ISSUE:
Whether the detention order issued under Rule 30(1)(b) of the Defence of India Rules was valid, given that it cited “law and order” instead of “public order” as the basis for detention?
Whether the President’s order under Article 359(1) completely barred judicial review of detention orders issued during an emergency?
RULE:
The terms “public order” and “law and order” are distinct; detention under a provision requiring “public order” must address severe disruptions affecting society at large, not minor or localized disturbances.
Courts retain the authority to review whether detention orders comply with legal provisions, even during an emergency when certain fundamental rights are suspended.