( 1 ) THE challenge in this petition is to the order dated 30th January, 1989 by Government of Kerala directing the detention of the petitioner in exercise of powers conferred by Sections 3 (1) (i),3 (1) (ii) and 3 (1) (iii) of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974 (for short the Act ), with view to prevnting him from sumggling goods, abetting the smuggling of goods and engaging in transporting or concealing or keeping smuggling goods. The declaration under Section 9 (1) of the Act dated 2nd March 1989 was made by Sh. B. V. Kumar, Additional Secretary to the Government of India. The said declaration is also under challenge in this petition.

( 2 ) ON 4th September 1989 a representation was made by the petitioner to Central Government of India. English translation of the said representation which was addressed to the President of India is Annexure G to the writ petition. In that representation the petitioner had also challenged the aforesaid declaration made under section 9 (1) of the Act.

( 3 ) THE present petition was filed on 4th October, 1989. One of the grounds taken in petition is that the representation dated