Actor Imran Khan Pal on Saturday moved the Bombay High Court challenging a notice issued by the Foreigners Regional Registration Officer (FRRO), Mumbai, directing him to leave India by October 28. In his petition, titled Imran Khan Pal v. Union of India & Ors, the actor has described the notice as “arbitrary, unreasoned and wholly misconceived”, alleging that it was issued without a hearing and violated his constitutional rights. Khan, around 44, filed the petition on Saturday through MZM Legal, seeking urgent intervention from the High Court to stay the notice issued on October 14. He has argued that the directive violates the principles of natural justice and his fundamental rights under Articles 14 and 21 of the Constitution. Khan also stated that he had been living in India since he was two years old. The petition is likely to be mentioned before the court on Monday.
Challenging the FRRO's October 14 notice, Khan has alleged that the authorities failed to provide reasons for directing him to leave the country or give him a reasonable opportunity to present his case. The petition argues that Articles 14 and 21 of the Constitution, which guarantee equality before the law and protection of life and personal liberty, also apply to foreign nationals in India. Khan has contended that the notice was issued without specifying the alleged violations or disclosing the material on which the decision was based.
“The notice doesn’t disclose statutory contravention or the semblance of any due process,” the petition states. The actor has also sought a stay on the notice, arguing that its enforcement would undermine constitutional protections and the principles of natural justice.
The FRRO issued the departure notice on October 14, directing Khan to leave India within two weeks, with October 28 set as the deadline. The action came within four days of a protest in Mumbai against the Special Intensive Revision (SIR) of electoral rolls, which Khan had attended. The FRRO, an office under the Bureau of Immigration, invoked the Immigration and Foreigners Act, 2025, in issuing the notice. However, Khan has challenged the basis of the directive, stating that it does not identify the specific provisions of the law he allegedly violated. According to the petition, the notice is silent on the alleged contravention, the underlying order or data used to justify the decision, and any security report forming the basis for the action. Khan has further stated that he has no criminal antecedents.
In his plea, Khan has denied any association with organisations or institutions involved in organising or participating in the demonstration against the incumbent Chief Election Commissioner in Mumbai. The petition states that he has “no association, affiliation or connection whatsoever with any organization or institution involved in organizing or participating in the protest against the incumbent chief election commissioner in Mumbai”. Khan has argued that the authorities failed to consider the complete facts and his rights as an Overseas Citizen of India (OCI) cardholder before issuing the notice.
The actor has alleged that the directive amounts to punitive executive action and has questioned the motives behind its issuance. Describing himself as a “scapegoat”, Khan has argued that the notice appears to have been issued for extraneous reasons, including to “stifle perceived dissent”. The petition states that such action cannot be allowed to suspend his constitutional guarantees or curtail rights without a fair, just and reasonable procedure. It further argues that the notice is disproportionate and reflects a failure by the authorities to apply their minds to the facts of the case.
On Saturday, the day Khan e-filed his petition challenging the departure notice, the FRRO issued him a fresh show-cause notice asking why action should not be initiated against him under the laws governing foreigners and OCI cardholders. Khan has challenged the October 14 notice and sought its quashing, along with urgent relief against its enforcement. The matter is likely to be mentioned before the Bombay High Court on Monday, where the actor is seeking judicial intervention against the direction to leave India by October 28.
