New Delhi: The Delhi High Court has held that an adverse police verification report (PVR) can constitute a valid ground to deny issuance or renewal of a passport, observing that the Passport Authority is entitled to rely on such a report while considering an application.
Justice Swarana Kanta Sharma, in a September 5 judgment, said the Passport Authority must independently apply its mind to a passport application and the material before it, but cannot disregard or independently re-examine the factual verification conducted by police authorities. The court said the Passport Authority ordinarily has no independent mechanism to conduct the kind of verification of antecedents undertaken by police and is therefore entitled to consider a PVR while deciding whether to issue or renew a passport.
“The mere fact that the Passport Authority has relied upon an adverse Police Verification Report cannot, by itself, be a ground to fault the decision-making process,” the court said. It added that the PVR “cannot be treated as not relevant” to the decision-making process, as police authorities are responsible for maintaining records and conducting verification within their jurisdictions.
The court was hearing a plea by an Indian national studying at the Australian National University in Canberra, challenging an order of the Office of the Joint Secretary (PSP) and Chief Passport Officer rejecting his passport renewal application. He also argued that the appellate authority had failed to independently apply its mind and that non-disclosure of the report and denial of an opportunity of hearing had rendered the statutory appeal ineffective. The man said he had submitted a complete application on February 1, 2024, but it remained pending for nearly 18 months without reasons being disclosed or a decision communicated. In December 2025, the High Commission of India (HCI) in Canberra rejected his application, citing an adverse PVR. His appeal before the Chief Passport Officer was rejected on March 10, following which he approached the high court.
