PUSHPADEVI M. JATIA vs M.L. WADHAVAN, ADDL. SECRETARY GOVERNMENTOF INDIA & ORS.

The Supreme Court examined the validity of a detention order under Section 3(1) of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974 (COFEPOSA), emphasizing that the court cannot assess the propriety of the grounds for detention but can verify if the authority's subjective satisfaction was reached. The Court held that even if one ground for detention is invalid, it does not automatically invalidate the entire order, thus overruling the previous principle. The Court also clarified that the period of parole must be excluded from the total detention period, ensuring compliance with Article 22(5) of the Constitution.