Liladhar Bhandari v. Government of Nepal — citizenship and freedom of movement

Exam Snapshot

In the landmark case of Liladhar Bhandari v. Government of Nepal (N.K.P. 2067, Decision No. 8393), the Supreme Court of Nepal ruled that the right to travel abroad and obtain a passport is a fundamental aspect of personal liberty and cannot be restricted arbitrarily by administrative obstacles or delayed citizenship procedures.

Core Concept

Nepal Law Anchors

Confusable Terms

Concept Freedom of Movement (Art 17(2)(e)) Right to Travel Abroad (Passport)
Scope Moving and residing freely within the territory of Nepal. Exiting Nepal and traveling to other countries.
Constitutional Text Explicitly enumerated as a fundamental freedom. Read judicially into "Personal Liberty" under Article 17(1).

MCQ Traps

Example

If a district administration refuses to issue a passport to an eligible citizen simply because their citizenship application is under a standard administrative review or because of minor clerical inconsistencies, this action violates the precedent of Liladhar Bhandari. Under this ruling, administrative delays in civil registries cannot be used to lock citizens inside national borders.

Memory Hook

Think of Liladhar as "Lila (play) Dhar (flow)" -> the flow of a person across borders. Flow represents Freedom of Movement and Passport.

Quick Revision