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Issues: Whether the detention order was liable to be quashed on account of unexplained and inordinate delay in passing the order after completion of investigation and filing of the criminal complaint.
Analysis: The record showed that the investigation had concluded, the show-cause notice had already been issued, and the criminal complaint had been filed before the detention order was made. No satisfactory explanation was offered for the substantial gap between the relevant stages of processing the preventive detention proposal. The file also disclosed a long unexplained period during which the matter remained unattended. In preventive detention matters, the detaining authority must act with urgency, and an unexplained delay breaks the live and proximate connection between the alleged prejudicial activity and the need for detention.
Conclusion: The detention order was vitiated by unexplained delay and was liable to be quashed in favour of the petitioner.
Ratio Decidendi: In preventive detention cases, unexplained inordinate delay in passing the detention order after the alleged activities and completion of investigation invalidates the detention because the requisite live nexus is lost.