SMT. ANGOORI DEVI FOR RAM RATAN vs UNION OF INDIA & ORS.

The Supreme Court quashed the detention orders under Section 3(2) of the National Security Act, 1980, for two police personnel accused of robbery under Section 392/34 IPC, holding that their isolated criminal act did not disturb 'public order' but was a matter of 'law and order'. The Court emphasized that the subjective satisfaction of the detaining authority must have a nexus with the grounds of detention, and that the law of preventive detention applies equally to police personnel as it does to the public. The Court concluded that the nature of the act did not warrant preventive detention as it did not endanger public tranquility.