Judicial review of subjective satisfaction in preventive detention matters

While constitutional courts do not act as courts of appeal over the subjective satisfaction of a detaining authority, they exercise robust judicial review to ensure constitutional and statutory boundaries are respected. Judicial scrutiny extends to checking whether the subjective satisfaction was formed on relevant material, without considering extraneous matters, and in absolute good faith. If the grounds of detention are vague, non-existent, irrational, or legally perverse, the High Court and Supreme Court possess full authority to set aside the detention order. Courts will intervene where the detaining authority fails to evaluate crucial factors, such as pending bail applications or the sufficiency of existing bail conditions. The constitutional guarantee of personal liberty under Article 21 demands that any administrative restraint be subjected to strict judicial review. The court will ensure that the power to detain is not converted into an instrument of executive arbitrariness or administrative convenience. Consequently, subjective satisfaction remains subject to judicial correction whenever fundamental legal principles are compromised. (Roshini Devi v. The State of Telangana and Others | 2026 INSC 41)