The Allahabad High Court termed the situation “shocking” after records showed that 4,847 people were placed in preventive detention in Prayagraj and Ghaziabad over two years. The Court expressed concern that many detainees remained jailed for days or weeks despite statutory safeguards under the law.
In April 1976, Justice H.R. Khanna dissented in the ADM Jabalpur case, arguing personal liberty cannot be suspended during emergencies. His principled stand against the Indira Gandhi government led to his bypassing for Chief Justice, marking a pivotal moment for judicial independence. His legacy continues through his nephew, Justice Sanjiv Khanna.
