JAHANGIRKHAN FAZALKHAN PATHAN vs POLICE COMMISSIONER, AHMEDABAD & ANOTHER

The Supreme Court held that under Section 15 of the Gujarat Prevention of Anti-Social Activities Act, 1985, a new detention order can be issued based on fresh facts after the previous order has been revoked or expired. However, if the previous grounds of detention, which have been quashed by the court, are considered in forming the subjective satisfaction for a new order, it will be vitiated. The Court found the detention order illegal due to vague averments regarding the petitioner's criminal activities, which did not satisfy the requirements of Section 3(1) of the Act, thus allowing the writ petition and quashing the detention order.