Gujarat High Court
Deepak Fertilisers And Petrochemicals ... vs Union Of India on 3 April, 2025
Author: Bhargav D. Karia
Bench: Bhargav D. Karia
NEUTRAL CITATION
C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025
undefined
IN THE HIGH COURT OF GUJARAT AT AHMEDABAD
R/SPECIAL CIVIL APPLICATION NO. 3828 of 2025
FOR APPROVAL AND SIGNATURE:
HONOURABLE MR. JUSTICE BHARGAV D. KARIA
and
HONOURABLE MR.JUSTICE D.N.RAY
==========================================================
Approved for Reporting Yes No
✓
==========================================================
DEEPAK FERTILISERS AND PETROCHEMICALS CORPORATION
LIMITED
Versus
UNION OF INDIA & ORS.
==========================================================
Appearance:
MR MIHIR JOSHI , SENIOR ADVOCATE WITH MR DIGANT POPAT for the
Petitioner(s) No. 1
MAUNIL G YAJNIK(9346) for the Respondent(s) No. 2,3
MR PRADIP D BHATE(1523) for the Respondent(s) No. 1
==========================================================
CORAM:HONOURABLE MR. JUSTICE BHARGAV D. KARIA
and
HONOURABLE MR.JUSTICE D.N.RAY
Date : 03/04/2025
ORAL JUDGMENT
(PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA)
1. Heard learned Senior Advocate Mr. Mihir Joshi with learned advocate Mr. Page 1 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined Digant Popat for the petitioner and learned advocate Mr. Maunil Yagnik for the respondents.
2. Learned advocate Mr. Maunil Yagnik has tendered the affidavit-in-reply on behalf of the respondent. The same is taken on record.
3. By this petition under Article 227 of the Constitution of India, the petitioner has challenged the impugned communications/orders dated 06.02.2025 and 12.03.2025 passed by the Assistant Commissioner of Customs, rejecting the application for license for Private Warehouse under section 58 of the Customs Act, 1962 (For short "the Customs Act") as per the provisions of para no. 3(2)(c) of Private Warehouse Licensing Regulations, Page 2 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined 2016 ( For short "the Regulations").
4. Brief facts of the case are that the petitioner filed an application dated 18.11.2024 for obtaining a private bonded warehouse license under section 58 of the Customs Act along with permission to carry out the manufacturing activities under section 65 of the Customs Act read with Manufacture and other Operations in Warehouse Regulations, 2019 (for short 'the Regulations').
5. The said application was rejected by the Commissioner of Customs, Ahmedabad by impugned order dated 06.02.2025 quoting the provisions of para no. 3(2)(c) of the Regulations.
6. The petitioner thereafter addressed Page 3 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined letter dated 11.02.2025 to the office of Assistant Commissioner of Customs, Ahmedabad requesting for grant of license contending that the petitioner is not penalised for any offence under the Customs Act,1962 or the Central Excise Act, 1944 or Finance Act, 1994. The petitioner also provided confirmation with respect to the Central Goods and Services Tax Act, 2017 and the Integrated Goods and Services Tax Act, 2017 and the Goods and Service Tax (Compensation to State) Act, 2017. The petitioner also clarified that there are multiple ongoing litigations which are under appeal in accordance with the applicable indirect tax laws along with an undertaking with the said letter.
7. The petitioner thereafter had written various letters to the respondent Page 4 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined authorities for grant of license under the regulations declaring that there is no penalty for offences levied against the petitioner.
8. The respondent Principal Commissioner again by communication/order dated 12.03.2025 rejected the application of the petitioner for the second time as per the provision of para 3(2)(c) of the Regulations.
9. Being aggrieved, the petitioner has preferred the present petition.
10. Learned Senior Advocate Mr. Mihir Joshi for the petitioner submitted that rejection of the application for Private Warehouse made by the petitioner has significantly impacted the petitioner and Page 5 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined financial viability of the project to be undertaken by the petitioner company by making huge investment as unfeasible because major consignments of the petitioner are currently stranded at the load Port in Germany, pending the issuance of the license and MOOWR permission.
11. It was submitted that the petitioner is incurring demurrage cost due to the delay in shipment on the request of the petitioner. It was further submitted that the grounds given by the respondent for rejecting the application of the petitioner as per the provision of para 3(2)(c) of the Regulations is not applicable in the facts of the case as none of the litigation pending against the petitioner involve the offences under any of the indirect tax laws.
Page 6 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined
12. Learned Senior Advocate Mr. Mihir Joshi invited the attention of the Court to the details of the pending litigation against the petitioner under various indirect tax laws as enumerated in para no. 7.8 and 7.9 of the memo of the petition.
13. On perusal of the said details, it appears that none of the litigation involve the penalty for any offence as per any of the provisions either of Customs Act, Central Excise Act or GST Act, as such litigation pertains only to contravention of general provisions of the respective Acts and none of the matters involve proposal/imposition of penalties for offences as per the provision of para 3(2)(c) of the Regulations.
Page 7 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined
14. It was therefore, submitted that the impugned communication rejecting the application for license for Private Warehouse may be quashed and set aside by directing the respondents to issue such license, as the provision of para 3(2)(c) of the Regulations regarding penalty for offences under the Central Excise Act, Finance Act and Customs Act are not applicable in the facts of the case.
15. On the other hand, learned advocate Mr. Maunil Yagnik for the respondent has relied upon Circular No.26/2016 - Customs dated 09.06.2016 issued by the Central Board of Indirect Taxes and Customs laying down the standard operating procedures for verification of antecedents of the applicant for issuance of license of Page 8 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined Private Warehouse under the regulations.
16. It was further pointed out from para 4.1 of the said circular that in order to minimise the time lag for verification of the antecedents of the applicant, it was proposed that a centralised system of verification be followed by referring the name of the applicant and Directors/ Partners/ Proprietor to DRI(HQ) and DGCEI(HQ) for checking antecedents and the existence of any past cases instead of referring to all formations. It was therefore, submitted that the respondents have considered the past cases of the petitioner to reject the application for Private Warehouse license.
17. Thereafter, learned advocate Mr. Yagnik referred to Circular No.34/2019- Page 9 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined Customs dated 01.10.2019, more particularly, Annexure-A thereto prescribing the application for license for a private bonded warehouse. It was pointed out by learned advocate Mr. Yagnik that clause 11 of the format of application refers to the declaration and petitioner therefore, was required to declare that the petitioner was not convicted for any offence under any law and the petitioner was neither being penalised or convicted nor are being prosecuted for any offense under the Customs Act, Central Excise Act, Finance Act, GST Act etc. It was therefore, submitted that the petitioner did not furnish any undertaking or declaration and thereafter the petitioner has submitted part details with regard to pending Page 10 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined litigation in various forums. It was therefore submitted that the respondent has rightly rejected the application made by the petitioner for private warehouse license as per the provision of para 3(2)
(c) of the Regulations in view of pending cases.
18. Considering the submissions made by learned advocate for the respective parties, it would be germane to refer to the provisions of para 3(2)(c) of the Regulations which reads as under:
"3. Licensing of private warehouse xxx (2) The Principal Commissioner of Customs or the Commissioner of Customs, as the case may be, shall not issue a licence to an applicant if,-
(a) he has been declared an insolvent or bankrupt by a Court or Tribunal;Page 11 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025
NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined
(b) he has been convicted for an offence under any law for the time being in force;
(c) he has been penalised for an offence under the Act, the Central Excise Act, 1944 (1 of 1944) or Chapter V of the Finance Act, 1994 (32 of 1994);
(d) he is of unsound mind and stands so declared by a competent court; or
(e) the Principal Commissioner of Customs or the Commissioner of Customs, as the case may be, is satisfied that-
(i) the site or building of the proposed private warehouse is not suitable for secure storage of dutiable goods;
(ii) the site or building of the proposed private warehouse is not suitable for general supervision by officers of customs;
(iii) bankruptcy proceedings are pending against the applicant; or
(iv) criminal proceedings are pending against the applicant ant the offences involved are of such nature that he is not a fit person for grant of licence."
Page 12 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined
19. On perusal of para 3(2)(c) of the Regulations, the Principal Commissioner of Customs or Commissioner of Customs as the case may be is precluded from issuance of license to an applicant if the applicant has been convicted for offence under the provisions of the Central Excise Act, 1944 or Chapter V of the Finance Act, 1994.
20. Therefore, the question arises as to what is the offence under the provisions of the Cental Excise Act or Customs Act.
Chapter 16 of the Customs Act provides for offences and prosecution comprising from section 132 to 140A of the Act. On perusal of the litigation pending against the petitioner, none of the provisions of section 132 to 140A of the Customs Act are alleged to have been violated or any Page 13 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined litigation is subject to the provisions.
The list of offences/litigation pending against the petitioner as per para no. 7.8 and 7.9 enumerated in the petition reads as under:
"7.8 Below is a summary of all pending cases against the petitioner under Customs Act, 1962, Central Excise Act 1944 and Chapter V of Finance Act 1994 (as required under though Regulation 3(2)(c) of the Warehouse Regulations) wherein the order in any proceeding against the Company has either been stayed through an order of the appellate authority.
Sr. Show Cause Legilatio Issue in Legal Penalty Current Comme No. Notice No. & n under brief Provisio section status nts Date which ns invoked issued invoked in the order (1) (2) (3) (4) (5) (6) (7) (8) 1 Show Cause Custom 1. Sections Section Appeal That Notice F. s Act Demurr 28 read 112(a) No.C/50 SCNs NO. age with rule (ii) of 697;202 have DRI/KZU/CF charger 3(1) and Custom 4- been /ENQ- s Rule s Act, CU(DB) issued 63(INT-43)/2 2. 10(2)(a) 1962 pending by 016/7245 Classific and (e) with invoking TO 7249 DT ation of of Section CESTA Sections 29/03/2017 Phosph Custom 112(a) T New 28 of received oric Acid s (ii) of Delhi the from DRI and Valuatio Custom Custom Page 14 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined Kolkatta Anhydro n s Act,s Act Zonal Uni us (Determi 1962 is read Ammoni nation of a with rule a under Value of penalty3(1) and Custom Importe for Rule s Tariff d contrave 10(2)(a) Heading Goods) ntion notand (e) 2809/28 Rules, an of 14 2007 offence Custom 2 DRI/MZU/CI- Custom CVD on Under Section Appeal s Valuatio 06/2012/674 s Act import Section 114A of is DATED of 28 read Custom pending n 1801.2012 fertilizer with s Act, before (Determi s section 1962 CESTA nation of Value of 28AA, T, 111(o) Section Mumbai Importe d of the 114A of Goods) Custom Custom Rules, Act, s Act, 2007 1962 1962 is and a Section penalty 28AA, for 111(o) contrave of the ntion, Custom not an Act, offence which are general in these matters demand s have been propose d by the Departm ent by issuing a SCN.
Further Penalty have been imposed under Page 15 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined section 112 and 114A of the Custom s Act.
Thus, these Sections are invoked for alleged contrave ntion of the provisio ns of the Custom s Act.
Therefor e, it can be said that the Compan y has not been issued SCNs for penalisa tion for offences under Chapter XVI of the Custom s Act.
3 F No. CUS Custom Finalisat Section No Appeal That (M&P)/ABC/ s Act ion of 18(2) penalty is SCN PNP/63/201 the bills has pending has 5 PT-I dated of entry imposed before invoked 30.03.2018 CESTA Section T, 18(2) Mumbai [i.e. Page 16 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined Provisio nal Assess ment] of the Custom s Act which is general in nature i.e. from which demand is propose d by the Departm ent by issuing a SCN.
Thus this section is invoked for alleged contrave ntion of the provisio ns of the Custom s Act.
Therefor e, it can be said that the Compan y has not been issued SCN for penalisa tion for Page 17 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined any offences under Chapter XVI of the Custom s Act.
4 21-22/ Excise Demand Section No Departm That SHH(21- Act in 11A of penalty ent has SCN
22)/PC/RG/ respect Excise has filed an has 2015-16 of Act read imposed Appeal invoked dated naptha with as first No. Section 08.10.2015 used in Rule Appeal E/85148 11A of the 6(3A) of order /2016 the generati the was in before Excise on of Cenvat favour the Act, steam Credit of the Hon'ble which is Rules, compan CESTA general 2004 y T, in Mumbai nature i.e. from which demand is propose d by the Departm ent issuing a SCN.
Thus, the section is invoked for alleged contrave ntion of the provisio ns of the Excise Act.
Therefor e, it can Page 18 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined be said that the Compan y has not been issued SCN for penalisa tion of any offences under Section 9 of the Excise Act.
5 PUNE- Service ITC Section Rule Appeal That EXCUS-001- Tax availabl 73(1) of 15(3) of is these APP- (Financ e in the the the CC pending SCNs 0041/2019- e Act, ISD Finance Rules, before have 20 1994) ledger Act, 2004 CESTA invoked was not 1994 read T, Section reported read with Mumbai 73 of in the with Section the ST-3 Rule 14 78(1) of Finance Return of the the Act, CCR, Finance 1994, 2004 Act, which is and 1994 general 174(2) in of the Rule nature CGST 15(3) of i.e., Act, the CC from 2017 Rules, which 2004 demand read is with propose section d by the 78(1) of Departm the ent by Finance issuing Act, SCNs.
1994 is Futher,
a penalty
penalty has
for been
Page 19 of 26
Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025
NEUTRAL CITATION
C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025
undefined
contrave imposed
ntion, under
not an Rule 15
offence of the
6 VADEXCUS Service ITC Section Rule Appeal Cenvat
Credit
-002 APP- Tax denial in 73 of 15(2) of is
208-2020-21 (Financ regard Finance the CC pending Rules,
dated e Act, to the Act, Rules, before 2004.
25.02.2021 1994) setting 1994 2004 CESTA Thus,
the
up of read read T,
the with with Ahmeda Section
and
compan Rule Section bad
Rules
y's plant 14(1)(ii) 11AC of have of the the been Cenvat Central invoked Credit Excise for Rules, Act, alleged 2004 contrave Rule ntion of 15(2) of the the CC provisio Rules, ns of the 2004 Finance read Act, with 1994.
section Therefor 11AC of e, it can the Central be said that the Excise Compan Act, is a y has penalty not for been contrave issued ntion, the not an SCNs offence for 7 PUN- Service Admissi Section Rule Departm penalisa EXCUS-003- Tax bility of 73 read 15(3) of ent has tion of COM-029- (Financ Cenvat with the CC filed an any 13-14 dated e Act, credit on Rule 14 Rules, Appeal offences 29 Nov 2103 1994) input of CC 2004 No,.203 under services Rules, read of 2019 Section and 2004 with before 89 of capital Section the the goods 78 of Hon'ble Finance Page 20 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined used for the Bombay Act, construc Finance High 1994.
tion and Act, Court
operatio 1994
n of the
mall Section
77(1)(c)
of the
Finance
Act,
1994
Rule
15(3) of
the CC
Rules,
2004
read
with
section
78 of
the
Finance
Act,
1994 is
a
penalty
for
contrave
ntion,
not an
offence
7.9 A perusal of Column No(6) of the aforesaid table makes it amply clear that the penalty proposed/imposed in all the above matters, is only for contravention of general provisions of the respective Acts and none of the matters involve any proposal/imposition of "penalty for offences."
Page 21 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined
21. Similarly, none of the offences as per the provisions of the Central Excise Act as well as Service Tax Act or GST Act are pending against the petitioner.
22. It appears that the respondents have failed to consider the offences under various indirect taxes Act and mixed up with the concept of contravention or breach of any of the provisions of the Act with the offences as enumerated in various Acts. Therefore, merely because the litigation is pending for any contravention of any of the provisions of the Act, same cannot be considered as an offence and there is a distinction between the "contravention" and "offence" of the Act which can be distinguished as under.
23. As per Black's Law Dictionary, Page 22 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined "offence" is defined in context of crime or criminal offence being a violation of law as under:
"offense (ə-fents). 1. A violation of the law; a crime, often a minor one. See CRIME. Also termed criminal offense. [Cases: Criminal Law 1. C.J.S. Affray §§ 2-12; Criminal Law §§ 2-8, 13.] "The terms 'crime,' 'offense,' and 'criminal offense' are all said to be synonymous, and ordinarily used interchangeably. 'Offense' may comprehend every crime and misdemeanor, or may be used in a specific sense as synonymous with 'felony' or with 'misdemeanor,' as the case may be, or as signifying a crime of lesser grade, or an act not indictable, but punishable summarily or by the forfeiture of a penalty." 22 C.J.S. Criminal Law § 3, at 4 (1989)."
24. The word "contravention" is from the word controvert and as per Black's Law Dictionary word "controvert" is defined as under:
"Controvert - To dispute or contest Page 23 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined esp to deny (as an allegation in a pleading) or oppose in argument the allegations in Peck's pleadings were never adequately controverted"
25. Therefore, contravention is nothing but disputing or denying or opposing the claim or eligibility of the petitioner under the provisions of various Acts.
26. Therefore, considering the litigations pending against the petitioner in the appellate forum, none of the provisions can be said to be an offence which can be considered falling under clause(c) of para 3(2) of the Regulation.
27. It is also pertinent to note that the petitioner or any of the officers, director etc. of the petitioner has never been penalised for an offence under the Act as the same is not even disputed by Page 24 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined the respondents by invoking the provisions of said para 3(2)(c) of the Regulation.
The respondents in both the occasions i.e. while rejecting the applications dated 06.02.2025 and 12.03.2025 has only referred to the provisions of para 3(2)(c) of the Regulations referring that there are three cases pending against the petitioner under the Customs Act and 9 cases under other Acts i.e. Central Excise Act and GST Act without considering as none of the cases are pending for penalising the petitioner or any officer of the petitioner company for the offences under the Customs Act 1962 and other Acts.
28. In view of the foregoing reasons, the petition succeeds and is accordingly allowed. The impugned orders are hereby quashed and set aside. The respondents are Page 25 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025 NEUTRAL CITATION C/SCA/3828/2025 JUDGMENT DATED: 03/04/2025 undefined directed to issue the license under the provisions of the Regulation as prayed for by the petitioner if further conditions are fulfilled except para 3(2)(c) of the Regulation. Such exercise shall be completed within a period of two weeks from the date of receipt of a copy of this order
29. Rule is made absolute to the aforesaid extent. No order as to costs.
Direct service is permitted.
(BHARGAV D. KARIA, J) (D.N.RAY,J) RAGHUNATH R NAIR Page 26 of 26 Uploaded by RAGHUNATH R NAIR(HC00196) on Thu May 01 2025 Downloaded on : Fri May 02 22:11:10 IST 2025