It is further held that if a brothel owner closed the said brothel then his bail application can be considered on closure of the said brothel.
