Grounds of arrest must be specific enough to inform the accused of the actual basis, not just the statutory section invoked.

Section 7 of the Criminal Law Amendment Act, 1932 was treated as severable, so any possible constitutional difficulty affecting peaceful picketing did not invalidate the provision to the extent it applied to intimidation-like conduct. The article also states that Article 22(1) is not satisfied by merely telling an arrested person the statutory section invoked; the grounds of arrest must be communicated with enough specificity to show the substance of the accusation and enable prompt legal steps. On the facts described, communication of only the section number was insufficient, making the detention unlawful.

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Issues: (i) Whether Section 7 of the Criminal Law Amendment Act, 1932 was ultra vires the Constitution in so far as it was applied to the petitioner. (ii) Whether the petitioner's detention was illegal for failure to communicate the grounds of arrest as required by Article 22(1) of the Constitution.

Issue (i): Whether Section 7 of the Criminal Law Amendment Act, 1932 was ultra vires the Constitution in so far as it was applied to the petitioner.

Analysis: Section 7 contains several distinct forms of prohibited conduct. Even if some parts of the section may possibly trench upon constitutional protection in relation to peaceful picketing, the validity of one part is not destroyed by the possible invalidity of another where the provisions are severable. The acts alleged against the petitioner were treated as amounting to intimidation and not merely peaceful picketing, and that part of the section was capable of valid operation consistently with the Constitution.

Conclusion: The challenge to Section 7 failed and the provision was held valid at least to the extent relevant to the charge against the petitioner.

Issue (ii): Whether the petitioner's detention was illegal for failure to communicate the grounds of arrest as required by Article 22(1) of the Constitution.

Analysis: The constitutional requirement is not satisfied by telling an arrested person only that he has been arrested under a particular statutory provision where that provision covers multiple forms of conduct. The information supplied must be sufficient to enable the arrested person to understand, in substance, why he has been arrested and to take immediate steps for bail, habeas corpus, or defence. On the facts accepted for the proceeding, the petitioner was told only that he had been arrested under Section 7 of the Criminal Law Amendment Act, 1932, without the specific allegation on which the arrest was based. That was held to be insufficient compliance with Article 22(1).

Conclusion: The petitioner's detention was unlawful for contravention of Article 22(1).

Final Conclusion: The petition succeeded because, although the statutory provision relied upon for arrest was not struck down, the arresting authority failed to communicate the grounds of arrest with the required specificity and promptness, rendering the detention illegal and entitling the petitioner to release.

Ratio Decidendi: Where a statute contains severable valid and invalid parts, the constitutionality of the provision must be tested only to the extent relevant to the charge, and an arrested person must be informed, as soon as may be, of the substance of the actual grounds of arrest, not merely the statutory section invoked.

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