MANGALBHAI MOTIRAM PATEL vs STATE OF MAHARASHTRA & ORS.

The Supreme Court held that under Article 22(5) of the Constitution and Section 3(3) of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974, the detaining authority must provide the detenu with the grounds of detention and relevant documents without unreasonable delay. The Court emphasized that the right to make an effective representation includes access to these documents, and failure to supply them timely invalidates continued detention. In this case, a delay of 43 days in providing documents rendered the detention unlawful, leading to the quashing of the detention order.