HC Relaxes Bail Condition to Permit Frequent Foreign Travel for Business

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Bail Condition for Foreign Travel

Case Details: Ankur Agrawal vs. Union of India - [2025] 179 taxmann.com 128 (Rajasthan)

Judiciary and Counsel Details

  • Maneesh Sharma, J.
  • Prakul Khurana for the Petitioner.
  • Kinshuk Jain, Senior Standing Counsel for the Respondent.

Facts of the Case

The petitioner, alleged to be involved in GST evasion, had been granted regular bail with conditions requiring prior permission for international travel and passport deposit. He contended that these conditions were onerous, as he was a director and operational head of the company requiring frequent foreign travel, while his family resided in India and his wife was undergoing medical treatment. The legal issue was whether the bail conditions restricting travel could be modified, and the matter was accordingly placed before the High Court.

High Court Held

The High Court held that requiring prior permission for each international trip was onerous and hampered the petitioner’s business activities. Considering his role, frequent travel needs, and lack of flight risk, the Court permitted him to travel abroad on condition of disclosing his travel schedule to the trial court, returning his passport, cooperating in the trial, and attending all hearings. The ruling clarified that bail conditions can be adjusted to accommodate professional obligations while ensuring compliance with judicial proceedings.

List of Cases Referred to

  • Jagdish Arora v. Union of India [MCRC No. 4923 of 2022, dated 31-3-2022] (para 7)
  • Aman Kumar Singh v. State of Chhattisgarh [CRMP No. 1835 of 2023, dated 20-9-2023] (para 7)
  • Kirti Vishwanath Kedia v. CBI (EOB) [Interim Application No. 3323 of 2024/Anticipatory Bail Application No. 960 of 2022, dated 22-8-2025] (para 7)
  • Barun Chandra Thakur v. Ryan Augustine Pinto [Criminal Appeal No. 1618 of 2019, dated 21-10-2019] (para 9)
  • Disha A. Ravi v. State (NCT of Delhi) [Crl.M.A. No. 22214 of 2023, dated 26-9-2023] (para 9)
  • Aparna Purohit v. State of U.P [Application u/s 482 No. 6022 of 2022, dated 2-11-1012] (para 9)
  • Ashutosh Bajoria v. Rajesh Kumar Sharma 2023 (1) Crimes 419 (Raj.) (para 19)
  • Smt. Maneka Gandhi v. Union of India AIR 1978 SC 597 (para 19)
  • Satish Chandra Verma v. Union of India [Civil Appeal No. 3802 of 2019, dated 9-4-2019] (para 19)
  • Parvez Noordin Lokhandwalla v. State of Maharashtra 2020 INSC 573 (para 20).

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Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied