Look Out Circulars during pending investigation may be sustained without prior hearing where flight risk and investigative need are shown.

A Look Out Circular may be issued or extended during a pending criminal investigation where authorities have a reasonable apprehension that the person may leave the jurisdiction and impede the inquiry. The right to travel abroad remains part of personal liberty, but it is subject to law, and the Passports Act permits restrictions in appropriate cases. On the facts, prior hearing was not treated as indispensable because the matter was regarded as an exceptional case involving investigative necessity. The challenge failed, the circular was sustained, and the petitioner was directed to cooperate with the investigation.

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Issues: Whether the Look Out Circular issued against the petitioner and its subsequent extension were illegal for want of hearing and for alleged inconsistency with the Passports Act, 1967 and Articles 14, 19 and 21 of the Constitution of India.

Analysis: The right to travel abroad is part of personal liberty, but it is subject to law. The Passports Act, 1967 recognizes restrictions where criminal proceedings are pending, and a Look Out Circular is a coercive measure intended to secure the presence of an accused during investigation. The investigation in the case was still pending, the petitioner had earlier been found not to have complied fully with conditions imposed in connected proceedings, and the authorities had material to apprehend that he might leave the jurisdiction and impede investigation. In such circumstances, the Court held that prior hearing was not indispensable and that the case fell within the category of an exceptional case in which the circular could be issued and extended.

Conclusion: The Look Out Circular and its extension were upheld as valid, and the challenge to them failed.

Final Conclusion: The writ petition was dismissed, with consequential directions requiring the petitioner to cooperate with the investigation and leaving it open to seek cancellation of the Look Out Circular in accordance with law after completion of investigation.

Ratio Decidendi: A Look Out Circular may be validly issued or extended in a pending criminal investigation where there is a reasonable apprehension that the accused may leave the country, and prior hearing is not mandatory if the measure is lawfully taken to secure investigation in an exceptional case.

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