The High Court of Karnataka dismissed a petition by Christopher, an Australian citizen, challenging a Leave India Notice (LIN) issued against him. The court found that Christopher was employed in India on an employment visa (E-2) obtained by misrepresentation by his employer-company in 2019. Justice Suraj Govindaraj ruled on the case. Christopher argued that he was not personally given notice before the LIN was issued. However, he left India after filing the petition. The Foreign Regional Registration Officer (FRRO) sent notices to Christopher’s employer, an Indian subsidiary of a multinational company that designs and markets medical devices for respiratory care. The company secured the employment visa, claiming no qualified Indian was available for the general manager post. FRRO made several inquiries and found many Indian professionals with the qualifications Christopher had - a Bachelor’s degree in Nursing and a Graduate Certificate in Critical Care Nursing. FRRO concluded appointing Christopher did not justify replacing Indian managerial talent and issued the Leave India Notice. The court dismissed claims that issuing the LIN violated natural justice. It said that when the employer misrepresents facts in visa applications, giving the employer notice ensures procedural fairness. Employees like Christopher, who benefit indirectly, do not get separate hearings if the key facts lie with the employer. The court also rejected the claim that FRRO cannot investigate visa fraud without approval from the visa-issuing authority. "Once the foreign national enters Indian territory, regulatory jurisdiction over his continued stay shifts to domestic authorities acting under the Foreigners Act," the court said. The FRRO told the court the LIN was enforced because Christopher left India without seeking restoration of his visa status. Later, Christopher was allowed to enter India again on business and tourist visas. The petition was dismissed on February 13, 2026.