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Passport Authority Can’t Refuse Renewal to GST Arrest Accused out on Bail when Trial Court NOC Exists: Delhi HC Directs Passport Renewal [Read Order]

The court held passport renewal can’t be denied in a GST arrest bail case despite trial court NOC, and ordered 10-year renewal.

Kavi Priya
Passport Authority Can’t Refuse Renewal to GST Arrest Accused out on Bail when Trial Court NOC Exists: Delhi HC Directs Passport Renewal [Read Order]
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In a recent ruling, the Delhi High Court held that the Passport Authority cannot refuse passport renewal to a person arrested in GST proceedings and later released on bail even when the trial court has given NOC for renewal for ten years. Mukul Mittal filed a writ petition challenging the order dated 27.02.2025 by the Regional Passport Office rejecting his renewal request. The RPO...


In a recent ruling, the Delhi High Court held that the Passport Authority cannot refuse passport renewal to a person arrested in GST proceedings and later released on bail even when the trial court has given NOC for renewal for ten years.

Mukul Mittal filed a writ petition challenging the order dated 27.02.2025 by the Regional Passport Office rejecting his renewal request. The RPO said he must submit a court order specifically permitting him to depart from India.

The petitioner’s passport was valid till 05.06.2025. He was facing GST related proceedings from DG GST Intelligence. A criminal complaint under Sections 172, 174 and 175 IPC was pending before Patiala House Court and GST investigation proceedings were also going on. He was arrested under Section 69 CGST Act and got bail with condition that he will not leave India without court permission.



When he applied for renewal earlier, the trial court gave orders allowing renewal, including one order permitting renewal for ten years. Still the passport office renewed it only for one year. Later he again applied for renewal and got fresh trial court orders in both matters clearly permitting renewal for ten years. Even after this, the passport office rejected the renewal on 27.02.2025 saying there is no order permitting him to depart from India.

The petitioner’s counsel argued that renewal of passport is different from permission to travel abroad, and the bail condition already requires him to take court permission before leaving India. He said the passport office is wrongly rejecting his case only on wording.



Justice Sachin Datta observed that GSR 570(E) allows passport renewal in pending criminal cases if court has applied mind. The court relied on Supreme Court judgment in Mahesh Kumar Agarwal (2025) and observed that passport authorities cannot demand a separate “depart from India” order for renewal. If the trial court allows renewal and keeps travel control with court, it is enough.

The court directed the passport authority to renew Mukul Mittal’s passport for ten years as per the trial court orders dated 03.02.2025.


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SH. MUKUL MITTAL vs SR. SUPERINTENDENT POLICY REGIONAL PASSPORT OFFICE , 2026 TAXSCAN (HC) 300 , W.P.(C) 6612/2025 , 02 February 2026 , Ms. Vibhooti Malhotra , Mr. Ashish K
SH. MUKUL MITTAL vs SR. SUPERINTENDENT POLICY REGIONAL PASSPORT OFFICE
CITATION :  2026 TAXSCAN (HC) 300Case Number :  W.P.(C) 6612/2025Date of Judgement :  02 February 2026Coram :  HON'BLE MR. JUSTICE SACHIN DATTACounsel of Appellant :  Ms. Vibhooti MalhotraCounsel Of Respondent :  Mr. Ashish K
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