Meaningful opportunity to represent against detention requires legible relied-upon documents before confirmation of detention.

Detention was held invalid where the detenu was denied a meaningful opportunity to make a representation because the relied-upon documents were not supplied in legible form before confirmation of detention. The demand for legible copies had been conceded, but the duplicate set was furnished only after the detention order had already been confirmed. That delay deprived the detenu of an effective constitutional safeguard under Article 22, and immediate release followed.

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Issues: Whether the detention order was vitiated by denial of a meaningful opportunity to make a representation because legible copies of the relied-upon documents were not supplied before confirmation of detention.

Analysis: The detenu complained that the documents supplied with the grounds of detention were illegible and sought legible copies. Although the demand was conceded and a duplicate set was directed to be supplied, the detention order had already been confirmed before such legible copies were furnished. In these circumstances, the detenu was deprived of an effective opportunity to make a representation against the detention, which offended the constitutional safeguard under Article 22.

Conclusion: The detention was held to be invalid and the detenu was entitled to immediate release.

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