A single judge bench of AP High Court held that Regional Passport Officer can be directed by Court to issue Police clearance certificate.

From Paras 4 and 5,

4. The learned Assistant Solicitor General, appearing for the 2nd respondent would submit that the service of issuing a police clearance certificate is a voluntary service being given for the benefit of Indian citizens and there is no underlying duty cast on the 2nd respondent, by virtue of any provision of law or Judgment of the Court, to issue such police clearance certificates. He would further submit that a Writ of Mandamus cannot lie against the 2nd respondent and there is no legal duty cast on the 2nd respondent to undertake such activities. Further, the 2nd respondent cannot give a clean chit to the petitioner and would have to incorporate the details of the aforesaid crime in any certificate that can be issued to the petitioner.
5. In view of the fact that the 2nd respondent has been issuing such certificates to citizens staying abroad, the 2nd respondent cannot take the stand that since it is a voluntary service, there cannot be any direction to the 2nd respondent to issue or not to issue such certificates.