SATYA DEO PRASAD GUPTA vs THE STATE OF BIHAR & ORS.

The Supreme Court held that the detention of the petitioner was invalid due to inordinate delay by the State Government in considering the petitioner's representation, violating Article 22(4) of the Constitution of India. The Court condemned the misleading affidavit submitted by a Deputy Collector, emphasizing the constitutional obligation to consider representations promptly. The Court ruled that the confirmation of detention beyond three months from the date of detention was unlawful, thereby allowing the petition and quashing the detention order.