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Issues: Whether the petitioner was entitled to a mandamus directing consideration of his representation for withdrawal of the look-out circular and whether the investigation required his continued restraint from foreign travel.
Analysis: The petitioner's travel restriction arose from a look-out circular issued in the course of an investigation under the Prevention of Money Laundering Act, 2002. The governing guidelines contemplated issuance of a look-out circular in cognizable offences and required the originating agency to review the need for its continuance. The petitioner asserted hardship arising from prolonged restraint on travel, while the respondents maintained that his cooperation was still necessary for completion of investigation, including disclosure of relevant access credentials and transaction details. The Court noted that a person connected with the investigation must cooperate, but also that a look-out circular cannot remain indefinitely as a perpetual restraint on movement. The Court therefore directed the Enforcement Directorate to complete the petitioner's interrogation and related inquiry within a fixed time and thereafter to consider the petitioner's representation for withdrawal of the look-out circular.
Conclusion: The petitioner was granted limited relief by way of a direction to the respondents to consider the representations and act in accordance with law after completion of the time-bound investigation steps.
Final Conclusion: The writ petition was disposed of with a time-bound direction balancing investigative necessity with the petitioner's right to travel, leaving the question of withdrawal of the look-out circular to be considered after completion of the directed investigation.
Ratio Decidendi: A look-out circular may be sustained for investigative necessity, but it cannot be allowed to operate indefinitely where the agency can complete the required inquiry within a fixed time and then reconsider withdrawal in accordance with law.
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