Gujarat High Court Permits Director Rajkumar Santoshi To Travel Abroad For 'Lahore 1947' Film Promotion, Relaxes Bail Condition

The Gujarat High Court on Tuesday (December 30) relaxed the bail condition imposed on film director Rajkumar Santoshi booked in a cheque dishonour case, permitting him to travel abroad between December 30-January 4, 2026 for promotion of his upcoming directorial movie 'Lahore 1947'.

For context, Santoshi was convicted by trial court for offence under Section 138 Negotiable Instruments Act and was sentenced to undergo 2 years simple imprisonment and pay fine twice the amount of cheques to the complainant within 30 days. He had challenged this order before the high court.

Before the high court Santoshi had given an "undertaking" that he shall deposit 5 Lakh on October 30 before the High Court's registry and balance amount of Rs 83 Lakh shall be deposited in two instalments– Rs. 41,50,000 on or before November 30 and balance Rs. 41,50,000 on or before December 31. Considering the same, the high court had on October 30 suspended the sentence and granted Santoshi bail subject to certain conditions.

Among these conditions includes that Santoshi "shall not leave India without prior permission" of the High Court and he shall deposit the amount as stated in undertaking and inform the trial court about the same.

Today the applicant had moved applications seeking permission to travel abroad and seeking eight weeks time to deposit the balance amount which was left.

After hearing the parties, a vacation bench of Justice PM Raval in his order dictated:

"Vide order dated 30-10-2025 while suspending the sentence the coordinate bench of this court had imposed a condition that the applicant shall not leave India without prior permission of this court. Learned advocate Mr Bhadrish Raju would submit that the applicant is required to travel abroad for the promotional event of the upcoming movie "Lahore 1947" and thus has prayed for modification of condition imposed while suspending the sentence and enlarging applicant on bail more particularly condition 9(b) of order dated 30-10-2025 in Cr.RA 2003 of 2025. The applicant has also placed on record the tickets for travelling abroad and on perusing the same it transpires that he would be leaving on December 30, 2025 and would be returning on Jan 4, 2026 midnight. Under the circumstances, when substantial amount of the entire cheques under question has been deposited, it would be interest of justice that the applicant may be allowed to leave India from December 30 and shall return to India on or before January 5, 2026 00:00 hours. Application allowed to afore-stated extent".

Meanwhile with respect to Santoshi's plea seeking extension of time by 8 weeks to deposit the balance amount of Rs. 35 Lakhs, the court granted him time till January 31, 2026 to deposit the same, making it clear that no further extension of time would be granted.

The court in its order dictated:

"...however today the applicant has preferred present application for extension of time to deposit the balance amount of Rs. 35 Lakhs out of Rs. 41,50,000 and has sought extension of 2 months from 31-12-2025. Learned advocate Ruchit Vyas for original complainant has vehemently opposed the application on the ground that undertaking given by applicant has not been followed in its true spirit...Having heard advocates for respective parties, and considering the averments made in the application, and also considering that substantial amount has been paid by applicant and that in all the group matters, a total amount of Rs 35 Lakhs is only remaining to be deposited in the registry of this court, the interest of justice would be served if time is extended upto January 31, 2026. It is made clear that no further extension will be granted under any circumstances for depositing the amount as stated by applicant in his undertaking which has been extended by this court vide the present order. Rest of the conditions remains unaltered. Application partly allowed to aforestated extent".

The court thus partly allowed the applicants.

Case Title: Rajkumar Santoshi v/s State of Gujarat & Anr. and Batch

CR.MA/1/2025 IN R/CR.RA/2003/2025, CR.MA/2/2025 IN R/CR.RA/2003/2025 and connected petitions

Citation: 2025 LiveLaw (Guj) 241