SMT. POONAM LATA vs M.L. WADHAWAN & ORS.

The Supreme Court held that under sub-section (1) of Section 3 of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974, the period of parole from May 15, 1986, to February 28, 1987, must be excluded when calculating the one-year maximum detention period. The Court clarified that the term 'detain' refers to actual custody, and parole does not constitute such custody, thus interrupting the detention period. The judgment distinguished the case of Amritlal Channumal Jain, affirming that the computation of detention time should not include periods of parole.