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Ranjitha v. the Principal Secretary to Government

Madras HC20 Apr 2026HCP/2197/2025

Case brief

AI extract

What is this about?

HCP No. 2197 of 2025; Madras High Court; habeas corpus; preventive detention; Tamil Nadu Preventive Detention Act, 1982; Goonda; Section 2(f); undated special report of sponsoring authority; irrelevant material; detention order BBCDEFGISSSV No.110/2025 dated 31.08.2025; Commissioner of Police Tambaram City; Central Prison Puzhal; Rekha 2011 (5) SCC 244; detention order set aside; detenu released; Sunder Mohan J.; Anita Sumanth J.

What did the court decide?

Detention Order in BBCDEFGISSSV No.110/2025 dated 31.08.2025 passed by the second respondent set aside; detenu R.Sridhar, aged 26 years, confined in Central Prison, Puzhal, Chennai, directed to be set at liberty forthwith unless his presence is required in connection with any other case. ¶31

Ranjitha Vs the Principal Secretary to Government — Writ and Judicial Review | Madras HC (2026)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the detention order dated 31.08.2025 (BBCDEFGISSSV No.110/2025) branding the detenu R.Sridhar as a 'Goonda' under the Tamil Nadu Preventive Detention Act, 1982 is sustainable in law.

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Court's answer

On perusal of the record and hearing submissions on either side, the impugned order cannot be sustained since the special report sent by the sponsoring authority is undated; in the absence of that date, the special report becomes irrelevant and the compelling necessity to detain the detenu becomes doubtful.

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Ratio / Principle

Applying the Supreme Court's holding in Rekha v. State of Tamil Nadu ((2011) 5 SCC 244) that a detention order passed on irrelevant material is liable to be quashed, this Court held that for the aforesaid reason the impugned detention order is liable to be set aside.

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Detailed headnote1 paragraphs

Habeas Corpus Petition (Art. 226) — Madras High Court, order dated 20-04-2026 made by Sunder Mohan J. for the Bench of Dr. Justice Anita Sumanth and Justice Sunder Mohan. Ranjitha, wife of the detenu R.Sridhar (aged 26), challenged her husband's preventive detention as a 'Goonda' (Section 2(f), Tamil Nadu Preventive Detention Act, 1982) under detention order dated 31.08.2025 made in proceedings BBCDEFGISSSV No.110/2025 by the Commissioner of Police, Tambaram City. The Court found the impugned order unsustainable because the special report sent by the sponsoring authority was undated — in the absence of the said date the special report became irrelevant and the compelling necessity to detain became doubtful. Invoking Rekha v. State of Tamil Nadu, 2011 (5) SCC 244, where a detention order is passed on irrelevant material it is liable to be quashed, the Court allowed the petition, set aside the detention order, and directed that the detenu be set at liberty forthwith unless his presence was required in connection with any other case.

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HCP No. 2197 of 2025

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IN THE HIGH COURT OF JUDICATURE AT MADRAS

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DATED: 20-04-2026

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CORAM

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THE HON'BLE DR.JUSTICE ANITA SUMANTH

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AND

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THE HON'BLE MR.JUSTICE SUNDER MOHAN

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HCP No. 2197 of 2025

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Ranjitha W/o.Sridhar, No.737, Gandhi Nagar, Erikarai, Solinganallur, Kancheepuram District.

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..Petitioner(s)

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The Principal Secretary To Government, Home Prohibition and Excise Department, Secretariat, Fort St.George, Chennai-600 009.

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The Commissioner Of Police, Tambaram City, Office of the Commissioner of Police, Sholinganallur, Chennai-600 119.

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The Superintendent Of Prison, Central Prison Puzhal, Chennai District.

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The Inspector Of Police, T-16, Semmanchery Police Station, Chennai.

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..Respondent(s)

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__________ Page 1 of 5

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https://www.mhc.tn.gov.in/judis

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HCP No. 2197 of 2025

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Prayer : Petition filed under Article 226 of Constitution of India praying for issuance of Writ of Habeas Corpus calling for the records pertaining to the petitioner’s husband detention under Tamil Nadu Act 14 of 1982 vide detention order, dated 31.08.2025 on the file of the second respondent herein made in proceedings BBCDEFGISSSV No.110/2025, quash the same as illegal and consequently direct the respondents herein to produce the petitioner’s husband namely Sridhar, S/o.Rajalingam, aged about 26 Years, before this Court and set the petitioner’s husband at liberty from detention, now the petitioner’s husband detained at Central Prison, Puzhal, Chennai.

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For Petitioner(s): Mr. D. Akash Kumar for Mr.W.Camyles Gandhi For Respondent(s): Mr. R. Muniyapparaj Additional Public Prosecutor Assisted By Mr. M. Sylvester John

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Order

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(Order of the Court was made by Sunder Mohan J.)

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The wife of detenu - R.Sridhar, S/o. Rajalingam, has filed this petition challenging detention order dated 31.08.2025, branding him as ‘Goonda’ under Section 2(f) of the Tamil Nadu Preventive Detention Act, 1982 (Act 14/1982).

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__________ Page 2 of 5

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https://www.mhc.tn.gov.in/judis

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HCP No. 2197 of 2025

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We have heard learned counsel for petitioner and learned Additional Public Prosecutor for respondents.

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We find on perusal of the record and on hearing the submissions on either side that the impugned order cannot be sustained since the special report sent by the sponsoring authority is undated. The detention order has been passed on the report of the sponsoring authority. The compelling necessity to detain the detenu would depend on the date on which the sponsoring authority has sent his report. In the absence of the said date, the special report would become irrelevant and the compelling necessity to detain the detenu becomes doubtful.

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Further in 'Rekha Vs. State of Tamil Nadu through Secretary to Government and another' reported in '2011 [5] SCC 244', the Hon’ble Supreme Court had held that where the detention order is passed on any irrelevant material, then, the detention order is liable to be quashed. Therefore, we are of the view that for the aforesaid reason the impugned detention order is liable to be set aside.

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In light of the aforesaid discussion, this Habeas Corpus Petition is allowed and the Detention Order passed by the second respondent in BBCDEFGISSSV No.110/2025, dated 31.08.2025 is set aside.

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__________ Page 3 of 5

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https://www.mhc.tn.gov.in/judis

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HCP No. 2197 of 2025

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The detenu, viz., R.Sridhar, S/o. Rajalingam, aged 26 years, who

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is now confined in Central Prison, Puzhal, Chennai, is hereby directed to be set at liberty forthwith unless his presence is required in connection with any other case.

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(A.S.M.,J.) (S.M.,J.) 20-04-2026

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Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No

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ssm/ars

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