Question juridique clé
Whether the security detention was unlawful after the expiry of the prior detention title on 18 June 2011 and required immediate release
Solution extraite
The detention lacked a valid formal title from 19 to 22 June 2011, but this did not justify immediate release because a new valid detention title existed from 22 June 2011 and the material conditions of detention were met.
Motifs extraits
Under art. 229 CPP in connection with art. 227 CPP, security detention following pre-trial detention must be renewed within the statutory period. The lapse of the title makes the detention irregular, but a later valid title restores legality prospectively; release is not automatic where grounds for detention continue to exist.