P.L. LAKHANPAL vs THE UNION OF INDIA AND ANOTHER

The Supreme Court held that the review of a detention order under Rule 30A(9) of the Defence of India Rules, 1962, is a quasi-judicial function requiring adherence to principles of natural justice. The Court found that the petitioner was not given an opportunity to represent his case before the continuation of his detention was ordered, which constituted a breach of natural justice. Consequently, the Court quashed the order of detention, establishing that quasi-judicial decisions must allow for representation and evidence contradiction.