Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Del) 500

IN THE HIGH COURT OF DELHI AT NEW DELHI
SWARANA KANTA SHARMA, J.
Karandeep Singh - Petitioner
Versus
Union of India - Respondent
W.P.(CRL.) 709 of 2025, CRL.M.A. 6538 of 2025, CRL.M.A. 18766 of 2025 & CRL.M.A. 32144 of 2025
Decided On : 03-06-2026

Advocates Appeared:
For the Petitioner:Mr. N. Hariharan and Mr. Pramod Kumar Dubey, Senior Advocates with Mr. Harshit Sethi, Mr. Gunjan Rishi, Ms. Shreya Sahni, Ms. Mansi Tripathi, Mr. Arya Yadav.
For the Respondent:Ms. Rukhmini Bobde, CGSC with Mr. Aman Sheoran, Senior Prosecutor, Mr. Jatin Dhamija, Mr. Vinayak Aren, Ms. Aishwarya Nigam, Advocates and Ms. Isha Tiwari, LC.

The suspension of international travel restrictions during an investigation is a discretionary measure. It is granted based on the applicant’s past compliance, professional necessity, and the court's imposition of rigorous conditions—such as financial bonds and immediate return undertakings—to protect the integrity of the investigative process.

Headnote:(A) Criminal Procedure - Travel Restrictions - Look Out Circular - Suspension of circular for international travel - Where an applicant seeks travel permission during an ongoing investigation, the court must balance individual liberty with the necessity of ensuring a fair and unhindered investigation - Past conduct of the applicant and the establishment of stringent conditions serve as safeguards against the risk of flight and non-cooperation (Paras 8, 10, 13, 15).

(B) Discretionary Power - Conditions of travel - Grant of permission to travel abroad is contingent upon the applicant's willingness to abide by conditions, including furnishing financial securities, providing undertakings for return, and ensuring availability to investigating authorities for the purpose of the ongoing proceedings (Paras 12, 14, 15).

Facts of the case:
The petitioner moved an application seeking the suspension of an existing travel circular to visit multiple zones abroad for professional conferences. The investigative agency opposed this request, citing the active status of the investigation, the respondent's failure to provide mandatory documents, and the potential impact of travel on the investigation's progress. The petitioner argued that previous permissions for travel had been granted without incident and that all conditions imposed by the court had been strictly adhered to previously.

Findings of Court:
The court noted that the petitioner's previous compliance record significantly minimized the apprehension of flight risk. While the court directed the immediate production of outstanding documents, it held that professional requirements justified temporary travel. The court determined that the interests of the investigation could be adequately safeguarded by imposing strict financial security requirements and mandatory cooperation clauses.

Issues: Whether the suspension of a travel circular is permissible during an active investigation and what, if any, conditions are necessary to ensure the accountability and return of the subject.

Ratio Decidendi: The court maintained that the right to travel, while not absolute, may be exercised subject to reasonable restrictions. Permission is granted when an applicant demonstrates a consistent history of legal compliance and agrees to rigorous conditions, including substantial financial bonds and temporary return obligations, which ensure that the investigation remains unhindered.

Result: Application allowed subject to strict conditions regarding security, documentation, and reporting requirements.

Table of Content
1. applicant seeks permission for scheduled international business travel. (Para 1 , 2)
2. parties contest the necessity of travel versus the requirements of an ongoing financial investigation. (Para 3 , 4 , 5 , 6)
3. court assesses petitioner's prior conduct and flight risk indicators. (Para 7 , 8 , 9 , 10 , 11)
4. compulsory document submission as a condition for travel approval. (Para 12)
5. conditional travel granted alongside strict financial and reporting safeguards. (Para 13 , 14 , 15 , 16 , 17 , 18 , 19 , 20)

JUDGMENT :

SWARANA KANTA SHARMA, J.

CRL.M.A. 15232/2026 (interim suspension of LOC to travel abroad i.e., from 09.06.2026 to 23.06.2026)

1. The present application has been filed by the applicant/petitioner seeking suspension of the impugned Look Out Circular (LOC) dated 18.12.2020 to enable him to travel to the United Kingdom, the Netherlands and Switzerland during the period from 09.06.2026 to 23.06.2026.

2. It is the case of the applicant that his visit to the aforesaid countries is necessitated for attending the following professional conferences and events: (i) NHS Confed Expo, scheduled on 10.06.2026 and 11.06.2026 at Manchester Central Convention Complex, Manchester, United Kingdom; (ii) European Healthcare Design, scheduled from 15.06.2026 to 17.06.2026 at the QEII Centre, Westminster, London, United Kingdom; (iii) International Conference on AI-Driven Data Science in Healthcare (ICIADSH-26), scheduled on 16.06.2026 and 17.06.2026 at Amsterdam, Netherlands; and (iv) International Conference on Healthcare Systems and Services (ICHSS-26), scheduled on 20.06.2026 and 21.06.2026 at Geneva, Switzerland.

3. The learned senior counsel appearing for the applicant submits that the applicant is engaged in running a hospital and that participation in the aforesaid conferences is of considerable professional and business significance. It is further submitted that the applicant has previously been granted permission by this Court to travel abroad on four occasions and, on each such occasion, he had returned to India within the stipulated period while duly complying with all conditions imposed by the Court. Reliance in this regard is placed upon orders dated 20.05.2025, 04.07.2025, 31.10.2025 and 23.03.2026 passed by this Court. It is, therefore, prayed that the applicant be permitted to travel to the United Kingdom, the Netherlands and Switzerland from 09.06.2026 to 23.06.2026. It is also submitted that the applicant is willing to abide by any condition that may be imposed by this Court, including the conditions imposed while granting similar permission vide order dated 23.03.2026.

4. The learned CGSC appearing for respondent no. 3/SFIO submits that a reply along with a duly attested affidavit has been filed opposing the present application. It is submitted that the present application constitutes the fifth successive request seeking suspension of the LOC within a period of about thirteen months and that repeated permissions granted on similar grounds have, in effect, resulted in the LOC remaining continuously suspended despite the investigation still being underway. It is contended that the LOC dated 18.12.2020 continues to be valid and necessary in the facts of the case. It is further submitted that the applicant has failed to comply with the undertaking recorded in paragraph 13(l) of the order dated 23.03.2026, whereby he had undertaken to furnish certain documents within two days. According to SFIO, the documents subsequently furnished were incomplete and did not conform to the commitments made by the applicant during his examination on 22.01.2026. The learned CGSC further submits that the investigation is presently at a crucial stage. The applicant has already been examined by SFIO and summons dated 21.05.2026 have been issued requiring his appearance on 01.06.2026. It is stated that the documents furnished by the applicant are still under scrutiny and his continued availability remains necessary for the effe

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2026 Supreme(Del) 500

IN THE HIGH COURT OF DELHI AT NEW DELHISWARANA KANTA SHARMA, J.Karandeep Singh - PetitionerVersusUnion of India - RespondentW.P.(CRL.) 709 of 2025, CRL.M.A. 6538 of 2025, CRL.M.A. 18766 of 2025 & CRL.M.A. 32144 of 2025Decided On : 03-06-2026

IN THE HIGH COURT OF DELHI AT NEW DELHI
SWARANA KANTA SHARMA, J.
Karandeep Singh - Petitioner
Versus
Union of India - Respondent
W.P.(CRL.) 709 of 2025, CRL.M.A. 6538 of 2025, CRL.M.A. 18766 of 2025 & CRL.M.A. 32144 of 2025
Decided On : 03-06-2026