Passport renewal cannot be withheld after investigation cooperation where no lawful impounding by the competent authority is shown.

Where a petitioner had cooperated with investigation from the UAE through audio-video electronic means and no lawful impounding by the competent passport authority was shown, continued restraint on passport renewal was not justified. The text notes that impounding of a passport lies with the competent authority under the Passports Act, and that renewal for ten years is legally permissible. In these circumstances, the court modified its earlier order to direct instructions for renewal of the passport for ten years and its handover to the petitioner in the UAE.

---

---

Issues: Whether the order dated 6 May 2025 required modification to direct the respondent to issue instructions for renewal of the petitioner's passport for ten years and its handover in the UAE after the petitioner had cooperated with the investigation.

Analysis: The request was confined to a limited modification of the earlier order. The petitioner had already joined the investigation from the UAE through audio-video electronic means on multiple dates in compliance with the earlier directions. The impugned restraint on renewal was not shown to be an impounding action by the competent passport authority. The legal position recognised that impounding of a passport lies with the competent authority under the Passports Act, and that renewal for ten years is permissible in law. In these peculiar circumstances, the continued withholding of the passport renewal was not justified after cooperation with the investigating agency.

Conclusion: The application was allowed and the order dated 6 May 2025 was modified so as to direct appropriate instructions for renewal of the passport for ten years and its handover to the petitioner in the UAE.

Ratio Decidendi: After a litigant has complied with investigation-related directions and no lawful impounding by the competent passport authority exists, withholding renewal of the passport cannot continue and the court may modify its earlier order to secure renewal and return of the passport.

---