Rana Ayyub vs UOI filing copy.pdf

IN THE HIGH COURT OF DELHI AT NEW DELHI
CRIMINAL WRIT JURISDICTION
WRIT PETITION (CRL.) No. __________ of 2022
IN THE MATTER OF:
RANAAYYUB …Petitioner
Versus
UNION OF INDIA & ANR. …Respondents
INDEX
Sr. No. Particulars Pages
1. Court Fee 1
2. Notice of Motion 2
3. Urgent Application 3
4. Memo of Parties 4-5
5. Synopsis and List of Dates 6-22
6. Writ Petition along with affidavit 23-60
7. Annexure A-1
True copy of two social media posts illustrative
of the relief work done by the Petitioner and her
team of volunteers
61
8. Annexure A-2
True copy of Discharge summary issued by
Lilavati Hospital and Research Centre
62-65
9. Annexure A-3
True copy of FEMA Order dt. 03.08.2021
66-67

10. Annexure A-4
True copy of the Petitioner’s reply to Mumbai
Zonal Office of the Enforcement Directorate dt.
20.08.2021
68-71
11. Annexure A-5
True copy of Notice of Demand dt. 04.09.2021
72
12. Annexure A-6
True copy of Summons dt. 10.12.2021
73-74
13. Annexure A-7
True typed copy of letter dt. 17.12.2021 sent by
the Petitioner
75
14. Annexure A-8
True copy of email dated 19.12.2021 sent by the
Petitioner
76
15. Annexure A-9
True copy of summon dt. 25.01.2022
77-79
16. Annexure A-10
True copy of letter dt. 27.01.2022 sent to
Mumbai Zonal Office of the Enforcement
Directorate
80
17. Annexure A-11(Colly)
True copy of email dt. 31.01.2022 along with
the response of the Petitioner dt. 31.01.2022
81-82
18. Annexure A-12
True copy of email dt. 01.02.2022 sent by Shri
Devender, Asst. Director of Respondent No. 2
83
19. Annexure A-13
True copy of communication dt. 05.02.2022
from HDFC Bank
84-84A
20. Annexure A-14
True copy of Show-Cause Notice dt. 08.03.2022
85
21. Annexure A-15
True copy and typed copy of
Petitioner’s application dt. 16.03.2022
86-87B

22. Annexure A-16
True copy of email dt. 22.03.2022 sent by
Respondent No. 2
88-89
True copy of invitation for event organised by
The International Center for Journalists (ICFJ),
Doughty Street Chambers and the International
Bar Association’s Human Rights Institute
(IBAHRI), as well as event images of the events
in Perugia, Italy
90-93
24. Annexure A-18
True copy of Petitioner’s round-trip tickets
94-100
25. Annexure A-19
True copy of Petitioner’s relevant passport
pages
101-103
True copy of email and summons dt. 29.03.2022
104-109
27. Annexure A-21
True copy of news report by Financial Express
110
28. Crl. M.A. No. ____ of 2022
APPLICATION UNDER SECTION 482 OF
THE CODE OF CRIMINAL PROCEDURE,
1973, SEEKING AD INTERIM EX-PARTE
STAY OF OPERATION OF ANY LOOK OUT
CIRCULAR, ORDER, INSTRUCTION OR
DIRECTION ISSUED BY RESPONDENT NO.
2 PREVENTING THE PETITIONER FROM
TRAVELLING OUTSIDE INDIA
(with supporting affidavit)
111-116
29. Crl. M.A. No. _____ of 2022
APPLICATION UNDER SECTION 482 OF
THE CODE OF CRIMINAL PROCEDURE,
1973, SEEKING EXEMPTION FROM FILING
CERTIFIED / TRUE TYPED COPIES OF DIM
/ ILLEGIBLE ANNEXURES
(with supporting affidavit)
117-120
30. Proof of Service 121-121A

31. Vakalatnama 122
Through:
Vrinda Grover, Soutik Banerjee,
Mannat Tipnis and Devika Tulsiani
Advocates
N-SQ. 7, Saket, New Delhi - 110017
8527075320
soutikbanerjee92@gmail.com
New Delhi
31.03.2022

IN THE MATTER OF:
Versus
COURT FEE
1

IN THE MATTER OF:
Versus
Notice of Motion
Sir,
Please take Notice that the present matter may be listed on 01.04.2022 or
any day thereafter.
Advocates
8527075320
New Delhi
31.03.2022
2

IN THE MATTER OF:
Versus
Urgent Application
To,
The Registrar
Hon’ble High Court of Delhi
New Delhi
Kindly treat the present petition as urgent as per Rules, and list the same
at the earliest. The grounds for urgency, detailed in the petition and
accompanying applications, is summarised as follows:
The Petitioner was wrongly and illegally detained and stopped from
travelling to London and Italy on 29.03.2022 on the instructions of
Respondent No. 2. That unless urgent reliefs as prayed for in the present
petition are granted, the Petitioner will be unable to travel in time to
attend the journalistic events scheduled between 01.04.2022 and
11.04.2022 in London and Italy.
Advocates
8527075320
New Delhi
31.03.2022
3

IN THE MATTER OF:
Versus
Memo of Parties
1. Rana Ayyub
D/o Ayyub Shaikh, aged about 38 years,
R/o 705, Sea Queen Avenue B wing, Sector – 14, Koperkhairane,
Navi Mumbai,
Thane, Maharashtra, 400709 …Petitioner
Versus
1. Union of India
Through Bureau of Immigration,
Ministry of Home Affairs,
East Block - 8, Level - 2, Sector-1, R.K. Puram,
New Delhi - 110066
E-mail: uoidhc@gmail.com / cgsc461@gmail.com
Contact: 9811191920 …Respondent 1
2. Directorate of Enforcement
Delhi Zonal Office - II
Pravartan Bhawan, Motilal Nehru Marg,
New Delhi - 110011
4

E-mail: uoidhc@gmail.com / cgsc461@gmail.com /
dddlzoii5-ed@gov.in
Contact: 9811191920 …Respondent 2
Advocates
8527075320
New Delhi
31.03.2022
5

SYNOPSIS
That the present petition is being filed by the Petitioner seeking
immediate and urgent reliefs in the nature of Mandamus / Certiorari,
seeking inter-alia that the Petitioner be enabled to travel out of India, and
that any order, Look Out Circular, instruction or direction preventing the
Petitioner from travelling abroad be quashed and set aside.
That the Petitioner is an Indian investigative female journalist and a
global opinions writer at the Washington Post. The Petitioner has worked
as a reporter, editor and columnist with some of the leading publications
in India and internationally. Her articles appear in the Time, New York
Times, Guardian and Foreign Policy among other foreign publications.
The Petitioner has been profiled by prestigious publications including
The New Yorker, the Atlantic, Time, Guardian and Observer among
others. In a career spanning fifteen years, the Petitioner has been awarded
the Sanskriti award for integrity and excellence in journalism by the
former President of India, Shri A.P.J. Abdul Kalam. She was also the
recipient of the Global Shining Light Award for Investigative Journalism
in the year 2017 by the Global Investigative Journalism Network. The
Petitioner was also awarded the Most Resilient Global Journalist of 2018
at the Peace Palace in The Hague by the Foreign Minister of Netherlands.
6

In 2019, the Petitioner was named by Time magazine among ten global
journalists who face maximum threats to their lives across the world.
That on 29.03.2022, the Petitioner arrived at Chhatrapati Shivaji Maharaj
International Airport to board Air India flight AI 0131 to London,
Heathrow, scheduled to depart at 14:25 hours, to attend events about the
global problem of cyber attacks on women journalists, as well as to
deliver a keynote speech on the status of journalism in India. Her return
ticket was booked for 11.04.2022. At around 11:50 hours, the Petitioner’s
passport and visa were checked by immigration authorities and it was
also stamped.
However, at around 12 noon, the Petitioner was detained in a room
adjacent to the immigration counter, and she was informed that the
immigration officers of Respondent No. 1 were seeking clarifications
regarding some “remark” on the Petitioner’s file. The Petitioner was then
informed, over the course of the next hour, that the officers of Respondent
No. 1 have instructions from the Respondent No. 2 (Enforcement
Directorate) to not allow the Petitioner to board her flight to London, and
her immigration stamp on her passport was stamped as “Cancelled”. The
Petitioner inquired about the basis of such a decision, and requested the
officers of Respondent No. 1 to furnish any written communication or
order barring the Petitioner from travelling to attend journalism related
7

events in London. No such order or communication was shown to the
Petitioner, however she was informed that the Respondent No. 2 will be
emailing summons to her any moment, and that forms the basis for the
decision to disallow the Petitioner from travelling. Curiously, around
13:46 hours, almost two hours after the Petitioner had been detained at
the airport, the Respondent No. 2 emailed summons to the Petitioner
under The Prevention of Money Laundering Act, 2002 (hereinafter
referred to as ‘PMLA’) directing her to appear before the Respondent No.
2 on 01.04.2022.
It is noteworthy, the information sought in the aforesaid summon is a
verbatim copy of the information already sought by the Respondent No. 2
in the summons dt. 25.01.2022, most of which has subsequently been
received by Respondent No. 2 from the Mumbai Zonal Office and forms
part of the record. It is also pertinent that the said information has been
relied upon by the Respondent No. 2 in its original complaint dt.
22.02.2022, upon which a Show Cause Notice in terms of Section 8(1)
PMLA, 2002, has already been issued to the Petitioner dt. 08.03.2022,
and the Petitioner is due to file a detailed reply within the stipulated time
frame by 17.04.2022. Thus the summon dt. 29.02.2022 is a clear sham
exercise, and an afterthought, to try and legitimise the illegal and
arbitrary action of the Respondent No. 1 on the instructions of the
8

Respondent No. 2, to deny the Petitioner her fundamental right to travel
as well as her fundamental right to freedom of speech and expression,
inter-alia to speak at a journalism related event in London and then in
Perugia near Rome, in Italy, regarding the gender based online violence
faced by women journalists globally. There are presently two FIRs
pending investigation into incidents of cyber crime committed against the
Petitioner targeting her for her work as a journalist, which makes her
participation in the event on 01.04.2022 in London of critical importance
to share her experience with others in her professional field. The details
of the FIRs are FIR No. 236/18 P.S. Saket u/Secs 354A/503/506/509 IPC
and 66E/67/67A IT Act, and FIR No. 5/2022, P.S. Bandra Kurla
Complex, Cyber Crime, u/Secs 354A, 503, 506(2) and 500 IPC. The
Petitioner is also scheduled to travel from London to Rome on
05.04.2022 to address the Keynote Speech at the Perugia International
Journalism Festival, 2022, where she is scheduled to speak about the state
of journalism in India, and then return to Mumbai on 11.04.2022 via
London.
The Petitioner has learnt from media reports that the Respondent No. 2
had issued a Look Out Circular against the Petitioner, which it is
submitted is wholly contrary to settled legal principles and is an
9

unreasonable restriction on the Petitioner’s rights u/Articles 14, 19 and 21
of the Constitution.
The action of the Respondents is mala fide, illegal, untenable and
unconstitutional inter-alia on the following grounds:
a) The Petitioner has responded to each and every summon issued by
the Respondent No. 2 under PMLA, 2002, and has also joined the
investigation and recorded her statement and provided necessary
documents. There is thus nothing on record to suggest that the
Petitioner was evading the legal process.
b) The Respondent No. 2 has already filed a complaint under the
PMLA, 2002, under Section 5 and provisionally attached part of
the Petitioner’s bank account. The proceedings are now past the
stage of inquiry / investigation and are pending before the PMLA
Adjudication Authority in New Delhi, where the Petitioner is due
to file her reply on or before 17.04.2022.
c) The Petitioner’s bank account was provisionally attached vide an
Order passed by Respondent No. 2 on 04.02.2022, and she has
subsequently been served a Show-Cause Notice dt. 08.03.2022
under Section 8(1) of PMLA, 2002, and has been directed to file a
reply on or before 17.04.2022. The Petitioner has in response
sought necessary documents from the Respondent No. 2, which the
10

Respondent No. 2 has supplied to the Petitioner on 22.03.2022 and
on 25.03,2022. Thus the Petitioner has been in constant
communication with the Respondent No. 2, and at no point of time
between the provisional attachment on 04.02,2022 till the
Petitioner being detained at the airport on 29.03.2022, has the
Respondent No. 2 issued any summon to the Petitioner or directed
the Petitioner to appear before the Respondent No. 2 although there
has been regular correspondence between the Petitioner and the
Respondent No. 2.
d) There is no cogent reason or ground for issuance of a Look Out
Circular against the Petitioner as she has cooperated with the
investigation throughout and has been in regular communication
with the Respondent No. 2. There is no flight risk and the
Petitioner has not evaded the legal process. The issuance of Look
Out Circulars in such circumstances is unwarranted, illegal,
arbitrary and unreasonable, and falls foul of settled law as held in
Maneka Gandhi vs Union of India and Anr. (1978) 1 SCC 248,
Karti P. Chidambaram vs Bureau of Immigration and Ors.(2018)
SCC OnLine Mad 2229, Sumer Singh Salkan v. Assistant Director
and others [Writ Petition (Crl) No.1315 of 2008 before this
Hon’ble Court] and Priya Parameswaran Pillai vs Union of India
and Ors. (2015) SCC OnLine Del 7987.
11

The Petitioner being a journalist who speaks truth to power, is at times
perceived to be a source of some discomfort or inconvenience for the
government, but that is no ground to deny the Petitioner her right to travel
abroad and exercise her freedom of speech and expression, as well as to
practise her profession as a journalist. Dissenting voices are integral to
the democratic society and polity envisaged by the Indian Constitution,
and any mala fide or arbitrary action of the Respondents which
unconstitutionally curbs free speech ought to be quashed and set aside by
constitutional courts, as held in Priya Parameswaran Pillai vs Union of
India and Ors. (2015) SCC OnLine Del 7987.
The Petitioner is constrained to file the present writ petition seeking
urgent reliefs as she has been harassed and humiliated by her unwarranted
and illegal detention at the Mumbai airport by Respondent No. 1 on the
instructions of Respondent No. 2, and that unless the arbitrary and
untenable Look Out Circular is set aside or its operation stayed, the
Petitioner will be unable to attend the remaining journalistic events
scheduled in London and Italy between 01.04.2022 and 11.04.2022,
which would be an egregious violation of her fundamental rights.
LIST OF DATES
12

24.03.2020 In view of the global and regional spread of the Covid-19
pandemic, a nationwide lockdown was announced by the
Government of India. In view of the suddenness of the
move, many were left stranded and the pandemic induced
a financially and socially draining era for large sections of
the population, especially the migrant workers, daily
wage labourers, farmers and economically marginalized
people.
April - May
2020
The Petitioner, being a well known journalist with
multiple renowned awards to her credit, received various
messages from people for help during the pandemic. The
Petitioner initially started to help people personally, but
her selflessness notwithstanding, the sheer scale of
distress across the country was far greater than what the
Petitioner could individually assist. Thus, the Petitioner
felt that it was incumbent upon her to use her
communication network to try and provide assistance to
as many people as possible. The Petitioner thus decided to
initiate crowd-funding campaigns through an online
crowdfunding platform named ‘Ketto’. In the months of
April-May, 2020, the Petitioner ran a campaign on Ketto
platform to raise funds for slum dwellers and farmers.
June-Septemb
er, 2020
The Petitioner ran a second crowdfunding campaign on
Ketto, for the purpose of providing relief work in Assam,
Bihar and Maharashtra, with special focus on the flood
related devastation caused in the state of Assam, even as
the state was fighting with the pandemic.
13

Submission: The Petitioner, along with a team of volunteers,
relentlessly worked through the pandemic providing
assistance to people in distress and dire need, despite
immense personal cost, including the loss of two
volunteer’s lives to Covid-19, as well as a significant
medical toll on the Petitioner, who not only contracted
Covid and was hospitalised, but also injured her spine
doing the heavy lifting and distribution of relief material.
15.01.2021 -
21.01.2021
The Petitioner was admitted to Lilavati Hospital and
Research Centre in Mumbai, where on 16.01.2021 she
underwent invasive surgery for her spinal and back injury
- complex right L4/L5 microlumbar discectomy.
May - June
2021
The Petitioner ran a third crowdfunding campaign on
Ketto, for the purpose of providing help for Covid-19
impacted people across India during the deadly second
wave of the pandemic in the country.
15.06.2021 The Income Tax Department issued summons to the
Petitioner u/Sec. 131 of The Income Tax Act, for enquiry
into the Petitioner’s tax assessment for the Assessment
Year 2021-22, due to the funds received by the Petitioner
from the crowd funding campaigns on Ketto platform.
11.08.2021 The Petitioner received an Office Order dt. 03.08.2021
from the Mumbai Zonal Office of the Enforcement
Directorate, initiating an enquiry under the Foreign
Exchange Management Act (FEMA).
20.08.2021 The Petitioner replied to the Mumbai Zonal Office of the
14

Enforcement Directorate, with requisite documents
(original bills) upto almost 2000 pages attached, as sought
by the Enforcement Directorate.
04.09.2021 The Income Tax Department issued a Notice of Demand
u/Section 156 of The Income Tax Act, tabulating the tax
payable by the Petitioner for the A.Y. 2021-22 as INR.
1,50,77,973, having included as the Petitioner’s income
the amounts which were raised through the three Ketto
campaigns. The Petitioner has paid the said amount in
protest, and an appeal against the said order is pending
before the Commissioner of Income Tax, Mumbai.
08.09.2021 The Petitioner received an Order under Sections 37 of
FEMA read with Section 133(6) of The Income Tax Act,
from the Mumbai Zonal Office of the Enforcement
Directorate, seeking more documents and information.
29.09.2021 The Petitioner provided a detailed response to the queries
raised in the 08.09.2021 order, including copies of all
documents sought by the Mumbai Zonal Office of the
Enforcement Directorate under provisions of FEMA.
Thereafter, the Petitioner was no longer contacted by the
Mumbai Zonal Office of the Enforcement Directorate for
any FEMA related proceedings, and on oral inquiry the
Petitioner was informed that no proceedings under FEMA
were being continued against the Petitioner.
10.12.2021 The Petitioner received a summon from the Delhi Zonal
Office - II of the Enforcement Directorate, u/Secs 50(2)
15

and 50(3) of the Prevention of Money Laundering Act,
2002, asking the Petitioner to appear before the concerned
officer in New Delhi on 15.12.2021.
15.12.2021 The Petitioner, being a law abiding citizen, travelled from
Mumbai to New Delhi and presented herself before the
concerned officer in the Delhi Zonal Office - II of the
Enforcement Directorate, and her statement was recorded
by the officers of the Respondent No. 2. It is submitted
that some of the documents sought by the Respondent No.
2, had already been submitted by the Petitioner, to the
Income Tax authorities in Mumbai and also to the
Mumbai Zonal Office of the Enforcement Directorate,
and the Petitioner informed the concerned officer of the
same. Accordingly, the Petitioner was directed to submit a
copy of the documents as and when received from the
Mumbai Zonal Office, and she was released after a
day-long interrogation late at night.
17.12.2021 The Petitioner, after returning to Mumbai, sent a letter to
the Mumbai Zonal Office of the Enforcement Directorate
on the immediate next day, with a copy to the concerned
officer in the Delhi Zonal - II Office, seeking copies of
the documents submitted by her to the Mumbai Zonal
Office, so that the same may be submitted to the Delhi
Zonal - II office. No reply was received to this letter. The
Petitioner thus made full endeavour to secure copies of
the documents at the earliest, so as to hand the same over
to the Respondent No. 2.
16

19.12.2021 The Petitioner sent an email to the concerned officers of
Respondent No. 2 stating that she is yet to receive a
response to the letter dt. 17.12.2022, and that she will
travel to New Delhi with the necessary documents once
they are received by her. This communication was not in
reply to any summons, but was a voluntary act by the
Petitioner which reflects her bona fides in cooperating
with the investigation.
27.01.2022 The Petitioner received a fresh summon bearing Summon
No. PMLA/SUMMON/DLZ/02/2022/294 from the Delhi
Zonal - II Office of the Enforcement Directorate.
On receipt of the fresh summon, the Petitioner again
wrote to the Mumbai Zonal Office of the Enforcement
Directorate on the same day, drawing its attention to the
summons dt. 27.01.2022, and requesting that copies of the
concerned documents may be provided at the earliest in
order to enable the Petitioner to comply with the summon.
31.01.2022 The Petitioner emailed the Respondent No.2 (Delhi Zonal
- II office) in response to the Summon No.
PMLA/SUMMON/DLZ/02/2022/294, with a copy of the
letter dt. 27.01.2021 sent by her to the Mumbai Zonal
Office, stating that she has not yet received the documents
from the Mumbai Office, and also informing that the
Petitioner along with all residents of her house were
Covid positive at the time. Further, attention was drawn to
the fact that all the information sought by the Respondent
17

No. 2 was already part of the submissions made to the
Mumbai Zonal Office, except for the Petitioner’s credit
card statement. In the said reply, the Petitioner also
provided details of her credit card.
01.02.2022 Shri Devender, Asst. Director of Respondent No. 2,
emailed the Petitioner stating that the documents sought
by them had been received from the Mumbai Zonal
Office by Respondent No. 2, and that the Petitioner could
travel to New Delhi and meet with the officers of
Respondent No. 2 anytime after her recovery from Covid.
No specific date was mentioned in the email and no fresh
summon was issued by Respondent No.2.
05.02.2022 Even as the Petitioner was recovering from Covid, she
received communication from her bank - HDFC, that by
an Order dt. 04.02.2022, the Enforcement Directorate had
directed the bank to place on hold certain funds in the
Petitioner’s accounts. The Petitioner learnt from media
reports that the Respondent No. 2 had passed a
provisional attachment order against the Petitioner.
08.03.2022 Pursuant to the Order of provisional attachment, the
Adjudicating Authority, PMLA, issued a Show Cause
Notice to the Petitioner under Section 8(1) of the PMLA,
2002, and directed the Petitioner to file her reply on or
before 17.04.2022. The same was received by the
Petitioner on 15.03.2022.
16.03.2022 The Petitioner filed an application for requisition of the
18

original complaint dt. 22.02.2022, the provisional
attachment order dt. 04.02.2022 as well as the relied upon
documents in the Show Cause Notice, and the same was
sent by email as well as delivered dasti to the Respondent
No. 2 and the Adjudicating Authority.
22.03.2022 The Respondent No. 2 served the copy of the original
complaint dt. 22.02.2022 by email to the Petitioner, and
stated that the relied upon documents had been sent by
post, which was received on 25.03.2022.
Submission: Since the issuance of Provisional Attachment Order dt.
04.02.2022, filing of original complaint dt. 22.02.2022,
and issuance of Show Cause Notice dt. 08.03.2022, the
Respondent No. 2 had not issued any summons to the
Petitioner.
28.03.2022 The Petitioner through public posts on social media site
Twitter announced that she would be travelling to London
and other European cities to speak at multiple events,
including on the issue of “Gender Based Online Violence
against Women Journalists” at an event scheduled to be
held on 01.04.2022 organized by The International Center
for Journalists (ICFJ), Doughty Street Chambers and the
International Bar Association’s Human Rights Institute
(IBAHRI). The Petitioner was also scheduled on the same
day to brief the Editors at the Guardian in the UK on
journalism and the challenges to journalism from
dictatorships.
19

29.03.2022 The Petitioner arrived at Chhatrapati Shivaji Maharaj
International Airport to board Air India flight AI 0131 to
London, Heathrow, scheduled to depart at 14:25 hours.
Her return ticket was booked for 11.04.2022. At around
11:50 hours, the Petitioner’s passport and visa were
checked by immigration authorities and it was also
stamped.
However, at around 12 noon, the Petitioner was detained
in a room adjacent to the immigration counter, and she
was informed that the immigration officers of Respondent
No. 1 were seeking clarifications regarding some
“remark” on the Petitioner’s file. The Petitioner was then
informed, over the course of the next hour, that the
officers of Respondent No. 1 have instructions from the
Respondent No. 2 (Enforcement Directorate) to not allow
the Petitioner to board her flight to London, and her
immigration stamp on her passport was stamped as
“Cancelled”.
The Petitioner inquired about the basis of such a decision,
and requested the officers of Respondent No. 1 to furnish
any written communication or order barring the Petitioner
from travelling to attend journalism related events in
London. No such order or communication was shown to
the Petitioner, however she was informed that the
Respondent No. 2 will be emailing summons to her any
moment, and that forms the basis for the decision to
disallow the Petitioner from travelling. Curiously, around
13:46 hours, almost two hours after the Petitioner had
20

been detained at the airport, the Respondent No. 2
emailed summons to the Petitioner directing her to appear
before the Respondent No. 2 on 01.04.2022.
It is noteworthy, the information sought in the aforesaid
summon is a verbatim copy of the information sought in
the summons dt. 25.01.2022, most of which has
subsequently been received from the Mumbai Zonal
Office and forms part of the record. It is also pertinent
that the said information has been relied upon by the
Respondent No. 2 in its original complaint dt. 22.02.2022,
upon which a Show Cause Notice in terms of Section 8(1)
PMLA, 2002, has already been issued to the Petitioner,
and the Petitioner is due to file a detailed reply. Thus the
summon dt. 29.02.2022 is a clear sham exercise, and an
afterthought, to try and legitimise the illegal and arbitrary
action of the Respondent No. 1 on the instructions of the
Respondent No. 2, to deny the Petitioner her fundamental
right to travel as well as her fundamental right to freedom
of speech and expression, inter-alia to speak at a
journalism related event in London and then in Perugia
near Rome, in Italy, regarding the gender based online
violence faced by women journalists globally.
There are presently two FIRs pending investigation into
incidents of cyber crime committed against the Petitioner
targeting her for her work as a journalist, which makes
her participation in the event on 01.04.2022 in London of
critical importance to share her experience with others in
her professional field. The details of the FIRs are FIR No.
21

236/18 P.S. Saket u/Secs 354A/503/506/509 IPC and
66E/67/67A IT Act, and FIR No. 5/2022, P.S. Bandra
Kurla Complex, Cyber Crime, u/Secs 354A, 503, 506(2)
and 500 IPC.
Similarly, the Petitioner is scheduled to travel from
London to Rome on 05.04.2022 to address the Keynote
Speech at the Perugia International Journalism Festival,
2022, where she is scheduled to speak about the state of
journalism in India, and then return to Mumbai on
11.04.2022 via London.
The Petitioner has learnt from various news reports that
the Respondent No. 2 had issued a Look Out Circular
(LOC) against the Petitioner, and the Petitioner was
detained on 29.03.2022 at the airport on the basis of the
said LOC.
31.03.2022 The Petitioner has wrongly, arbitrarily, in a malafide
exercise of power and a gross abuse of the process of law,
been denied her fundamental right to travel abroad and
perform her professional duties as a journalist as well as
exercise her constitutionally guaranteed right to free
speech, in grave breach of her fundamental rights
u/Articles 14, 19(1)(a), 19(1)(g) and 21 of the
Constitution of India. Hence this writ petition.
22
Through:

IN THE MATTER OF:
Versus
WRIT PETITION UNDER ARTICLE 226 OF THE
CONSTITUTION OF INDIA, READ WITH SECTION 482 OF THE
CODE OF CRIMINAL PROCEDURE, 1973, SEEKING
INTER-ALIA THAT THE PETITIONER BE ENABLED TO
TRAVEL OUTSIDE INDIA BY QUASHING AND SETTING
ASIDE ANY ORDER, LOOK OUT CIRCULAR, INSTRUCTION
OR DIRECTION PREVENTING THE PETITIONER FROM
TRAVELLING OUTSIDE INDIA
To,
The Hon’ble Chief Justice,
And His Companion Justices of the Hon’ble High Court of Delhi,
The present petition of the Petitioner,
MOST RESPECTFULLY SHOWETH:
23

1. That the present petition is being filed by the Petitioner seeking
immediate and urgent reliefs in the nature of Mandamus /
Certiorari, seeking inter-alia that the Petitioner be enabled to travel
out of India, and that any order, Look Out Circular, instruction or
direction preventing the Petitioner from travelling abroad be
quashed and set aside.
About the Petitioner
2. That the Petitioner is an Indian investigative female journalist and a
global opinions writer at the Washington Post. The Petitioner has
worked as a reporter, editor and columnist with some of the leading
publications in India and internationally. Her articles appear in the
Time, New York Times, Guardian and Foreign Policy among other
foreign publications. The Petitioner has been profiled by
prestigious publications including The New Yorker, the Atlantic,
Time, Guardian and Observer among others. In a career spanning
fifteen years, the Petitioner has been awarded the Sanskriti award
for integrity and excellence in journalism by the former President
of India, Shri A.P.J. Abdul Kalam. She was also the recipient of the
Global Shining Light Award for Investigative Journalism in the
year 2017 by the Global Investigative Journalism Network. The
Petitioner was also awarded the Most Resilient Global Journalist of
24

2018 at the Peace Palace in The Hague by the Foreign Minister of
Netherlands. In 2019, the Petitioner was named by Time magazine
among ten global journalists who face maximum threats to their
lives across the world. The Petitioner was also an Editor with
Tehelka magazine and she has reported on issues of religious
violence, extrajudicial killings, terrorism in Sri Lanka. She also
authored an international bestseller titled, “Gujarat Files: Anatomy
of a Cover-Up”, an undercover investigation.
About the Respondents
3. That the Respondent No. 1 is the Union of India through the
Bureau of Immigration, Ministry of Home Affairs, being the
authority that detained the Petitioner at Chhatrapati Shivaji
International Airport in Mumbai on 29.03.2022, on the instructions
of Respondent No. 2. The Respondent No. 2 is the Directorate of
Enforcement, Delhi - II Zonal Office, being the authority on whose
instructions the Respondent No. 1 detained the Petitioner and did
not allow her to travel to London on 29.03.2022.
Brief Facts
4. That the brief facts for the purpose of the present petition are listed
below:
25

4.1. On 24.03.2020, in view of the global and regional spread of
the Covid-19 pandemic, a nationwide lockdown was announced by
the Government of India. In view of the suddenness of the move,
many were left stranded and the pandemic induced a financially
and socially draining era for large sections of the population,
especially the migrant workers, daily wage labourers, farmers and
economically marginalised people.
4.2. The Petitioner, being a well known journalist with multiple
renowned awards to her credit, received various messages from
people for help during the pandemic. The Petitioner initially started
to help people personally, but her selflessness notwithstanding, the
sheer scale of distress across the country was far greater than what
the Petitioner could individually assist. Thus, the Petitioner felt that
it was incumbent upon her to use her communication network to
try and provide assistance to as many people as possible. The
Petitioner thus decided to initiate crowd-funding campaigns
through an online crowdfunding platform named ‘Ketto’. In the
months of April-May, 2020, the Petitioner ran a campaign on Ketto
platform to raise funds for slum dwellers and farmers.
26

4.3. The Petitioner ran a second crowdfunding campaign on Ketto
from June to September, 2020, for the purpose of providing relief
work in Assam, Bihar and Maharashtra, with special focus on the
flood related devastation caused in the state of Assam, even as the
state was fighting with the pandemic.
4.4. The Petitioner, along with a team of volunteers, relentlessly
worked through the pandemic providing assistance to people in
distress and dire need, despite immense personal cost, including the
loss of two volunteer’s lives to Covid-19, as well as a significant
medical toll on the Petitioner, who not only contracted Covid and
was hospitalised, but also injured her spine doing the heavy lifting
and distribution of relief material. [True copy of two social media
posts illustrative of the relief work done by the Petitioner and her
team of volunteers is marked as Annexure A-1]
4.5. From 15.01.2021 to 21.01.2021, the Petitioner was admitted to
Lilavati Hospital and Research Centre in Mumbai, where on
16.01.2021 she underwent invasive surgery for her spinal and back
injury - complex right L4/L5 microlumbar discectomy. [True copy
27

of Discharge summary issued by Lilavati Hospital and Research
Centre is marked and annexed as Annexure A-2]
4.6. Between May and June, 2021, the Petitioner ran a third
crowdfunding campaign on Ketto, for the purpose of providing
help for Covid-19 impacted people across India during the deadly
second wave of the pandemic in the country.
4.7. That on 15.06.2021, the Income Tax Department issued
summons to the Petitioner u/Sec. 131 of The Income Tax Act, for
enquiry into the Petitioner’s tax assessment for the Assessment
Year 2021-22, due to the funds received by the Petitioner from the
crowd funding campaigns on Ketto platform.
4.8. The Petitioner received an Office Order dt. 03.08.2021 from
the Mumbai Zonal Office of the Enforcement Directorate, initiating
an enquiry under the Foreign Exchange Management Act (FEMA).
[True copy of Order dt. 03.08.2021 is marked as Annexure A-3]
28

4.9. That on 20.08.2021, the Petitioner replied to the Mumbai
Zonal Office of the Enforcement Directorate, with requisite
documents (original bills) upto almost 2000 pages attached, as
sought by the Enforcement Directorate. [True copy of the
Petitioner’s reply to Mumbai Zonal Office of the Enforcement
Directorate dt. 20.08.2021 is marked as Annexure A-4]
4.10. On 04.09.2021, the Income Tax Department issued a Notice
of Demand u/Section 156 of The Income Tax Act, tabulating the
tax payable by the Petitioner for the A.Y. 2021-22 as INR.
1,50,77,973, having included as the Petitioner’s income the
amounts which were raised through the three Ketto campaigns. The
Petitioner has paid the said amount in protest, and an appeal against
the said order is pending before the Commissioner of Income Tax,
Mumbai. [True copy of Notice of Demand dt. 04.09.2021 is
marked as Annexure A-5]
4.11. That on 08.09.2021, the Petitioner received an Order under
Sections 37 of FEMA read with Section 133(6) of The Income Tax
29

Act, from the Mumbai Zonal Office of the Enforcement
Directorate, seeking more documents and information.
4.12. That on 29.09.2021, the Petitioner provided a detailed
response to the queries raised in the 08.09.2021 order, including
copies of all documents sought by the Mumbai Zonal Office of the
Enforcement Directorate under provisions of FEMA. Thereafter,
the Petitioner was no longer contacted by the Mumbai Zonal Office
of the Enforcement Directorate for any FEMA related proceedings,
and on oral inquiry the Petitioner was informed that no proceedings
under FEMA were being continued against the Petitioner.
4.13. That on 10.12.2021, the Petitioner received a summon from
the Delhi Zonal Office - II of the Enforcement Directorate, u/Secs
50(2) and 50(3) of the Prevention of Money Laundering Act, 2002,
asking the Petitioner to appear before the concerned officer in New
Delhi on 15.12.2021. [True copy of Summons dt. 10.12.2021 is
30

4.14. The Petitioner, being a law abiding citizen, travelled from
Mumbai to New Delhi and presented herself before the concerned
officer in the Delhi Zonal Office - II of the Enforcement
Directorate, and her statement was recorded by the officers of the
Respondent No. 2 on 15.12.2021. It is submitted that some of the
documents sought by the Respondent No. 2, had already been
submitted by the Petitioner, to the Income Tax authorities in
Mumbai and also to the Mumbai Zonal Office of the Enforcement
Directorate, and the Petitioner informed the concerned officer of
the same. Accordingly, the Petitioner was directed to submit a copy
of the documents as and when received from the Mumbai Zonal
Office, and she was released after a day-long interrogation late at
night.
4.15. The Petitioner, after returning to Mumbai, sent a letter to the
Mumbai Zonal Office of the Enforcement Directorate on the
immediate next day on 17.12.2021, with a copy to the concerned
officer in the Delhi Zonal - II Office, seeking copies of the
documents submitted by her to the Mumbai Zonal Office, so that
the same may be submitted to the Delhi Zonal - II office. No reply
was received to this letter. The Petitioner thus made full endeavour
31

to secure copies of the documents at the earliest, so as to hand the
same over to the Respondent No. 2. [True typed copy of letter dt.
17.12.2021 sent by the Petitioner is marked as Annexure A-7]
4.16. On 19.12.2021, the Petitioner sent an email to the concerned
officers of Respondent No. 2 stating that she is yet to receive a
response to the letter dt. 17.12.2022, and that she will travel to New
Delhi with the necessary documents once they are received by her.
This communication was not in reply to any summons, but was a
voluntary act by the Petitioner which reflects her bona fides in
cooperating with the investigation. [True copy of email dated
19.12.2021 sent by the Petitioner is marked as Annexure A-8]
4.17. That on 27.01.2022, the Petitioner received a fresh summon
bearing Summon No. PMLA/SUMMON/DLZ/02/2022/294 from
the Delhi Zonal - II Office of the Enforcement Directorate dt.
25.01.2022. On receipt of the fresh summon, the Petitioner again
wrote to the Mumbai Zonal Office of the Enforcement Directorate
on the same day, drawing its attention to the summons dt.
27.01.2022, and requesting that copies of the concerned documents
32

may be provided at the earliest in order to enable the Petitioner to
comply with the summon. [True copy of summon dt. 25.01.2022 is
marked as Annexure A-9; True copy of letter dt. 27.01.2022 sent
to Mumbai Zonal Office of the Enforcement Directorate is marked
as Annexure A-10]
4.18. That on 31.01.2022, the Petitioner emailed the Respondent
No.2 (Delhi Zonal - II office) in response to the Summon No.
PMLA/SUMMON/DLZ/02/2022/294, with a copy of the letter dt.
27.01.2021 sent by her to the Mumbai Zonal Office, stating that
she has not yet received the documents from the Mumbai Office,
and also informing that the Petitioner along with all residents of her
house were Covid positive at the time. Further, attention was drawn
to the fact that all the information sought by the Respondent No. 2
was already part of the submissions made to the Mumbai Zonal
Office, except for the Petitioner’s credit card statement. In the said
reply, the Petitioner also provided details of her credit card. [True
copy of email dt. 31.01.2022 along with the response of the
Petitioner dt. 31.01.2022 is marked as Annexure A-11 (Colly)]
33

4.19. That on 01.02.2022, Shri Devender, Asst. Director of
Respondent No. 2, emailed the Petitioner stating that the
documents sought by them had been received from the Mumbai
Zonal Office by Respondent No. 2, and that the Petitioner could
travel to New Delhi and meet with the officers of Respondent No.
2 anytime after her recovery from Covid. No specific date was
mentioned in the email and no fresh summons was issued by
Respondent No.2. [True copy of email dt. 01.02.2022 sent by Shri
Devender, Asst. Director of Respondent No. 2, is marked as
Annexure A-12]
4.20. That on 05.02.2022, even as the Petitioner was recovering
from Covid, she received communication from her bank - HDFC,
that by an Order dt. 04.02.2022, the Enforcement Directorate had
directed the bank to place on hold certain funds in the Petitioner’s
accounts. The Petitioner learnt from media reports that the
Respondent No. 2 had passed a provisional attachment order
against the Petitioner. [True copy of communication dt. 05.02.2022
from HDFC Bank is marked as Annexure A-13]
34

4.21. On 08.03.2022, pursuant to the Order of provisional
attachment, the Adjudicating Authority, PMLA, issued a Show
Cause Notice to the Petitioner under Section 8(1) of the PMLA,
2002, and directed the Petitioner to file her reply on or before
17.04.2022. The same was received by the Petitioner on
15.03.2022. [True copy of Show-Cause Notice dt. 08.03.2022 is
4.22. That on 16.03.2022, the Petitioner filed an application for
requisition of the original complaint dt. 22.02.2022, the provisional
attachment order dt. 04.02.2022 as well as the relied upon
documents in the Show Cause Notice, and the same was sent by
email as well as delivered dasti to the Respondent No. 2 and the
Adjudicating Authority. [True copy of Petitioner’s application dt.
16.03.2022 is marked as Annexure A-15]
4.33. That on 22.03.2022, the Respondent No. 2 served the copy of
the original complaint dt. 22.02.2022 by email to the Petitioner,
and stated that the relied upon documents had been sent by post,
which was received on 25.03.2022. [True copy of email dt.
35

22.03.2022 sent by Respondent No. 2 is marked as Annexure
A-16]
4.34. It is pertinent that since the issuance of Provisional
Attachment Order dt. 04.02.2022, filing of original complaint dt.
22.02.2022, and issuance of Show Cause Notice dt. 08.03.2022, the
Respondent No. 2 had not issued any summons to the Petitioner.
4.35. The Petitioner through public posts on social media site
Twitter announced that she would be travelling to London and
other European cities to speak at multiple events, including on the
issue of “Gender Based Online Violence against Women
Journalists” at an event scheduled to be held on 01.04.2022
organized by The International Center for Journalists (ICFJ),
Doughty Street Chambers and the International Bar Association’s
Human Rights Institute (IBAHRI). The Petitioner was also
scheduled on the same day to brief the Editors at the Guardian in
the UK on journalism and the challenges to journalism from
dictatorships. [True copy of invitation for event organised by The
International Center for Journalists (ICFJ), Doughty Street
36

Chambers and the International Bar Association’s Human Rights
Institute (IBAHRI), as well as event images of the events in
Perugia, Italy, is marked as Annexure A-17(Colly)]
4.36. On 29.03.2022, the Petitioner arrived at Chhatrapati Shivaji
Maharaj International Airport to board Air India flight AI 0131 to
London, Heathrow, scheduled to depart at 14:25 hours. Her return
ticket was booked for 11.04.2022. [True copy of Petitioner’s
round-trip tickets are marked as Annexure A-18]
At around 11:50 hours, the Petitioner’s passport and visa were
checked by immigration authorities and it was also stamped.
However, at around 12 noon, the Petitioner was detained in a room
adjacent to the immigration counter, and she was informed that the
immigration officers of Respondent No. 1 were seeking
clarifications regarding some “remark” on the Petitioner’s file. The
Petitioner was then informed, over the course of the next hour, that
the officers of Respondent No. 1 have instructions from the
Respondent No. 2 (Enforcement Directorate) to not allow the
Petitioner to board her flight to London, and her immigration stamp
on her passport was stamped as “Cancelled”. The Petitioner
inquired about the basis of such a decision, and requested the
37

officers of Respondent No. 1 to furnish any written communication
or order barring the Petitioner from travelling to attend journalism
related events in London. No such order or communication was
shown to the Petitioner, however she was informed that the
Respondent No. 2 will be emailing summons to her any moment,
and that forms the basis for the decision to disallow the Petitioner
from travelling. [True copy of Petitioner’s relevant passport pages
is marked as Annexure A-19]
4.37. Curiously, around 13:46 hours, almost two hours after the
Petitioner had been detained at the airport, the Respondent No. 2
emailed summons to the Petitioner directing her to appear before
the Respondent No. 2 on 01.04.2022. It is noteworthy, the
information sought in the aforesaid summon is a verbatim copy of
the information sought in the summons dt. 25.01.2022, most of
which has subsequently been received from the Mumbai Zonal
Office and forms part of the record. It is also pertinent that the said
information has been relied upon by the Respondent No. 2 in its
original complaint dt. 22.02.2022, upon which a Show Cause
Notice in terms of Section 8(1) PMLA, 2002, has already been
issued to the Petitioner, and the Petitioner is due to file a detailed
38

reply. Thus the summon dt. 29.02.2022 is a clear sham exercise,
and an afterthought, to try and legitimise the illegal and arbitrary
action of the Respondent No. 1 on the instructions of the
Respondent No. 2, to deny the Petitioner her fundamental right to
travel as well as her fundamental right to freedom of speech and
expression, inter-alia to speak at a journalism related event in
London and then in Perugia near Rome, in Italy, regarding the
gender based online violence faced by women journalists globally.
[True copy of email and summons dt. 29.03.2022 is marked as
Annexure A-20(Colly)]
4.38. There are presently two FIRs pending investigation into
incidents of cyber crime committed against the Petitioner targeting
her for her work as a journalist, which makes her participation in
the event on 01.04.2022 in London of critical importance to share
her experience with others in her professional field. The details of
the FIRs are FIR No. 236/18 P.S. Saket u/Secs 354A/503/506/509
IPC and 66E/67/67A IT Act, and FIR No. 5/2022, P.S. Bandra
Kurla Complex, Cyber Crime, u/Secs 354A, 503, 506(2) and 500
IPC. Similarly, the Petitioner is scheduled to travel from London to
Rome on 05.04.2022 to address the Keynote Speech at the Perugia
39

International Journalism Festival, 2022, where she is scheduled to
speak about the state of journalism in India, and then return to
Mumbai on 11.04.2022 via London.
4.39. The Petitioner has learnt from various news reports that the
Respondent No. 2 had issued a Look Out Circular (LOC) against
the Petitioner, and the Petitioner was detained on 29.03.2022 at the
airport on the basis of the said LOC. [True copy of news report by
Financial Express is marked as Annexure A-21]
4.40. The Petitioner has wrongly, arbitrarily, in a malafide exercise
of power and a gross abuse of the process of law, been denied her
fundamental right to travel abroad and perform her professional
duties as a journalist as well as exercise her constitutionally
guaranteed right to free speech, in grave breach of her fundamental
rights u/Articles 14, 19(1)(a), 19(1)(g) and 21 of the Constitution of
India.
40

4.41. The Petitioner has not filed any similar writ or any other
petition seeking similar reliefs either before this Hon’ble Court or
any other court or fora.
Grounds
5. That the present Petition has been filed inter-alia on the following
Grounds:
A. BECAUSE the Petitioner’s fundamental right to travel has been
arbitrarily, without cogent grounds or reason, and contrary to
settled legal principles, grossly violated by the actions of
Respondent No. 1 on 29.03.2022 at the behest of Respondent No.
2, and the same is violative of Articles 14, 19(1)(a), 19(1)(g) and
21 of the Constitution of India. The action of the Respondents falls
foul of the principles laid down in Maneka Gandhi vs Union of
India and Anr. (1978) 1 SCC 248 and a plethora of judgments that
follow the ratio laid down therein.
B. BECAUSE the Petitioner has been in regular communication with
Respondent No. 2, since December, 2021, and has accepted all
summons issued to her, provided all information asked for, and has
41

not evaded or avoided the legal process. The same is explained in
tabular form below:
Sr. No. Date of summon Petitioner’s response
1. 10.12.2021 Petitioner travels from Mumbai to
Respondent No. 2’s office in New
Delhi and appears before the
concerned officer on 15.12.2021 as
directed, and answers all questions put
to her till late at night. The Petitioner
is questioned for about 10 hours and
answers every query put to her. For
some documents sought by
Respondent No. 2, the Petitioner
informs that they are in the custody of
the Mumbai Zonal Office of the
Enforcement Directorate, and she is
instructed to take steps to secure
copies of the same from the Mumbai
Zonal Office and file it with
Respondent No. 2 in New Delhi.
Accordingly, Petitioner writes
representation on 17.12.2021 to the
Mumbai Zonal Office of the
Enforcement Directorate.
Thereafter, on 11.01.2022, the
Petitioner wrote an email to the
Respondent No. 2 informing them that
42

she is yet to receive any reply from the
Mumbai Zonal Office, and that as
soon as she gets the necessary
documents, she would travel to New
Delhi with the documents to submit
them to the Respondent No. 2.
2. 27.01.2022 On receipt of the fresh summon on
27.01.2022, the Petitioner again wrote
to the Mumbai Zonal Office of the
Enforcement Directorate on the same
day, bringing its attention to the
summons dt. 27.01.2022, and
requesting that copies of the concerned
documents may be provided at the
earliest in order to enable the
Petitioner to comply with the
summons of Respondent No. 2. No
response was received to the
Petitioner’s communication.
Thereafter, on 31.01.2022, the
Petitioner wrote an email to the
Respondent No. 2, informing them
that she is yet to receive the
documents from the Mumbai Zonal
Office, and providing them the details
of her HDFC Credit Card. The
Petitioner further informed
43

Respondent No. 2 that she and her
entire family was Covid positive at the
time and she cannot travel to New
Delhi at that time.
The Respondent No. 2 acknowledged
receipt of the 31.01.2022 email, and
Asst. Director Shri Devender wrote an
email on 01.02.2022 stating that the
documents had been directly
transmitted by the Mumbai Zonal
Office to the Respondent No. 2, and he
also stated that the Petitioner could
come to the New Delhi office anytime
after she recovers from Covid. No date
or time was notified for the said visit
of the Petitioner.
a) Even as the Petitioner was recovering from Covid-19, the
Respondent No. 2 passed an Order of Provisional
Attachment on 04.02.2022 in terms of Section 5(1) of the
PMLA, 2002, which was followed by an original complaint
dt. 22.02.2022 in terms of Section 5(5) of the PMLA, 2002,
pursuant to which Show Cause notice was issued by the
Adjudicating Authority u/Sec 8(1) of the PMLA, 2002, on
08.03.2022.
44

b) The proceedings are now at the stage of filing of the
Petitioner’s reply, for which the Petitioner has been granted
time till 17.04.2022.
c) It is pertinent to state that no summon had been issued to the
Petitioner by Respondent No.2 since the summon dt.
27.01.2022, nor was she asked by the Respondent No. 2 to
appear before them on any specific date, after the passing of
the provisional attachment order on 04.02.2022, which
initiated proceedings u/Section 5 of the PMLA, 2002.
Throughout this period, the Respondent No. 2 has been in
communication with the Petitioner and vice-versa with
regard to the proceedings under Section 8 of PMLA before
the Adjudicating Authority, till as recently as 22.03.2022
when the Respondent No.2 served some documents as
sought by the Petitioner.
d) There is thus no attempt by the Petitioner to avoid or evade
the legal process and the same is substantiated by the record.
C. BECAUSE the Respondent No. 2, in an act that reeks of malice
and abuse of power, unsustainable in the eyes of law, after
instructing agents of Respondent No. 1 around 12 noon on
45

29.03.2022 to stop the Petitioner from travelling to the journalism
related conferences scheduled in London and Italy, manufactured a
ground for such detention of the Petitioner belatedly by emailing
fresh summons to her on 29.03.2022 at 13:46 hours, almost 2 hours
after the Petitioner was detained, directing her to appear before
Respondent No. 2 on 01.04.2022 in New Delhi.
D. BECAUSE it is a matter of record that at the time when the
Petitioner was stopped from leaving Chhatrapati Shivaji Terminal
in Mumbai by Respondent No. 1 on 29.03.2022 around 12 noon,
there was no summon issued to the Petitioner, and all earlier
summons to the Petitioner had been duly complied with and
answered. The Respondent No. 2 had taken no steps since the
passing of the provisional attachment order on 04.02.2022 to
secure the Petitioner’s attendance for any lawful purpose, despite
being in regular communication with the Petitioner. Thus, the
curious and rather convenient issuance of a summon on 29.03.2022
requiring the Petitioner’s presence in New Delhi on 01.04.2022,
having already detained her for purported reasons not explained to
the Petitioner, casts a dark shadow on the legality of the actions of
Respondent No. 1 and Respondent No. 2.
46

E. BECAUSE the Petitioner is a journalist by profession with many
accolades to her name, and her travel to London and Italy was
scheduled for the Petitioner to participate in important journalism
related events pertaining to the issue of online harassment of
women journalists across the globe, as well as the status of
journalism in India. Keeping with the highest traditions of
journalism, the Petitioner has always written without fear or favour
and sought accountability from those that hold power and position
in society and polity. This honest, bold approach of the Petitioner
has at times led her work to be perceived as unfavourable or
disagreeable by the government. This however provides no ground
to arbitrarily deny the Petitioner her right to travel, and
consequently to unreasonably restrict her freedom of speech and
expression, as well as the right to practise one’s profession. The
abuse of power by state agencies, to deny Indian citizens the right
to travel abroad and to prevent them from presenting their views on
contentious issues at an international forum which may be
unfavourable towards the government, has been chastised by this
Hon’ble Court in the landmark judgement in the case of Priya
47

Parameswaran Pillai vs Union of India and Ors. (2015) SCC
OnLine Del 7987, where it was held:
“The sense that I get, upon perusal of the stand taken by the
respondents in their pleadings, is that, they do not approve
of the view expressed by civil right activists, in forums
outside the country, which tend to portray, according to
them, an inaccurate picture of the state of human rights in
the country. In other words, the respondents are concerned
by the fact that such portrayal generates an atmosphere,
which retards investment of foreign funds, in vital
infrastructural projects.
Whether this concern of the respondents is valid or not, in
my opinion, is not the issue. The reason for the same is that
developmental activities, not now, but for ages have always
had a counterpoint. The advancement in knowledge base,
and the ability of common citizen to access information
vis-à-vis public projects, has only made dissent more strident
and vigorous. Whether one model of development has to be
rolled out as against the other, is an on-going debate. This
debate impinges upon all kinds of developmental projects,
which includes project, such as, mining, setting up of nuclear
48

plants, construction of roads through forests, acquisition of
land for housing projects/ industries, construction of
highways, roads, dams and bridges etc. – none of which
have stopped if, the executive of the day, is convinced of their
need and necessity.
The mere fact that such debates obtain, or such debates
metamorphose into peaceful protests, cannot be the reason
for curtailing a citizen’s fundamental rights. In this case, Ms
Pillai’s right to travel abroad and interact with relevant
stakeholders (i.e., the British Parliamentarians), to persuade
them, to have entities incorporated in their country, to fall in
line, with the developmental ethos, which is close to her
ideology and belief, cannot be impeded only because it is not
in sync with policy perspective of the executive.”
F. BECAUSE the right to travel abroad has been recognized as an
inalienable facet of the right to life and personal liberty under
Article 21, and any act of the Respondents to preclude the
Petitioner from exercising her right to travel, which is not in
accordance with the procedure established by law, fails the test of
just, fair and reasonableness, and is hence unconstitutional and
49

invalid. Reliance is placed herein on Maneka Gandhi vs Union of
India and Anr. (1978) 1 SCC 248, wherein the Hon’ble Supreme
Court held:
“The expression 'personal liberty' in Article 21 is of the
widest amplitude and it covers a variety of rights which go to
constitute the personal liberty of man and some of them have
been raised to the status of distinct fundamental rights and
given additional protection under Article 19. Now, it has
been held by this Court in Satwant Singh's case that
'personal liberty' within the meaning of Article 21 includes
within its ambit the right to go abroad and consequently no
person can be deprived of this right except according to
procedure prescribed by law.”
G. BECAUSE the Petitioner had a valid passport and visa to
undertake her journey on 29.03.2022 from New Delhi to London,
then to Rome, and back to New Delhi via London on 11.04.2022,
for which she had reserved tickets. No action had been initiated
against the Petitioner under The Passports Act, 1967, and thus the
Petitioner’s right to travel abroad was unreasonably curtailed by
the Respondents.
50

H. BECAUSE issuance of a belated summon as an afterthought by the
Respondent No. 2 does not justify the act of the Respondent No. 1
to detain the Petitioner around 12 noon on 29.03.2022 at the
Chhatrapati Shivaji Terminal in Mumbai, and that there existed no
cogent grounds or sufficient reasons to justify the action of the
Respondent No. 1 at the time when the same was carried out.
I. BECAUSE the Petitioner had a return ticket booked for
11.04.2022, and was also due to file her reply before the
Adjudicating Authority, PMLA, in New Delhi, on or before
17.04.2022, for which the Petitioner had already sought copies of
relevant documents from the Respondent No. 2. Thus, the material
on record clearly establishes that the Petitioner was in no way a
flight risk, and she was not absconding from the legal process,
which is also manifest in the fact that the Petitioner was not
clandestinely travelling out of India, but had shared her travel
itinerary in terms of the various events she was due to attend on her
Twitter handle which is publicly accessible.
51

J. BECAUSE various judgments passed by this Hon’ble High Court
as well other constitutional courts have discussed, in the context of
Look Out Circulars (LOCs), how the same cannot be mechanically
issued, and there must be cogent grounds and sufficient reasons to
justify issuance of an LOC, as it has a severely prejudicial impact
on a person’s personal liberty. It is submitted that no such cogent
ground or sufficient reason exists in the present case, as the
Petitioner was duly participating in the legal process and not
evading or avoiding the same.
a) In Writ Petition (Crl) No.1315 of 2008 being Sumer Singh
Salkan v. Assistant Director and others, this Hon’ble Court
stipulated categories of cases in which the Investigating
agency could seek recourse to Look Out Circular, and under
what circumstances, the High Court held that, “recourse to
Look Out Circular can be taken by the Investigating agency
in cognizable offences under Indian Penal Code or other
penal laws, where the accused was deliberately evading
arrest or not appearing in the trial Court despite
Non-Bailable warrant and other coercive measures and
there was likelihood of the accused leaving the country to
52

evade trial/arrest.” [Emphasis supplied]
b) The Hon’ble High Court of Madras in the case of Karti P.
Chidambaram vs Bureau of Immigration and Ors.(2018)
SCC OnLine Mad 2229 has held that:
“As observed above, the issuance of Look Out
Circulars is governed by executive instructions as
contained in the Office Memoranda
Nos.25022/13/78-F1 dated 05.09.1979 and
25022/20/98-FIV dated 27.12.2000, as modified by
Office Memorandum dated 27.10.2010. Such LOCs
cannot be issued as a matter of course, but when
reasons exist, where an accused deliberately evades
arrest or does not appear in the trial Court. The
argument of the learned Additional Solicitor General
that a request for Look Out Circular could have been
made in view of the inherent power of the
investigating authority to secure attendance and
cooperation of an accused is contrary to the aforesaid
circulars and thus, not sustainable.
53

It is, in the view of this Court, too late in the day to
contend that whether or not to issue an LOC, being an
executive decision, the same is not subject to judicial
review. It is now well settled that any decision, be it
executive or quasi-judicial, is amenable to the power
of judicial review of the writ Court under Article 226
of the Constitution of India, when such decision has
adverse civil consequences. An LOC, which is a
coercive measure to make a person surrender and
consequentially interferes with his right of personal
liberty and free movement, certainly has adverse civil
consequences. This Court, therefore, holds that in
exercise of power of judicial review under Article 226
of the Constitution, the writ Court can interfere with
an LOC.” [Emphasis supplied]
K. BECAUSE the issuance of an LOC is wholly unwarranted when
the Petitioner has cooperated with the proceedings, answered all
summons, and is in the process of filing a reply to the Show-cause
under Section 8(1) of the PMLA, 2002, within the stipulated time.
There is no plausible reason to apprehend that the Petitioner is a
flight risk, having strong roots in society with her entire family
54

including her aged and ailing father residing with her in Mumbai
for whom she is the primary caregiver. Further the Petitioner’s
travel itinerary was publicly disclosed by her. No person evading
the eyes of law maintains such a transparent schedule of plans.
L. BECAUSE the existence of the source of power, is not a
justification for its unbridled and arbitrary use, especially when the
use of such power has direct consequences on the enjoyment of
fundamental rights for citizens. In the absence of reasons to justify
the severe step of issuing a Look Out Circular (LOC) or any such
direction to prevent the Petitioner from travelling abroad, merely
because the Respondents may have such a power is not reason
enough to save the Respondents’ actions from being quashed in
judicial review, for the action of the Respondent must pass the test
of reasonableness, non-arbitrariness and proportionality. It is
well-settled that where a power is required to be exercised by a
certain authority in a certain way, it should be exercised in that
manner or not at all [Hukum Chand Shyam Lal vs. Union of India
(1976) 2 SCC 128].
55

M.BECAUSE in the garb of ongoing investigation, dissenting voices
in society cannot be muzzled from speaking, as that would be an
anathema to the idea of democracy, which is part of the basic
structure of the Indian Constitution.
N. BECAUSE the Petitioner has been harassed, humiliated and
insulted by the mala fide action of the Respondents, and the
organisers of the journalist events in London and Italy have also
suffered losses and experienced grave inconvenience and
disturbance due to the arbitrary detention of the Petitioner at the
airport on 29.03.2022. It is pertinent that as a global opinions writer
at the Washington Post, the Petitioner is required professionally to
frequently travel across the globe, and unreasonable, arbitrary and
mala fide restrictions on such travel is a direct violation of the
Petitioner’s right to free speech and expression, and right to
practice her profession, as a member of the global and national
media fraternity.
56

O. BECAUSE the Petitioner has not filed any other petition with
similar reliefs either before this Hon’ble Court or any other court or
fora.
P. BECAUSE the Petitioner craves leave to rely on additional
grounds at the stage of arguments.
PRAYER
6. That in light of the facts and circumstances stated hereinabove, it is
most humbly prayed that this Hon’ble Court may be pleased to:
A) Issue a writ, order or direction in the nature of Mandamus or
Certiorari, or any other order, writ or direction, quashing and
setting aside any order, Look Out Circular, instruction or direction
issued by the Respondent No. 2 to stop the Petitioner from
travelling abroad; and
B) Pass any further orders as this Hon’ble Court may deem fit and
necessary.
AND FOR THIS ACT OF KINDNESS THE PETITIONER
SHALL AS IN DUTY BOUND FOREVER PRAY
57

PETITIONER
Through:
Advocates
8527075320
New Delhi
31.03.2022
58

To
Mr.Rajesh Kumar
Assistant Director, Enforcement Directorate
Date : 17-12-2021
Sir,
I have appeared before the Enforcement Directorate twice since June this year for
submissions pertaining to my fundraiser and that of my foreign remittances, mainly my source
of income from international publications. I also represented my sister Iffat Khalid who lives
in Dubai and my ailing father, Mohammad Ayyub Waquif. A copy of my submissions has been
received with acknowledgement from your department in September. For three months I did
not hear anything. Suddenly in the first week of December my sister and my father get
summons again. When I called your Mumbai number, the one on which I have communicated
earlier, I was told by an official that the case has been transferred to New Delhi.
I was at the ED office in New Delhi in response to a summon sent to me, my sister and my
father. On reaching New Delhi on the 15th
, I was told by Mr.Devender, the Assistant Director
of the ED that this summon had nothing to do with submissions made in the Mumbai office
but was in response to an FIR filed by the Right wing nationalist group ‘Hindu IT cell’ in Uttar
Pradesh.
I have appeared before the Income tax multiple times, complied with multiple demands,
provided them all originals of receipts and expenditure including sensitive communications
with my editors. I was asked to submit the same by you and I complied with the same. Now
the ED office in Delhi is asking for the very same documents. I am writing to you to provide to
me all the expenditures and evidences, testimonials of expenditure as soon as possible
because I have to furnish the same to the ED office in Delhi to Ms.Indu Bala.
When I requested Ms.Bala to seek these documents from the Mumbai office, I was asked to
do it myself before I appear again. I was told by Mr.Devender that neither he nor his
colleagues had the email id of the ED office in Mumbai. Since I do not have your email, I am
sending you this application via speedpost so you can furnish the documents for my
compliance of the ED summons in Delhi. I am sending a copy of this letter to Ms.Indu Bala in
New Delhi.
Sincerely,
--Sd--
Rana Ayyub
//TRUE TYPED COPY//
75
Annexure A-7

To,
Mr. Rajesh Kumar
Assistant Director, Enforcement Directorate
Mumbai Zonal Office
KAISER–I-HIND, 4th FLOOR,
CURRIMBHOY ROAD, BALLARD ESTATE,
MUMBAI – 400001 Date: 27.01.2022
Sir,
Sub: Reminder letter to provide me a copy of all the bills, invoices,
testimonials and record of evidence submitted to the Mumbai Zonal Office
of Enforcement Directorate
I am writing this letter as a follow up to my letter dt. 17.12.2021, where I had requested
you to provide me a copy of all the bills, invoices, testimonials and record of evidence
which I had submitted to the Mumbai Zonal Office of the Enforcement Directorate, as
I have been directed by the Delhi – II Zonal Office to provide the same to them for an
ongoing investigation.
I have received no response from your office to my communication dated 17.12.2021
in over a month.
That you are now informed that I am in receipt of PMLA/SUMMON/DLZ02/2022/294
dated 25.01.2022, by which I have been directed to appear before Shri Devender, Asst.
Director of ED, Delhi – II Zonal Office on 31.01.2022, along with a copy of all the
documents which I have submitted to your office. A copy of the summon is attached.
You are also informed, at the cost of repetition, that unless I am provided a copy of the
aforesaid documents by your office, I shall be unable to comply with the summons
issued by the Delhi – II Zonal Office for 31.01.2022.
In view of the above, you are again requested to expeditiously provide me a copy of the
aforesaid documents which are now in your custody and control.
Yours Sincerely,
Rana Ayyub
//True Typed Copy//
80
Annexure A-10

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2
82

//TRUE TYPED COPY//
Date: 05/02/2022
Ref- 05/02/2022/1575/CR0339/797
To:
Ms. RANA AYYUB SHAIKH
ROOM NO-705 SEA QUEEN AVENUE B-WING
SECTOR-14 KOPARKHAIRANE,
NAVI MUMBAI-400709
Sub: ED order for RANA AYYUB SHAIKH of account nos. 05401000205235,
59209820179688 and 50300428324932
Ref: ED order dt. 04.02.2022
PAN: BMEPS7947H
Dear Madam,
We have received mail from ED on 04.02.2022- to hold that funds to the account nos.
05401000205235, 59209820179688 and 50300428324932.
Basis the above instructions – we have HOLD the funds in our system for your accounts.
Details are as follows:-
Customer ID Customer Name Account Number Instruction from ED/ Hold
Amount
21113976 RANA AYYUB
SHAIKH
05401000205235 70,08,525.00
21113976 RANA AYYUB
SHAIKH
59209820179688 57,19,179.00
21113976 RANA AYYUB
SHAIKH
50300428324932 Fixed Deposit of Rs. 50 lakh
which was created on
19.05.2020 and interest
generated upon the said
Deposit- Same has already in
lien as per Income Tax
Department notice dt.-
02.11.2021
[Order no.
ITBA/COM/F/17/2021-
22/10367_]
Thanking you,
For HDFC Bank Ltd.,
Authorised Signatory
Name and Employee ID
84A

1
//TRUE TYPED COPY//
To,
Dr. Indu Bala
Deputy Director
Directorate of Enforcement, Delhi Zonal Office – II
(Prevention of Money Laundering Act, 2002)
Govt of India, Pravartan Bhawan, Motilal Nehru Marg
Opp. Taj Mahal Hotel, New Delhi – 110011
E-mail: dddlzoii5-ed@gov.in Date: 16.03.2022
Dr. Bala,
Sub: Requisition for copy of complaint under Section 5(5) of Prevention of
Money Laundering Act, 2002, along with all Annexures / relied upon
documents
1. The undersigned is in receipt of a show cause Notice u/Section 8(1) of the
Prevention of Money Laundering Act, 2002, dated 08.03.2022, which has been
physically delivered to the undersigned defendant on 15.03.2022 (yesterday) in
the second half of the day.
2. That an envelope containing the following documents, adding up to 14 pages,
was delivered to the undersigned defendant:
a) Show-Cause Notice dt. 08.03.2022 (1 page)
b) Document titled ‘Note for the Defendants / Complainant for compliance with
reference to Notice under Section 8(1) of PMLA, 2002, as directed by the
Adjudicating Authority’ (4 pages)
c) Document titled ‘Recording of reasons u/S 8(1) of PMLA, 2002, by the
Adjudicating Authority (9 pages)
3. That it is pertinent to mention that although the Show Cause Notice dt.
08.03.2022 states that “Copy of the complaint and Annexure / relied upon
documents thereto are enclosed here with”, the said complaint and its annexures
/ relied upon documents were not enclosed along with the Show Cause Notice
delivered to the residence of the undersigned defendant.
4. That the ‘Note for the Defendants / Complainant for compliance with reference
to Notice under Section 8(1) of PMLA, 2002, as directed by the Adjudicating
Authority’ served to the undersigned defendant in Para 2 at Page 2 of 4 states
that the defendant may make a requisition for documents to the Complainant
within 3 days of receipt of the notice. Needless to state that it is settled law that
the defendant has an indefeasible right to be supplied a copy of the Complaint
under Section 5(5) PMLA, 2002, along with a copy of all the relied upon
87 A

2
//TRUE TYPED COPY//
documents therein, in order to be provided an effective opportunity to respond
to the Show Cause Notice.
5. That in view of the above, the present requisition is being sent to you by email,
and also through hard copy, well within the stipulated time frame, with a copy
duly marked to the Adjudicating Authority.
6. That you are hereby requested to provide me the following documents within 3
days from receipt of the present requisition:
i. True copy of Complaint dt. 04.02.2022 u/Section 5(5) PMLA, 2002,
referred to in the Show Cause Notice dt. 08.03.2022
ii. A complete list of all relied upon documents in your complaint
iii. A true copy of all relied upon documents
7. That you are requested to provide both soft copies (scanned copies) and a hard
copy of the aforesaid documents to the undersigned defendant.
Yours Sincerely,
Rana Ayyub
R/o Flat No. 705, Sea Queen Avenue,
B Wing, Sector 14, Koparkhairane,
Navi Mumbai, Maharashtra – 400709
E-mail: rana.ayyub@gmail.com
Copy to:
1. Registrar / Administrative Officer
Adjudicating Authority (PMLA)
Room No. 26, 4th
Floor,
Jeevandeep Building, Parliament Street,
New Delhi – 110001
E-mail: registraraapmla-rev@nic.in
87 B

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Annexure A-16

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89

25 March, 2022
Ms Rana Ayyub Shaikh
Sector 14,
Koparkhairane,
Navi Mumbai
400709
India
Dear Ms Ayyub,
The International Center for Journalists (ICFJ) and Doughty Street Chambers (DSC)
would like to formally invite you to address an invitation-only event about gender-
based online violence to be staged at DSC in London(UK) 0730-1000 on April 1, 2022.
The event will take the form of a breakfast meeting for senior diplomats, editors,
human rights lawyers, elected officials and NGO directors. This event forms part of
the stakeholder engagement required by the Online Violence Early Warning System
project led by ICFJ for the UK Foreign, Commonwealth and Development Office
(FCDO). It will begin with a panel discussion in the DSC auditorium followed by a
question-and-answer session with the specialist audience. Other speakers will
include Caoilfhionn Gallagher QC, a BBC Persian service journalist and me.
Following the event, you will accompany me to The Guardian where we will address
their morning conference, at the invitation of the editor. I will be your main contact
point for this event and I can be reached at +44 7398190 552/jposetti@icfj.org. My
colleague Caoilfhionn Gallagher QC from Doughty Street Chambers can be reached at
+44 7799661924 /c.gallagher@doughtystreet.co.uk.
We would be honoured if you could accept this invitation - we know your
interventions will be valuable for all those in attendance to hear.
Kind regards,
Julie Posetti (and Caoilfhionn Gallagher QC for Doughty Street Chambers)
Dr. Julie Posetti – Deputy Vice President and Global Director of Research
International Censer for Journalists
| www.icfj.org | @ICFJ + @julieposetti |
90
Annexure A-17(colly)

Gender-Based Online Violence against Women Journalists
Friday 1st
April 2022, 8.30am – 10am BST (registration from 8.15am)
Doughty Street Chambers, 54 Doughty Street, London WC1N 2LS, United Kingdom
The International Center for Journalists (ICFJ), Doughty Street Chambers and the International Bar
Association’s Human Rights Institute (IBAHRI) invite you to join us for this expert discussion about
the problem of gender-based online violence against women journalists, and proposed solutions.
• Welcome: Tatyana Eatwell, Co-Head, Doughty Street International
• Moderator: Dr Julie Posetti, ICFJ
• Speakers: Rana Ayyub, Washington Post
Caoilfhionn Gallagher QC, Doughty Street Chambers
Baroness Helena Kennedy QC, Director, IBAHRI and member of the High
Level Panel on Media Freedom
This event forms part of the stakeholder engagement required by the Online Violence Early Warning
System project led by ICFJ for the UK’s Foreign, Commonwealth and Development Office (FCDO).
This event will take place in person, by invitation only, and advance registration is essential. Please
RSVP to events@doughtystreet.co.uk.
91

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07

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