The Bombay High Court has quashed a Look Out Circular (LOC) issued against industrialist Baldevraj Topan Ram Taneja, holding that the restriction on his foreign travel was unnecessary when he had consistently cooperated with investigators. The court observed that the right to travel abroad forms part of the constitutional guarantee of personal liberty and cannot be curtailed without sufficient justification.
The ruling came in a writ petition filed by the 89-year-old businessman challenging the LOC issued during an investigation by the Serious Fraud Investigation Office (SFIO).
Background of the Case
Baldevraj Topan Ram Taneja, a Pune resident and founder associated with M/s ISMT Limited, approached the court seeking the cancellation of a Look Out Circular issued against him. The circular was linked to an SFIO investigation initiated in October 2020 under Section 212(1) of the Companies Act, 2013 regarding the affairs of the company.
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According to the petitioner, he had served on the board of ISMT until March 10, 2022. The company later resolved its debt through a one-time settlement with lenders, clearing its outstanding liabilities.
However, on April 18, 2022, Taneja was stopped at Mumbai’s Chhatrapati Shivaji Maharaj International Airport when he attempted to travel abroad. He later learned that an LOC had been issued against him, effectively preventing him from leaving the country.
Through the petition, he argued that the LOC violated established legal guidelines and interfered with his fundamental rights, particularly his ability to travel abroad.
Counsel for the petitioner told the bench that Taneja had consistently cooperated with the investigation and had deep social and business ties in India.
“The petitioner has always cooperated with the investigation and has never attempted to evade the authorities,” the counsel submitted, emphasizing that he was neither arrested nor accused of breaching any conditions imposed by the court.
During the pendency of the case, the High Court had also permitted him to travel abroad on specific occasions. The petitioner complied with all conditions and returned to India within the permitted time, which, according to his counsel, showed there was no risk of him absconding.
On the other hand, the prosecution argued that the SFIO investigation report indicated that the petitioner, as founder of ISMT, failed to ensure accurate financial disclosures and approved statements that allegedly violated provisions of the Companies Act.
The government suggested that even if the LOC were removed, the court could require the petitioner to deposit his passport and obtain court permission before traveling abroad.
After hearing both sides, the division bench noted that the petitioner’s cooperation with the investigation was not disputed by the authorities. The court also observed that he had previously been allowed to travel abroad and had returned without violating any conditions.
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The bench Justice A. S. Gadkari and Justice Shyam C. Chandak stated that there was no serious apprehension that Taneja would flee the country if the LOC were cancelled.
“The right to travel is an integral part of the right to personal liberty under Article 21 of the Constitution,” the court observed, adding that unreasonable restrictions on such travel could affect a person’s quality of life and personal well-being.
The judges also took into account the petitioner’s advanced age and his wish to visit family and friends abroad while his health permitted.
Concluding that the Look Out Circular served no necessary purpose in the circumstances, the Bombay High Court allowed the petition.
The bench ordered that the LOC issued against Baldevraj Topan Ram Taneja on February 22, 2021, be quashed and set aside, thereby restoring his ability to travel abroad.
The court made the rule absolute and disposed of the petition accordingly.
Case Title:- Baldevraj Topan Ram Taneja v. Assistant Director, Serious Fraud Investigation Office & Ors.
Case Number:- Criminal Writ Petition No. 4234 of 2022
Date of Judgment:- 25 February 2026
