Subject: Political Science.

Paper: Constitutional Democracy and Government in

India.
Chapter: Preventive Detention in India.
Course Developer: Pooja Bakshi.
Department: Department of Political Science,
University of Delhi.

Institute of Lifelong Learning, university of Delhi 1

Contents.

1. Section 1: Introduction.
2. Section 2: Origins of Preventive Detention
during Colonial Rule.
3. Section 3: Debates held in the Constituent
Assembly of India.
4. Section 4: Provisions present in the Indian
Constitution pertaining to Preventive Detention.
5. Section 5: Working of Preventive Detention in
India.
6. Section 6: Role of Judiciary in case of
Preventive Detention.
7. Section 7: Conclusion.
8. Exercise.
9. Bibliography.

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Section 1: Introduction.

Preventive detention laws were used for the first time in the Indian context by the
Colonial British government in 1784. Even after independence, preventive
detention laws have been used in India. The Indian State’s rationale for using
these laws is based on the need for securing national interest. However, the
history of use of preventive detention laws in India has been replete with
instances of misuse in terms of violations of individual freedom, and due process
of law.

It is important to point out that preventive detention is applied to a person when

it is anticipated that she/he may commit a crime in the future. It is different from
punitive detention which is imposed on someone by a court of law if that person
has committed a crime.

Preventive detention laws have been used as tools by States, including

democratic States to anticipate threats to national security. In more recent times
preventive detention has also been used as a method in counter-terrorism
strategies.

In the following chapter, preventive detention in the Indian context will be

elaborated upon. In the second section an attempt will be made to examine the
origins of preventive detention in the context of British rule in India. In the third
section, a discussion will ensue on the debates held during the Constituent
Assembly and in section four there will be a discussion on the provisions present
in the Indian Constitution which make preventive detention a possibility. Section
five will elaborate upon certain preventive detention laws and their functioning in
the Indian context. Section six will examine the role of the judiciary in the case of
preventive detention. Finally, section seven will offer some conclusions.

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Section 2: Origins of Preventive Detention during
Colonial Rule.

Question.
When was Preventive Detention
used for the first time by the
Colonial State in India?
In the Colonial State, Preventive
detention was used for the first
time in 1784.

It has been argued that preventive detention was used during the First and
Second World Wars as a tool in war. Subsequently, as it has been mentioned
above under colonial rule in India preventive detention was used for the first time
in 1784 (Abraham, 1993). The British East India Company Act was formulated
such that it allowed the Governor General to detain someone in case if he/she
was suspected for committing any action which would go against the interests of
British settlements in India.

What is
Preventive
Detention?
Preventive detention is
applied to a person
when it is anticipated
that she/he may commit
a crime in the future

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 What is
Punitive
Detention?

Punitive detention
which is imposed on
someone by a court of
law if that person has
committed a crime

In 1818, the Bengali State Prisoners Regulation made it possible for the British in
India to detain people if they were suspected for having caused damage in the
realm of foreign affairs and internal security in the British colony. Such
regulations were also created in the Bombay and Madras, whereby the executive
was given the power to detain on discretionary grounds without the need to
conform to legal procedures.

After the outbreak of the First World War, the British introduced the Defense of
India Act in 1915 which had the provisions allowing preventive detention. In
1919, under the ambit of the Rowlatt Act the executive in the Colonial State was
granted extensive powers to detain and/or arrest in peacetime.

At the time of the Second World War also, the Defense of India Act 1939 was
introduced which had provisions for preventive detention for anyone suspected of
acting in a manner that would harm the Colonial State.

Section 3: Debates held in the Constituent Assembly

of India.

Despite the experience of witnessing the use of preventive detention laws during
the Colonial rule, the Constituent Assembly considered keeping provisions
pertaining to preventive detention in the Constitution (Austin, 1966). The debates
on the right to individual liberty and provisions against arrest and detention were
part of Articles 15 and 15 (A) during the functioning of the Constituent Assembly.

The Constituent Assembly faced a dilemma. On one hand the need was felt for
providing the most extensive individual liberty in independent India and on the
other hand the need was felt for creating a strong government which could take
care of the crisis present during independence. Several members of the

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Constituent Assembly expressed their concern regarding the potential misuse of
preventive detention. The experience of Colonial rule had made it apparent that
governments and members of the executive could misuse preventive detention.
This could severely inhibit personal liberty and would also hinder the application
of due process of law.

What would make the use

of preventive detention
differnet in independent
India as compared to
Colonial times?

The Colonial State had used preventive detention to

mainly imprision freedom fighters during the struggle
for independence in India. The Colonial State had
arbitrarily used preventive detnetion. But after
independence, the democratic Indian State was
expected to use Preventive Detention with utmost
descretion. It was hoped that the independent Indian
State would not use preventive detention arbitrarily
and would safeguard the rights of detainees.

The experience of the partition of India and Pakistan made many member of the
Constituent Assembly agree to the need for stringent provisions in the
Constitution, including provision for prevention detention. It was felt that the
independent democratic Indian State would be vastly different from the Colonial
State in its functioning.

Since India would function as a democracy after independence, the potential for
misuse of power and the potential for the misuse of prevention detention would
be very low. The democratic state would do its utmost to respect and further
individual liberties. Yet, in order to safeguard national interest, it was important
to have provisions such as preventive detention.

One of the members of the Constituent Assembly in 1949 pointed out that no
other democratic State had made a Constitutional provision for enacting
preventive detention, unless it was a matter of national emergency (Austin,
1966).

In response to this it was argued that the security threats that India faced at the
time of independence were too grave to be ignored and hence provisions such as
preventive detention were necessary. It was also suggested that procedural
protections would be provided in order to check for the potential misuse of
preventive detention.

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It has been argued that the justification for including the provisions on preventive
detention in the Indian Constitution rested on the anxieties present at the time of
independence (Noorani, 2012). These anxieties were a product of the violence
faced during partition and the political fragility of independent India. Given these
circumstances it was considered viable to have a provision for using preventive
detention even during peace-time.

•The Indian State faced many

Why would
security threats immidiately
after independence, especially
in the context of partition
there be a between India and Pakistan.
There also existed seperatist
need for the movements which wanted to
break away from the Indian
use of State.
•In this context, it was argued
preventive that provisions pertaining to
preventive detention were
detention in necessary to ensure the
security of the newly

independent independent State. It was also

argued that the rights of the
detainees would be
India? safeguarded.

Another important debate was held in this context with regard to the ‘due process
of law’ and the ‘procedure established by law’. This debate related to whether the
legislature or the judiciary was to be trusted more as being the protector of
individual liberty.

Due process of law would enable the judiciary to be the interpreter and protector
of individual rights where as procedure established by law, would empower the
legislative to have the last word on the matter. When the matter was put to vote,
the phrase ‘procedure established by law’ was chosen by the Constituent
Assembly (Noorani, 2012). By so do doing the power of the judiciary was reduced
in the contest of questioning the validity of the law with respect to due process.

Dr. Ambedkar proposed that the article in the Indian Constitution pertaining to
arrest should have minimum safeguards for personal liberty. He argued that it
was critical that the person being arrested must be informed about the grounds
on which the arrest was being made. Additionally, the person being arrested was
to have the right to have a legal attorney of their choice and to be produced
before a magistrate within 24 hours of arrest.

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It was also argued that extra-ordinary times would require extra-ordinary
provisions (Austin, 1966). Simultaneously, it was argued that the provisions
pertaining to preventive detention were not to have such extensive safeguards.

The presence of an advisory board was suggested which could look into the
matters of preventive detention and decide case to case the duration for
detention. When the matter was put to vote in the Constituent Assembly, it was
decided that the detainee would be informed of the causes for arrest ‘as soon as
possible’ and would be granted the right to prove his/her case against the
charges filled against him/her.

Section 4: Provisions present in the Indian

Constitution pertaining to Preventive Detention.

What are the provisions in the

Indian Constitution which
allow for preventive detention
?

These provisions pertain to

Article 22 which is part of the
Fundamental Rights, and List
I and List II of the Seventh
Schedule in the Indian
Constitution.

At present the provisions pertaining to preventive detention in the Indian

Constitution are contained in Article 22 (see Annexure 1) and in List I and List III
of the Seventh Schedule.

The first two provisions of the Article 22 are to be applied in cases of general
rights of arrested persons. Both these parts provide that the arrested person
should be informed about the reasons for arrest as soon as possible, such person
will have the right to consult a legal attorney and within 24 hours will have to be
produced before a magistrate.

However, part 3 or Article 22 provides that the safeguards and provisions

presented in the first two parts of Article 22 are not to apply to people who are
arrested under any preventive detention laws. This implies that the persons who
will be detained under preventive detention will not immediately have the right to
know the reasons for the detention (unless decided otherwise), nor will they have

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the right to have an attorney and nor will they be produced before a magistrate
within 24 hours of arrest.

Some provisions under the ambit of Article 22 also provide for protection for
people arrested under preventive detention. Part 4 of Article 22 provides for the
process by which a person can be detained for a period of more than three
months. In this manner a procedural safeguard is created whereby it is required
for an Advisory Board to review preventive detention.

Part 5 of Article 22 does state that those who are arrested under preventive
detention should be informed as soon as possible about the reasons for arrest
and is to be allowed to be able to make a presentation against these reasons for
arrest.

However, part 7 of Article 22 provides for the Parliament to be also to make laws
determining the maximum period for which a person can be detained in
preventive detention, and the groups of people who can be detained.

It needs to be pointed out that this means that the Indian Parliament has the
power to adopt laws which have provisions for preventive detention for any
possible period of time without having to justify this time period to any advisory
board.

Additionally, it needs to be pointed out that under the ambit of the seventh
Schedule of the Indian Constitution the Union and state government shave the
power to enact preventive detention legislations.

Section 5: Working of Preventive Detention in India.

Within a month of the enactment of the Indian Constitution in 1950, the

Preventive Detention Act 1950 was introduced. Since then Indian democracy’s
history has been replete with the use of laws containing preventive detention
clauses. The Preventive Detention Act (PDA) 1950 was formulated to take
requisite State action against communists in Telengana.

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 When and Why was
the first preventive
detnetion law used in
independent India?

After independence, the first time

that a preventive detention law
was used in India was in 1950. In
1950, in order to respond to the
security threats posed by the
Telengana struggle, the
Preventive Detention Act 1950
was formulated.

This was enacted as an emergency provision and was expected to lapse after a
short duration of time. However, the Preventive Detention Act remained in force
for about two decades after it was enacted.

Taking from the work of Upendra Baxi (1982), Singh (2007) has argued that it is
important to understand the different registers present within the legal system in
India. After the enactment of the Preventive Detention Act 1950, it can be argued
that there has existed the Preventive Detention System within the legal system in
India and this has run parallel to the Criminal Justice System. Baxi (1982)
suggests that these two systems are different in terms of their object, standards
of justice and the manner of power sharing.

Indian Legal System

(Upendra Baxi, 1982)

Preventive Detention
Criminal Justice System. System
It functions on the It is based on the
assumption that social assumption that repression
defense is the primary of ideological and political
object of law State opposition, is its main
task

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The Preventive Detention System is based on the assumption that repression of
ideological and political State opposition, is its main task. It exists on providing
minimum adherence to due process of law and gives more importance to
decisions made by the executive part of the government. The legislation and use
of extra-ordinary laws and provisions comes under the Preventive Detention
System.

On the other hand, the Criminal Justice System functions on the assumption that
social defense is the primary object of law. It uses due process of law as its
strategy. Additionally, it gives importance to the judiciary in interpretation of laws
and legal procedures, as it is pro-accused in its outlook. It has been argued that
both these systems comprise the legal system in the Indian context as they
symbolize the contradictory pulls and pressures present within the Indian legal
system.

In the context of the war between India and China in 1962, the Defense of India
Act (DSA) 1962 was introduced. This also had provisions for preventive detention.
Singh (2007) has argued that this gave the Central government the power to
create rules for ensuring the security, public order, military operations of the
State. Even during the wars with Pakistan in 1965, and 1971, the Indian State
continued to detain people under the Defense of India Act 1962.

Next, the Unlawful Activities Prevention Act (UAPA) was passed in 1968. Within
the ambit of this law the Indian State could declare any organization illegal and
could imprison anyone for interrogation if the said organization or person
critiqued/questioned Indian sovereignty territorially.

In 1969, the Preventive Detention Act lapsed as it did not get the requisite
support form the then Prime Minister Indira Gandhi. After this for a period of two
years, no Central government initiated preventive detention laws were enacted
though different states still had their own preventive detention laws.

The Maintenance of Internal Security Act (MISA) was passed in 1971. It was
framed along the contours of the Preventive Detention Act 1950. Singh (2007)
suggests that MISA had provisions which were based on Article 22 (4) and (5) of
the Indian Constitution. These concerned stringent provisions for detention and
the opportunity to respond legally to the accusations made against the detainee.

The Defense of India Act 1971 introduced some provisions in MISA making it
even more stringent. During the period of National Emergency in India from
1975-77, MISA was used as one of the instruments by the executive to
extensively detain people who did not support the Indian government (Noorani,
2012).

With the 39th Amendment and the 42nd Amendment to the Indian Constitution,
MISA was strengthened and was made a part of the Indian Constitution itself. In
1976, the Supreme Court also held the validity of MISA. The powers of the
Central government were strengthened to create further such laws.

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In 1977, the Janata Party government repealed MISA. At the same time the
Janata Party government did not repeal other extra-ordinary laws such as Armed
Forces Special Powers Act and the UAPA. In 1978, the 44 th Amendment was
introduced to the Constitution which made it harder for the government to use
extra-ordinary provisions.

Name some of the

preventive detention
laws formulated by the
central government in
India

The Preventive
Detention Act 1950.

The Defense of India

Act 1962.

The Maintenance of
Internal Security Act
1971.

The Unlawful Activities

Prevention Act 1968.

It was made more difficult for subsequent governments to declare emergency,

the government’s power to infringe upon fundamental rights was restricted and
minimum protection accorded under the ambit of preventive detention laws was

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expanded. Although both the houses of the Indian parliament passed this
Amendment, the provisions mentioned were not officially notified. This made it
possible for preventive detention legislations to still be passed.

Noorani (2012) has argued that preventive detention provisions in subsequent

legislations continued to become more stringent. For instance, the National
Security Act 1980 was amended in 1984 and 1987 in order to respond to the
political turmoil in Punjab and in this process the protections accorded to
detainees were thinned down further.

With the above-mentioned amendments, people could be detained for up to six

months without seeking permission/approval for the detention from an Advisory
Board. These amendments also made it difficult for the courts of law to invalidate
detention orders.

The anti-terror laws which have been introduced subsequently, including Terrorist
and Disruptive Activities (Prevention) (TADA) Act 1985 and Prevention of
Terrorism Act (POTA) 2002 had provisions for preventive detention. Under these
laws, a person could be detained for up to a period of 180 days or under TADA for
a period of up to even one year. It has been argued that these laws were misused
to target minorities and disadvantaged groups in some states in India.

TADA and POTA were repealed but most of their provisions live on in different
versions of the UAPA. The UAPA has been recently amended in the wake of the
terror attacks in Mumbai in 2008. Under the ambit of this law it is possible to
detain a person for unto 90 days without charge and further it is possible to
detain a person for up to 180 days if the Public Prosecutor is able to prove that
the investigation has not been completed.

Name some of the

preventive detention laws
formulated by different
state governments in India

Jammu and Kashmir

Public Safety Act
1978

Assam Preventive
Detention Act 1980

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It needs to be pointed out that in addition to these Central government laws,
there have also existed state laws in India, which have had provisions for
preventive detention. For instance the Jammu and Kashmir Public Safety Act
(PSA) 1978 has severely restricted the rights of the detainees. Under the ambit of
this law a person can be detained for a period of up to a year if it is deemed that
she/he can act to disturb public order, and can be detained for up to two years if
his/her actions are deemed to upset the security of the state.

The PSA also allows the detaining authorities discretion in terms of deciding the
manner in which the person has to be detained, in other words the detaining
authorities can decide upon the severity of circumstances under which a person is
being detained and the manner in which the investigation has to be carried out.
An Advisory Board is to be approached within a period of eight weeks each time a
person id detained in order to get approval for the detention.

It has been argued that the actual implementation of the PSA has been even
worse that than its inherent provisions permit (Noorani, 2012). For instance,
authorities have many times not informed the detainees of the reasons for which
they are being detained. Further those held under preventive detention have
faced torture in different forms. The government authorities have even used the
provisions of PSA to detain political opponents. For instance, in 1999 most of the
leaders of the All Parties Hurriyat (Freedom) Conference were held under
detention.

Similarly in the context of Assam, the Assam Preventive Detention Act 1980 has
been in force. This law is similar to the PSA in many ways and allows for
protracted period of time for keeping some one in preventive detention. This act
allows for keeping someone in detention on vague grounds.

Thus, both at the level of the Central government and at the level of the state
governments preventive detention laws have been formulated since
independence in the Indian context.

Section 6: Role of Judiciary in case of Preventive

Detention.

Noorani (2012) has argued that the judiciary has played a limited role in
enforcing procedural protections present in Article 22 of the Indian Constitution.
The courts have not been able to effectively challenge the powers of the
legislature in formulating and implementing preventive detention laws.

The Supreme Court has held that the detainees must be informed about the
grounds on which they are being held in detention. The detainee must be
provided all the required information based on which the detainee can make a
case to defend himself/herself. No grounds, or facts are to be withheld from the
detainees with regard to the reasons for which they are being withheld.

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 Recommendations of the Supreme Court with regard to use of preventive
detention.

Detainees must be informed about the grounds for arrest.

Detainees must not be held in detention without permission from the requisite legal
authority.

Detainee must be provided all the required information needed for her/him to defend
herself/himself before a legal authority.

Detainees must not be held on vague grounds.

Further the Supreme Court has held that the detaining authority must work hard
to clearly define the grounds on which a person is being held in preventive
detention. It is considered illegal for the detaining authority to withhold someone
on vague or irrelevant grounds. It has also been argued that a detention order
can be held invalid in case insufficient information is provided for proving the
grounds for the detention.

The Court has also stated that the detention order can be invalidated in case it is
found that the detaining authority has mala fide intentions for detaining the
person for reasons other than those stated for the detention. Additionally, the
Supreme Court has also held that it is a prerequisite that the detainees must be
informed about the reasons for her/his detention within the specified time.

Even though the Supreme Court has attempted to provide safeguards to those
held in preventive detention, the Court has not been able to provide protection of
individual rights on many accounts. For instance the Court has stated that it does
not have the authority to comment on the propriety or sufficiency of the grounds
on which a person is being held in preventive detention.

It also needs to be pointed out that the Court has not been able to take sufficient
action against those people/authorities who have abused the provisions of
preventive detention. For instance, in 2009 in the case of Shri Pawan Kharetilaa
Arora vs Shri Ramrao Wagh, someone was held in preventive detention under 24
false charges for a period of nine months.

Noorani (2012) suggests that the Bombay High Court struck done the preventive
detention in this case and asked the concerned authorities to pay compensation
to the person falsely accused but the amount of compensation accorded was very
limited.

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The Supreme Court has not been able to effectively question the need for
preventive detention in a democracy. For instance in the A. K. Gopalan vs State
of Madras case in 1950, the Supreme Court rulled against the use of preventive
detention in the said case but at the same time upheld the validity of the use of
preventive detention in other contexts.

It also needs to be pointed out that not only have the courts not adequately
questioned the use of preventive detention, the orders passed by the courts
questioning preventive detention have not been adequately implemented.

Section 7: Conclusion.

Provisions for preventive detention were provided in the Indian Constitution as

emergency provisions to be used in dire circumstances. However, over a period of
time the use of preventive detention laws or the presence of provisions for
preventive detention in extra-ordinary laws seems to have become a regular
feature in India.

It can be argued that there is merit in the argument that preventive detention
needs to be present in order to ensure the security of the Indian State and
citizens. However, it is important to ensure that there exist sufficient safeguards
for those held under preventive detention. It is critical to ensure that the
provisions for preventive detention are not misused.

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 Safeguards to be provided
to detainees in a democracy

Must be informed of the reasons for arrest

as soon as possible.

Preventive detention for long periods of

time (for instance three months and
longer) should not be allowed without
permission from a legal authority, and
without proof agaisnt the person detained.

Detainees must not be tortured and their

human rights should be respected.

must be produced infornt of a legal authority in

the shortest possible period of time.

Detainees held under preventive detention must not be tortured and must exist
sufficient safeguards to ensure that their basic rights are not infringed upon.
Detainees need to be informed about the reasons for their detention.

Importantly, preventive detention laws must be reviewed by the legislature within

specified period of time. Periodic reviews of preventive detention orders also need
to be made by Advisory Boards.

The detaining authorities must me held accountable for their conduct and they
must be answerable for the reasons for which they hold someone in preventive

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detention. In conclusion, it can be argued that the use of preventive detention
needs to be held in check in order to avoid abuse.

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Exercise

1. What is preventive detention? Did the Colonial

State in India use preventive detention, why?
What were the debates regarding this in the
Constituent Assembly?
2. Write an essay on the use of preventive
detention in India.
3. What were the debates held during the
Constituent Assembly in India on the issue of
preventive detention? What are the provisions
present in the Indian Constitution which deal
with preventive detention?
4. What role has the Indian Supreme Court played
in the debates on use of preventive detention in
India ?
5. Critically analyze the use of preventive
detention in India. What are the limitations of
the use of preventive detention in a
democracy?

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