Quasi-judicial detention review requires natural justice and a fair chance to answer adverse material before continuation.

The power to continue detention under Rule 30A(9) was held to depend on an objective assessment of existing facts and circumstances, not mere subjective satisfaction. Because that review affects personal liberty and requires consideration of relevant material, the authority acts quasi-judicially and must observe natural justice. The detenue was entitled to a fair opportunity to meet or contradict the adverse material relied on, unless privilege was lawfully claimed in an appropriate case. As no such opportunity was given, the continuation order was invalid and could not stand.

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Issues: Whether the power under Rule 30A(9) to review and continue detention is quasi-judicial and, if so, whether continuation of detention without giving the detenue an opportunity to meet the material relied on is invalid.

Analysis: The power to make the original detention order under Rule 30(1)(b) is based on subjective satisfaction, but the power to continue detention under Rule 30A(9) is to be exercised on an objective assessment of facts and circumstances showing that continuation is necessary. The decision on review is not a mere executive opinion; it requires consideration of relevant material and is materially affected by the detenue's liberty. For such an objective determination, the authority must act fairly and give the person affected an opportunity to explain or contradict the material relied on, unless privilege is lawfully asserted in appropriate cases. Since no such opportunity was given, the continuation order offended the principles of natural justice.

Conclusion: The function under Rule 30A(9) is quasi-judicial, and the impugned order continuing detention is invalid for breach of natural justice.

Final Conclusion: The detention continuation order could not stand and the petitioner was entitled to immediate release.

Ratio Decidendi: Where a statute requires continued detention to be decided on existing facts and circumstances rather than mere subjective satisfaction, the reviewing authority acts quasi-judicially and must comply with natural justice, including a fair opportunity to meet the adverse material relied upon.

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