AMIR SHAD KHAN AZIZ AHMEDKHAN @ AZIZMOHD. KHAN vs L. HMINGLIANA AND ORS.

The Supreme Court held that under Section 3 of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974, the detaining authority is obligated to forward representations to the Central Government. The Court found that the failure to forward the appellants' representation, despite their request, constituted a violation of their rights under Article 22 of the Constitution of India. Consequently, the Court quashed the detention orders, emphasizing that the detaining authority must comply with procedural safeguards to ensure the legality of detention.