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    <title>2019 (12) TMI 23 - DELHI HIGH COURT</title>
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    <description>Preventive detention was upheld where the record showed that recoveries were properly linked to the detenue through voluntary statements under Section 108 of the Customs Act, and the clubbing of goods was not found to be artificial. The 03.08.2012 notification did not bar action because the detenue fell within the exception for a kingpin and repeat offender, with multiple prior smuggling-related incidents. Custody, passport issues and the availability of ordinary criminal law did not invalidate detention, since the authority was aware of custody, anticipated possible release on bail, and had material to support subjective satisfaction that future prejudicial activity was likely.</description>
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