1997 for an indefinite period. He applied for a writ of habeas corpus subjiciendum and also argued that the President had abused his powers in to declaring a State of emergency as the facts on the ground did not justify the declaration. 231. In obiter, the Court observed that toppling a democratically elected Government by mutiny, force or other undemocratic means was a very grave situation which called for the proclamation of a State of emergency in the country. 232. The Court held that it had no jurisdiction to inquire into the reasons or discretion of the President in declaring a State of emergency. It also held that the detention or imprisonment of the appellant could not be legally justified, hence his application was granted. C. ADMINISTRATIVE MEASURES 233. In order to avoid over detention of suspects and to ensure expediency in dealing with cases; Magistrates have developed a procedure obliging police officers to table a book known as the “Arrest and Prisoners’ Property Book” (APPB) weekly. The APPB keeps a record of all suspects kept in police custody and informs the Magistrate of the status of the suspect. By this measure the Magistrate is able to check and compel police officers to bring suspects timely to court. 234. The HRC and PPCA as already stated continue to offer administrative relief to victims of violations of human rights. 101

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