VIJAY NARAIN SINGH vs STATE OF BIHAR & ORS.

The Supreme Court held that under Section 12(2) of the Bihar Control of Crimes Act, 1981, preventive detention must be strictly construed, ensuring that a person's liberty is not jeopardized without clear justification. The Court found that one of the grounds for detention was too remote and lacked a rational connection to the District Magistrate's satisfaction, violating Article 22(5) of the Constitution. Consequently, the Court allowed the petition, emphasizing that preventive detention should not be used to circumvent bail orders granted by competent criminal courts.