Preventive detention revocation requests need not be reconsidered repeatedly once the original representation has been duly examined.

Article 22(5) requires communication of detention grounds and a real opportunity to make a representation, and that safeguard was complied with here because the detenu's representation was forwarded and considered by the State Government and the Central Government. Section 14 of the National Security Act confers a statutory power of revocation, but it does not create a separate right to repeated consideration of successive revocation requests on the same grounds. As the original representation had already been examined by the competent authorities, the Central Government was not obliged to consider a later representation addressed through counsel to the Prime Minister. Continued detention was therefore not rendered illegal.

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Issues: Whether the failure of the Central Government to consider a second representation for revocation of detention under Section 14 of the National Security Act, 1980 rendered the continued detention illegal, despite compliance with Article 22(5) of the Constitution of India and Section 8(1) of the Act.

Analysis: The constitutional safeguard under Article 22(5) requires communication of grounds and an earliest opportunity to make a representation against the detention order. The detenu's representation against the detention was in fact forwarded and considered by the State Government and the Central Government; that representation was treated in substance as a request for revocation. The power of revocation under Section 14 is a statutory, supervisory power that may be exercised on information from any source, but it does not create a separate constitutional right to insist on repeated consideration of successive revocation requests on identical grounds. Once the competent authorities had considered the representation already made, the Central Government was under no obligation to deal again with a subsequent representation addressed through counsel to the Prime Minister.

Conclusion: The continued detention was not rendered illegal by non-consideration of the second representation, and the contention based on Article 22(5) failed.

Ratio Decidendi: A second representation for revocation of preventive detention under Section 14 of the National Security Act, 1980 need not be separately considered where the detenu's representation has already been duly considered by the competent authorities and Article 22(5) has otherwise been complied with.

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