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

A preventive detention order was held unsustainable where the detaining authority relied on irrelevant material with no discernible nexus to any prejudicial activity attributed to the detenu. Because the subjective satisfaction was based on extraneous material rather than pertinent and proximate facts, the authority was found to have failed to apply its mind to the actual grounds of detention. The detention order was therefore vitiated and quashed.

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Issues: Whether the detention order was liable to be quashed because the detaining authority relied on irrelevant material, resulting in non-application of mind while recording subjective satisfaction under preventive detention law.

Analysis: The detention order was founded, among other documents, on a statement that had no discernible nexus with any prejudicial activity attributed to the detenu. When the material relied upon does not bear relevance to the grounds of detention, it cannot validly support the requisite subjective satisfaction. Reliance on such extraneous material demonstrates failure to apply mind to pertinent and proximate facts, rendering the detention decision legally unsustainable.

Conclusion: The detention order was vitiated and liable to be quashed.

Ratio Decidendi: A preventive detention order is invalid if the detaining authority's subjective satisfaction is founded on irrelevant material, because such reliance shows non-application of mind to the pertinent grounds.

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