The Delhi High Court on September 19, 2025, quashed a Look Out Circular (LOC) against a British citizen of Indian origin who was detained in India over alleged links to her uncle, an accused in a Black Money Act and Imposition of Tax Act, 2015 case. Justice Sachin Datta concluded that mere familial ties of an accused does not validate the issuance of LOC to the petitioner.
The petitioner, a British citizen woman of Indian origin, approached the court seeking the withdrawal of a Look Out Circular (LOC) issued against her by the Enforcement Directorate (ED). The LOC stemmed from a 2017 Enforcement Case Information Report (ECIR) against her estranged maternal uncle under the Black Money Act, 2015. Although she was not named in the complaint, she was stopped at Delhi airport on March 23 2025, detained for several hours, interrogated, and had her passport and phone confiscated, preventing her from returning to the UK for medical treatment and to care for her minor son. The petitioner argued that the LOC was unlawful, pointing out that she was not an accused and that LOCs are meant to be issued only in cases involving cognizable offences.The respondents contended that she had close personal and business ties with her uncle and husband, citing her admission of handing over her debit card to Sanjay Bhandari and witness statements indicating joint management of funds reportedly worth ₹535 crores. They noted pending details, data retrieved from her impounded phone, and the need for her cooperation in the ongoing investigation.The respondents also disputed her medical urgency, stating treatment could be conducted in India, and emphasized that LOCs are administrative measures with limited judicial review, citing precedents denying quashing on medical grounds.
The Court noted that the petitioner had never been named as an accused since the 2017 ECIR and held that mere familial ties with an accused cannot warrant the issuance of an LOC. The Court also emphasized that LOCs cannot be used preventively against individuals who are not accused and that exceptions relating to economic or public interest cannot be invoked lightly. Therefore, considering the petitioner’s full cooperation, serious health conditions, expired/expiring visa, and need to care for her minor son, the Court directed that the petitioner file an undertaking to cooperate fully with ongoing investigations. The Court quashed the LOC and permitted the petitioner to return to the UK, cautioning that any breach of her undertaking would attract contempt proceedings and other legal consequences, thereby disposing of the petition and all pending applications.
Appearances:
For the Petitioner : Advs. Mr. Amit Sibal, Sr. Adv., Mr. Ankit Bhatia, Mr. Vinay Tripathi, Mr. Rajat Bector and Ms. Smriti Nair
For the Respondent : Advs. Mr. Zoheb Hossain, Spl. Counsel, Mr. Vivek Gurnani, Panel Counsel, Mr. Kartik Sabharwal, Mr. Pranjal Tripathi and Mr. S.K. Raqeeb ED.
