Look Out Circulars require recorded necessity and evasion before issuance; absent those conditions, writ review can quash them.

Writ jurisdiction was held available where part of the cause of action arose within the court's territorial limits, because the FIR, Section 41A notice, and the petitioner's residence had a sufficient nexus with Chennai and forum conveniens did not justify refusal. The Look Out Circular was quashed because the governing instructions required cognizable offence-based necessity, deliberate evasion of arrest or appearance, and recorded reasons, none of which were shown when notice to appear had already been issued and no material supported coercive action. The circular was treated as amenable to judicial review due to its adverse civil consequences, while the FIR proceedings themselves were left unaffected.

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Issues: (i) Whether the writ petitions were maintainable before the High Court on the basis that part of the cause of action arose within its territorial jurisdiction. (ii) Whether the Look Out Circular was validly issued when the statutory and administrative conditions for such coercive action were not shown to exist.

Issue (i): Whether the writ petitions were maintainable before the High Court on the basis that part of the cause of action arose within its territorial jurisdiction.

Analysis: The FIR, the notice under Section 41A, and the petitioner's residence and alleged place of implementation of the impugned circular had nexus with Chennai. In writ jurisdiction, even a part of the cause of action is sufficient to confer jurisdiction, and the doctrine of forum conveniens did not justify refusal to entertain the petitions on these facts.

Conclusion: The writ petitions were maintainable before the High Court, and the territorial jurisdiction objection was rejected.

Issue (ii): Whether the Look Out Circular was validly issued when the statutory and administrative conditions for such coercive action were not shown to exist.

Analysis: The governing executive instructions contemplated recourse to a Look Out Circular only in cognizable offences where the accused was deliberately evading arrest or avoiding appearance, and reasons had to be stated in support of the request. On the date of issuance, notice under Section 41A had already been issued for appearance and there was no material showing evasion, failure to appear despite coercive steps, or recorded reasons demonstrating necessity for the circular. The court held that such a circular is amenable to judicial review under Article 226 because it carries adverse civil consequences affecting liberty and free movement.

Conclusion: The Look Out Circular was invalid and liable to be quashed.

Final Conclusion: The writ petitions succeeded, the impugned Look Out Circular was set aside, and the criminal proceedings arising from the FIR were left unaffected.

Ratio Decidendi: A Look Out Circular, being a coercive executive measure with adverse civil consequences, can be interfered with in writ jurisdiction when the prescribed conditions for its issuance are absent and no recorded reasons justify action against a person who is not shown to be evading arrest or appearance.

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