The Supreme Court held that preventive detention cannot be sustained solely on the basis of a confessional statement made before police authorities without independent supporting evidence. In Mulla Afroz v. Union of India and Others, the appellant challenged his detention under the National Security Act, 1980, following violence during a court-ordered mosque survey in Sambhal, Uttar Pradesh. Although he had secured bail in the criminal cases arising from the incident, preventive detention was imposed on the basis of material that included an alleged custodial confession. The Court observed that preventive detention is an extraordinary restriction on personal liberty and requires strict compliance with constitutional safeguards. It emphasised that multiple pending criminal cases do not automatically justify preventive detention without credible material establishing a genuine threat to public order. The Court also distinguished preventive detention from punitive detention and cautioned against using detention orders to defeat bail granted through ordinary criminal proceedings. Finding insufficient justification for continued detention, the Supreme Court quashed the detention order and directed payment of ₹10 lakh in costs. The judgment reinforces Articles 14, 19, 20(3), 21 and 22 of the Constitution.