Real judgements, distilled

Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway: what a lawyer should factor into case strategy or client advice as a result of this precedent.

Is the full judgment available, or just a summary?+

Both. Each case shows a distilled summary (case type, key holding, and lesson learnt) and links to the full judgment as a PDF for when you need the complete text for research or citation.

Can I filter judgments by date or case type?+

Yes. Use Advanced Filters to narrow results by decision date and by practice area, including Constitutional Law, Criminal Law, Service & Administrative Law, Family Law, Civil Property & Inheritance, and Labour & Industrial Law.

Can I search judgments by a specific judge?+

Yes. You can filter judgments by the judge or bench that decided the case, which is useful for tracking how a particular judge has reasoned on similar issues across multiple rulings.

What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Criminal LawSupreme Court of India

Sushanta Kumar Banik vs. State of Tripura & Ors.

Criminal AppealDecided 30 Sept 2022
Criminal Appeal No. 1708 of 2022
Uday Umesh Lalit · S. Ravindra Bhat · J.B. Pardiwala

Background

The appellant was preventively detained by the Tripura government under Section 3(1) of the Prevention of Illicit Traffic in Narcotic Drugs and Psychotropic Substances Act, 1988, based on two earlier NDPS cases registered against him (in November 2019 and April 2021). The police proposal for detention was made on 28 June 2021, but the actual detention order was passed only on 12 November 2021, nearly five months later, with no explanation for the delay. Crucially, in both of the underlying criminal cases relied on for the detention order, the appellant had already been granted bail by the Special Court, but this fact was never disclosed to the detaining authority. The Tripura High Court upheld the detention order, and the appellant challenged that before the Supreme Court.

Decision Breakdown

The Supreme Court allowed the appeal on two independent grounds. First, the nearly five-month unexplained delay between the detention proposal and the actual detention order snapped the required "live and proximate link" between the alleged prejudicial activities and the purpose of the detention, relying on a long line of precedent that unexplained delay casts doubt on the genuineness of the detaining authority's satisfaction. Second, the fact that the appellant had been granted bail in both underlying cases despite the strict bail conditions under Section 37 of the NDPS Act was a vital fact that should have been placed before the detaining authority, and its suppression by the sponsoring police authority vitiated the detaining authority's subjective satisfaction. The Court quashed the detention order and the High Court judgment, and ordered the appellant's immediate release (if not required in any other case).

Lesson Learnt

Preventive detention is an extraordinary curtailment of personal liberty, so authorities must act with promptness and full disclosure: an unexplained long delay in passing a detention order, or withholding a material fact like the detenu already being out on bail, can by itself invalidate the detention regardless of the underlying allegations.

Sushanta Kumar Banik vs. State of Tripura & Ors. – Legal Case Shots | LegalAware