In an atmosphere where a large number of people had been detained without trial under the repressive Maintenance of Internal Security Act (MISA), several high courts had given relief to the detainees by accepting their right to habeas corpus as stated in Article 21 of the Indian constitution. This issue was at the heart of the case of the "Additional District Magistrate of Jabalpur v. Shiv Kant Shukla", popularly known as the "Habeas Corpus case", which came up for hearing in front of the