Preventive detention and effective representation fail when relied-upon documents are illegible and unreadable.

Non-supply of legible copies of material documents relied upon in a preventive detention order violates the detenue's right to make an effective representation under Article 22(5). Where the detention grounds are supported by documents such as a panchnama, the detenue must receive readable copies so the basis of detention can be meaningfully met. A prompt request for typed or legible copies, if refused or left unmet, defeats the constitutional safeguard. The detention order was therefore vitiated.

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Issues: Whether non-supply of legible copies of material documents relied upon in a preventive detention order deprived the detenue of the constitutional right to make an effective representation under Article 22(5) of the Constitution of India.

Analysis: The detention order was founded on material documents, including a panchnama, which formed part of the grounds supplied to the detenue. The detenue promptly complained that the copies furnished were illegible and sought typed copies to enable an effective representation. The request was ed and no legible copies were supplied. In preventive detention matters, the grounds necessarily include the material documents relied upon by the detaining authority, and the detenue must be given a real and meaningful opportunity to make a representation. If the supplied documents are illegible, the constitutional safeguard is not satisfied because the detenue cannot effectively meet the basis of detention.

Conclusion: The refusal to furnish legible copies of the relied-upon document violated Article 22(5) and vitiated the detention order.

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