Pangi Mangamma filed a Habeas Corpus writ petition before the Andhra Pradesh High Court challenging the preventive detention of her relative Pangi Krishna Rao, who was detained under Section 3(1) of the Prevention of Illicit Traffic in Narcotic Drugs and Psychotropic Substances Act, 1988 (PIT NDPS Act) based on five criminal cases under the NDPS Act. The petitioner argued that bail orders in three of the five predicate cases were neither placed before the detaining authority nor supplied to the detenu, that the detenu's judicial custody in Crime No.127/2025 was not communicated to the detaining authority despite the detention order being passed nearly four months after that case was registered, and that the detenu was not informed of his right to make a representation to the Central Government. The court found that the fact of the detenu's judicial custody in Crime No.127/2025 was relevant material that ought to have been brought to the detaining authority's notice before the detention order was passed on 14.10.2025, and that failure to do so vitiated the subjective satisfaction of the detaining authority. Applying the 'triple test' laid down by the Supreme Court in Kamarunnissa v. Union of India (1991) and reiterated in Champion R. Sangma v. State of Meghalaya, the court held that a detaining authority must be aware of the detenu's judicial custody and must be satisfied of the real possibility of bail and likelihood of prejudicial activity before passing a detention order against a person already in custody.