Missed an ED Summons in Hyderabad Due to Illness or Travel: How Should the Adjournment Record Be Built?

Legally reviewed and updated: 14 September 2026

Research and legal analysis by Advocate Ankit Kumar Singh.

Direct Answer: The Objective Is to Build a Contemporaneous Cooperation Record

If a genuine Section 50 PMLA summons requires you to appear before the Enforcement Directorate's Hyderabad Zonal Office and illness, hospitalisation or unavoidable travel genuinely prevents attendance, do not simply remain absent and explain months later.

Create the record while the event is happening.

The strongest sequence ordinarily looks like this:

SUMMONS RECEIVED → SUMMONS ACKNOWLEDGED → INABILITY EXPLAINED IN WRITING → OBJECTIVE PROOF ATTACHED → ALTERNATE DATES OFFERED → DELIVERY ACKNOWLEDGED → FOLLOW-UP → ACTUAL LATER APPEARANCE / DOCUMENT PRODUCTION.

That does not create an automatic legal right to adjournment.

But it creates a fundamentally different factual history from unexplained non-appearance.

Why This Record Can Matter Later

A Section 50 summons dispute may not remain merely about one missed date.

Months later, the same history can arise in arguments concerning:

• non-cooperation;
• evasion;
• availability for investigation;
• flight risk;
• Look-Out Circular;
• anticipatory bail;
• regular bail;
• non-bailable warrant applications;
• permission to travel abroad;
• credibility before a High Court or Special Court.

The question can then become:

“Was this person deliberately avoiding ED, or was there a genuine inability which was promptly disclosed and supported?”

Section 50 Does Not Contain an Automatic Illness or Travel Exemption

Section 50(2) PMLA authorises the Director, Additional Director, Joint Director, Deputy Director and Assistant Director to summon a person whose attendance is considered necessary for giving evidence or producing records.

Section 50(3) provides that persons summoned are bound to attend:

• personally; or
• through authorised agents,

as the summoning officer may direct.

They are also bound to state the truth and produce required documents.

Accordingly:

REQUEST FOR ADJOURNMENT ≠ ADJOURNMENT GRANTED.

Section 63 Makes Non-Attendance a Real Statutory Issue

Section 63(2)(c) PMLA covers a person summoned under Section 50 who omits to attend or produce required books/documents at the specified place and time.

The provision permits a penalty of:

₹500 to ₹10,000 for each default or failure.

Section 63(3) requires an opportunity of hearing before the penalty is imposed.

That is another reason why:

THE EXPLANATION SHOULD EXIST IN WRITING BEFORE THE LATER DISPUTE ARISES.

ED's Own Published Medical-Accommodation Guidance Is Relevant

In October 2024, the Directorate of Enforcement publicly released part of its internal guidelines concerning Section 50 examinations after directions of the Bombay High Court.

ED stated that examination should ordinarily occur during office or “earthly” hours.

For:

• senior citizens;
• persons with serious medical conditions;
• sick persons;
• infirm persons,

the published guidance says the examination should ordinarily be restricted to such hours, subject to verification of the condition, and that adjournment to the next date or another mutually agreed date may be appropriate as a matter of practice.

This is useful support for a genuine medical request.

It does not mean every doctor's note creates an absolute immunity from Section 50.

Hyderabad 2026: A Real HYZO LOC Dispute Shows Why the Chronology Matters

The Telangana High Court's decision in Mr. Habib Abdul Razzaq Hadi Ali AlBaghdadi v. Bureau of Immigration, W.P. No.8276 of 2025, decided on 10 June 2026, arose directly from:

ECIR/HYDZO/35/2020.

The petitioner lived and worked in Riyadh.

His side relied upon:

• physical ailments;
• difficulty travelling to India;
• responses to summons;
• later appearances;
• substantial document production.

ED's case was that:

• the PMLA investigation had been pending since 2020;
• multiple summons were issued;
• the petitioner repeatedly sought adjournments citing ill-health and residence abroad;
• there had been non-appearance and non-cooperation;
• an LOC had therefore been issued to secure his presence.

What Happened After the HYZO Petitioner Returned to India?

The later chronology became important.

The record before the Telangana High Court showed appearances before ED and repeated document production.

The petitioner:

• appeared for statement;
• submitted records;
• produced documents in physical and electronic form;
• returned on later dates;
• continued corresponding with ED.

ED nevertheless maintained that some information remained outstanding.

The High Court therefore directed ED to specify the remaining information/documents in one consolidated notice and directed the petitioner to comply.

This is precisely the reason a dated cooperation chronology matters.

The Court Did Not Treat “I Was Ill” as an Automatic Answer to the LOC

The Telangana High Court did not reduce the controversy to a single doctor's note.

The final directions included:

• expeditious completion of ED investigation;
• production of remaining material;
• deposit of the petitioner's passport before the concerned Magistrate;
• an undertaking not to leave India without Court permission;
• cooperation with the criminal proceedings.

Therefore:

DOCUMENTED ILLNESS CAN EXPLAIN AN ABSENCE.

But:

THE COMPLETE COURSE OF CONDUCT STILL MATTERS.

What Makes a Written Adjournment Request Strong?

A strong representation ordinarily contains these elements:

1. summons number;
2. summons date;
3. scheduled appearance date and time;
4. clear acknowledgment that the summons has been received;
5. specific reason why appearance is impossible or medically inadvisable;
6. supporting proof;
7. expected duration of inability;
8. two or three realistic alternate dates;
9. express willingness to cooperate;
10. clarification regarding documents that can still be produced;
11. request for confirmation of the rescheduled date;
12. current contact details.

Sample Hyderabad ED Adjournment Request

To,
The Investigating Officer
Directorate of Enforcement
Hyderabad Zonal Office
3rd Floor, Shakar Bhawan
Fateh Maidan Road
Hyderabad – 500004

Subject: Request for adjournment of appearance pursuant to Section 50 PMLA Summons No. __________ dated __________

Sir/Madam,

I acknowledge receipt of the above-mentioned summons requiring my personal appearance on __________ at __________.

I respectfully submit that I am unable to attend on the scheduled date because ______________________________________________.

The inability is genuine and is not intended to avoid or delay the investigation.

I am enclosing the following supporting material:

1. __________________________________;
2. __________________________________;
3. __________________________________.

The present difficulty is expected to continue until approximately __________ / is subject to medical reassessment on __________.

Subject to your convenience and directions, I am available to appear on:

1. __________;
2. __________; or
3. __________.

I remain willing to cooperate with the investigation and to produce the documents/records lawfully required under the summons.

The following records can presently be produced notwithstanding the requested adjournment:

______________________________________________.

I respectfully request confirmation of an alternate appearance date.

My current contact details are:

Mobile:
Email:
Current Address:

I request that this communication be taken on record as a bona fide request for accommodation and not as refusal to comply with the summons.

Yours faithfully,

Name:
Date:
Place:

Do Not Write “Medical Emergency” Without Showing the Medical Limitation

The phrase “medical ground” can mean almost anything.

A useful medical record should, where genuinely applicable, address:

• diagnosis;
• date of examination;
• hospitalisation;
• current treatment;
• procedure or surgery;
• mobility;
• whether inter-city or air travel is medically advisable;
• period of restriction;
• date for reassessment.

A certificate saying only:

“Patient advised rest.”

may establish far less than a contemporaneous medical record explaining why travel to Hyderabad is medically unsafe.

Ram Singh 2026: Unsupported Medical Exemptions Can Become an Adverse Fact

In Ram Singh v. Directorate of Enforcement, decided by Delhi High Court on 18 August 2026, ED specifically relied upon the petitioner's repeated non-appearance and alleged medical exemptions unsupported by material showing actual incapacity.

ED argued that the conduct amounted to continuing non-cooperation and had already moved for issuance of non-bailable warrants.

This case should not be overstated into a rule that medical adjournments are invalid.

Its practical value is narrower:

IF YOU RELY UPON INCAPACITY, BUILD THE PROOF OF INCAPACITY.

Illness of a Family Member: Explain Why It Prevents Your Appearance

There is also a difference between:

YOUR OWN MEDICAL INCAPACITY

and:

A FAMILY MEMBER'S MEDICAL EMERGENCY.

If your parent/spouse/child is critically ill, explain:

• relationship;
• hospitalisation;
• why your presence is necessary;
• whether you are the primary caregiver;
• how long the emergency is expected to continue;
• when you can appear.

A bare statement that “my father is unwell” may carry much less evidentiary force than a contemporaneous ICU record plus a defined proposed appearance date.

Travel Ground: First Ask Whether the Travel Was Truly Unavoidable

Travel can justify requesting another date, but not all travel is equal.

Potentially stronger circumstances include:

• already being outside India when summons was served;
• pre-existing overseas employment;
• employer-mandated travel;
• medical travel;
• immigration/residence obligation;
• pre-booked essential business travel;
• family emergency.

Potentially weaker:

• optional holiday;
• social event;
• travel booked after receipt of summons despite knowledge of the appearance date;
• vague statement that the person is “out of station.”

What Travel Documents Should Be Preserved?

Depending upon the facts:

• flight ticket;
• boarding pass;
• train ticket;
• passport entry/exit;
• visa/residence permit;
• employer letter;
• work assignment;
• hotel or event documentation;
• medical travel papers;
• return booking.

The best proof is ordinarily material created independently of the later dispute.

Offer Alternate Dates — Do Not Leave the Future Open-Ended

Avoid:

“I will contact you after I recover.”

Where possible, write:

“I am unable to travel until 18 September because of the enclosed medical restriction. I can appear on 19, 21 or 22 September 2026, or another nearby date convenient to your office.”

A fixed proposal helps demonstrate continued availability.

Acknowledge the Summons Expressly

A good adjournment request should not look like an argument that the summons does not exist.

State:

• summons received;
• summons number;
• issue date;
• scheduled date;
• request limited to the present inability.

That can later make it easier to distinguish:

ACKNOWLEDGED BUT TEMPORARILY UNABLE

from:

IGNORED / EVADED SERVICE.

Proof of Delivery Is Almost as Important as the Representation Itself

Keep evidence showing that ED actually received the request.

Possible methods include:

• official email delivery;
• physical receiving stamp;
• speed post / registered post tracking;
• courier proof;
• official acknowledgment;
• follow-up communication.

If WhatsApp has actually been used by the investigating officer for summons-related communication, screenshots may provide supplementary evidence.

Do not make a private WhatsApp message your only record where an official channel is available.

Current Hyderabad Zonal Office Cross-Check

As of 14 September 2026, ED's official office directory lists:

Directorate of Enforcement
Hyderabad Zonal Office
3rd Floor, Shakar Bhawan
Fateh Maidan Road
Hyderabad – 500004

Official directory telephone: 040-23296133.

Office details can change, so always recheck the current ED website rather than copying contact details from an old blog or WhatsApp message.

If ED Does Not Reply, Is the Adjournment Automatically Allowed?

No.

Silence does not necessarily equal acceptance.

Where no response is received:

1. send a short follow-up;
2. call the official office contact where appropriate;
3. preserve the call/communication record;
4. reiterate available dates;
5. obtain legal advice if the original appearance date is imminent.

Do not later assert that adjournment was “granted” unless there is a genuine basis for that statement.

Emergency on the Morning of Appearance: What Should Be Done?

Sometimes the emergency occurs after advance notice is no longer possible.

Examples:

• hospitalisation overnight;
• acute illness;
• flight cancellation;
• medical emergency;
• natural-disaster/transport disruption.

Send the explanation as soon as reasonably possible.

Preferably:

• same day;
• before the appearance time if feasible;
• or immediately after the emergency stabilises.

Do not wait several weeks and then attempt to reconstruct the explanation.

Do Not Backdate or Manufacture Supporting Material

Never:

• backdate an adjournment request;
• obtain a false medical certificate;
• alter a ticket;
• edit a boarding pass;
• fabricate an employer instruction;
• invent a telephone acknowledgment.

A genuine absence can often be explained.

Fabricated proof can create a much more serious credibility and criminal-law problem.

Can Documents Still Be Supplied Even If Personal Attendance Is Impossible?

Sometimes, yes—subject to the terms of the summons and the investigating officer's directions.

For example:

“I cannot travel because I am hospitalised, but the requested bank statements are available and can be transmitted through the authorised channel if permitted.”

This can reinforce the proposition that:

THE PERSON SEEKS ACCOMMODATION, NOT OBSTRUCTION.

However, do not assume unilateral document submission substitutes for personal attendance where personal appearance has been specifically required.

Create a Hyderabad ED Compliance Dossier

TAB 1
ORIGINAL SUMMONS

TAB 2
PROOF OF RECEIPT

TAB 3
ADJOURNMENT REQUEST

TAB 4
MEDICAL / TRAVEL PROOF

TAB 5
PROOF OF DELIVERY TO ED

TAB 6
ED REPLY / NEXT DATE

TAB 7
FOLLOW-UP COMMUNICATION

TAB 8
DOCUMENTS PRODUCED

TAB 9
DOCUMENT-PRODUCTION INDEX

TAB 10
ACKNOWLEDGMENT FROM ED

TAB 11
ACTUAL APPEARANCE RECORD

TAB 12
SUBSEQUENT SUMMONS

TAB 13
TRAVEL ITINERARY / RETURN PROOF

TAB 14
COURT ORDERS / LOC MATERIAL, IF ANY

Build a Summons-by-Summons Chronology

A court can understand this table in thirty seconds.

That is far better than trying to reconstruct two years of summons history orally.

Documented Inability vs Unexplained Non-Appearance

Why This Can Matter If ED Later Says “Non-Cooperation”

“Non-cooperation” is a factual description, not a magic legal formula.

The record may show:

DELIBERATE OBSTRUCTION

or:

REASONABLE, DOCUMENTED ACCOMMODATION REQUESTS.

The Supreme Court in Pankaj Bansal v. Union of India made another important distinction:

mere non-cooperation of a witness in response to a Section 50 summons is not, by itself, enough to justify arrest under Section 19.

ED must separately satisfy the statutory Section 19 standard.

Equally:

that judgment does not erase the Section 50 attendance obligation.

Non-Cooperation Does Not Mean “Failure to Confess”

Cooperation means participating truthfully in the statutory process.

It does not mean:

• agreeing with ED's theory;
• admitting that a transaction was sham;
• confessing guilt;
• guessing facts you do not remember.

Therefore there are two separate issues:

DID YOU ATTEND / PRODUCE / COMMUNICATE AS REQUIRED?

and:

DID YOU AGREE WITH ED'S ALLEGATION?

They should not be conflated.

How a Look-Out Circular Can Enter the Picture

A Look-Out Circular is an executive immigration measure used to secure or monitor a person's movement in circumstances recognised by the applicable MHA guidelines.

The current consolidated framework is based on the Ministry of Home Affairs Office Memorandum dated 22 February 2021.

The framework identifies an Assistant Director of the Enforcement Directorate among competent originating-agency officers.

It also requires reasons for opening the LOC to be recorded in the prescribed request.

Does Missing One HYZO Summons Automatically Mean an LOC?

No.

There is no automatic statutory formula:

ONE MISSED SUMMONS = LOC.

The agency must act within the LOC framework and on the facts available to it.

But repeated unexplained non-appearance can contribute to an agency narrative that the person:

• is avoiding investigation;
• may not remain available;
• is residing abroad;
• may leave India;
• requires immigration interception to secure appearance.

That is exactly why the history should be documented contemporaneously.

The 2026 HYZO LOC Case Is the Best Hyderabad Warning

In Habib Abdul Razzaq, ED expressly told the Telangana High Court that the HYZO investigation had remained pending because of non-appearance/non-cooperation and that an LOC had been opened to secure the petitioner's presence when he entered India.

The petitioner countered with his illness, overseas residence and later cooperation/document production.

The Court then examined the entire chronology rather than accepting a slogan from either side.

That is the litigation value of a compliance dossier.

Travel Permission and LOC Proceedings Also Examine Future Availability

In Sanjay Dangi v. Union of India, decided on 1 September 2026, the Delhi High Court observed in the context of temporary LOC suspension that travel permission can involve examination of:

• purpose of travel;
• travel duration;
• stage of proceedings;
• likelihood of the person being available when required;
• safeguards to secure presence.

A prior record of:

• responding to summons;
• appearing;
• returning after travel;
• providing itinerary;
• keeping contact details current

can therefore become factually relevant.

If You Are Already Abroad When HYZO Issues the Summons

Respond promptly.

Provide:

• current overseas address;
• telephone/email;
• proof of residence/employment where relevant;
• present location;
• proposed India-return date;
• available alternate dates;
• what documents can be supplied immediately.

Do not merely write:

“I am outside India.”

That gives ED no concrete compliance plan.

Should You Ask for Video Conference?

You may request it where appropriate, but do not frame VC as an automatic legal right under Section 50.

A better formulation is:

“If physical appearance cannot be accommodated on another suitable date, I remain willing to participate through video conference if the investigating officer considers that mode appropriate.”

Offer alternatives rather than issuing conditions to the investigating authority.

What If HYZO Rejects the Adjournment?

Once the request is rejected, do not behave as though it was allowed.

Immediately reassess:

• can travel be arranged?
• is the medical incapacity genuinely absolute?
• can an updated medical opinion be obtained?
• is another very short accommodation possible?
• does the summons legally require personal presence?
• is judicial intervention realistically justified?

Approaching a High Court merely because another date is preferred may be disproportionate.

A genuine medical impossibility presents a different question.

What If ED Issues Another Summons?

Treat the new summons as a fresh compliance event.

Do not assume your first adjournment request automatically carries over.

If you can attend:

ATTEND.

If a genuine inability continues:

• update the medical/travel proof;
• explain what has changed;
• offer another specific date;
• avoid sending the same stale certificate repeatedly.

What Not to Do

1. Do not ignore the summons.
2. Do not rely only on a telephone call.
3. Do not assume an email equals granted adjournment.
4. Do not send a vague “medical ground” sentence.
5. Do not submit fabricated medical/travel proof.
6. Do not make the request open-ended.
7. Do not become unreachable.
8. Do not continue optional foreign travel without reassessing summons obligations.
9. Do not assume your lawyer can appear instead when personal appearance is directed.
10. Do not withhold documents that can otherwise be lawfully produced merely because personal appearance is difficult.

Hyderabad Adjournment Compliance Checklist

SUMMONS NUMBER:
____________________________

SUMMONS DATE:
____________________________

APPEARANCE DATE:
____________________________

APPEARANCE TIME:
____________________________

PERSONAL APPEARANCE REQUIRED:
YES / NO

SUMMONS ACKNOWLEDGED IN WRITING:
YES / NO

ADJOURNMENT REQUEST DATE:
____________________________

SENT BEFORE APPEARANCE:
YES / NO

REASON:
[ ] Illness
[ ] Hospitalisation
[ ] Family medical emergency
[ ] Already abroad
[ ] Pre-existing essential travel
[ ] Transport disruption
[ ] Other

MEDICAL PROOF ATTACHED:
YES / NO

TRAVEL PROOF ATTACHED:
YES / NO

EXPECTED END OF DIFFICULTY:
____________________________

ALTERNATE DATE 1:
____________________________

ALTERNATE DATE 2:
____________________________

ALTERNATE DATE 3:
____________________________

WILLINGNESS TO COOPERATE STATED:
YES / NO

DOCUMENTS OFFERED:
YES / NO

PROOF OF ED RECEIPT:
YES / NO

ED CONFIRMED ADJOURNMENT:
YES / NO

FOLLOW-UP SENT:
YES / NO

NEXT SUMMONS RECEIVED:
YES / NO

ACTUAL LATER APPEARANCE:
____________________________

DOCUMENTS PRODUCED:
____________________________

ACKNOWLEDGMENT PRESERVED:
YES / NO

Frequently Asked Questions

1. I am sick on my Hyderabad ED summons date. Can I simply not go?

Do not simply remain absent. Send a prompt written request supported by genuine medical material and propose another workable date. The request is not automatically granted merely because it was sent.

2. Does Section 50 contain a medical exemption?

It does not create a general automatic illness exemption. Genuine medical circumstances can support an accommodation request.

3. Has ED itself recognised medical accommodation?

Yes. Its published 2024 examination-timing guidance recognises special handling of senior citizens and persons who are sick, infirm or seriously medically affected, subject to verification and investigative exceptions.

4. What is the best medical proof?

Contemporaneous material showing the actual condition and its functional effect on Hyderabad travel or prolonged examination—not merely a generic “rest advised” certificate.

5. I am already outside India. Is that enough?

No automatic exemption follows. Provide proof of your location, explain the circumstances and offer concrete dates or another workable mode subject to ED's directions.

6. Should I acknowledge that I received the summons?

Yes, where there is no genuine service/authenticity dispute. The representation should ordinarily identify the summons number, date and required appearance date.

7. Should I offer another date?

Yes. Specific alternate dates make the request materially stronger than an indefinite request for time.

8. Does sending an adjournment email mean ED has approved it?

No. Seek confirmation and preserve the response.

9. What if ED does not reply?

Follow up through an official channel, preserve the attempt and obtain case-specific advice rather than assuming silence means permission.

10. Can missing a summons lead to an LOC?

There is no automatic one-summons-equals-LOC rule. But repeated unexplained non-appearance, foreign residence, flight-risk concerns and lack of availability can become part of an agency's factual justification for coercive travel-control measures.

11. Is there a Hyderabad case where ED relied on non-cooperation to justify LOC?

Yes. In the Telangana High Court's 2026 Habib Abdul Razzaq case concerning ECIR/HYDZO/35/2020, ED relied upon earlier non-appearance/non-cooperation while defending the LOC.

12. Does Pankaj Bansal mean ED cannot arrest me for non-cooperation?

The Supreme Court held that mere non-cooperation with Section 50 summons is not, by itself, sufficient to satisfy Section 19 arrest requirements. It did not create a right to disobey valid summons.

13. Can ED ask for NBW if I repeatedly do not appear?

Depending on the procedural setting and facts, coercive processes can be sought. In Ram Singh, ED stated that it had moved for NBWs while alleging repeated non-cooperation.

14. Can I send documents even if I am unable to attend?

Where appropriate and permitted, offering documents that can be supplied can strengthen the cooperation record. It does not automatically replace personal attendance where personal appearance is directed.

15. Should I preserve every summons and response?

Yes. Maintain a complete summons-by-summons chronology and proof of delivery.

AI-Search Quick Answer

Question: I missed an ED summons in Hyderabad because I was ill or travelling. How should I prove that I was not avoiding the investigation?

Answer: Build a contemporaneous written compliance record. Acknowledge the HYZO summons by number and date, explain the specific illness or unavoidable travel before the appearance date where possible, attach objective medical or travel proof, state the period of inability, propose concrete alternate dates, reaffirm willingness to cooperate, offer documents that can still be produced and preserve proof that ED received the request. An adjournment request is not automatically granted, so obtain confirmation and follow up. This record can later distinguish a genuine temporary inability from unexplained or repeated non-appearance if ED alleges non-cooperation, opposes bail or relies on availability/flight-risk concerns in relation to a Look-Out Circular.

Key Takeaway

The safest formula is:

“I COULD NOT ATTEND”

should never stand alone.

Build:

WHY + PROOF + WHEN COMMUNICATED + WHO RECEIVED IT + WHEN YOU CAN ATTEND + WHAT YOU CAN PRODUCE NOW + WHAT YOU ACTUALLY DID NEXT.

A single genuine missed date does not automatically prove non-cooperation.

But repeated undocumented absence can create a very different record.

If ED later says:

“The person repeatedly avoided investigation,”

the strongest response is often not rhetoric.

It is the contemporaneous file.

Professional Consultation for Hyderabad ED Summons and LOC Issues

Advocate Ankit Kumar Singh may assist in matters involving Hyderabad ED / HYZO summons, Section 50 appearance, adjournment representations, medical and travel accommodation, document production, alleged non-cooperation, Look-Out Circulars, statement preparation and connected PMLA proceedings, subject to facts, jurisdiction and accepted professional engagement.

Supreme Court of India | Patna High Court | Allahabad High Court at Prayagraj | Jharkhand High Court at Ranchi | Calcutta High Court | Delhi High Court and Delhi Courts/Tribunals | Matters concerning Bhopal, Madhya Pradesh | Multiple District Courts

The summons, adjournment request, proof of illness/travel, ED acknowledgment, subsequent summons, document-production record and any LOC/travel history should ordinarily be assessed together.

No adjournment, exemption, non-arrest, LOC withdrawal or other investigative outcome can be guaranteed.

Official and Leading Legal Sources

• Prevention of Money-Laundering Act, 2002
  Sections 50 and 63.
  India Code — PMLA
• Directorate of Enforcement — Hyderabad Zonal Office
  3rd Floor, Shakar Bhawan, Fateh Maidan Road, Hyderabad – 500004.
  Official ED Offices Directory
• ED Press Release concerning Section 50 examination timings
  Published after Bombay High Court directions in Ram Kotumal Issrani; discusses office-hour examination and accommodation for serious medical condition/sick/infirm persons.
• Abhishek Banerjee & Anr. v. Directorate of Enforcement
  2024 INSC 668
  Supreme Court of India
  9 September 2024.
• Pankaj Bansal v. Union of India
  2023 INSC 866
  Supreme Court of India
  3 October 2023.
  Mere non-cooperation with Section 50 summons is not by itself sufficient for Section 19 arrest.
• Mr. Habib Abdul Razzaq Hadi Ali AlBaghdadi v. Bureau of Immigration
  W.P. No.8276 of 2025
  Telangana High Court
  10 June 2026.
  HYZO LOC, non-appearance, later cooperation and document-production chronology.
• Ram Singh v. Directorate of Enforcement
  BAIL APPLN. 2393 of 2026
  Delhi High Court
  18 August 2026.
  ED alleged repeated medical exemptions without material establishing incapacity.
• Shri Amrit Pal Singh v. Directorate of Enforcement
  Bail Application No.1322 of 2025
  Delhi High Court
  1 July 2025.
  Repeated adjournments and medical/family-emergency justification examined in the context of cooperation.
• Sanjay Dangi v. Union of India & Ors.
  W.P.(CRL.) 2587 of 2026 with connected matter
  Delhi High Court
  1 September 2026.
  LOC/travel assessment includes future availability to participate in investigation and safeguards securing presence.
• Ministry of Home Affairs O.M. No.25016/10/2017-Imm(Pt.) dated 22.02.2021
  Consolidated Look-Out Circular guidelines.

Related Legal Research

For a broader discussion of medical, age, pregnancy and disability-related accommodation under Section 50, see the existing article:

Summons Strategy for a Vulnerable Person Under PMLA

For the distinction between genuine non-cooperation and merely declining to accept ED's allegation:

Non-Cooperation Psychology Under PMLA

For preparation once a fresh appearance date is fixed:

How to Prepare Before ED Questioning on the Summons Date

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Disclaimer: This article provides general legal information. A written adjournment request does not automatically suspend or cancel a Section 50 summons. Whether illness, travel or another circumstance justifies accommodation depends upon the summons, supporting evidence, prior conduct, ED's response and subsequent compliance. Look-Out Circulars are governed by a separate administrative/legal framework and do not arise automatically from a single missed summons. Obtain case-specific advice where appearance is imminent or coercive action is apprehended.