Preventive detention orders require clear subjective satisfaction; equivocal wording can show casualness and invalidate detention.

A preventive detention order was held invalid where the detaining authority's wording suggested non-application of mind and casualness in recording subjective satisfaction. The Court noted that, when detention is based on multiple connected activities, the order must clearly reflect the basis for detention; the use of the disjunctive "or" instead of "and" could indicate mechanical reproduction of statutory language and uncertainty in the authority's mind. Because such equivocal drafting may prejudice the detenue's right to make an effective representation, the detention order could not be sustained and was quashed.

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Issues: Whether the detention order was vitiated for non-application of mind and casualness because it used the disjunctive "or" in describing the detenue's alleged activities instead of the conjunctive "and".

Analysis: The detention order was examined in the light of the settled principle that, where the authority proposes detention on multiple activities forming the basis of subjective satisfaction, the language used in the order must reflect that satisfaction with clarity. If the order suggests uncertainty or mechanically reproduces the statutory language, it may indicate that the authority did not properly apply its mind. The Court applied the principle that, where the alleged conduct is relied upon cumulatively or across several connected activities, the use of the disjunctive expression may show casualness in the making of the order and can prejudice the detenue's right to make an effective representation.

Conclusion: The detention order was vitiated by casualness and non-application of mind and could not be sustained.

Final Conclusion: The writ petition succeeded and the preventive detention order was quashed, resulting in release of the petitioner unless required in any other case.

Ratio Decidendi: A preventive detention order is invalid if its language shows that the detaining authority did not clearly and correctly record subjective satisfaction as to the basis of detention, including by using equivocal or mechanically reproduced terms that reveal casualness in the exercise of power.

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