The Bombay High Court has paved the way for Dr. Sangram Patil, a consultant with the National Health Service (NHS) in the United Kingdom, to travel abroad by ordering the modification of a Look Out Circular (LOC) issued against him. The travel ban had been in place following a criminal investigation into social media posts allegedly containing disinformation about Prime Minister Narendra Modi and the Bharatiya Janata Party (BJP).
Background and Legal Issue
The Petitioner, Dr. Sangram Patil, had been restricted to India since January 10, 2026, due to an LOC issued on December 22, 2025 (read with January 10, 2026). The criminal case originated from a complaint alleging that a Facebook page titled “Shehar Vikas Aghadi” spread “disinformation and falsehoods” concerning Prime Minister Narendra Modi, the political leadership, and the BJP.
Following the registration of a First Information Report (FIR) at the N. M. Joshi Marg Police Station in December 2025, Dr. Patil moved the High Court seeking to quash the FIR and the LOC. The Petitioner argued that the travel restriction threatened his employment as a consultant with the NHS in the UK. During the proceedings, Dr. Patil submitted an affidavit dated March 24, 2026, stating:
“On reflection, I realise that the language used in the said post may be perceived as harsh and inappropriate. I sincerely state that if the subject post hurt the sentiments of any person, I regret the same. This statement is made in good faith and without admission of any offence.”
Arguments of the Parties
Mr. Rajiv Shakdher, learned Senior Advocate for the Petitioner, contended that Dr. Patil must return to the United Kingdom to join his duty or face removal from his post. He submitted that the Petitioner was willing to provide personal undertakings, supported by his parents—who are permanent residents of India—guaranteeing his return to India as required by the investigation.
Mr. Milind Sathe, the learned Advocate General for the State of Maharashtra, informed the Court that while the investigation was proceeding, it was taking time because reports were still awaited from various agencies. However, the Advocate General stated that if the reports were not received within three weeks from April 20, 2026, the State had no objection to modifying the LOC, provided the Petitioner and his parents furnished undertakings guaranteeing his presence for investigation upon receiving a 15-day advance notice.
Court’s Analysis and Decision
The Court noted that the petition was admitted on April 15, 2026. Pursuant to the discussions regarding travel conditions, the Petitioner and his parents (Mr. Gokulsingh Indrasingh Patil and Mrs. Kalpana Gokulsingh Patil) filed formal undertakings on April 24, 2026.
Advocate General Milind Sathe confirmed that Respondent No. 1 was satisfied with the content of the undertakings. Justice Ashwin D. Bhobe accepted these as formal statements and undertakings to the Court.
The Court ordered:
“Respondent No.1 shall modify the LOC dated 22nd December 2025 read with 10th January 2026. To clarify… by virtue of the said modification… the Petitioner would be able to travel outside India.”
The State was further directed to communicate this modification to the relevant authorities on or before May 11, 2026. The Court recorded that no further orders were required regarding the travel restrictions at this stage.
Case Details:
Case Title: Dr. Sangram Patil v. Vilas Ramchandra Rane and Ors.
Case No.: Criminal Writ Petition No. 1409 of 2026
Bench: Justice Ashwin D. Bhobe
Date: May 05, 2026
