Preventive detention requires relevant material and real application of mind; reliance on irrelevant documents vitiates the detention order.

In preventive detention, the detaining authority must base subjective satisfaction on pertinent and proximate material with a clear nexus to the alleged prejudicial conduct. Reliance on irrelevant documents while recording detention grounds indicates mechanical exercise of power and non-application of mind. On the stated facts, the materials referred to in the detention record were not shown to bear on the alleged prejudicial activity, and that vitiated the detention decision, making the order liable to be quashed.

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Issues: Whether the detention order was vitiated for non-application of mind because the detaining authority relied upon irrelevant documents while recording subjective satisfaction under preventive detention law.

Analysis: The detention record showed that the grounds of detention expressly referred to a list of documents, including materials that had no apparent connection with the alleged prejudicial activity. In preventive detention matters, the detaining authority must apply its mind to pertinent and proximate material and rely only on documents having a nexus with the satisfaction required for detention. Reliance on irrelevant documents indicates that the satisfaction was formed mechanically and not on legally relevant material. On the facts, the documents relied upon were not shown to have any bearing on the alleged prejudicial conduct, and this affected the validity of the detention decision.

Conclusion: The detention order was vitiated by non-application of mind and was liable to be quashed in favour of the petitioner.

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