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2026 Supreme(Online)(Guj) 17106

IN THE HIGH COURT OF GUJARAT AT AHMEDABAD
Gita Gopi, J
SUNIL SURENDRAKUMAR KAKKADV/sSTATE OF GUJARAT
R/CRIMINAL REVISION APPLICATION (MODIFICATION OF CONDITION/ORDER) NO. 1328 of 2026



Advocates:
For the Appellants/Petitioners: Aditya A Gupta
For the Respondents: Pranav Dhagat

A court may temporarily suspend travel restrictions imposed as a condition of bail to allow an individual to travel abroad for legitimate business purposes upon verification of supporting documentation.

Headnote:The applicant sought the suspension of a bail condition prohibiting travel outside the local limits of Gujarat without prior court permission. The applicant presented a purchase order for a business assignment in Dubai with a duration of 13 months plus an additional 6 months, noting that the initial period had expired on 10.3.2026. The primary issue was whether the travel restriction should be modified to allow the applicant to travel for business purposes. The court reasoned that based on the perusal of the purchase order and the fact that the matter had been stayed, the restriction could be suspended for a specific period to facilitate the business trip. Rule made absolute.

Table of Content
1. request for modification of bail conditions regarding travel restrictions. (Para 1 , 2)
2. evaluation of business documentation to justify travel necessity. (Para 3 , 4)
3. granting temporary suspension of travel restrictions for business purposes. (Para 5 , 6 , 7)

ORDER

1. RULE. Learned APP waives service of notice on behalf of the respondent-State.

2. By way of this application, a prayer is made for suspension of condition no.(2)(f) passed in the order dated 25.1.2024 by the learned Sessions Judge, Amreli in Criminal Miscellaneous Application no.50 of 2024. Condition No.(2)(f) reads as under:-

“(f) applicant shall not leave the local limits of Gujarat without prior permission of this Court;”

3. Mr. Aditya Gupta, learned advocate for the applicant submitted that the learned Sessions Judge while rejecting the application on 2.4.2026 in Criminal Misc. Application no.145 of 2026 has not perused the referred documents, i.e. the Purchase Order in its totality. It is further submitted that the duration of the purchase assignment is 13 months + 6 months and submitted that the case where bail has been granted has been stayed by way of ad-interim relief on 5.9.2024 by this Court and the matter has been admitted and the interim relief has been confirmed.

4. Learned Additional Public Prosecutor referring to the observations made by the learned Sessions Judge, has place reliance on the purchase order to submit that the learned Sessions Judge has referred to only 13 months, which has been specifically stated and further submitted that the observations made therein are just and proper.

5. Having heard the submissions canvassed and on perusing the records of the case, it is clear that the purchase order is for a duration of 13 months + 6 months. As observed, the 13 months period got exhausted on 10.3.2026, as per the Purchase Order. Since the matter has been stayed, and the applicant would like to visit Dubai for the purpose of business, the condition no.(2)(f) of the order of bail dated 25.1.2024 passed in Criminal Miscellaneous Application no.50 of 2024 is suspended for a period of six (6) months from today.

6. It is directed that the Passport be handed over to the applicant after carrying out the appropriate procedures for verification of his identity. The applicant is permitted to travel out of India during the period as prayed for, after disclosing his detailed itinerary before the learned Sessions Court and on his return, within one week, shall deposit the Passport to the CBI Court.

7. With the aforesaid direction, this application stands disposed of. Rule made absolute. Direct Service is permitted.

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