The petitioner, Shaikh Adil Shaikh Shahrukh, challenged a detention order under the Maharashtra Prevention of Dangerous Activities of Slumlords, Bootleggers, Drug-offenders, Dangerous Persons, Video Pirates, Sand Smugglers, Persons Engaged in Black-Marketing of Essential Commodities, Illegal Gambling, Illegal Lottery and Human Trafficker Act, 1981. The detention order was based on two crimes registered against the petitioner. The petitioner's counsel argued that the detention order was invalid as it did not consider the bail orders and conditions imposed by the court. The court held that the detaining authority failed to consider the efficacy of the bail conditions, which is a necessary aspect of preventive detention. The court relied on the judgments of the Hon'ble Apex Court in Joyi Kitty Joseph and Shaik Nazneen cases.