Delhi High Court

### LOC may be quashed if personal liberty outweighs flight risk during pending statutory inquiries.

Saurabh Khanna v. Union of India through Ministry of Corporate Affairs & Anr. [W.P.(C) 4801/2025]

Delhi High Court2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner, an NRI residing in the UAE and Managing Director of Grownd Realty Pvt. Ltd., challenged a Look Out Circular (LOC) issued against him by the Ministry of Corporate Affairs

Source reference: p. 1-2

The LOC originated from a complaint by the Petitioner’s father and a statutory auditor’s report under Section 143(12) of the Companies Act, alleging a siphoning of ₹58 Crores

Source reference: p. 2

An inquiry was initiated under Section 210(1)(c) of the Act.

Source reference: no citation

The Petitioner failed to appear for a summons on 10.01.2025, leading to the LOC

Source reference: p. 2

During the pendency of the writ, the Petitioner was granted permission to travel abroad on five separate occasions and returned each time

Source reference: p. 3-4

Notably, the father had since withdrawn his complaint

Source reference: p. 4
02

Issues

Whether the continued subsistence of the Look Out Circular (LOC) against the Petitioner is legally sustainable in light of his cooperation and the fundamental right to travel

Source reference: p. 4-5

Whether an LOC can be maintained when no FIR has been registered and the subject has demonstrated no risk of absconding

Source reference: p. 5-7
03

Law Applied

The Court primarily applied the principles governing personal liberty under Article 21 of the Constitution of India, establishing that the right to travel abroad is an integral facet of personal liberty

Source reference: p. 4

It relied on *Maneka Gandhi v. Union of India* regarding the necessity of fair procedure

Source reference: p. 4

and *Sumer Singh Salkan v. Asst. Director* regarding the conditional nature of LOCs

Source reference: p. 4, 6

Furthermore, the court applied the "guiding principles" from *Vineet Gupta v. Union of India*, which mandate that LOCs must satisfy the tests of necessity, proportionality, and due process; they cannot be indefinite and must be narrowly construed, especially under Clause 6(L) of the Office Memorandum dated 22.02.2021

Source reference: p. 5-6
04

Reasoning

The Court reasoned that an LOC is a coercive measure that must be exercised sparingly

Source reference: p. 5

It observed that despite the Respondent's apprehension regarding the Petitioner's "Golden Visa" status in Dubai, there was no tangible evidence of him evading the law

Source reference: p. 3

The Court highlighted that no FIR had been registered to date

Source reference: p. 3

Crucially, the Petitioner’s conduct—having traveled abroad five times under court permission and returning to join the proceedings—demonstrated that he was not a flight risk

Source reference: p. 3-4

The Court noted that since the original complainant (the Petitioner's father) had withdrawn the complaint and the Petitioner committed to future cooperation, the LOC no longer met the threshold of "necessity" or "proportionality" required to restrict a citizen's fundamental right to travel under Article 21

Source reference: p. 4, 6
05

Holding

The Court quashed and set aside the Look Out Circular issued against the Petitioner

The holding was subject to conditions: the Petitioner must file an undertaking to cooperate with the investigation, produce requested documents, and provide a full itinerary and contact details to the Investigating Agency 15 days prior to any travel

Source reference: p. 7

The Court reserved liberty for the Respondents to reopen the LOC or restrain travel should the Petitioner fail to cooperate or if circumstances warrant fresh restrictions

Source reference: p. 7

The writ petition was disposed of accordingly

Source reference: p. 7
Delhi High Court

Original Court PDF

Saurabh Khanna v. Union of India through Ministry of Corporate Affairs & Anr. [W.P.(C) 4801/2025]

Delhi High Court

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment