SECRETARY TO GOVERNMENT OF TAMIL NADU PUBLIC (LAW AND ORDER) REVENUE DEPARTMENT vs KAMALA

The Supreme Court held that the absence of a specified period in a detention order under Section 3(1)(ii) of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974 does not render the order invalid. The Court overruled the earlier decision in Commissioner of Police v Gurbux Anandram Bhiryani, affirming that the detaining authority is not required to specify a period of detention. Consequently, the High Court's decision to quash the detention order was found to be unjustified, and the appeal by the Government of Tamil Nadu was allowed.