Citation : 2025 Latest Caselaw 3114 Ker
Judgement Date : 31 January, 2025
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE P.B.SURESH KUMAR
&
THE HONOURABLE MR.JUSTICE JOBIN SEBASTIAN
FRIDAY, THE 31ST DAY OF JANUARY 2025 / 11TH MAGHA, 1946
WP(CRL.) NO. 1292 OF 2024
PETITIONER:
DHANYA M., AGED 30 YEARS
W/O RAJESH, KANAVU VEEDU, KUNDUKKADI,
KOTTEKKAD, MARUTHARODE, PALAKKAD, PIN - 678732
BY ADVS.
M.H.HANIS
T.N.LEKSHMI SHANKAR
NANCY MOL P.
ANANDHU P.C.
NEETHU.G.NADH
RIA ELIZABETH T.J.
ANN MARY ANSEL
SINISHA JOSHY
SAHAD M. HANIS
RESPONDENTS:
1 STATE OF KERALA
REPRESENTED BY THE ADDITIONAL CHIEF SECRETARY
TO GOVERNMENT, HOME AND VIGILANCE DEPARTMENT,
GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM,, PIN - 695001
2 THE DISTRICT COLLECTOR & DISTRICT MAGISTRATE,
CIVIL STATION, PALAKKAD DISTRICT, PIN - 678001
3 THE DISTRICT POLICE CHIEF,
CIVIL STATION,PALAKKAD DISTRICT, PIN - 678001
W.P.(Crl.)No.1292 of 2024
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4 THE CHAIRMAN
ADVISORY BOARD, KAAPA, SREENIVAS,
PADAM ROAD, VIVEKANANDA NAGAR, ELAMAKKARA,
ERNAKULAM DIST, PIN - 682026
5 THE SUPERINTENDENT OF JAIL,
CENTRAL JAIL, VIYYUR,
THRISSUR DIST, PIN - 670004
BY GOVERNMENT PLEADER SRI.K.A.ANAS
THIS WRIT PETITION (CRIMINAL) HAVING BEEN FINALLY
HEARD ON 21.01.2025, THE COURT ON 31.01.2025 DELIVERED
THE FOLLOWING:
W.P.(Crl.)No.1292 of 2024
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C.R.
P.B.SURESH KUMAR & JOBIN SEBASTIAN, JJ.
-----------------------------------------------
W.P.(Crl) No.1292 of 2024
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Dated this the 31st day of January, 2025
JUDGMENT
P.B.Suresh Kumar, J.
This writ petition is instituted seeking, among
others, a writ of habeas corpus directing the respondents to
produce the friend of the petitioner, Nandakumar, who is
detained in terms of an order issued under Section 3(1) of the
Kerala Anti-Social Activities (Prevention) Act, 2007 (the Act),
and to set him at liberty.
2. Heard the learned counsel for the petitioner as
also the learned Government Pleader.
3. Ext.P1 order of detention was issued on
20.06.2024 and the same was executed on 30.09.2024. The
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detenu is involved in four cases of which the last one was
Crime No.401 of 2024 of Palakkad Town North Police Station
registered on 06.04.2024 under Sections 341, 323, 324 and
326 of the Indian Penal Code (IPC), Section 17 of the Kerala
Money Lenders Act, 1958 and Section 4 of the Kerala
Prohibition of Charging Exorbitant Interest Act, 2012. The
detenu was arrested in connection with the last case on
16.04.2024 and he was enlarged on bail on 27.05.2024.
4. The first and foremost contention raised by the
learned counsel for the petitioner is that there is inordinate
delay in executing the order of detention and that the
detention is therefore illegal. It was also contended by the
learned counsel that there is a long delay of 75 days from the
date of the last prejudicial activity and the order of detention
and the said delay snapped the live link between the order of
detention and the grounds of detention and that the order of
detention is, therefore, vitiated. It was further contended by
the learned counsel that there is non-compliance of the
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mandatory requirement contained under Section 3(3) of the
Act inasmuch as the order of detention has not been reported
forthwith to the Government and the Director General of Police,
together with a copy of the order and supporting records and
that therefore, the detention is illegal. It was further contended
by the learned counsel that Ext.P4 representation preferred by
the petitioner before the Government against the order of
detention has not been considered by the Government at the
earliest opportunity on the ground that the matter is seized of
by the Advisory Board and that the representation has been
considered only after the receipt of the report of the Advisory
Board. According to the learned counsel, the course adopted
by the Government in this regard is faulty and that the
Government ought to have considered and disposed of Ext.P4
representation notwithstanding the fact that the matter is
seized of by the Advisory Board. The learned counsel has relied
on the decision of the Constitution Bench of the Apex Court in
Pankaj Kumar Chakrabarty v. State of W.B., (1969) 3 SCC
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400, the decision of the two Judge Bench of the Apex Court in
Pramod Singla v. Union of India, 2023 SCC OnLine SC 374
and the decision of a Division Bench of this Court in Kumari
A.V. v. State of Kerala, 2024 KHC 646, in support of his
argument. It was the submission of the learned counsel that
inasmuch as the said course has not been adopted by the
Government, the detention is illegal.
5. The learned Government Pleader submitted
that when the order of detention was issued, it was noticed
that the detenu was arrested in connection with a case
registered in Madukkarai Police Station in the State of Tamil
Nadu under Section 398 IPC and that he was in judicial custody
in connection with that case. According to the learned
Government Pleader, it was on account of that reason that the
order of detention could not be executed with immediate
effect. It was pointed out that the detenu was enlarged on bail
in that case only on 07.09.2024 and that immediately
thereafter, the order of detention was executed on 30.09.2024.
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As regards the contention that there is delay from the date of
the last prejudicial activity to the order of detention, it was
pointed out by the learned Government Pleader that the
proposal to detain the detenu under the Act was submitted on
05.06.2024, immediately after he was enlarged on bail in
connection with Crime No.401 of 2024 and the order of
detention was issued immediately thereafter on 20.06.2024
and therefore, there is no delay. As regards the contention that
there is non-compliance of the mandatory requirement under
Section 3(3) of the Act, the learned Government Pleader
brought to our attention the communication dated 20.06.2024
issued by the detaining authority in compliance of the said
statutory provision and argued that the requirement under the
said statutory provision has been complied with. As regards the
contention that Ext.P4 representation preferred by the
petitioner before the Government has not been considered at
the earliest opportunity, the learned Government Pleader
pointed out that by the time the representation was received,
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the matter was already referred to the Advisory Board and it is
on account of that reason that the representation could not
have been considered until receipt of the report of the
Advisory Board. The learned Government pleader relied on the
decision of the Apex Court in Golam Biswas v. Union of
India, (2015) 16 SCC 177, in support of his argument.
6. In reply to the submission made by the learned
Government Pleader, the learned counsel for the petitioner
contended that even if it is taken that the Government was
unable to execute the order of detention till the release of the
detenu from the Tamil Nadu jail, there is still a delay of 23 days
in executing the order of detention. According to the learned
counsel, in the absence of any explanation, the said delay
would make the order of detention unenforceable.
7. We have examined the contentions raised by
the learned counsel for the petitioner. No doubt, if an order of
detention is not executed within a reasonable time, the order
would become unenforceable. Likewise, the fact that the
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detenu was undergoing judicial custody cannot be projected as
an impediment in executing an order of detention. But at the
same time, the decision taken by the authorities empowered to
execute the order of detention to wait until the release of the
detenu from the Tamil Nadu jail, cannot be said to be faulty for,
the authorities empowered to execute the order are not bound,
in all cases, to detain the person concerned even if he is in
judicial custody. As pointed out by the learned counsel for the
petitioner, even though the detenu was released on bail in
connection with the case registered in Madukkarai Police
Station on 07.09.2024, the order of detention was executed
only on 30.09.2024 and there is still a delay of 23 days in
executing the order of detention. The learned Government
Pleader has made available a copy of the order granting bail to
the detenu in the case registered in Tamil Nadu and pointed
out that bail was granted to the detenu in the said case subject
to the condition that he should appear before the Jurisdictional
Magistrate everyday for a period of one month at 10 a.m. and
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that the detenu remained in the State of Tamil Nadu itself,
owing to the said condition. According to the learned
Government pleader, the detenu came to Kerala only on
30.09.2024 and the detention order was executed on that day
itself. True, the explanation aforesaid has not been stated in
the counter affidavit. But, the respondents cannot be blamed
for having not stated the said explanation in the counter
affidavit, as the contention that there is delay even after the
release of the detenu from Tamil Nadu jail is not raised in the
writ petition. It is an argument that was raised at the time of
hearing. Be that as it may, inasmuch as the detenu was
undergoing judicial custody pursuant to his arrest in
connection with a case registered outside the territory of the
State, regard being had to the common course of natural
events, human conduct and public and private business in their
relation to the facts of this case, we are of the view that the
delay of 23 days in executing the order of detention, under the
circumstances, cannot be said to be fatal.
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8. As regards the contention that there is
inordinate and unexplained delay from the date of the last
prejudicial activity to the date of the order of detention, it is to
be noted that the occurrence which is subject matter of the
last crime in which the detenu was involved, was one that took
place on 06.04.2024. He was arrested in connection with the
said case on 16.04.2024 and enlarged on bail only on
27.05.2024 and immediately thereafter, proposal for the
detention of the detenu was submitted on 05.06.2024 and the
order of detention was issued on 20.06.2024 itself. In WP(Crl.)
No.1329 of 2024, it was held by us that even though the
principle is that the delay between the last prejudicial activity
and the order of detention, unless satisfactorily explained,
would throw a considerable doubt on the genuineness of the
requisite subjective satisfaction of the detaining authority in
passing the order of detention and render the order of
detention bad and invalid for want of live and proximate link
between the grounds of detention and the purpose of
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detention, if the detenu is in custody all throughout, it is not
possible to make an inference straight away that the live and
proximate link between the grounds of detention and the
purpose of detention has been snapped on account of the
delay. As such, in the case on hand, if the period during which
the detenu was undergoing judicial custody in connection with
the last prejudicial activity is excluded from consideration, we
do not think that there is unexplained delay, on the basis of
which it could be contended legitimately that the live link
between the prejudicial activities and the grounds of detention
has been snapped.
9. As regards the contention that there is non-
compliance of the mandatory provision contained in Section
3(3) of the Act, it is seen that it is based on Ext.P3 reply given
by the Public Information Officer to Ext.P2 application preferred
by the counsel for the petitioner under the Right to Information
Act that the said contention has been raised. No doubt, in
terms of the provision contained in Section 3(3) of the Act,
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when an order of detention is issued, it is obligatory on the
part of the authorised officer to forthwith report that fact to the
Government and the Director General of Police, Kerala,
together with a copy of the order and supporting records
which, in his opinion, has a bearing on the matter. The letter
addressed by the authorised officer to the Additional Chief
Secretary to Government, and the Director General of Police on
20.06.2024 which has been produced by the petitioner in the
writ petition itself, reads thus:
"Kind attention is invited to the subject and reference cited. It is hereby informed that a detention order No.DCPKD/6661/2024-S1 Dated:20.06.2024 has been duly passed u/s 3(1) and 3(2) of KAAPA, 2007 in respect of Nandakumar, Age-32, S/o Narayanaswamy, Chithira House, Jayram Colony, Chirakkad, Kunnathurmedu, Palakkad. Copies of the detention order, grounds and relevant records are enclosed herewith for information."
The contents of the extracted letter reveal compliance of the
mandatory requirement under Section 3(3) of the Act. Be that
as it may, the query made by the counsel for the petitioner in
Ext.P2 was the following:
"സചന ഉതരവ എന ണ ആദ മ യ ത ങളട ഓഫസൽ എതനത?
എങടനയ ണ എതയത? ഇ-ടമയൽ മഖ നരമ ണണ ? തപ ൽ വകപ മഖ നരമ ണണ ? ണനരട യരണന ? എത ണപജകളള ണരഖകള ണ ടമ ത/
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ഉണ യരനത? ആയതട1 വശദ വവരങൾ ആവശ ടപടന?"
The reply in Ext.P3 for the query referred to above, reads thus:
"സചന (2) അണപകയൽ ത ങൾ ആവശ ടപട രന വവരങളൽ സചന (1) ഉതരവ/ കവറങ ട:റർ ഉൾടപട 20/06/2024 തയത തടന ഇ-ടമയൽ മഖ നര/ ടസകനൽ :ഭ മ യടണ എന അറയകന. "
As noted, the argument of the learned counsel for the
petitioner is that in the light of Ext.P3 reply, it will have to be
presumed that the detaining authority has forwarded to the
Government only the order of detention and not the supporting
records. In Ext.P2 query, the counsel for the petitioner only
sought information as to when the order of detention has been
received in the office of the Additional Chief Secretary and how
the same was received. Similarly, the counsel for the petitioner
sought information as to the number of pages of the materials
and the particulars of the same. Going by Ext.P3 reply, the
query sought by the counsel for the petitioner as to the
number of pages of the materials and the particulars of the
same were not furnished by the Public information Officer.
Even though it was mentioned in Ext.P3 reply that the counsel
for the petitioner can prefer an appeal against the reply given
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to the information sought by him, no appeal has been
preferred. As such, from Ext.P3 reply alone, according to us, it
cannot be inferred that the detaining authority has not
forwarded the supporting records along with the copy of the
order of detention.
10. Coming to the contention that Ext.P4
representation preferred by the petitioner has not been
considered by the Government at the earliest opportunity,
there is no dispute to the fact that Ext.P4 representation has
been received by the Government only after the case of the
detenu has been placed before the Advisory Board. Similarly,
there is no dispute to the fact that the Advisory Board has
formulated its report in relation to the case of the detenu only
on 14.11.2024 and the Government confirmed the detention
order on 22.11.2024 on receipt of the report of the Advisory
Board. The confirmation order which was made available by
the learned Government Pleader refers to the representation
submitted by the petitioner. As such, it can be presumed that it
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is after considering Ext.P4 representation that the order of
detention has been confirmed by the Government. There is
also no dispute to the fact that the detenu was informed by the
Government thereupon by letter dated 25.11.2024 about the
decision taken in the representation. The petitioner has no
case that there is any delay on the part of the Government in
considering the representation of the petitioner after receiving
the report of the Advisory Board. As noted, the contention is
only that the representation preferred by the petitioner should
have been considered by the Government at the earliest
opportunity, notwithstanding the fact that the case of the
detenu has been placed before Advisory Board, and that the
course adopted by the Government in waiting for the report of
the Advisory Board for considering the representation is faulty.
The question, therefore, is whether the Government was
justified, on the facts of this case, in not considering the
representation submitted by the petitioner on the ground that
the case of the petitioner has been placed before the Advisory
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Board.
11. In Pankaj Kumar Chakrabarty, a case
arising under the Preventive Detention Act, 1950, the
provisions of which are pari materia to the provisions contained
in the Act, the Constitution Bench of the Apex Court held that
the State Government is constitutionally bound to consider the
representation of the detenu independently, irrespective of the
fact whether the same was made before or after his case has
been placed before the Advisory Board. That was a case where
the representations were made to the Government by the
detenus after their detentions, and the Government did not
consider the said representations and merely passed them on
to the Advisory Board for its opinion. Since Ext.P4
representation of the petitioner in the case on hand has been
considered and disposed of by the Government, the decision in
Pankaj Kumar Chakrabarty may not have any application to
the facts of the present case. Be that as it may, in K.M.
Abdulla Kunhi v. Union of India, (1991) 1 SCC 476, a case
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arising under the Conservation of Foreign Exchange and
Prevention of Smuggling Activities Act, 1974, (COFEPOSA) it
was held by the Apex Court that in cases where the
representation of the detenu is received before the case is
referred to the Advisory Board, but there is no time to dispose
of the representation before referring the case to the Advisory
Board, then in such a situation, the representation must also
be forwarded to the Advisory Board along with the case of the
detenu and in cases where the representation is received after
the case is referred to the Advisory Board, then too the
Government has to forward the representation to the Advisory
Board, provided the Board has not concluded its proceedings.
The Apex Court clarified that in both these situations, there is
no question of consideration of the representation before the
receipt of the report of the Advisory Board. It was also clarified
by the Apex Court in the said case that in such situation, it
cannot be contended that the Government has delayed the
consideration of the representation, unnecessarily awaiting the
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report of the Board. Paragraph 16 of the said judgment reads
thus:
"16. We agree with the observations in Frances Coralie Mullin case. The time imperative for consideration of representation can never be absolute or obsessive. It depends upon the necessities and the time at which the representation is made. The representation may be received before the case is referred to the Advisory Board, but there may not be time to dispose of the representation before referring the case to the Advisory Board. In that situation the representation must also be forwarded to the Advisory Board along with the case of the detenu. The representation may be received after the case of the detenu is referred to the Board. Even in this situation the representation should be forwarded to the Advisory Board provided the Board has not concluded the proceedings. In both the situations there is no question of consideration of the representation before the receipt of report of the Advisory Board. Nor it could be said that the government has delayed consideration of the representation, unnecessarily awaiting the report of the Board. It is proper for the government in such situations to await the report of the Board. If the Board finds no material for detention on the merits and reports accordingly, the government is bound to revoke the order of detention. Secondly, even if the Board expresses the view that there is sufficient cause for detention, the government after considering the representation could revoke the detention. The Board has to submit its report within eleven weeks from the date of detention. The Advisory Board may hear the detenu at his request. The constitution of the Board shows that it consists of eminent persons who are Judges or persons qualified to be Judges of the High Court. It is therefore, proper that the government considers the representation in the aforesaid two situations only after the receipt of the report of the Board. If the representation is received by the government after the Advisory Board has made its report, there could then of course be no question of sending the representation to the Advisory Board. It will have to be dealt with and disposed of by the government as early as possible."
(Underline supplied)
Later, in Ankit Ashok Jalan v. Union of India, (2020) 16 SCC
127, a Three Judge Bench of the Apex Court, after referring to
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the Constitution Bench decisions of the Apex Court in Pankaj
Kumar Chakrabarty and K.M. Abdulla Kunhi, held that in
all cases, the Government would be acting in two capacities;
one while considering the representation and the other, while
taking appropriate decision after a report is received from the
Advisory Board that there is sufficient cause for detention and
it is on account of that reason that it was held by the Apex
Court in K.M.Abdulla Kunhi that it would be proper for the
appropriate Government to wait till the report of the Advisory
Board is received. Ankit Ashok Jalan was a case where the
detention orders were passed by the Joint Secretary to the
Government of India, specially empowered under Section 3(1)
of COFEPOSA and the representations preferred by the detenus
before the specially empowered officer were not considered by
the said officer. Instead, the detenus were given a
communication that in the light of the decision of the Apex
Court in Golam Biswas which was rendered following the
decision of the Apex Court in K.M.Abdulla Kunhi, the
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representations will be considered for disposal by the
competent authority only after receipt of opinion of the
Advisory Board. It was also held by the Apex Court in Ankit
Ashok Jalan that a representation if made to the specially
empowered officer under COFEPOSA who had passed the order
of detention in accordance with the power vested in him, the
same has to be independently considered by such detaining
authority and in that case, the principles concerned adverted
to in para 16 of the decision in K.M. Abdulla Kunhi would not
be the governing principles for such specially empowered
officer and that the discussion in K.M. Abdulla Kunhi was
purely in the context where the order of detention was passed
by the appropriate Government and not by the specially
empowered officer. The relevant portions of paragraphs 23 to
28 of the judgment of the Apex Court in Ankit Ashok Jalan
read thus:
"23. It must also be borne in mind that in all cases, the appropriate Government would be acting in two capacities; one while considering the representation and the other while taking appropriate decision after a report is received from the Advisory Board that there is sufficient cause for detention.
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Since the decision would be required to be taken in these two capacities, it was observed in K.M. Abdulla Kunhi that it would be proper for the appropriate Government to wait till the report is received from the Advisory Board in cases dealt with in para 16 of the decision. But such may not be the case with the detaining authority who is a specially empowered officer.
24. A specially empowered officer who passes the order of detention, in exercise of special empowerment, has no statutory role to play at the stage when the report is received from the Advisory Board. The report is to be considered by the appropriate Government and not by the specially empowered officer. It may also be relevant at this stage to consider the element of confidentiality associated with the report of the Advisory Board. Section 8 of the Cofeposa Act states:
xxx xxx xxx
25. In terms of Section 8, the report of the Advisory Board is meant only for the consumption of the appropriate Government and apart from the operative part of the report which is to be specified in a separate paragraph as per sub- section (c), the mandate in terms of sub-section (e) is to keep the report of the Advisory Board completely confidential. Thus, a specially empowered officer who may have passed the order of detention, by statutory intent is not to be privy to the report nor does the statute contemplate any role for such specially empowered officer at the stage of consideration of the opinion of the Advisory Board. The report of the Advisory Board may provide some qualitative inputs for the appropriate Government but none to the specially empowered officer who acted as the detaining authority. If that be so, would a specially empowered officer who had passed the order of detention be bound by what has been laid down by this Court in para 16 of the decision in K.M. Abdulla Kunhi in the context of the appropriate Government?
26. It must also be stated here that when K.M. Abdulla Kunhi was decided on 23-1-1991, the decision that was holding the field as to the role of a specially empowered officer who had passed an order of detention, was one rendered in Sushila Mafatlal Shah . The law that was holding the field was the concept of deemed approval as was explained in Sushila
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Mafatlal Shah and any representation made to such specially empowered officer who had passed the order of detention, in terms of the decision in Sushila Mafatlal Shah could be considered by the appropriate Government itself and not separately by such specially empowered officer. The subsequent decision in Amir Shad Khan was rendered by a Bench of three Judges on 9-8-1991 and the apparent conflict in the decisions between Sushila Mafatlal Shah and Amir Shad Khan was resolved by the Constitution Bench of this Court in Kamleshkumar rendered on 17-4-1995 i.e. well after the decision in K.M. Abdulla Kunhi.
27. Thus, if the law is now settled that a representation can be made to the specially empowered officer who had passed the order of detention in accordance with the power vested in him and the representation has to be independently considered by such detaining authority, the principles concerned adverted to in para 16 of the decision in K.M. Abdulla Kunhi would not be the governing principles for such specially empowered officer. It must be stated that the discussion in K.M. Abdulla Kunhi was purely in the context where the order of detention was passed by the appropriate Government and not by the specially empowered officer. The principle laid down in said para 16 has therefore to be understood in the light of the subsequent decision rendered by another Constitution Bench of this Court in Kamleshkumar .
28. In the light of the aforesaid discussion, our answer to first two questions is that the detaining authority ought to have considered the representation independently and without waiting for the report of the Central Advisory Board."
12. Reverting to the facts, Section 7 of the Act
confers on the detenu a right to prefer a representation only
before the Government and the Advisory Board and not before
the authorised officer, when the power of detention is
exercised by the authorised officer, unlike in the case of the
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detention under the COFEPOSA where, if the order of detention
is passed by the specially empowered officer, representation
can be preferred against the order of detention before the
specially empowered officer also. Inasmuch as the Government
has dual roles to play in the case on hand, also as clarified by
the Apex Court in Ankit Ashok Jalan, one while considering
the representation and the other while taking appropriate
decision after a report is received from the Advisory Board that
there is sufficient cause for detention, we do not find any
reason to hold that the ratio in K.M.Abdulla Kunhi does not
apply to the facts of this case, merely for the reason that the
scheme of the Act is such that it does not confer any right on
the detenu to prefer a representation before the authorised
officer.
13. Pramod Singla was a decision which
examined the question whether there exists any incongruity
between Pankaj Kumar Chakrabarty and K.M.Abdulla
Kunhi and even in that case, after holding that there exists no
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friction between Pankaj Kumar Chakrabarty and
K.M.Abdulla Kunhi, it was held that the mandate to not wait
for the Advisory Board, would be applicable only to the
detaining authority. Similarly, Kumari A.V. was a case where,
unlike the case on hand, the representation of the detenu was
received by the Government long before the case of the
detenu therein was placed before the Advisory Board and we
understand that it is in that context that this Court has held
that it was obligatory for the Government to consider the
representation, and interfered with the order of detention for
non-consideration of the representation by the Government.
In the light of the discussion aforesaid, the writ
petition is devoid of merits and the same is therefore,
dismissed.
Sd/-
P.B.SURESH KUMAR, JUDGE.
Sd/-
JOBIN SEBASTIAN, JUDGE.
Ds 2025:KER:7296 APPENDIX OF WP(CRL.) 1292/2024 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF ORDER NO. DCPKD/6661/2024-S1 DATED 20.06.2024 OF THE 2ND RESPONDENT Exhibit P2 A TRUE COPY OF THE APPLICATION UNDER THE RIGHT TO INFORMATION ACT BEFORE THE 1ST RESPONDENT Exhibit P3 A TRUE COPY OF THE REPLY NO.SSA1/656/2024-HOME DATED 05.11.2024 Exhibit P4 A TRUE COPY OF THE REPRESENTATION DATE 28.10.2024 SUBMITTED BEFORE THE 1ST RESPONDENT Exhibit P5 A TRUE COPY OF THE ACKNOWLEDGMENT CARD EVIDENCING THE RECEIPT OF EXT P4 Exhibit P6 A TRUE COPY OF THE REPRESENTATION DATE 28.10.2024 SUBMITTED BEFORE THE 4TH RESPONDENT Exhibit P7 A TRUE COPY OF THE ACKNOWLEDGMENT CARD EVIDENCING THE RECEIPT OF EXT P6
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