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Supreme Court of India 2025-12-19 allowed

Mahesh Kumar Agarwal vs Union of India & Anr

Bench: 2 — Vikram Nath, Augustine George Masih

In Brief

A man facing criminal proceedings and a pending appeal sought passport renewal. The passport authority refused, citing a statutory bar against issuing passports when proceedings are pending. However, the criminal courts themselves had permitted renewal, imposing strict conditions. The Supreme Court held that while the statute contains such a bar, an exemption notification allows renewal when criminal courts grant permission. The courts' conditions—requiring prior permission for travel and redeposit of the passport—adequately protected judicial interests. Treating the bar as absolute despite court permission was disproportionate to Article 21's protection of personal liberty. The Court directed passport re-issuance for the normal 10-year period, subject to the criminal courts' control over travel.

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Constitutional Law Personal Liberty Passports Criminal Procedure Administrative Law Right to Travel Statutory Exemptions

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