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Issues: (i) Whether a detention order expressed in disjunctive terms as being necessary to prevent prejudicial acts affecting "public order or the security of the State" showed inadequate application of mind to the statutory grounds. (ii) Whether a detention order was vitiated when one of the detention grounds was extraneous to the statutory heads under which detention could be ordered.
Issue (i): Whether a detention order expressed in disjunctive terms as being necessary to prevent prejudicial acts affecting "public order or the security of the State" showed inadequate application of mind to the statutory grounds.
Analysis: The power of preventive detention is extraordinary and must be exercised strictly within the bounds of the statute. The expressions "public order" and "security of the State" are distinct statutory concepts, and where the authority is satisfied that conduct affects both, the order should clearly reflect that conjunctive satisfaction. Use of the disjunctive "or" in the detention order indicated uncertainty as to which statutory head was attracted, or a mechanical reproduction of the statutory language rather than a reasoned application of mind.
Conclusion: The detention order was defective because it did not clearly specify whether the alleged conduct affected public order, the security of the State, or both.
Issue (ii): Whether a detention order was vitiated when one of the detention grounds was extraneous to the statutory heads under which detention could be ordered.
Analysis: One of the grounds related only to an assault on an individual and did not have the potentiality to disturb public order or the security of the State. Such a ground was merely a law-and-order matter and was unrelated to the statutory basis for detention. An order founded partly on an extraneous ground cannot be sustained because it is impossible to say whether the requisite satisfaction would have been reached without it.
Conclusion: The detention order was vitiated by the inclusion of an extraneous ground and could not be upheld.
Final Conclusion: The preventive detention order was invalid and the detenu was entitled to immediate release.
Ratio Decidendi: A preventive detention order must clearly and expressly disclose satisfaction on the correct statutory ground or grounds, and inclusion of an extraneous ground, or use of ambiguous disjunctive language showing uncertainty as to the statutory basis, vitiates the order.