Look Out Circulars must rest on disclosed reasons and real flight-risk material; an unsupported economic-interest claim is insufficient.

A Look Out Circular was held to be a coercive restriction on the right to travel abroad under Article 21 and could issue only if the governing Office Memorandum and procedural safeguards were satisfied. The framework required disclosed reasons and material showing deliberate evasion, non-appearance, or a real likelihood that the person would leave India to avoid investigation or trial. On the facts, the record showed prior cooperation with investigation and no substantiated finding of flight risk, lack of roots in India, or demonstrated prejudice to India's economic interests. The LOC and its extension were therefore quashed as unsustainable, but the investigation itself remained unaffected.

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Issues: Whether the Look Out Circular issued and extended against the petitioner was valid in law, particularly in the absence of disclosed reasons, any material showing a likelihood of flight, or any demonstrated prejudice to the economic interest of India.

Analysis: The right to travel abroad was treated as part of personal liberty under Article 21 of the Constitution of India, and a Look Out Circular was recognised as a coercive measure that must satisfy the conditions laid down in the governing Office Memorandum and the applicable procedural safeguards. The governing framework required the request for issuance of an LOC to contain reasons, and LOCs could not be issued as a matter of course; they were justified where there was material showing deliberate evasion, non-appearance, or a real likelihood of the person leaving the country to evade investigation or trial. On the facts, the petitioner had joined investigation on earlier occasions, and the record did not disclose any finding that he was a flight risk or that he had no roots in India. The only basis relied upon was alleged evasive or non-cooperative conduct, which was held insufficient by itself. The asserted economic-interest justification was also not substantiated by any specific reason showing how travel would prejudice that interest.

Conclusion: The Look Out Circular and its extension were held to be unsustainable and were quashed, while the investigation itself was left unaffected.

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