SMT. BIMLA RANI vs UNION OF INDIA AND OTHERS

The Supreme Court upheld the detention order under Section 3(2) and 3(3) of the National Security Act, 1980, stating that a solitary incident causing communal tension can justify preventive detention to maintain public order. The Court emphasized that even in the absence of a criminal history, the apprehension of a communal riot based on the incident was sufficient for the detaining authority's satisfaction. The petition for quashing the detention order was dismissed, affirming the legality of the detention based on the serious situation arising from the incident.