SHYAM AMBALAL SIROYA vs UNION OF INDIA AND OTHERS

The Supreme Court held that under Section 3(1) of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974, the Central Government has a statutory duty to consider representations against detention orders. The Court found that the detaining authority failed to forward the detenu's representation for revocation to the Central Government, rendering the detention order illegal. Consequently, the Court ruled that the detention must be quashed due to the non-consideration of the representation by the Central Government.