Delivering a sharp rebuke to law enforcement over the misuse of exceptional detention statutes, the Supreme Court of India on Tuesday, September 29, 2026, quashed the preventive detention of Mullah Afroz under the National Security Act (NSA), 1980, in connection with the 2024 Sambhal violence. Overruling an earlier order of the Allahabad High Court that had upheld the state's action, a division bench comprising Justice Dipankar Datta and Justice Sheel Nagu imposed an exemplary cost of ₹10 lakh on the Uttar Pradesh government. The apex court held that district authorities acted arbitrarily, failed to assess comprehensive factual circumstances, and engaged in an abuse of executive power by depriving an individual of personal liberty without satisfying statutory standards.

Custodial Confessions Cannot Form the Sole Basis for Preventive Custody

Central to the top court's landmark ruling was the legal invalidity of relying strictly on extra-judicial or custodial statements to order preventive detention. Mullah Afroz was arrested approximately 54 days following the clashes that erupted during a court-ordered survey of the historic Shahi Jama Masjid in Sambhal—an incident that tragically claimed four lives. The bench emphasized that confessions made while in police custody carry no evidentiary value in the eyes of the law and cannot stand as the single substantive ground to detain a person under national security provisions. Furthermore, the court noted that mere registration of past criminal charges or vague administrative apprehensions that a person might incite unrest do not warrant preventive incarceration in the absence of fresh, credible, and verifiable evidence.

Judicial Precedent Reaffirmed: Protecting Personal Liberty Against Administrative Overreach

Reinforcing established constitutional benchmarks laid down in landmark judgments such as Rekha v. State of Tamil Nadu and Amina Begum v. State of Telangana, the Supreme Court ruled that state agencies cannot bypass criminal jurisprudence through administrative detention when ordinary criminal laws suffice. The petitioner’s legal counsel had also brought to the court’s attention that police firing occurred during the unrest and demanded an impartial probe through a formal protest petition. By setting aside the NSA order issued on October 13, 2025, and levying a ₹1 million financial penalty on the state machinery, the apex court sent an unequivocal directive to detaining authorities across Uttar Pradesh to adhere to strict constitutional guarantees before invoking harsh preventive measures.