# Mahmood Ali v. U.O.I. & Ors

- **Citation:** (2026) 3 ILRA 826
- **Court:** High Court of Judicature at Allahabad
- **Decided:** 2026-03-16
- **Case number:** Writ C No. 8218 of 2026
- **Bench:** Ajit Kumar, Mrs. Swarupama Chaturvedi
- **Source:** https://unisonlegal.in/judgment/allahabad-high-court/mahmood-ali-v-u-o-i-ors-54316
- **Pages:** 9

## Text

826 INDIAN LAW REPORTS ALLAHABAD SERIES
State of U.P. and others); the order dated 15.3.2021 (Annexure-3 to the Civil Misc. Writ Petition
No.7029 of 2026, Smt. Saraswati Devi Vs. State of U.P. and others; and order dated 11.11.2025
(Annexure-4 to the Civil Misc. Writ Petition No.7050 of 2026 Shiv Kumari Vs. State of U.P. and
others), to the extent of the petitioners, respectively.

39. The aforesaid writ petitions are disposed of with the following directions to the
respective respondent-authorities:-

 (i) The petitioner may be permitted to file an additional affidavit explaining the delay,
which have occasioned in filing of the claim under the Mukhyamantri Krishak Durghatana
Kalyan Yojana from the date of expiry of limitation, to the date of application; and

 (ii) In case the aforesaid affidavit is filed within 30 days from today, the authorities
concerned, shall consider the same and after giving due opportunity to the petitioner, in case
required, pass a reasoned order, as expeditiously as possible, preferably within a period of four
weeks from the date of filing of the aforementioned affidavit by the petitioner; and

 (iii) In case the claim is being rejected on the ground of limitation and delay being not
condoned, the claim shall be subject to the outcome of the decision of the Apex Court in National
Insurance Co. Ltd. (Supra).
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(2026) 3 ILRA 826
ORIGINAL JURISDICTION
CIVIL SIDE
DATED: ALLAHABAD 16.03.2026

BEFORE

THE HON'BLE AJIT KUMAR, J.
THE HON'BLE MRS. SWARUPAMA CHATURVEDI, J.

Writ C No. 8218 of 2026

Mahmood Ali ...Petitioner
Versus
U.O.I. & Ors. ...Respondents
ISSUE FOR CONSIDERATION
Matter pertains to whether learned Magistrate was justified in rejecting petitioner's application
seeking permission for renewal of passport and travel abroad on ground that criminal
proceedings were pending and case was fixed for framing of charges.
HEADNOTE
Constitution of India - Arts.21, 226 - Passports Act, 1967 - ss.5, 6(2)(f), 7, 8, 9, 10(3)(e), 22 -
Gazette Notification No. GSR 570(E) dated 25.08.1993 - Petitioner was holding passport issued
on 07.10.2015 and same was valid up to 06.10.2025 - During subsistence of said passport
3 All. Mahmood Ali Vs. U.O.I. & Ors.
827
petitioner came to be implicated in criminal case - Show cause notice issued requiring
petitioner to explain suppression of material information in passport application regarding
criminal proceedings pending before Court - Passport thereafter impounded - Earlier writ
petition disposed of by the Court directing petitioner to move fresh application before concerned
court - Petitioner thereafter moved application before learned Magistrate praying for
appropriate order required for passport renewal - Application rejected on ground that charge
sheet had already been submitted, case was fixed for framing of charges and from order of High
Court it was not clear in respect of which case direction had been issued - Challenge in writ
jurisdiction - Justification:
Held: Court observed that right to hold passport and right to travel abroad are facets of right to
personal liberty guaranteed under Article 21 of Constitution of India - Under Section 6(2)(f) of
the Passports Act, passport authority shall refuse to issue a passport if proceedings in respect of
an offence alleged to have been committed by applicant are pending before a criminal court in
India - Through Notification No. GSR 570(E) issued under Section 22 of the Act, conditional
exemption has been created from restriction contained in Section 6(2)(f) in respect of persons
against whom criminal proceedings are pending, provided they obtain permission from
concerned criminal court and comply with conditions prescribed therein - Notification No. GSR
570(E) clarifies that pendency of criminal proceedings does not render person absolutely
disentitled to obtain passport - Court observed that trial court, which remains seized of
proceedings, is competent authority to regulate or permit travel abroad and impose conditions
necessary to secure attendance in trial - While exercising such power, court must act strictly in
accordance with law ensuring that right to travel is not curtailed mechanically or arbitrarily but
balanced in fair, reasoned and legally compliant manner consistent with Article 21 and broader
right to free movement - Criminal court seized with trial is mandatorily required to consider
application for no objection to travel abroad and to pass order both for issuance of passport and
permission to travel abroad in event it considers appropriate to grant no objection - For arriving
at a subjective satisfaction to reject or grant a passport application, there must be objective
consideration of all documents placed before authority.
In the instant case, the learned Magistrate rejected petitioner's application for passport renewal
mainly on ground that order passed by this Court did not clearly specify case crime number and
that case was fixed for framing of charges - Court held that mentioning specific case crime
number in High Court's order was immaterial, as petitioner was required to apply for permission
to travel abroad in respect of all pending cases.[Paras 12, 13, 15, 19, 20, 22, 23, 24] (E-5)
CASE LAW CITED
Pawan Kumar Rajbhar v. Union of India and 2 Ors., Neutral Citation No. 2024:AHC:9963-DB;
Rahimuddin vs. Union of India & Another, 2025 SCC OnLine All 6964;
Rahimuddin v. Union of India and another, 2025:AHC:181505-DB;
Mahesh Kumar Agarwal v. Union of India & Another, 2025 INSC 1476;
Maneka Gandhi v. Union of India, (1978) 1 SCC 248;
Satwant Singh Sawhney v. D. Ramarathnam, Assistant Passport Officer, Government of India, New Delhi and
others, AIR 1967 SC 1836

List of Acts
Constitution of India;
Passports Act, 1967.
List of Keywords
828 INDIAN LAW REPORTS ALLAHABAD SERIES
Right to hold passport; Right to travel abroad; Right to personal liberty; Article 21 of the Constitution of India;
Section 6(2)(f) of the Passports Act; Gazette Notification No. GSR 570(E); Impounding of passport; Issuance
and renewal of passport; Conditional exemption;
CASE ARISING FROM
From the order dated 16.01.2026 passed by M.P./M.L.A. Court/Additional Chief Judicial Magistrate-IVth,
Saharanpur rejecting petitioner's application seeking permission for renewal of passport and travel abroad.
Appearances for Parties
Advs. for the Petitioner: Indra Bhan Yadav
Advs. for the Respondents: A.S.G.I., Dhurva Kant Chaturvedi
(Delivered by Hon'ble Mrs. Swarupama Chaturvedi, J.)

 1. Heard Dr. S.B. Singh, learned Advocate holding brief of Sri Indra Bhan Yadav, learned
counsel for the petitioner and Sri Dhurva Kant Chaturvedi, learned panel counsel for the respondent
concerned.

2. This petition under Article 226 of the Constitution has been filed against the order
impugned dated 16.01.2026 passed by M.P./M.L.A. Court/Additional Chief Judicial MagistrateIVth, Saharanpur having following prayers:

 "i. Issue a writ, order direction in the nature of certiorari quashing the order impugned
dated 16.1.2026 (Annexure-1 to the writ petition) passed by M.P./M.L.A. Court/Additional Chief
Judicial Magistrate IVth Saharanpur.

 ii. Issue a writ, order direction in the nature of mandamus directing the M.P./M.L.A
Court/Additional Chief Judicial Magistrate IVth Saharanpur to grant permission to petitioner to
renew his passport bearing Passport No. N3475038 dated 7.10.2015 within stipulated period."

3. The brief fact giving rise to the present petition is that the petitioner was holding
passport no. N3475038 which was issued on 07.10.2015 and the same was valid up to 06.10.2025.
During the subsistence of the said passport, the petitioner came to be implicated in Case Crime No.
127 of 2022 registered at Police Station Mirzapur, District Saharanpur. Thereafter, a show cause
notice bearing no. S.C.N./323095228/23 dated 25.01.2023 was issued to the petitioner under
Section 10(3)(e) of the Passports Act, 1967 requiring him to explain the alleged suppression of
material information in the passport application regarding criminal proceedings pending before the
Court. Subsequently, the passport of the petitioner was impounded by the order dated 27.02.2023
passed by the respondent no.3, under the provisions of Section 10(3)(e) of the Passports Act, 1967.

4. The petitioner came to know about the impounding order dated 27.02.2023 after being
released from jail and thereafter approached this Court in Mahmood Ali vs. Union of India and 4
3 All. Mahmood Ali Vs. U.O.I. & Ors.
829
Others, Writ-C No. 42705 of 2025, which was disposed by this Court vide its order dated
04.12.2025. Relevant part of the order is reproduced below for easy reference:

 "5. However, in paragraph '18' of the petition, it is disclosed that the said FIR was
registered against the petitioner in the year 2022, whereas the passport was renewed on
07.10.2015 and its validity expired only on 06.10.2025. Therefore, it is clear from the undisputed
fact that the criminal case against the petitioner came to be registered during the validity of the
previous passport, which was renewed in the year 2015 for which the petitioner cannot be held at
fault. However, as on date, as the validity of the passport was been impounded has already expired,
the petitioner shall move a fresh application in accordance with Pawan Kumar Rajbhar Vs. Union
of India & 2 Ors.: Neutral Citation No.-2024:AHC:9963-DB and Rahimuddin Vs. Union of India
and another (Writ-C No.34412 of 2025) before the learned court below, to seek permission and
thereafter move a fresh application for renewal of the passport. The respondent shall consider the
said application, uninfluenced by the earlier order of impounding, which has been passed as that
passport has already expired.

 With these directions, the petition stands disposed of."

5. In compliance of the aforesaid order, the petitioner moved the application before learned
magistrate, praying for the appropriate order required for his passport renewal. The learned
Magistrate, however, by order dated 16.01.2026 rejected the application of the petitioner while
recording that a charge sheet had already been submitted against the accused and the case file was
fixed for framing of charges. The Magistrate further observed that from the order of the High Court
dated 04.12.2025, it was not clear in respect of which case the direction had been issued. It was
also observed that the presence of the accused is mandatory at the stage of framing of charges and
therefore the application was not fit to be allowed. Consequently, the application was dismissed,
and the case was fixed for framing of charges on 02.02.2026.

6. Learned counsel for the petitioner submits that the petitioner could not file response to
the show cause notice before impounding because he was detained in jail. It is further submitted
that the proceedings of Case Crime No. 127 of 2022 have been quashed the Apex Court vide its
order dated 08.08.2023. Although, it was also submitted by the learned counsel that subsequently
the petitioner has been made accused in many other cases.

7. He contends that learned Magistrate has failed to appreciate the order passed by this
Court on 04.12.2025 in Mahmood Ali (supra) and has mechanically rejected the application of the
petitioner. It is also submitted that the right to travel abroad forms part of the right to life and
personal liberty guaranteed under Article 21 of the Constitution of India and therefore the
impugned order results in an unreasonable restriction upon the fundamental rights of the petitioner.
Reliance has been placed upon the judgment of the Supreme Court in Mahesh Kumar Agarwal vs.
Union of India & Another, 2025 INSC 1476 and the judgment of this Court in Rahimuddin vs.
Union of India & Another, 2025 SCC OnLine All 6964.

8. Per contra, learned counsel representing respondents submits on the basis of instructions,
that a letter dated 24.01.2023 was received from the office of the Senior Superintendent of Police,
830 INDIAN LAW REPORTS ALLAHABAD SERIES
Saharanpur informing that multiple cases were registered against the petitioner and requesting the
Regional Passport Office to impound his passport. It is submitted that since the petitioner did not
disclose details of criminal cases in his passport application, a show cause notice dated 25.01.2023
was issued requiring him to explain the suppression of material information and to show cause why
action should not be taken to impound the passport and thereafter his passport was impounded on
27.02.2023 while issuing an intimation letter requesting him to submit the passport to the office.
Learned counsel further submits that as per the Ministry of External Affairs" Gazette Notification
No. GSR 570(E) dated 25.08.1993 read with Section 22 and Section 6 of the Passports Act, 1967, a
citizen against whom criminal proceedings are pending cannot be granted passport facilities unless
he produces an Orders or No Objection Certificate (N.O.C.) from the concerned court permitting
him to depart from India.

9. In view of the submissions advanced by learned counsel for the parties and the material
brought on record, the issue which arises for consideration before this Court is whether the learned
Magistrate has rightly rejected the petitioner"s application seeking appropriate order to apply for
renewal of his passport, particularly in the light of the directions issued by this Court on 04.12.2025
in Mahmood Ali (supra) and the legal position governing renewal of passport where criminal
proceedings are pending.

10. Having considered the submissions advanced by learned counsel for the parties and
upon perusal of the record, it appears that the learned Magistrate has rejected the application of the
petitioner mainly on the ground that the order passed by this Court on 04.12.2025 in Mahmood Ali
(supra) does not clearly specify the case crime number and that the case is fixed for framing of
charges for which the date was already fixed.

11. To decide the above issue, it is necessary to go through the order passed by this Court
on 04.12.2025 in Mahmood Ali (supra) which in our considered view, leaves no ambiguity
regarding the directions issued. This Court had clearly held in above mentioned order, that the
criminal case against the petitioner came to be registered during the subsistence of the passport
which had been issued in the year 2015 and whose validity expired on 06.10.2025. The Court
therefore directed the petitioner to move a fresh application before the concerned court seeking
permission and thereafter to apply for renewal of the passport without getting influenced by the
earlier order for impounding of the passport of the petitioner.

12. The impugned order itself records that a charge sheet has been submitted and that the
matter is fixed for framing of charges. Thus, the learned Magistrate was evidently aware of the
criminal proceedings in which the petitioner was required to appear and therefore the statement that
the High Court order doesn"t give clarity on criminal case details becomes a hyper-technical
reason, especially when the application mentions the case details and the copy of the High Court
petition could also show those details, if the same can be directed to be filed if not filed already and
the order doesn"t record the case crime number. In such circumstances, the observation that the
case crime number was not clear from the High Court"s order appears to be inconsistent and cannot
be a justified reason for the rejection of the petitioner"s application.
3 All. Mahmood Ali Vs. U.O.I. & Ors.
831
13. This court has observed in Rahimuddin vs Union Of India And Another
2025:AHC:181505-DB that:

 "17. We would also like here to consider legal right of a person seeking a passport to
travel abroad and exercise of discretion by the authority while dealing with such application. In
our considered view for arriving at a subjective satisfaction to reject or grant a passport
application, there must be objective consideration of all documents placed before the authority. In
our considered view a passport related application is also to be disposed of timely to enable a
person to opt for other remedies available in law in the event of refusal of passport and in cases of
one year extension of the validity of passport, this becomes more crucial."

 The above-mentioned legal principle applies to learned Magistrate Court also while
dealing with the application, which has direct impact of the exercise of petitioner"s fundamental
right.

14. It is also noteworthy that the application moved by the petitioner before the Magistrate
clearly indicates that the permission was sought to travel abroad and not merely for issuance or
renewal of the passport as records in the order, which means the petitioner has moved the correct
application as directed by this court because it is a matter of fact that such permission is a
prerequisite in the facts of the matter in view of the Gazette Notification No. GSR 570(E) where
criminal proceedings are pending.

15. The Court is also mindful of the legal position that the right to hold a passport and the
right to travel abroad are facets of the right to personal liberty guaranteed under Article 21 of the
Constitution of India as decided by the Supreme Court in various cases including Maneka Gandhi
v. Union of India, (1978) 1 SCC 248, Satwant Singh Sawhney v. D. Ramarathnam, Assistant
Passport Officer, Government of India, New Delhi & Ors. AIR 1967 SC 1836.

16. We have gone through relevant provisions of the Passport Act and observed that the
collective reading of Sections 5, 6, 7 and 8 of the Passports Act brings the legislative framework
governing the issuance, validity and renewal of the passport. Section 5 provides the procedure
through which an application for a passport is to be submitted and casts a corresponding obligation
upon the passport authority, subject to the other provisions of the Act, to consider such application
and decide whether the passport ought to be issued or refused. The power contemplated under
Section 5 does not operate in isolation. Section 6 imposes substantive limitations upon that power
by specifying the circumstances in which the passport authority must decline issuance of a passport
or travel document. Sub-section (1) deals with refusal to make endorsements relating to travel to
particular countries. Sub-section (2) concerns refusal of the passport itself and again begins with
the expression "subject to the other provisions of this Act", thereby indicating that the decision
must be taken within the broader statutory framework. The provision obligates the authority to
refuse issuance of passport where any of the situations enumerated in clauses (a) to (i) exist. Clause
(f), of this provision deals with the situation, where criminal proceedings in respect of an alleged
offence are pending against the applicant.
832 INDIAN LAW REPORTS ALLAHABAD SERIES
17. Section 7 of the Passport Act addresses the question of validity of a passport. It
provides that a passport ordinarily remains in force for such duration as may be prescribed by the
rules framed under the Act. At the same time, it empowers the passport authority, to issue a
passport for a shorter period, provided the reasons for doing so are communicated to the applicant
in writing. Section 8 deals with the converse situation where a passport has already been issued for
a reduced period. In such a case, the provision permits extension of the passport.

18. The scheme is further reinforced by Sections 9, 10 and 22 of the Act. Section 9
empowers the Central Government to prescribe, by rules, the form in which passports are to be
issued or renewed as well as the conditions subject to which such issuance or renewal may take
place. Section 10 addresses the position after a passport has been issued. It authorizes the passport
authority, in certain defined circumstances, to require the holder to produce the passport and, if
necessary, to impound or revoke it. Relevant provision for the facts of this case is Section 10(3)(e),
where criminal proceedings in respect of an alleged offence committed by the holder are pending
before a criminal court in India but the order passed by this Court on 04.12.2025 in Mahmood Ali
(supra) has made it clear that the trial court shall consider the said application, uninfluenced by the
earlier order of impounding, which has been passed as that passport has already expired.

19. Another crucial provision is Section 22 of the Passport Act which completes the
statutory framework by further enabling the Central Government, where it considers necessary or
expedient in the public interest, to grant exemptions from the operation of any provision of the Act
or the Rules in favour of any individual or class of persons, subject to such conditions as may be
specified. Notification No. GSR 570(E) has been issued in exercise of this power. Through this
notification, a conditional exemption has been created from the restriction contained in Section
6(2)(f) in respect of persons against whom criminal proceedings are pending, provided they obtain
permission from the concerned criminal court and comply with the conditions prescribed therein.

20. The Notification has got interpreted in various judgement of the Supreme Court
including in Mahesh Kumar Agarwal vs. Union of India & Another 2025 SCC OnLine SC 2887,
and a plain reading of Notification No. GSR 570(E) shows that it serves two principal purposes.
First, it clarifies that the pendency of criminal proceedings does not render a person absolutely
disentitled to obtain a passport. Instead, the notification permits such a person to obtain a passport
notwithstanding the restriction contained in Section 6(2)(f), where the criminal court concerned has
applied its mind and passed an order in relation to the issuance or use of the passport and where the
applicant furnishes an undertaking to appear before the court as and when required. Secondly, the
notification regulates the operation of this exemption by linking the validity and use of the passport
to the directions contained in the order passed by the criminal court. Where the court specifies the
period for which the passport may be issued, the passport authority is required to issue the passport
in accordance with that direction. Where the court does not prescribe any specific duration, the
notification itself provides guiding parameters, including issuance for a shorter period ordinarily
one year in appropriate circumstances.

21. The Supreme Court in Mahesh Kumar Agarwal (supra) has reiterated that Section
6(2)(f) of the Passports Act cannot be treated as an absolute bar merely because criminal
proceedings are pending and that the statutory exemption mechanism provided under Section 22 of
3 All. Mahmood Ali Vs. U.O.I. & Ors.
833
the Act read with Gazette Notification No. GSR 570(E) must be given full effect. The relevant
observations of the Supreme Court in the aforesaid judgment read as follows:

 "11. The OM dated 10.10.2019 does not create a new regime. It reiterates that GSR
570(E) must be "strictly applied", explains the procedure where criminal cases are pending and
makes it clear that a "no objection certificate" or permission from the criminal court, read with
the applicant's undertaking, may override an adverse police report with reasons recorded by the
Passport Officer. It also contemplates situations where more than one court is dealing with the
matter and indicates that the orders of all such courts are to be read together. The OM is thus an
administrative restatement of the position under Section 6(2)(f), Section 22 and GSR 570(E), and
cannot add to or cut down the exemption which the notification itself grants.

 .....

 25. In the light of the above discussion, we are unable to sustain the approach adopted by
the learned Single Judge and the Division Bench. Both have treated Section 6(2)(f) as an absolute
bar so long as any criminal proceeding is pending, without giving full effect to the statutory
exemption mechanism under Section 22 and GSR 570(E), and without adequately appreciating that
the criminal courts actually dealing with the appellant's cases have consciously permitted renewal
while retaining stringent control over any foreign travel. They have, in effect, converted a qualified
restriction, designed to secure the presence of an accused, into a near-permanent disability to hold
a valid passport, even where the criminal courts themselves do not consider such a disability
necessary."

22. We are conscious that in several jurisdictions, flexible visa regimes or visa-on-arrival
facilities are available for the Indian passport holders and therefore, ensuring the presence of an
accused during trial, where personal attendance is mandatory, may lead to delay in trial. This infact
justifies the legal status that the trial court, which remains seized of the proceedings, is the
competent authority to regulate or permit travel abroad and impose conditions necessary to secure
attendance in the trail. While exercising this power, the court must act strictly in accordance with
law, ensuring that the right to travel is not curtailed mechanically or arbitrarily but is balanced in a
fair, reasoned, and legally compliant manner, consistent with Article 21 and the broader right to
free movement. Thus the criminal law court seized with a trial or even in case only cognizance has
been taken is mandatorily required to consider application for no objection to travel abroad and to
pass order both for issuance of passport and permission to travel abroad in the event it considers
appropriate to grant no objection. The Regional Passport Officers are required to examine and
ensure that no objection is granted on both counts while issuing or reissuing a passport applied for.

23. On a comprehensive consideration of the facts, the submissions of the parties, and the
relevant legal and constitutional provisions, we are of the considered view that the impugned order
dated 16.01.2026 cannot be sustained. Accordingly, the petition is allowed. The impugned order is
hereby quashed, and the matter is remanded back to the learned Magistrate to consider the
petitioner"s application afresh in accordance with law. In the light of the observations made
hereinabove and the High Court order dated 04.12.2025, the mentioning specific case crime
834 INDIAN LAW REPORTS ALLAHABAD SERIES
number in High Court"s order was immaterial, as the petitioner is required to apply for permission
to travel abroad in respect of all pending cases.

24. The learned Magistrate shall pass an appropriate order after due consideration of the
principles laid down herein, ensuring that the right to travel is not curtailed mechanically or
arbitrarily, but is balanced in a fair, reasoned, and legally compliant manner with the necessity of
securing attendance at trial. No order as to costs.
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(2026) 3 ILRA 834
ORIGINAL JURISDICTION
CIVIL SIDE
DATED: ALLAHABAD 12.03.2026

BEFORE

THE HON'BLE AJIT KUMAR, J.
THE HON'BLE MRS. GARIMA PRASHAD, J.

Writ C No. 12356 of 2022

Lalsa Devi ...Petitioner
Versus
State of U.P. & Ors. ...Respondents
ISSUE FOR CONSIDERATION
Matter pertains to whether claim of the petitioner under the "Mukhyamantri Kisan Evam
Sarvahit Bima Yojna" arising out of death of petitioner's husband on 06.09.2016 was liable to be
rejected on the ground that claim processed on 27.01.2018 was delayed by more than 20
months beyond the prescribed period under the Scheme; and whether respondent authorities
were justified in rejecting the claim on limitation.
HEADNOTE
Constitution of India - Art.226 - "Mukhyamantri Kisan Evam Sarvahit Bima Yojna" - Welfare
scheme framed to provide immediate financial assistance to families of farmers in cases of
accidental death or permanent disability - Petitioner's husband, a marginal farmer, died on
06.09.2016 after being attacked by a buffalo - Petitioner submitted all claim documents before
the concerned Lekhpal well before April, 2017 but said official failed to forward the same to the
competent authority - After transfer of said Lekhpal, petitioner again handed over documents to
newly posted Lekhpal on 27.01.2018 - District Magistrate treated 27.01.2018 as the date of
filing of claim application and rejected claim by order dated 16.12.2021 holding that claim had
been filed after delay of more than 20 months beyond the prescribed period - Challenge in writ
jurisdiction - Justification:
Held: Object of the Scheme, 'Mukhyamantri Kisan Evam Sarvahit Bima Yojna', is to provide immediate
financial assistance to family of farmer who suffers accidental death or permanent disability so that family may
overcome sudden economic distress caused by loss of sole earning member - Scheme forms part of State's
welfare policy aimed at providing socio-economic protection to vulnerable sections of society, particularly
farming community - Beneficial or welfare statutes should be given liberal interpretation and not narrow and
technical interpretation - Administrative action in such matters must adopt proactive and pragmatic approach