( 1 ) THESE three appeals which raise common questions have been argued together.

( 2 ) LETTERS Patent Appeal No. 477 of 1997 has been directed against the judgment and order dated 26-12-1996 of the learned single Judge in Special Civil application No. 3477 of 1996 in which the petitioner had challenged the order of his detention which was made on 19-12-1974 and sought for a declaration that the detention order being void and illegal, no action could be taken against the petitioner and his relatives under the provisions of the Smugglers and Foreign Exchange manipulators (Forfeiture of Property) Act, 1976 (s. A. F. E. M. A. for short ). A copy of the order dated 19-12-1974 is at Annexure b and a copy of the communication of the grounds of the detention is at Annexure c to the petition.

( 3 ) THE petitioner (Kantilal Damodardas Shah) was ordered to be detained pursuant to the detention order dated 19-12-1974 made under Sec. 5 of the conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974 (c. O. F. E. P. O. S. A. for short ). According to the petitioner, the respondent no. 2 issued a notice under Sec. 6 of S. A. F. E. M. A. on 28-4-1979