Janasakthi vs The State Of Kerala

Citation : 2021 Latest Caselaw 488 Ker
Judgement Date : 7 January, 2021

Kerala High Court
Janasakthi vs The State Of Kerala on 7 January, 2021
               IN THE HIGH COURT OF KERALA AT ERNAKULAM

                               PRESENT

          THE HONOURABLE THE CHIEF JUSTICE MR.S.MANIKUMAR

                                  &

               THE HONOURABLE MR. JUSTICE SHAJI P.CHALY

    THURSDAY, THE 07TH DAY OF JANUARY 2021 / 17TH POUSHA, 1942

                      WP(C).No.30113 OF 2018(S)


PETITIONERS:

      1        JANASAKTHI, IDUKKI UNIT,
               REP. BY A.P.MATHEW, UNIT PRESIDENT,
               AYATHUPADATH HOUSE, IDUKKI COLNY P.O.,
               THANNIKANDAM, IDUKKI DISTRICT,PIN- 685 602.

      2        P.L.BENNY,
               SECRETARY, JANASAKTHI, IDUKKI UNIT, POONTHURYTHIL
               HOUSE, IDUKKI COLNY, P.O.IDUKKI DISTRICT,
               PIN-685 602.

               BY ADVS.
               S.K. MURALEEDHARA KAIMAL
               A.K.MADHAVAN UNNI

RESPONDENTS:

      1        THE STATE OF KERALA
               REP. BY THE CHIEF SECRETARY AND CHAIRMAN,
               KERALA STATE DISASTER MANAGEMENT AUTHORITY,
               GOVERNMENT SECRETARIAT,
               THIRUVANANTHAPURAM-695 001.

      2        THE DISTRICT COLLECTOR IDUKKI AND CHAIRMAN IDUKKI
               DISASTER MANAGEMENT AUTHORITY,
               PAINAVU [PO]PIN-685 602.

      3        THE TOWN PLANNER, IDUKKI,
               VANCHIKAVALA ROAD, VANCHJIKKAVALA, CHERUTHONI,
               KERALA-685 602.

      4        THE SECRETARY, DISTRICT PANCHAYATH,
               IDUKKI PAINAVU(P.O.), PIN-685 602.

      5        THE SECRETARY, VAZHATHOPE GRAMA PANCHAYATH,
               THADIYANPADU(P.O.), IDUKKI DISTRICT, PIN-685 602.
 WP(C).No.30113 OF 2018(S)         2



      6      THE TAHSILDAR, IDUKKI TALUK,
             PAINAVU(P.O.), PIN-685 602.

      7      PARATHODU ANTONY,
             STONAGE TORIST COMPLEX, RESIDING AT MAYPPAN HOUSE,
             CHERUTONI, IDUKKI COLNY P.O., IDUKKI DISTRICT,
             PIN-685 602.

      8      MUMTAZ BASHEER,
             AKKOTHU HOUSE, CHERUTONI, IDUKKI COLNY P.O.,
             IDUKKI DISTRICT, PIN-685 602.

      9      K.P.M.BASHEER,
             KONNAMKUDIYIL HOUSE, CHERUTONI, IDUKKI COLNY P.O.,
             IDUKKI DISTRICT, PIN-686 602.

      10     BAPPU OOMMER,
             ALIAKKUNNEL HOUSE, CHERUTONI, IDUKKI COLNY P.O.,
             IDUKKI DISTRICT, PIN-685 602.

      11     A.P.USMAN,
             ARIMBASSERYIL HOUSE, CHERUTONI, IDUKKI COLNY P.O.,
             IDUKKI DISTRICT, PIN-685 602.

      12     VYAPARI VYAVASAYI EKOPANA SAMITHY,
             CHERUTONI, IDUKKI, REPRESENTED BY ITS SECRETARY,
             IDUKKI COLNY P.O., PIN-685 602.

      13     ADDL.R13 IDUKKI DISTRICT RESIDENTIAL AND COMMERCIAL
             BUILDING OWNERS ASSOCIATION
             CHERUTHONY, REPRESENTED BY ITS SECRETARY, IDUKKI
             COLONY POST, IDUKKI DISTRICT-685602.
             (ADDL.R13 IS IMPLEADED AS PER ORDER DATED
             08/11/2018 IN IA.01/2018)

      14     ADDL.R14 THE KERALA STATE ELECTRICITY BOARD
             VYDHYUDHI BHAVANAM, PATTOM,
             THIRUVANANTHAPURAM-695004, REPRESENTED BY ITS
             CHAIRMAN. (ADDL.R14 IS SUO MOTU IMPLEADED AS PER
             ORDER DATED 22/11/2018)



             SRI.K.V.SOHAN, STATE ATTORNEY FOR R1 TO R3 AND R6,
             SRI.UNNIKRISHNAN V. ALAPPAT FOR R4,
             SRI. JIMMY GEORGE (THADATHIL) FOR R5,
             SMT. SUMATHY DANDAPANI(SR) FOR R7,
             SRI.TERRY V.JAMES FOR R8,
             SRI. N.RAMESH CHANDER FOR R10,
 WP(C).No.30113 OF 2018(S)         3



             SRI.SANTHEEP ANKARATH FOR R11
             SRI.A SHAFEEK (KAYAMKULAM) FOR R12
             SRI.P.K.RAVISANKAR FOR R13
             SRI.JACOB P. ALEX, AMICUS CURIAE.
             SRI.N.KRISHNAPRASAD FOR R14

     THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
07.01.2021, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
 WP(C).No.30113 OF 2018(S)                     4




                                   JUDGMENT

SHAJI P.CHALY,J.

This writ petition is filed as a Public Interest Litigation by an unregistered association viz., Janasakthi Idukki Unit, represented by its unit President A.P.Mathew and an individual claims to be the Secretary of the said association seeking the following reliefs:

1.To issue a writ of mandamus, direction or order commanding respondents 1 to 6 to ensure that No person shall erect or re-erect any building within construction free zone Area under Idukki Township Area Development scheme.
2.To prohibit respondents 3 and 5 from issuing any building permits for erection or re- erection of any construction within the construction free zone area under Idukki Township Area Development scheme.
3. To prohibit respondents 7 to 12 from erecting or re-erecting any structures or buildings within the construction free zone area under Idukki Township Area Development scheme.
4. To direct the 5th respondent to take all necessary immediate action for demolition and removal of all unauthorised constructions including flood damaged building remains within the construction free zone area under Idukki Township Area Development scheme.
5.To pass such other interim and consequential orders
2. Brief material facts for the disposal of the writ petition are as follows;

Petitioners are permanent residents of Idukki Village. According to them, they WP(C).No.30113 OF 2018(S) 5 are Members of Janasakthi, a social welfare organization; respondents 7 to 11 are owners and occupants of some buildings in Cheruthony Idukki district and they are interested persons as they are owners and occupants of unauthorised constructions within a prohibited construction free zone in Idukki.

3. According to the petitioners, as per Idukki Township Area Development Scheme, no person shall erect or re-erect any building within construction free zone in Idukki and the said scheme stood violated and more than 344 buildings have been constructed by different persons and organizations in the construction free zone. According to them, the 2018 August floods washed away many such unauthorised buildings partly and fully and the remaining of the collapsed and half collapsed 7 storied and 5 storied and other buildings stand near the river and roads posing danger to public, tourists and also animals. Attempts are now being made by respondents 7 to 10 and many others to reclaim the washed away shores of the Cheruthony River running at Cheruthoni town construction free zone area, as if they are mending the damages caused to the buildings in the flood of august 2018. The attempt, according to the petitioners, is to save their unauthorised constructions and expand holdings by encroaching the damaged river bed at Cheruthony Idukki. The Authorities failed to implement a Government approved scheme in its letter and spirit and in order to prevent violations and encroachment of river, in the interests of public, the petitioners filed this public interest writ petition before WP(C).No.30113 OF 2018(S) 6 this Court.

4. Counter affidavits are filed by the party respondents as well as Government refuting the contentions raised in the writ petition. It is contended by all that, the scheme envisaged by the State Government viz., Idukki Township Area Development Scheme, in exercise of the powers conferred by section 4 of the Travancore Town and Country Planning Act, 1120 r/w. Rule 12 of the Travancore Town and Country Planning Rules, 1953 dated 27.9.1980 was never notified by the State Government. Petitioners have not produced the copy of the scheme published by the State Government. However, the 13th respondent, viz., Idukki District Residential and Commercial Building Owners Association, Cheruthoni, Idukki District, has produced the scheme as Ext.R13(a).

5. We have heard Sri.A.K.Madhavanunni, learned counsel for petitioners, Sri.K.V.Sohan, learned State Attorney appeared for respondents 1, 3 and 6, Sri.Unnikrishnan V. Alappat, learned Standing Counsel appeared for respondent No.4, Sri.Jimmi George Thadathi, learned counsel, appeared for respondent No.5, Smt.Sumathy Dandapany, learned Senior counsel, appeared for respondent No.7, Sri.Terrry V. James, learned counsel, appeared for respondent No.8, Sri.M.Ramesh Chandra, learned Senior Counsel, appeared for respondent No.10, Sri.Santheep Ankarath, learned counsel, appeared for respondent No.11, Sri.A.Shafeek (Kayamkulam), learned counsel, appeared for respondent No.12, Sri.P.K.Ravishankar, learned counsel, appeared for respondent No.13 and WP(C).No.30113 OF 2018(S) 7 Sri.Jacob P. Alex, learned Amicus Curiae.

6. It is clear from the pleadings and the legal grounds raised by the writ petitioners that, the case is built upon Ext.R13(a) scheme of the State Government. In our considered opinion, if the scheme is not implemented by the State Government by notifying the same in the official gazette, petitioners are not entitled to get any reliefs as are sought for in the writ petition. We will come to the said aspect at a later point of time. Nowhere in the writ petition petitioners have stated that 1st petitioner is a registered association under any of the statutes in vogue in the State of Kerala. The 7 th respondent i.e., one Antony, owner of a building, has specifically taken a contention that the 1 st petitioner is not a registered association and therefore, no writ petition can be filed by the 1 st petitioner. Seventh respondent has also submitted that it is not stated anywhere in the writ petition, who are the members of the 1 st petitioner association and no court fee has paid on behalf of the members of the association, who are said to be the beneficiaries of the association on account of the filing of the writ petition.

7. It is the settled position in law that no writ petition can be maintained by an unregistered association and also without producing the list of the members of the association, who are also liable to pay court fees. Therefore, we are of the opinion that, 1st petitioner has no locus standi to file the public interest litigation.

8. Whatever that may be, the 2 nd petitioner is an individual, who claims WP(C).No.30113 OF 2018(S) 8 to be the Secretary of the 1st petitioner association and therefore, we are of the considered opinion that even though the 1 st petitioner is not a competent person, the 2nd petitioner being an individual is entitled to maintain the writ petition. We are not going into the rival contentions raised by the parties in the writ petition since the learned State Attorney has submitted before this Court that Ext.R13(a) scheme is not notified by the State Government in contemplation of the provisions of the scheme. However, learned counsel for petitioners submitted that a further notification of the scheme is not required since the explanatory note in Ext.R13(a) scheme makes it clear that it was notified. The relevant portion of the scheme reads thus:

       Government of Kerala                               Reg.No.KL/TV(N)/12
                     1980



                                         KERALA GAZETTE

                                         EXTRAORDINARY
                                     PUBLISHED BY AUTHORITY

__________________________________________________________________________________ . Vol.XXV] Trivandrum, Saturday, 27th September 1980 _____________________[No.710 5th Asvina 1902 __________________________________________________________________________________ GOVERNMENT OF KERALA Local Administration & Social Welfare (G) Department NOTIFICATION WP(C).No.30113 OF 2018(S) 9 G.O. (Ms) No. 240/80/LA&SWD. Dated, Trivandrum, 26th September 1930. S. R. O. No. 900/80:-- In exercise of the powers conferred by section 4 of the Travancore-Town and Country Planning Act; 1120 (Travancore Act XXI of 1120 ) read with rule 12 of the Travancore Town and Country Planning Rules, 1953, Government of Kerala hereby promulgate the Idukki Township Area Development Scheme, the same having been previously published as required by rule 11 of the Travancore Town and Country Planning Rules, 1953.

By order of the Governor, M. DANDAPANI, Special Secretary to Government.

Explanatory Note (This does not form part of the notification, but is intended to indicate its general purport) In the notification No. 303/76/LA&SWD dated 21-12-1976 published in the Gazette Extraordinary No.751 dated 31st December, 1976, Government constituted the Idukki Township Area Development Authority for the preparation of a scheme for the development of the Township area. The said Authority has prepared and submitted a scheme for the development of the area for approval. Government have published the scheme for the information of persons likely to be affected thereby. They have now approved the scheme. It has to be published in the Gazette as required under the provisions of the Travancore Town and Country Planning Act, 1120. This notification is intended to achieve the above purpose.

THE IDUKKI TOWNSHIP AREA DEVELOPMENT SCHEME

1. Short title and commencement.--(a) This scheme may be called as the "Idukki Township Area Development Scheme.

(b) It shall come into force with effect from a date to be announced later by Government."

9. On a reading of the explanatory note, it is clear that the scheme was published for the information of persons likely to be affected thereby and it was accordingly published in the gazette. However, clause 1(b) of the scheme extracted above makes it clear that it shall come into force only with effect from the date to be announced later by the Government. The scheme is of the WP(C).No.30113 OF 2018(S) 10 year, 1980 and when the matter was taken up before this Court on 5 th February, 2020, the learned State Attorney submitted that the scheme was not notified. However, on that date the State was directed to file a counter affidavit. Anyhow when the matter came up before this Court on 6.1.2021, the learned State Attorney again submitted that the scheme is not yet notified by the State Government.

10. Taking into account the above said aspect, we are of the considered opinion that since the scheme has not yet come into force by issuing appropriate notification by the State Government in contemplation of the provisions of the scheme, petitioners are not entitled to get any reliefs as are sought for in the writ petition, due to the prime reason that, the entire pleadings made in the writ petition is dependent on the scheme and the mistaken impression that the scheme was implemented by the State Government.

Therefore, the writ petition has no sustenance, accordingly it is dismissed.

Sd/-

S.MANIKUMAR CHIEF JUSTICE This writ petition is filed as a Public Interest Litigation by an unregistered association viz., Janasakthi Idukki Unit, represented by its unit President A.P.Mathew and an individual claims to be the Secretary of the said association seeking the following reliefs: WP(C).No.30113 OF 2018(S) 11

1.To issue a writ of mandamus, direction or order commanding respondents 1 to 6 to ensure that No person shall erect or re-erect any building within construction free zone Area under Idukki Township Area Development scheme.
2.To prohibit respondents 3 and 5 from issuing any building permits for erection or re- erection of any construction within the construction free zone area under Idukki Township Area Development scheme.
3. To prohibit respondents 7 to 12 from erecting or re-erecting any structures or buildings within the construction free zone area under Idukki Township Area Development scheme.
4. To direct the 5th respondent to take all necessary immediate action for demolition and removal of all unauthorised constructions including flood damaged building remains within the construction free zone area under Idukki Township Area Development scheme.
5.To pass such other interim and consequential orders
2. Brief material facts for the disposal of the writ petition are as follows;

Petitioners are permanent residents of Idukki Village. According to them, they are Members of Janasakthi, a social welfare organization; respondents 7 to 11 are owners and occupants of some buildings in Cheruthony Idukki district and they are interested persons as they are owners and occupants of unauthorised constructions within a prohibited construction free zone in Idukki.

3. According to the petitioners, as per Idukki Township Area Development Scheme, no person shall erect or re-erect any building within construction free zone in Idukki and the said scheme stood violated and more than 344 buildings have been constructed by different persons and organizations in the WP(C).No.30113 OF 2018(S) 12 construction free zone. According to them, the 2018 August floods washed away many such unauthorised buildings partly and fully and the remaining of the collapsed and half collapsed 7 storied and 5 storied and other buildings stand near the river and roads posing danger to public, tourists and also animals. Attempts are now being made by respondents 7 to 10 and many others to reclaim the washed away shores of the Cheruthony River running at Cheruthoni town construction free zone area, as if they are mending the damages caused to the buildings in the flood of august 2018. The attempt, according to the petitioners, is to save their unauthorised constructions and expand holdings by encroaching the damaged river bed at Cheruthony Idukki. The Authorities failed to implement a Government approved scheme in its letter and spirit and in order to prevent violations and encroachment of river, in the interests of public, the petitioners filed this public interest writ petition before this Court.

4. Counter affidavits are filed by the party respondents as well as Government refuting the contentions raised in the writ petition. It is contended by all that, the scheme envisaged by the State Government viz., Idukki Township Area Development Scheme, in exercise of the powers conferred by section 4 of the Travancore Town and Country Planning Act, 1120 r/w. Rule 12 of the Travancore Town and Country Planning Rules, 1953 dated 27.9.1980 was never notified by the State Government. Petitioners have not produced the WP(C).No.30113 OF 2018(S) 13 copy of the scheme published by the State Government. However, the 13th respondent, viz., Idukki District Residential and Commercial Building Owners Association, Cheruthoni, Idukki District, has produced the scheme as Ext.R13(a).

5. We have heard Sri.A.K.Madhavanunni, learned counsel for petitioners, Sri.K.V.Sohan, learned State Attorney appeared for respondents 1, 3 and 6, Sri.Unnikrishnan V. Alappat, learned Standing Counsel appeared for respondent No.4, Sri.Jimmi George Thadathi, learned counsel, appeared for respondent No.5, Smt.Sumathy Dandapany, learned Senior counsel, appeared for respondent No.7, Sri.Terrry V. James, learned counsel, appeared for respondent No.8, Sri.M.Ramesh Chandra, learned Senior Counsel, appeared for respondent No.10, Sri.Santheep Ankarath, learned counsel, appeared for respondent No.11, Sri.A.Shafeek (Kayamkulam), learned counsel, appeared for respondent No.12, Sri.P.K.Ravishankar, learned counsel, appeared for respondent No.13 and Sri.Jacob P. Alex, learned Amicus Curiae.

6. It is clear from the pleadings and the legal grounds raised by the writ petitioners that, the case is built upon Ext.R13(a) scheme of the State Government. In our considered opinion, if the scheme is not implemented by the State Government by notifying the same in the official gazette, petitioners are not entitled to get any reliefs as are sought for in the writ petition. We will come to the said aspect at a later point of time. Nowhere in the writ petition petitioners have stated that 1st petitioner is a registered association under any of WP(C).No.30113 OF 2018(S) 14 the statutes in vogue in the State of Kerala. The 7 th respondent i.e., one Antony, owner of a building, has specifically taken a contention that the 1 st petitioner is not a registered association and therefore, no writ petition can be filed by the 1 st petitioner. Seventh respondent has also submitted that it is not stated anywhere in the writ petition, who are the members of the 1 st petitioner association and no court fee has paid on behalf of the members of the association, who are said to be the beneficiaries of the association on account of the filing of the writ petition.

7. It is the settled position in law that no writ petition can be maintained by an unregistered association and also without producing the list of the members of the association, who are also liable to pay court fees. Therefore, we are of the opinion that, 1st petitioner has no locus standi to file the public interest litigation.

8. Whatever that may be, the 2 nd petitioner is an individual, who claims to be the Secretary of the 1st petitioner association and therefore, we are of the considered opinion that even though the 1 st petitioner is not a competent person, the 2nd petitioner being an individual is entitled to maintain the writ petition. We are not going into the rival contentions raised by the parties in the writ petition since the learned State Attorney has submitted before this Court that Ext.R13(a) scheme is not notified by the State Government in contemplation of the provisions of the scheme. However, learned counsel for petitioners submitted that a further notification of the scheme is not required WP(C).No.30113 OF 2018(S) 15 since the explanatory note in Ext.R13(a) scheme makes it clear that it was notified. The relevant portion of the scheme reads thus:

       Government of Kerala                                        Reg.No.KL/TV(N)/12
                     1980



                                             KERALA GAZETTE

                                         EXTRAORDINARY
                                     PUBLISHED BY AUTHORITY

__________________________________________________________________________________ . Vol.XXV] Trivandrum, Saturday, 27th September 1980 _____________________[No.710 5th Asvina 1902 __________________________________________________________________________________ GOVERNMENT OF KERALA Local Administration & Social Welfare (G) Department NOTIFICATION G.O. (Ms) No. 240/80/LA&SWD. Dated, Trivandrum, 26th September 1930. S. R. O. No. 900/80:-- In exercise of the powers conferred by section 4 of the Travancore-Town and Country Planning Act; 1120 (Travancore Act XXI of 1120 ) read with rule 12 of the Travancore Town and Country Planning Rules, 1953, Government of Kerala hereby promulgate the Idukki Township Area Development Scheme, the same having been previously published as required by rule 11 of the Travancore Town and Country Planning Rules, 1953.

By order of the Governor, M. DANDAPANI, Special Secretary to Government.

Explanatory Note (This does not form part of the notification, but is intended to indicate its general purport) In the notification No. 303/76/LA&SWD dated 21-12-1976 published in the Gazette Extraordinary No.751 dated 31st December, 1976, Government constituted the Idukki Township Area WP(C).No.30113 OF 2018(S) 16 Development Authority for the preparation of a scheme for the development of the Township area. The said Authority has prepared and submitted a scheme for the development of the area for approval. Government have published the scheme for the information of persons likely to be affected thereby. They have now approved the scheme. It has to be published in the Gazette as required under the provisions of the Travancore Town and Country Planning Act, 1120. This notification is intended to achieve the above purpose.

THE IDUKKI TOWNSHIP AREA DEVELOPMENT SCHEME

1. Short title and commencement.--(a) This scheme may be called as the "Idukki Township Area Development Scheme.

(b) It shall come into force with effect from a date to be announced later by Government."

9. On a reading of the explanatory note, it is clear that the scheme was published for the information of persons likely to be affected thereby and it was accordingly published in the gazette. However, clause 1(b) of the scheme extracted above makes it clear that it shall come into force only with effect from the date to be announced later by the Government. The scheme is of the year, 1980 and when the matter was taken up before this Court on 5 th February, 2020, the learned State Attorney submitted that the scheme was not notified. However, on that date the State was directed to file a counter affidavit. Anyhow when the matter came up before this Court on 6.1.2021, the learned State Attorney again submitted that the scheme is not yet notified by the State Government.

10. Taking into account the above said aspect, we are of the considered opinion that since the scheme has not yet come into force by issuing appropriate notification by the State Government in contemplation of the provisions of the scheme, petitioners are not entitled to get any reliefs as are WP(C).No.30113 OF 2018(S) 17 sought for in the writ petition, due to the prime reason that, the entire pleadings made in the writ petition is dependent on the scheme and the mistaken impression that the scheme was implemented by the State Government.

Therefore, the writ petition has no sustenance, accordingly it is dismissed.

Sd/-

S.MANIKUMAR CHIEF JUSTICE Sd/-

SHAJI P.CHALY JUDGE WP(C).No.30113 OF 2018(S) 18 APPENDIX PETITIONER'S EXHIBITS:

EXHIBIT P1           A TRUE PHOTOSTAT COPY OF THE REPORT OF
                     INSPECTOR GENERAL OF POLICE, INTERNAL
                     SECURITY, SBCID, THIRUVANANTHAPURAM FILED
                     BEFORE THE LOKAYUKTHA, KERALA.

EXHIBIT P2           A TRUE PHOTOSTAT COPY OF ORDER OF THE
                     CHAIRMAN, DISTRICT DISASTER MANAGEMENT
                     AUTHORITY.

EXHIBIT P3           A TRUE PHOTOSTAT COPY OF THE LETTER OF THE
                     KERALA DAM SAFETY AUTHORITY WROTE TO THE
                     DISTRICT COLLECTOR, IDUKKI.

RESPONDENT'S EXHIBITS:

EXHIBIT R7(a)        TRUE COPY OF THE GAZETTE NOTIFICATION G.O.
                     (MS)NO.240/80/LA&SWD DTD.26.09.1980

EXHIBIT R7(b)        TRUE COPY OF THE MAP OF THE COUNTER
                     AFFIDAVIT FILED BY THE 2ND RESPONDENT -
                     SECRETARY, VAZHATHOPPU GRAMA PANCHAYATH
                     WITHOUT ITS EXHIBITS IN W.P.(C)
                     NO.32317/2011.
EXHIBIT R7(c)        TRUE COPY OF THE JUDGMENT DTD.3.12.2008 IN
                     W.P.(C) NO.32434 OF 2008.
EXHIBIT R7(d)        TRUE COPY OF THE BUILDING PERMIT
                     DTD.26.2.2007 ISSUED BY THE SECRETARY.
EXHIBIT R7(e)        TRUE COPY OF THE JUDGMENT DTD.1.4.2009 IN
                     W.P.(C) NO.8025/2009.

EXHIBIT R8(a)        TRUE COPY OF   THE BUILDING PERMIT NO.B1-
                     247/17 DATED   17.1.2018 GRANTED BY THE 6TH
                     RESPONDENT
EXHIBIT R8(b)        TRUE COPY OF   THE PHOTOGRAPH OF THE 8TH
                     RESPONDENT'S   BUILDING AT CHERUTHONI TOWN

EXHIBIT R7(f)        TRUE COPY OF THE PHOTOGRAPHS WHICH SHOWS
                     THE LEVEL OF THE CONSTRUCTION CARRIED OUT
                     BY THIS RESPONDENT.
EXHIBIT R13(a)       TRUE COPY OF THE MAP OF THE IDUKKI TOWNSHIP
                     AREA DEVELOPMENT SCHEME PUBLISHED AS GO(MS)
                     NO.240/80/LA&SWD DATED 26.9.1980.

EXHIBIT R13(b)       TRUE COPY OF G.O.MS.NO.303/76/LA&SWD DATED
                     21.12.1976.
 WP(C).No.30113 OF 2018(S)        19




EXHIBIT R13(c)       TRUE PHOTOGRAPH OF CHERUTHONI TOWN AS ON
                     11.11.2018.
EXHIBIT R14(a)       TRUE COPY OF THE BUILDING PERMIT NO.B1-
                     4056/17 DATED 29.7.2017.

EXHIBIT R14(b)       TRUE COPY OF THE MAP OF THE IDUKKI TOWNSHIP
                     AREA DEVELOPMENT SCHEME PUBLISHED AS PER
                     GO(MS) NO.240/80/LSGD DATED 26.9.1980.