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Issues: Whether the detention order was vitiated because the detenu was denied an effective representation by non-supply or delayed supply of relevant documents, and because the detaining authority failed to apply its mind to the material relied upon.
Analysis: The withheld or belatedly supplied statements were material to the question of the detenu's involvement and could have affected the detaining authority's decision. The material placed before the authority did not provide a reasonable basis to infer that the detenu, an illiterate and ailing elderly woman, was herself participating in the alleged activities. The authority also failed to consider the practical improbability of the detenu maintaining correspondence, accounts, payments, and telephone communications as suggested by the record.
Conclusion: The detention order was vitiated by non-application of mind and by denial of an effective representation. The petition was allowed and the detention order quashed.
Ratio Decidendi: In preventive detention matters, material documents that bear on the detenu's involvement must be disclosed and meaningfully considered, and a detention order based on an unreasonable inference from the record is invalid for non-application of mind.