A pending investigation alone cannot keep a Look Out Circular alive, Delhi High Court holds

1 October 2026

Justice Amit Mahajan of the Delhi High Court has quashed Look Out Circulars issued by the Directorate of Enforcement against two persons during a money-laundering investigation.
The judgment was delivered on 1 October 2026 in Deep Kumar Rastogi v. Directorate of Enforcement & Another, reported as 2026 LiveLaw (Del) 939.
The court said a Look Out Circular is a coercive measure and cannot be resorted to as a matter of routine merely because an investigation is pending.
The investigation under the Prevention of Money Laundering Act had run for nearly six years.
The court noted that both persons had appeared before the investigators in 2020, had supplied documents and statements, had complied with summons in December 2025, and had travelled abroad without absconding.
While quashing the circulars the court imposed travel conditions reflecting that the investigation is still going on.