Allowed¶30

Mahalakshmi v. The State of Tamil Nadu

Madras HC1 Jun 2026HCP(MD)/580/2026

Case brief

AI extract

What is this about?

Keywords: habeas corpus; preventive detention; 'Goonda'; Tamil Nadu Act 14 of 1982 S.2(f); non-application of mind; similarity of bail orders; Crl.M.P.No.2236 of 2023; TNPPDL Act S.3(1); BNS 2023; Arms Act 1959 S.25(1); adverse cases; pending investigation; District Magistrate Dindigul; Madurai Central Prison; detention set aside; release of detenu. Parties: Mahalakshmi (petitioner, wife of detenu); Yuvaraj @ Yuvarajkumar (detenu). Bench: N. Anand Venkatesh, J. (author) with K.K. Ramakrishnan, J.; decided 01.06.2026.

What did the court decide?

Order of detention No.68/2025 dated 11.11.2025 set aside; detenu Yuvaraj @ Yuvarajkumar directed to be released forthwith unless his detention is required in connection with any other case. ¶30

Mahalakshmi Vs The State of Tamil Nadu — Writ and Judicial Review | Madras HC (2026)

What the court decided

AI extract

Outcome

Order of detention No.68/2025 dated 11.11.2025 set aside; detenu Yuvaraj @ Yuvarajkumar directed to be released forthwith unless his detention is required in connection with any other case.

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Issue for consideration

Whether the detention order suffers from non-application of mind because the Detaining Authority, though aware that the detenu's bail petition had been rejected, relied on a bail order (Crl.M.P.No.2236 of 2023, dated 20.06.2023) that did not arise out of a similar case to conclude there was a likelihood of the detenu being let out on bail.

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Court's answer

The order relied upon by the Detaining Authority does not arise out of a similar case, and consequently the detention order suffers from non-application of mind.

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Ratio / Principle

The relied-upon bail order was dissimilar to the detenu's case: it did not cover an offence under the TNPPDL Act, and bail there had been granted because the investigation was completed and the charge sheet filed, whereas in the detenu's case the investigation was pending.

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Detailed headnote1 paragraphs

Habeas Corpus Petition H.C.P.(MD)No.580 of 2026 (decided 01.06.2026) before the Madurai Bench of the Madras High Court challenged Detention Order No.68/2025 dated 11.11.2025 passed by the District Magistrate and District Collector, Dindigul, detaining Yuvaraj @ Yuvarajkumar as a 'Goonda' under Section 2(f) of the Tamil Nadu Act 14 of 1982. Although aware that the detenu's bail petition had been rejected, the Detaining Authority had relied on a bail order in Crl.M.P.No.2236 of 2023 dated 20.06.2023 as a 'similar case' to infer a likelihood of release on bail. The Court held that the relied-upon order was not a similar case - it involved no TNPPDL Act offence, and bail there rested on completion of investigation and filing of the charge sheet, whereas the detenu's investigation was pending - so the detention order suffered from non-application of mind. The petition was allowed, the detention order was set aside, and the detenu was directed to be released forthwith unless required in connection with any other case.

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BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

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DATED: 01.06.2026

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CORAM

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THE HON'BLE MR JUSTICE N.ANAND VENKATESH

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AND

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THE HON'BLE MR JUSTICE K.K.RAMAKRISHNAN

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H.C.P.(MD)No.580 of 2026

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Mahalakshmi .. Petitioner / Wife of the detenu

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Vs.

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1.The State of Tamil Nadu, Represented by the Additional Chief Secretary to Government, Home, Prohibition and Excise Department, Fort St.George, Chennai -9.

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2.The District Magistrate and District Collector, O/o.The District Magistrate and District Collector, Dindigul District.

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3.The Superintendent of Prison, Madurai Central Prison, Madurai District. .. Respondents

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Prayer :Petition filed under Article 226 of the Constitution of India to issue a writ of Habeas Corpus, to call for the entire records connected with the detention order of the Respondent No.2 in Detention Order No.68/2025 dated 11.11.2025 and quash the same and direct the respondents to produce

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Page 1 of 6

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

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the detenu by name Yuvaraj @ Yuvarajkumar, S/o.Kannan, aged 31 years, now confining at Madurai Central Prison, before this Court and set him at liberty forthwith.

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For Petitioner : Mr.R.Alagumani For Respondents : Mr.G.Karuppasamy Pandian Counsel for State of TN (crl.side)

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ORDER

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(Order of the Court was made by N. ANAND VENKATESH,J.)

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The petitioner is the wife of the detenu, by name, Yuvaraj @ Yuvarajkumar, S/o. Kannan, aged 31 years. The detenu has been detained by the second respondent by his order in Detention Order No.68/2025 dated 11.11.2025, holding him to be a "Goonda", as contemplated under Section 2(f) of the Tamil Nadu Act 14 of 1982. The said order is under challenge in this Habeas Corpus Petition.

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We have heard the learned counsel appearing for the petitioner and the learned Additional Public Prosecutor appearing for the respondents. We have also perused the records produced by the Detaining Authority.

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Page 2 of 6

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Apart from the other grounds that were raised by the learned

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counsel for the petitioner, one of the main ground that was raised is that the Detaining Authority was aware of the fact that the bail petition filed by the detenue was rejected and in spite of the same, the Detaining Authority took into consideration an order passed in Crl.M.P.No.2236 of 2023, dated 20.06.2023 and came to the conclusion that in a similar case, bail has been granted and therefore, there is a likelihood of the detenue being let out on bail. The learned counsel submitted that the order that was relied upon by the Detaining Authority does not arise out of a similar case and therefore, the detention order suffers from non-application of mind.

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In the case in hand, the detenue had three adverse cases apart from the ground case. The ground case was for various offences under BNS, 2023, Section 25(1) of the Arms Act, 1959 and Section 3(1) of the TNPPDL Act. In the bail order that was relied upon by the Detaining Authority as a similar case, it did not cover an offence under the TNPPDL Act. Apart from that, bail was granted on the ground that the investigation had been completed and the charge sheet had been filed. In the case in hand, the investigation was pending. Hence, the order that was relied upon by the

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

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Detaining Authority does not arise out of a similar case and consequently, the detention order suffers from non-application of mind.

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In the result, the Habeas Corpus Petition is allowed and the order of detention in No.68/2025, dated 11.11.2025, passed by the second respondent is set aside. The detenu, viz., Yuvaraj @ Yuvarajkumar, S/o. Kannan, aged 31 years, is directed to be released forthwith unless his detention is required in connection with any other case.

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(N.A.V.,J..) (K.K.R.K.,J.,) 01.06.2026 Index : Yes / No Internet : Yes / No

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Indu

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