Preventive detention disclosure: basic grounds must be timely, while further particulars may follow with reasonable expedition.

Article 22(5) requires communication of the basic facts and materials forming the grounds of detention within the prescribed time, while further particulars or subsidiary details may be supplied with reasonable expedition depending on the circumstances. The commentary notes that, where the grounds are elaborate and the requested material is spread across a bulky record, delay in furnishing copies will not automatically vitiate detention if the core facts were timely communicated. It also highlights that delay in arranging lawyer consultation is assessed in context, including public interest concerns and whether the detainee later received the facility and still made no representation. On these facts, the delay was held not unreasonable.

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Issues: Whether the detention order was vitiated by delay in supplying copies of the documents and statements relied upon, and by delay in permitting interview with the detenu's lawyer, so as to infringe the detenu's right to make an effective representation under Article 22(5) of the Constitution.

Analysis: The expression "grounds" in Article 22(5) was held to comprise the basic facts and materials on which the detention is founded, while further particulars or subsidiary details are distinct from those basic facts. The basic facts must be communicated within the statutory time, but additional particulars sought by the detenu are to be furnished with reasonable expedition, the question of reasonableness depending on the facts of each case. In the present matter, the supplied grounds were elaborate and contained the basic facts, while the requested copies related to further particulars spread over a bulky record. The detention also involved alleged large-scale smuggling with international ramifications, which made consultation on possible public interest implications relevant. The time taken to consider and supply the copies, and the delay in processing the lawyer interview request, were assessed in the totality of the circumstances, including the fact that permission to interview the lawyer was eventually granted and no representation was made even after the copies were supplied.

Conclusion: The delay was not unreasonable and did not amount to a denial of the constitutional right to make an effective representation. The detention was upheld and the petition failed.

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