Pebam Ningol Mikoi Devi vs State Of Manipur And Ors

The Supreme Court held that the detention of the appellant's husband under Section 3(2) of the National Security Act, 1980 was unconstitutional as it violated Article 21 of the Constitution, which guarantees the right to life and personal liberty. The Court emphasized that preventive detention must adhere to the procedural safeguards outlined in Article 22, including the right to be informed of the grounds for detention and the opportunity to make a representation. The appeal was allowed, and the detention order was quashed, leading to the release of the detenu.