Correct option is D
In
A.K. Gopalan v. State of Madras, the Supreme Court referred to
Article 22 as an "ugly provision." Article 22 deals with preventive detention and provides certain protections to individuals arrested under such laws, but it has been criticized for being misused.
Information Booster:
A.K. Gopalan v. State of Madras (1950) was a landmark case where the Supreme Court narrowly interpreted the
Right to Life and Personal Liberty. However, later cases like
Maneka Gandhi v. Union of India broadened the scope of
Article 21.