Preventive detention can rest on a single incident when surrounding material and antecedents justify future prejudice risk.

Preventive detention may be sustained on a single incident if surrounding circumstances and antecedents provide material for the detaining authority's reasonable satisfaction that the detenu is likely to repeat prejudicial conduct. The quashing of a co-detenu's detention does not automatically confer parity where the earlier decision rested on a ground not accepted in the present matter and no prejudice to the detenu is shown. An unsigned and undated communication is not treated as a valid representation for Article 22(5) scrutiny, and no unexplained delay in consideration was established on the record.

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Issues: (i) Whether a detention order could be sustained on the basis of a single incident when surrounding circumstances and antecedents were relied upon to infer future prejudicial activity; (ii) whether the quashing of the co-detenu's detention order entitled the detenu to the same relief; (iii) whether the alleged delay in considering an unsigned and undated representation vitiated the detention under Article 22(5) of the Constitution of India.

Issue (i): Whether a detention order could be sustained on the basis of a single incident when surrounding circumstances and antecedents were relied upon to infer future prejudicial activity.

Analysis: A single incident does not, by itself, bar preventive detention. The legal test is whether the detaining authority had material from which it could form a reasonable satisfaction that, viewed with surrounding circumstances and antecedents, the detenu was likely to indulge in similar prejudicial activity in future. Here, the arrest at the airport, the seizure of foreign currency and mobile phones, the repeated travel pattern, the association with the co-detenu, and the material indicating that the detenu had frequently undertaken similar trips furnished a sufficient basis for such satisfaction.

Conclusion: The detention order was validly sustained on this ground and the contention failed.

Issue (ii): Whether the quashing of the co-detenu's detention order entitled the detenu to the same relief.

Analysis: Parity was unavailable because the co-detenu's detention had been set aside on a ground not accepted in the present case. The error relied upon in the co-detenu's matter was treated as a typographical mistake in the present proceedings and was found not to have prejudiced the detenu or vitiated the detaining authority's satisfaction. The earlier decision therefore did not automatically govern the present case.

Conclusion: The detenu was not entitled to the benefit of the co-detenu's order.

Issue (iii): Whether the alleged delay in considering an unsigned and undated representation vitiated the detention under Article 22(5) of the Constitution of India.

Analysis: A representation that is unsigned and undated was treated as not amounting to a valid representation requiring immediate consideration under Article 22(5). On the record, the authorities considered the matter and rejected it within the time stated, and no unexplained or inordinate delay was established. The detenu could not rely on a communication lacking the basic attributes of a valid representation to claim constitutional infirmity in the detention.

Conclusion: No delay vitiating the detention was made out.

Final Conclusion: The preventive detention was upheld, and the appeal was dismissed as no ground for interference was established.

Ratio Decidendi: Preventive detention may be sustained on a single incident if surrounding material and antecedents justify a reasonable satisfaction of likely future prejudicial conduct, and an unsigned or undated communication does not constitute a valid representation for the purpose of Article 22(5) scrutiny.

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