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2026 Supreme(AP) 1008

IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI
BATTU DEVANAND, J.
Sajjala Bharghav Reddy, S/o. S. Ramakrishna Reddy – Petitioner
Versus
The Union India, Rep. By Its Secretary, Ministry Of Home Affairs (MHA) Government Of India – Respondent
Writ Petition No. 6748 of 2026
Decided On : 17-04-2026

Advocates Appeared:
For the Petitioner: Patil Yugandhar Reddy
For the Respondents: GP For Home, Y.V. Anil Kumar (Central Government Counsel), A. Ravindra Babu (Central Govt. Counsel)

A Look-Out Circular constitutes a significant restraint on the fundamental right to travel under Article 21. Its issuance must be strictly necessary, proportionate, and based on evidence of a subject absconding; it cannot be maintained indefinitely during ongoing investigations without periodic review and proof of non-cooperation.

Headnote:(A) Constitution of India - Articles 14 and 21 - Bharatiya Nagarik Suraksha Sanhita (BNSS) - Section 35(3) - Information Technology Act, 2000 - Sections 66 and 67 - Look-Out Circular (LOC) - Issuance and continuance - Right to travel abroad is an integral facet of the right to life and personal liberty guaranteed under Article 21. LOC is a coercive measure, and its issuance must be sparingly used, strictly in accordance with law, and only where an accused is deliberately evading arrest or judicial process, or there is a real likelihood of absconding. The State cannot indefinitely curtail such liberty based on a prolonged and uncertain investigation. Originating agencies bear the burden of justifying the necessity, proportionality, and legality of the restraint, and are required to conduct periodic reviews of such circulars. (Paras 9, 13, 14, 15, 18)

Facts of the case:
The petitioner approached the Court challenging the Look-Out Circular (LOC) issued against him in relation to multiple ongoing criminal investigations pertaining to alleged social media activities. The petitioner contended that the restrictive measure violated his fundamental rights, particularly the right to travel, while respondents argued the measure was necessary for investigation and to secure the presence of the accused in cases involving potential incitement and inflammatory content.

Findings of Court:
The Court observed that while the State has the power to issue an LOC to prevent an accused from absconding during investigation, such power must not be exercised arbitrarily. The investigation failed to provide sufficient evidence that the petitioner was evading legal process. Furthermore, the authorities failed to demonstrate compliance with mandatory review requirements for the circular. Consequently, the continued operation of the LOC was found to be unjustified.

Issues: The main issues were whether the issuance and continued operation of the Look-Out Circular against the petitioner were arbitrary and violative of fundamental rights guaranteed under the Constitution, and whether the investigating agency followed the due process of law in securing the presence of the accused.

Ratio Decidendi: The Court held that the right to travel is a fundamental human right. Since there was no evidence that the petitioner was evading the investigative process—and considering the failure of agencies to adhere to periodic review guidelines for LOCs—the continued restriction on freedom of movement was disproportionate and violative of personal liberty. The Court directed the recall of the circular subject to the petitioner furnishing contact details and undertaking to cooperate with the ongoing investigations.

Result: Petition disposed of with directions.

Table of Content
1. procedural record of the writ petition filings. (Para 1 , 2 , 3)
2. petitioner and respondents' arguments regarding loc validity. (Para 4 , 5 , 6)
3. legal standard for issuance and review of locs. (Para 7 , 8 , 9 , 10 , 11 , 12)
4. right to travel and proportionality in investigation. (Para 13 , 14 , 15 , 16 , 17 , 18)
5. judicial order quashing loc subject to cooperation. (Para 19 , 20 , 21 , 22)
6. judicial commentary on social media ethics and law. (Para 23)

ORDER :

BATTU DEVANAND, J.

This writ petition is filed under Article 226 of the Constitution of India seeking the following relief:

“…. to issue a Writ, Order, or Direction, more particularly one in the nature of 'Writ of Mandamus, declaring the Look Out Circular (LOC) issued against the Petitioner by the Respondents 1 to 3 at the instance of Respondents 5 to 17 in relation to Cr.Nos.263/2024 of II Town Gudiwada PS., 228/2024 of Macharla PS, 409/2024 of Pulivendula U/G PS, 213/2024 of Prakash Nagar PS, 411/2024 Pulivendula U/G PS, 165/2024 of Kadiri Rural U/G PS, 495/2024 of Mangalagiri Rural PS, 189/2024 of B. Kothakota U/G PS, 132/2024 of Roddam PS, Penukonda Circle, 30/2024 of Cyber Crime PS NTR Dist., 321/2024 of Bhimavaram I Town PS, 8/2024 of General Offences PS CID2, 16/2024 of General Offences PS CID2, and 256/2024 of Chirala PS as arbitrary, illegal, malafide, and violative of the Articles 14 and 21 of the Constitution of India, and consequently direct the Respondents not to obstruct or restrain the Petitioner from travelling within or outside India, by setting aside the LOC issued against the petitioner.”

2. Heard Sri R. Yella Reddy, learned counsel for the petitioner; Sri Challa Dhanumjaya, learned Additional Solicitor General for Respondent Nos.1 to 3; Sri M. Laxminarayana, learned Public Prosecutor for Respondent Nos.6 and 16 and Smt. A. Jayanthi, learned Government Pleader for Home for remaining respondents.

3. All the respondents filed their counter-affidavits.

4. Submissions of the learned counsel for the petitioner:

(i) The allegations made against the petitioner are baseless, unsubstantiated and are made with an ulterior motive to harass him and to damage his reputation. In all 14 criminal cases registered against the petitioner in different police stations, the petitioner approached this Court by filing quash petitions and anticipatory bail petitions and he is protected by the interim orders passed by this Court.

(ii) The learned counsel further submits that despite of the petitioner bonafide cooperation with the ongoing investigation, the respondent Nos.5 to 17 as arbitrarily, illegally and without following due process has issued a Look-out-Circular (LOC) against the petitioner which has curtailed the fundamental right to travel and personal liberty which is arbitrary and illegal and violative of Articles 14 and 21 of the Constitution of India and the same is liable to be quashed.

5. Submissions of the learned Public Prosecutor and learned Government Pleader for Home for Respondent Nos.4 to 17:

(i) It is submitted that 14 criminal cases were registered in different police stations against the accused including the petitioner. The allegations pertains to posting derogatory, obscene and inflammatory content on social media plot forms targeting the Hon’ble Chief Minister of Andhra Pradesh, other Public Representatives, and Institutions, thereby allegedly promoting enmity, disturbing public peace and inciting communal disharmony. It is further submitted that the investigation in the above crimes is still in progress and further examination of witnesses is pending.

(ii) It is further submitted that though the petitioner is arrayed as accused in all 14 criminal cases in only 02 cases i.e., Crime No.263/2024 of II Town Police Station, Gudivada, Krishna District and Crime No.189/2024 of B. Kothakota U/G Police Station, Annamayya District, Look-out-Circulars were issued against the petitioner. It is further submitted that as all required legal formalitie

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2026 Supreme(AP) 1008

IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATIBATTU DEVANAND, J.Sajjala Bharghav Reddy, S/o. S. Ramakrishna Reddy – PetitionerVersusThe Union India, Rep. By Its Secretary, Ministry Of Home Affairs (MHA) Government Of India – RespondentWrit Petition No. 6748 of 2026Decided On : 17-04-2026