SMT. SHALINI SONI ETC. vs UNION OF INDIA & ORS. ETC.

The Supreme Court held that under Article 22(5) of the Constitution, a representation by a detenu does not require a prescribed form, as long as it contains a request for release and grounds for such a request. The Court emphasized that the detaining authority must consider the representation at the earliest opportunity, and failure to do so necessitates the release of the detenu. The judgment clarified that the communication of grounds for detention must reflect the application of mind by the detaining authority to relevant facts, ensuring procedural fairness in preventive detention.