Preventive detention fails when subjective satisfaction rests on irrelevant material, showing non-application of mind.

Preventive detention is vitiated when the detaining authority forms subjective satisfaction on the basis of irrelevant or unconnected documents. The text notes that the detention grounds expressly stated that all accompanying documents were relied upon, yet several listed papers and search panchnamas had no nexus with the alleged smuggling activity or the detainee's conduct. That mismatch indicated mechanical exercise and non-application of mind. A later attempt in the counter-affidavit to describe the material as merely considered did not cure the defect because it conflicted with the categorical statement in the detention grounds and did not identify the actual relied-upon documents. The detention order was therefore liable to be quashed.

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Issues: Whether the detention order was vitiated because the detaining authority relied upon irrelevant and unconnected documents while forming the requisite subjective satisfaction for preventive detention.

Analysis: The detention order expressly stated that all documents accompanying the grounds of detention had been relied upon in forming subjective satisfaction. The listed material included several documents and search panchnamas that had no bearing on the alleged smuggling activity or the petitioner's conduct. The presence of such unrelated material showed that the detaining authority acted mechanically and without proper application of mind. The attempt in the counter-affidavit to say that all documents were merely considered, and not relied upon, did not reconcile with the categorical statement in the grounds of detention, nor did it identify which documents were actually relied upon.

Conclusion: The detention order was invalid and liable to be quashed for reliance on irrelevant material and non-application of mind.

Ratio Decidendi: In preventive detention, subjective satisfaction is vitiated where the detaining authority relies on irrelevant or unrelated material for the detention decision, because such reliance shows non-application of mind.

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