Union Of India (Uoi) vs Paul Manickam And Anr.

The Supreme Court held that the detention order under Section 3(1)(i) of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974 was invalid due to the failure to provide the detenue with legible documents, violating her right to make an effective representation as guaranteed under Article 22(5) of the Constitution of India. The Court emphasized that the authorities must ensure timely consideration of representations against detention orders. The Court ultimately quashed the detention order, ruling in favor of the detenue.