Passport renewal can be refused during a PMLA investigation when personal appearance and cooperation are not provided.

Refusal to renew a passport may be sustained where a person is subject to a continuing PMLA investigation, repeated summons under Section 50, and a legitimate insistence on personal appearance for interrogation. Sending an authorised representative and documents was treated as insufficient when the investigating agency required the individual's own cooperation. The court also referred to the statutory presumption under Section 23 of the PMLA and the expectation that a person seeking discretionary relief under Section 482 CrPC must approach with clean hands and cooperate with the investigation. On those facts, no interference with the refusal to renew the passport was called for.

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Issues: Whether the refusal to permit renewal of the petitioner's passport, during pending further investigation under the Prevention of Money-Laundering Act, 2002, called for interference.

Analysis: The renewal request was considered against the backdrop of an ongoing further investigation, repeated summons issued under Section 50 of the Prevention of Money-Laundering Act, 2002, and the petitioner's failure to appear in person despite insistence by the investigating agency. Sending an authorised representative and documents was held insufficient where personal appearance was required for interrogation. The Court also noted the statutory presumption operating under Section 23 of the Prevention of Money-Laundering Act, 2002 and the expectation that a person seeking discretionary relief under Section 482 of the Code of Criminal Procedure, 1973 must approach with clean hands and cooperate with the investigation.

Conclusion: The refusal to renew the passport was upheld and no interference was called for.

Final Conclusion: The petition failed because the petitioner had not complied with the investigation requirements and the requested relief could not be granted without his personal cooperation.

Ratio Decidendi: Where personal appearance is legitimately required in a continuing investigation, discretionary relief affecting travel documents may be declined until the person concerned submits to interrogation and cooperates with the investigating agency.

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