Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Online)(AP) 12911

HIGH COURT OF ANDHRA PRADESH
Battu Devanand, J
Sajjala Bharghav Reddy – Appellant
Versus
Union India – Respondent
WRIT PETITION NO: 6748/2026

Advocates:
For the Appellants/Petitioners: Patil Yugandhar Reddy, R. Yella Reddy
For the Respondents: GP For Home, Y V Anil Kumar, A Ravindra Babu, M. Laxminarayana, A. Jayanthi

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)

Petition under Article 226 of the Constitution of India praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a Writ, Order, or Direction, more particularly one in the nature '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.No's. 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, and to pass

IA NO: 1 OF 2026

Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased to suspend the operation of the Look-Out Circular (LOC) issued by Respondent No.5 to 17 against the Petitioner, by duly directing the respondents herein, not to prevent or obstruct the Petitioner from travelling within or outside India, including for medical, professional, or personal purposes, pending disposal of the present Writ Petition, and to pass

Counsel for the Petitioner:

1.PATIL YUGANDHAR REDDY

Counsel for the Respondent(S):

1.GP FOR HOME

2.Y V ANIL KUMAR (Central Government Counsel)

3.A RAVINDRA BABU (CENTRAL GOVT COUNSEL)

The Court made the following:

THE HONOURABLE SRI JUSTICE BATTU DEVANAND

WRIT PETITION No.6748 of 2026

ORDER: -

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:

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2026 Supreme(Online)(AP) 12911

HIGH COURT OF ANDHRA PRADESHBattu Devanand, JSajjala Bharghav Reddy – AppellantVersusUnion India – RespondentWRIT PETITION NO: 6748/2026

Cases Referred (4)

HIGH COURT OF ANDHRA PRADESH
Battu Devanand, J
Sajjala Bharghav Reddy – Appellant
Versus
Union India – Respondent
WRIT PETITION NO: 6748/2026