The Bombay High Court on Tuesday pulled up the Foreigners Regional Registration Office (FRRO) for refusing to comply with a sessions court order to process the exit permit of a US national facing trial in Maharashtra in a case of religious conversion [James Watson v. Union of India & Ors.]
Justice NJ Jamadar held that when a court order is in force, the FRRO cannot refuse to process the exit permit citing objections raised by the investigating agency.
Further, an investigating agency cannot overreach a judicial order by indirectly blocking a foreign accused from leaving India, the Court made it clear.
“The FRRO was therefore not at all justified in refusing to process the application further on the ground that the Investigating Agency has raised the objection,” the order stated.
The Court was hearing an application filed by James Leonard Watson, accused of attempting religious conversion during a prayer gathering in Bhiwandi.
Watson was booked under the Bharatiya Nyaya Sanhita for deliberate and malicious acts intended to outrage religious feelings along with alleged offences under the Maharashtra Black Magic Act, 2013 and Foreigners Act, 1946 for visa violations.
A Thane sessions court granted bail to Watson in October 2025 subject to the condition that he could not travel abroad without the court’s prior permission.
In February 2026, the sessions court allowed him to visit his mother in United States between March 9 and April 18 after she was diagnosed with breast cancer.
He then applied to the FRRO for an exit permit. But on March 10, he was informed that his application would not be processed as the investigating agency had objected.
Watson challenged this before the High Court, arguing that FRRO’s stand effectively frustrated the sessions court’s travel order and was “patently illegal”.
The State opposed the plea, citing the grave nature of the charges. It informed the court that it has also challenged the session court’s order permitting the travel.
However, Justice Jamadar confined the inquiry to the legality of the FRRO’s refusal.
“A judicial order of a Competent Court cannot be denuded of its meaning and content, in an indirect manner. Till the order permitting the applicant to travel abroad is in force, it commands obedience by the authorities. The binding efficacy and force of the order cannot be permitted to be diluted or otherwise defeated,” the Court said.
Justice Jamadar reasoned that the investigating authority ought to have assailed the order sooner if it was aggrieved by the order.
Thus, the Court directed FRRO to process Watson’s exit permit application within two days.
Advocate Zaman Ali appeared for Watson.
Advocate PS Gujar appeared for the FRRO.
Special public prosecutor Kaushik Mhatre with advocate Sanket Dhawan appeared for State.
[Read Order]