The Delhi High Court has ruled that an adverse Police Verification Report (PVR) can be a valid reason for denying or refusing to renew an Indian passport. However, the court ordered a fresh review of the case after finding that the applicant had not been given a fair chance to challenge the negative findings. The judgment was delivered by Justice Swarana Kanta Sharma on September 5, 2026.
The court said passport authorities must consider the police report and other material before making their decision, but they are not expected to carry out the police verification all over again.
It noted that passport authorities generally do not have the same resources or access to records as police agencies for conducting detailed background checks. As a result, they can rely on an adverse PVR when deciding whether to issue or renew a passport. The fact that the police are responsible for maintaining records and conducting the verification does not, by itself, make the report unreliable, Hindustan Times reported.
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The case concerned an Indian national studying at the Australian National University in Canberra, who applied for passport renewal in February 2024. After the application remained pending for nearly 18 months, the High Commission of India in Canberra rejected it in December 2025, citing an adverse PVR marked “Not Recommended” on grounds relating to India's sovereignty, integrity and security.
His appeal before the Chief Passport Officer was subsequently rejected in March. The petitioner then approached the High Court, contending that the adverse PVR had not been supplied to him, that he was denied an opportunity of hearing and that no specific material had been disclosed to establish his involvement in activities prejudicial to national security.
While upholding the Passport Authority's power to rely on an adverse PVR, the High Court remanded the matter for fresh consideration, holding that the petitioner must be given a fair opportunity to respond to the adverse findings.
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