Bombay High Court

PATRICIA REITERversusUNION OF INDIA THR THE SECRETARY AND 4 ORS

Disposal: Disposed of

Holding

The order dated 18‑08‑2026 was quashed for violating natural justice, and the petitioner must be given a hearing before the FRRO.

Summary

Petitioner Patricia Reiter challenged an order dated 18‑08‑2026 issued by the Foreigners Regional Registration Officer (FRRO) which was passed without giving her a chance to be heard. The High Court examined whether the principles of natural justice, particularly the audi alteram partem rule, were violated. Relying on the submission of the Additional Government Advocate that the petitioner was denied a hearing, the Court held that the impugned order was procedurally defective. Consequently, the order was quashed and set aside, and the petitioner was directed to be heard by the FRRO on 23‑09‑2026, with the petition itself deemed a representation. The petition was thereafter disposed of in these terms.

Issues considered

Whether the order dated 18‑08‑2026 passed by the FRRO violated the principles of natural justice by not affording the petitioner a hearing.

Subjects

natural justice
right to be heard
FRRO
writ petition
quashing order
procedural fairness

Judgment

2026:BHC-GOA:1868-DB
                                             4 WP 1222 2026

                vinita

                         IN THE HIGH COURT OF BOMBAY AT GOA
                               WRIT PETITION NO.1222 OF 2026

           PATRICIA REITER                                          ... PETITIONER
             Versus
           UNION OF INDIA THR THE SECRETARY
           AND 4 ORS                                                ... RESPONDENTS


           Mr Sahil Deshprabhu, Advocate for the Petitioner.
           Ms S. Vaigankar, Advocate holding for Mr Somnath Karpe,
           Central Govt. Standing Counsel for the Respondent Nos. 1, 4 and
           5.
           Mr Shubham Priolkar, Addl. Govt Advocate for the Respondent
           Nos.2 and 3.


                                 CORAM:- VALMIKI MENEZES &
                                         AMIT S. JAMSANDEKAR, JJ.
                                 DATED :- 16th September, 2026

           P.C.
                     Mr. Priolkar, learned Additional Government Advocate, on
           instructions, submits that the Petitioner was, in fact, not afforded an
           opportunity of being heard before the impugned order dated
           18.8.2026 was passed.
           2.     In view of the aforesaid submission, and on the ground that the
           principles of natural justice were not followed, the impugned order
           dated 18.8.2026 is hereby quashed and set aside.
           3.     The Petitioner shall be afforded an opportunity of being heard
           by the FRRO on 23.09.2026 at 11:00 a.m. at the office of the
           FRRO, Panaji. Upon hearing the Petitioner, the FRRO shall pass an

                                                 Page 1 of 2
                                             16th September, 2026
                                                             4 WP 1222 2026


                       appropriate order in accordance with law. Petition shall itself be
                       considered as a representation of the Petitioner before the FRRO.
                       4.        The Petition stands disposed of in the above terms.



                         AMIT S. JAMSANDEKAR, J.                        VALMIKI MENEZES, J.




Signed by: VINITA VIKAS NAIK
Designation: Private Secretary
                                                                Page 2 of 2
Date: 21/09/2026 12:34:40
                                                            16th September, 2026

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