law: Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974
  10. Maximum period of detention -
  The maximum period for which any person may be detained in pursuance
  
  of any detention order to which the provisions of section 9 do not apply and
  
  which has been confirmed under clause (f) of section 8 shall be [(Note:-
  
  Subs. by Act No.20 of 1976 for words "one year from the date of
  
  detention") a period of one year from the date of detention or the
  
  specified period, whichever period expires later] and the maximum period for
  
  which any person may be detained in pursuance of any detention order to which
  
  the provisions of section 9 apply and which has been confirmed under clause (f)
  
  of section 8 read with sub-section (2) of section 9 shall be [(Note:- Ibid,
  
  for words "two years from the date of detention") a period of two
  
  years from the date of detention or the specified period, whichever period
  
  expires later :
  Provided that nothing contained in this section shall
  
  affect the power of the appropriate Government in neither case to revoke or
  
  modify the detention order at any earlier time.
  [(Note:- Ins. by Act No.20 of 1976) Explanation.-In this
  
  section and in section 10A, "specified period" means the period
  
  during which the Proclamation of Emergency issued under clause (1) of article
  
  352 of the Constitution on the 3rd day of December, 1971 and the
  
  Proclamation of Emergency issued under that clause on the 25th day
  
  of June, 1975, are both in operation.]
  Comment : we hold that since no order of confirmation
  
  of the detention was made under Cl . (f) of S. 8
  
  within three months of the date of detention by the appropriate Government,
  
  further detention of the petitioner after the expiry of that period is without
  
  the authority of law.  Nirmal Kumar  Khandelwal v. The Union of India AIR 1978 SUPREME COURT
  
  1155