BINOD SINGH vs DISTRICT MAGISTRATE DHANBAD BIHAR & OTHERS

The Supreme Court held that the order of detention under Section 3(2) of the National Security Act, 1980, was invalid as the detaining authority failed to consider the fact that the appellant was already in jail and there was no imminent possibility of his release. The Court emphasized that preventive detention should only be exercised in exceptional cases and with proper consideration of relevant factors. The detention order was set aside, but it did not affect the appellant's detention under pending criminal cases, allowing for reconsideration if he were to be released on bail.