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Issues: Whether the continued operation of the Look Out Circular against the petitioner was justified and liable to be withdrawn.
Analysis: The right to travel abroad is part of personal liberty under Article 21 and may be restricted only in accordance with a just, fair and reasonable procedure established by law. The governing instructions permit recourse to a Look Out Circular where the accused is deliberately evading arrest or is not appearing before the trial court despite coercive process, coupled with a likelihood of leaving the country to evade trial or arrest. The petitioner was not evading arrest, had joined investigation whenever called, had not been arrested, and had earlier travelled abroad on permitted occasions without violating the terms of permission. In these circumstances, the preconditions for continuing the Look Out Circular were not satisfied.
Conclusion: The continued Look Out Circular was unlawful and was directed to be withdrawn.
Ratio Decidendi: A Look Out Circular can be sustained only when the prescribed conditions for its issuance exist, namely deliberate evasion of arrest or failure to appear despite coercive process, together with a real likelihood of leaving the country to evade the legal process.