Supreme Court Upholds COFEPOSA Detention Of Kannada Actress Ranya Rao In Gold Smuggling Case

The Supreme Court on Thursday upheld the preventive detention order passed by the Central Economic Intelligence Bureau (CEIB) against Kannada actress Ranya Rao alias Harshavardhini Ranya for allegedly smuggling gold into the country. The Court also upheld the detention of her aide Sahil Sarkariya Jain under the provisions of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act (COFEPOSA).

A Bench of Justice MM Sundresh and Justice Nongmeikapam Kotiswar Singh dismissed the Special Leave Petitions challenging the detention orders dated April 22, 2025, which had earlier been upheld by the Karnataka High Court.

Background

According to the authorities, specific intelligence inputs led officials of the Directorate of Revenue Intelligence (DRI) to intercept Ranya Rao on March 3, 2025, near the Green Channel of the International Customs Arrival Hall at Kempegowda International Airport, Bengaluru. A search resulted in the recovery of 17 foreign-marked gold bars weighing approximately 14.2 kilograms.

Subsequently, statements were recorded under Section 108 of the Customs Act. Based on these statements and other materials, Sahil Sarkariya Jain was arrested on April 7, 2025. The authorities alleged that Jain had facilitated the disposal of foreign-marked gold consignments on four occasions between November 14, 2024 and February 14, 2025, along with the actress.

Invoking powers under Section 3(1) of the COFEPOSA Act, the Joint Secretary in the Ministry of Finance issued preventive detention orders against both detenus on April 22, 2025, citing their alleged involvement in organised gold smuggling activities.

Challenge To Detention

Before the High Court and the Supreme Court, the detenus and their relatives challenged the detention orders on multiple grounds. Among other contentions, they argued that relied-upon documents were not properly supplied, that there was no imminent possibility of future smuggling activities, and that the detention orders lacked proper subjective satisfaction by the detaining authority.

It was also contended that the refusal to permit legal representation before the Advisory Board vitiated the detention proceedings and that the authorities had failed to establish a proximate link between the alleged past activities and the necessity for preventive detention.

Supreme Court's Findings

Rejecting the challenges, the Supreme Court held that substantial procedural compliance had been made by the authorities while issuing the detention orders. The Court found that the detenus had been furnished with the relied-upon documents within the prescribed time and that the contents of electronic evidence, including CCTV footage, had been displayed to them in prison.

The Bench also clarified that a detenu has no right to be represented by a legal practitioner before the Advisory Board as a matter of course. Such a right would arise only if the detaining authority itself participates through a legal practitioner, which was not the case here.

On the issue of subjective satisfaction, the Court observed that the detention order contained adequate reasons, including prior instances of disposal of foreign-marked gold bars, and that a live and proximate link existed between the alleged activities and the need for preventive detention.

Finding no illegality or violation of constitutional safeguards under Article 22, the Court dismissed both Special Leave Petitions and upheld the preventive detention of the actress and her aide under the COFEPOSA Act.

Appearances :

For Priyanka Sarkariya - Mr. Amol B. Karande and Mr. T. Chezhiyan

For Harshavardhini Ranya - Senior Advocate Mr. R. Basant

For Union - Additional Solicitor General HP Rohini.

Case : Priyanka Sarkariya v The Union of India

Citation : 2026 LiveLaw (SC) 380

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