Allahabad High Court
VIKRAM PATELversusUNION OF INDIA AND 6 OTHERS
- Decided
Holding
The petition is disposed with a direction that the petitioner first comply with the guidelines of the cited judgments before the passport authority decides the application.
Summary
The petitioner, Vikram Patel, filed a writ petition under Article 226 seeking the disposal of his pending application for a fresh passport. The respondents, the Union of India and others, argued that a show‑cause notice had been issued to the petitioner because of a criminal case pending against him under Sections 506, 504, 325 and 323 of the Indian Penal Code. The Court observed that the petitioner must first comply with the procedural guidelines laid down in the earlier judgments of Rahimuddin v. Union of India and Wajiruddin Khan v. Union of India. After complying with those guidelines, the Regional Passport Officer should decide the passport application within the timelines prescribed. Accordingly, the Court disposed of the petition with directions to follow the said guidelines.
Issues considered
- Whether a pending criminal case under the IPC bars the issuance of a fresh passport to the petitioner.
- Whether the petitioner must comply with the procedural guidelines issued in Rahimuddin v. Union of India and Wajiruddin Khan v. Union of India before the passport application can be decided.
Legislation cited
- Indian Penal Code — s. 323, 325, 504, 506
Subjects
- passport issuance
- criminal case
- show cause notice
- Article 226
- procedural guidelines
- Indian Penal Code
- High Court
Judgment
HIGH COURT OF JUDICATURE AT ALLAHABAD
WRIT - C No. - 38169 of 2026
Vikram Patel
.....Petitioner(s)
Versus
Union Of India And 6 Others
.....Respondent(s)
Counsel for Petitioner(s) : Shivam Kumar Mishra
Counsel for Respondent(s) : A.S.G.I., C.S.C.
Court No. - 1
HON'BLE AJIT KUMAR, J.
HON'BLE GARIMA PRASHAD, J.
1. Heard Sri Manoj Kumar singh, learned counsel for the petitioner as
well as Mr. Gaurav Kumar Chand, learned counsel for the respondents-
Union of India and learned Standing Counsel for the State respondents.
2. By means of this petition filed under Article 226 of the Constitution
petitioner has prayed for disposal of his application for issuance of fresh
passport pending with the concerned Regional Passport Officer.
3. Per contra, it is submitted by learned counsel for the respondents that
the petitioner has been issued with the show cause notice to explain about
the following criminal case which is pending against him:
(i) Case Crime No.- 0186 of 2018, under Sections 506, 504, 325, 323
I.P.C., Police Station - Madanpur, District - Deoria.
4. In our considered view, petitioner should, in the first instance, take
steps according to the guidelines and follow the procedures 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) and
recently in the case of Wajiruddin Khan v. Union of India & 2 Others,
(Neutral Citation No. – 2026:AHC:138176-DB) and thereafter, the
Regional Passport Officer concerned shall dispose of the application of
the petitioner in accordance with guidelines laid down and timeline
provided in the aforesaid judgments.
WRIC No. 38169 of 2026
2
5. With the aforesaid observations and directions, this petition stands
disposed of.
(Garima Prashad,J.) (Ajit Kumar,J.)
September 30, 2026
Atmesh
Digitally signed by :-
ATMESH KESARI
High Court of Judicature at Allahabad
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