Allahabad High Court
SATKAR KUMARversusUNION OF INDIA AND 5 OTHERS
- Decided
Holding
The court ordered the Regional Passport Officer to process the passport renewal as per the guidelines of Rahimuddin and Wajiruddin Khan, effectively allowing the renewal.
Summary
Satkar Kumar filed a writ petition under Article 226 seeking the renewal of his passport, which was pending before the Regional Passport Officer. He is a bail‑granted accused in NCR No. 0097 of 2020 under Sections 323 and 504 of the Indian Penal Code. The petitioner relied on the Supreme Court’s guidelines in Rahimuddin v. Union of India, arguing that no court permission is required for passport renewal in a non‑cognizable case. The respondents did not contest this contention. The High Court directed the Regional Passport Officer to decide the renewal application in accordance with the guidelines laid down in Rahimuddin and the later case of Wajiruddin Khan, and disposed of the petition.
Issues considered
- Whether a person involved in a non‑cognizable offence and on bail is entitled to passport renewal without a specific court order under the guidelines of Rahimuddin v. Union of India.
Legislation cited
- Indian Penal Code — s. 323, 504
Subjects
- passport renewal
- non‑cognizable offence
- bail
- Article 226
- High Court
- guidelines
- Indian Penal Code
- Section 323
- Section 504
Judgment
HIGH COURT OF JUDICATURE AT ALLAHABAD
WRIT - C No. - 35714 of 2026
Satkar Kumar
.....Petitioner(s)
Versus
Union Of India And 5 Others
.....Respondent(s)
Counsel for Petitioner(s) : Kiran Yadav, Sanjay Kumar Yadav
Counsel for Respondent(s) : A.S.G.I., C.S.C., Sarveshwar Lal
Srivastava
Court No. - 1
HON'BLE AJIT KUMAR, J.
HON'BLE SIDDHARTH NANDAN, J.
1. Heard learned counsel for the parties.
2. By means of this petition filed under Article 226 of the
Constitution petitioner has prayed for disposal of his application
for renewal of passport pending with the concerned Regional
Passport Officer.
3. Petitioner claims to be involved in NCR No. 0097 of 2020,
under Sections 323, 504 IPC and he is enjoying bail in that case.
Copy of bail order is brought on record as Annexure No. 3 to the
writ petition. It is submitted that the application of the petitioner
is to be processed in view of the guidelines laid down in the
judgment of this Court in the case of Rahimuddin vs. Union of
India & Another (Neutral Citation No. - 2025:AHC:181505-
DB) as no permission of the competent court is required in NCR.
4. Learned counsel for the respondent could not dispute the
aforesaid argument.
5. Be that as it may, we dispose of this petition with a direction to
the Regional Passport Officer concerned to decide the application
of the petitioner in accordance with guidelines laid down and
timeline provided in view of the judgment of this Court in the
case of Rahimuddin vs. Union of India & Another (Neutral
WRIC No. 35714 of 2026
2
Citation No. - 2025:AHC:181505-DB) and recently in the case of
Wajiruddin Khan v. Union of India & 2 Others, (Neutral
Citation No. - 2026:AHC:138176-DB).
6. With the aforesaid observations and directions, this petition
stands disposed of.
(Siddharth Nandan,J.) (Ajit Kumar,J.)
September 16, 2026
A.K.Srivastava
Digitally signed by :-
ARUN KUMAR SRIVASTAVA
High Court of Judicature at Allahabad
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