PEBAM NINGOL MIKOI DEVI vs STATE OF MANIPUR .

The Supreme Court held that the detention of the appellant's husband under Section 3(2) of the National Security Act, 1980 was unlawful as it violated the fundamental right to liberty guaranteed under Article 21 of the Constitution. The Court emphasized that preventive detention must adhere to the safeguards outlined in Article 22, which include the right to be informed of the grounds for detention and the right to make a representation. The appeal was allowed, and the detention order was quashed, reinforcing the importance of individual liberty in a democratic society.