Article 22(5) detention challenge fails where only relied-on material must be supplied and nonessential documents do not impair representation.

Article 22(5) requires that a detenu be supplied the grounds of detention and the material relied on, so as to enable an effective representation. Documents only casually referred to need not be furnished unless their absence actually handicaps that right. On the facts, the detenu had received the grounds, relied-on material, and disclosure of the complaints and crime details; the record also showed that FIR copies were supplied, and the bail applications and orders were already within the detenu's knowledge. The non-supply of the requested documents therefore did not infringe Article 22(5), and the detention was not invalid on that ground.

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Issues: Whether non-supply of the requested FIRs, bail applications, and bail orders to the detenu violated Article 22(5) of the Constitution and rendered the detention illegal.

Analysis: The right under Article 22(5) requires that the detenu be informed of the grounds of detention and be afforded the earliest opportunity to make an effective representation. Documents relied upon or forming the basis of detention must be supplied, while documents only casually referred to need not be supplied unless their non-supply actually handicaps the detenu in making a representation. On the facts, the detenu had been supplied the grounds and relied upon material, the complaints and details of the crimes were disclosed, the affidavit stated that FIR copies were also supplied, and the detenu was already aware of the bail applications and orders since they were filed by him and reflected in the arrest records. The detenu had earlier made representations and had also filed an earlier habeas corpus petition without raising this grievance. No authority showed that every requested document, regardless of relevance or effect on representation, must be supplied as a matter of course.

Conclusion: The non-supply of the requested documents did not violate Article 22(5), and the detention was not illegal on that ground.

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