Delhi High Court Upholds Travel Restriction in Bail Conditions: Balancing Freedom and Investigation Integrity   

Case Title: Disha A. Ravi vs. State (NCT of Delhi) 

Date of Decision: 26.09.2023 

Case Number: CRL.M.C. 5914/2023 & CRL. M.A. 22214/2023 

Coram: Hon’ble Ms. Justice Swarana Kanta Sharma 




Disha A. Ravi, the petitioner, sought the setting aside of an order dated 09.08.2023 passed by the Additional Sessions Judge, Patiala House Courts, New Delhi. This order sought the modification of bail conditions imposed on the petitioner earlier in a case arising from FIR No. 49/2021 registered at the Special Cell, New Delhi, under Sections 124A/153/153A/120B of the Indian Penal Code, 1860 (IPC). 


Factual Background 


The case originated from allegations of a concerted campaign by banned terror organizations to disrupt the Republic Day national ceremony. A Google Document (“toolkit”) was shared on Twitter, allegedly containing plans for a larger conspiracy against India. The toolkit promoted material circulated by a Canada-based organization, and it called for protests outside Indian Embassies. Vandalism occurred outside the Indian Embassy in Rome, Italy, and violence erupted in Delhi on Republic Day, causing substantial damage. The petitioner was arrested on 13.02.2021, granted bail on 23.02.2021, and had been required to seek court permission before traveling abroad. 


Legal Issues 


The primary issue before the court was whether the condition of obtaining prior court permission for foreign travel, as imposed in the bail order, violated the petitioner’s fundamental right under Article 21 of the Indian Constitution. 


Contentions of the Parties 


  • The petitioner argued that the condition of seeking court permission for foreign travel was inconvenient and sought modification to inform the court instead.  
  • The State contended that the condition was necessary to ensure cooperation during ongoing investigations and to prevent any hindrance to future investigations. 


Observation and Analysis 


  • The court analyzed the allegations against the petitioner and the conditions imposed in the bail order.  
  • It emphasized the balance between an individual’s right to travel and the State’s interest in conducting investigations and protecting the proceedings.  
  • The court noted that the right to travel abroad is not absolute and may be subject to reasonable restrictions, especially in criminal cases.  
  • It referred to precedents highlighting that inconvenience to the accused cannot be the sole reason for deleting a reasonable condition imposed by the court.  
  • The court concluded that the condition was a rational restriction meant to secure the petitioner’s presence and ensure the integrity of the investigation.  


Decision of the Court 


The court rejected the petitioner’s request to delete the bail condition requiring prior court permission for foreign travel. However, it directed that the petitioner should apply for permission at least one month in advance, allowing the court to consider the plea and the State’s response promptly. The court clarified that its decision did not express any opinion on the merits of the case. 


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Written by – Ananya Chaudhary 

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