In Brief
A preventive detention order under the Bihar Control of Crimes Act, 1981 was challenged after the State passed a second detention order on the same grounds following revocation of the first. The Supreme Court held that Section 23(2) of the Act prohibits a fresh detention order unless 'fresh facts' arose after the revocation date. The Court followed prior precedent holding that 'revocation' includes all detention orders, whether valid or defective. Since the second order relied entirely on grounds existing before revocation, it violated Section 23(2). The Court allowed the appeal and set aside the detention order.
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