Kerala High Court
Sudha Sasikumar vs The Regional Transport Authority on 18 July, 2025
2025:KER:53342
WP(C).19863 OF 2025 1
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE MOHAMMED NIAS C.P.
FRIDAY, THE 18TH DAY OF JULY 2025 / 27TH ASHADHA, 1947
WP(C) NO. 19863 OF 2025
PETITIONER/S:
SUDHA SASIKUMAR,
AGED 55 YEARS,W/O SASIKUMAR, BALAKRISHNA MOTORS,
GURUVAYOOR, THRISSUR, PIN - 680101
BY ADVS.
SRI. P. DEEPAK (SR.)
SRI.RILGIN V.GEORGE
SRI.K.T.RAVEENDRAN
SMT.AKSHARA K.P.
SMT.MEERA J. MENON
SMT.ARATHY P.S.
SMT.ANAGHA MANOJ
RESPONDENT/S:
1 THE REGIONAL TRANSPORT AUTHORITY,
PALAKKAD, REPRESENTED BY ITS SECRETARY, REGIONAL
TRANSPORT OFFICE, PALAKKAD, PIN - 678001
2 THE SECRETARY,
REGIONAL TRANSPORT AUTHORITY, PALAKKAD, REGIONAL
TRANSPORT OFFICE, PALAKKAD, PIN - 678001
3 SABU VARGHESE,
AGED 35 YEARS,S/O.VARGHESE, CHERAVATTOM HOUSE, MANGADU
P.O., PAZHANJI, THRISSUR, PIN - 680542
4 P.V.RAMAKRISHNAN,
S/O.VELAYUDHAN, PADIYANKATTIL HOUSE, KUNDANNOOR P.O.,
2025:KER:53342
WP(C).19863 OF 2025 2
KUMBALANGAD, VADAKKANCHERRY, THRISSUR, PIN - 680590
5 NISHAD K.K.,
S/O KASIM, KODAMANATH HOUSE, AYYAPPESAN PADY, PAINKULAN
P.O, THRISSUR, PIN - 679531
6 C.A.ABRAHAM,
AGED 71 YEARS S/O.ABRAHAM, 612, MAYOORAM, MAYILVAHANAM,
SHORNUR, PALAKKAD DISTRICT, PIN - 679121
SRI. V.S. SREEJITH, GOVT. PLEADER FOR R1 AND R2
ADV SRI.K.V.GOPINATHAN NAIR FOR R3 TO R6
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
07.07.2025, THE COURT ON 18.07.2025 DELIVERED THE FOLLOWING:
2025:KER:53342
WP(C).19863 OF 2025 3
MOHAMMED NIAS C.P., J.
......................................................
W.P(C) No.19863 of 2025
.............................................................
Dated this the 18th day of July, 2025
JUDGMENT
Petitioner is aggrieved by Ext.P13 decision of the Regional Transport Authority, Palakkad, which declined her request for renewal of Ext.P2 stage carriage permit granted on 17.06.2011, in the curtailed route Palakkad-Pattambi.
2. The facts of the case, in brief, are as follows:-
The petitioner had submitted an application on 10.10.2005 for the grant of a regular stage carriage permit on the interregional (interdistrict) route Guruvayur-Palakkad in respect of her stage carriage bearing Registration No. KL-8-AJ-9550. Since the route traversed the districts of Thrissur and Palakkad, the application was submitted to the Regional Transport Authority, Palakkad, as a major portion of the proposed route lies within the Palakkad district. By an order dated 25.05.2006, the aforementioned application for regular permit was sanctioned subject to 2025:KER:53342 WP(C).19863 OF 2025 4 counter signature of RTA, Thrissur and thereafter, by the proceedings of the Secretary, RTA, Palakkad, dated 20.06.2006 regular permit valid for five years from 20.6.2006 to 19.06.2011 was issued to the petitioner, as seen from Ext.P1, subject to counter signature of RTA, Thrissur. Ext.P2 is a true copy of the regular permit valid till 19.06.2011 issued concerning the vehicle in question.
3. Upon the issuance of Ext.P2 permit on 20.06.2006, the operation of the stage carriage commenced on the route Pattambi - Palakkad on the strength of the time schedule approved in Ext.P1 proceedings as the operation of the stage carriage service on the strength of Ext.P2 was confined to Palakkad District alone since the permit was granted subject to the counter signature of RTA, Thrissur. The application for counter signature was rejected by RTA, Thrissur, as by then the approved scheme of nationalisation had come into force, whereby a portion of the route spanning 19 Kms lying within the jurisdiction of RTA, Thrissur, was notified under the said scheme. The petitioner unsuccessfully challenged the rejection by RTA, Thrissur and Ext.P3 is the judgment in W.A. No.712 2007 dated 29.01.2009. In view of the above, the stage carriage operated in the sector Pattambi - Palakkad 2025:KER:53342 WP(C).19863 OF 2025 5 for the full duration of the permit within the jurisdiction of RTA, Palakkad.
4. Thereafter though the petitioner had filed an application for renewal of Ext.P2 permit for a further period of five years, the RTA, Palakkad rejected the said application by order dated 29.07.2011 on the ground that the petitioner is seeking renewal of the permit on the entire route namely Guruvayur - Palakkad by including the portions of notified route falling within the jurisdiction of RTA, Thrissur. In other words, the RTA, Palakkad, found the petitioner's application to be not maintainable, as a valid permit for operation throughout the route was required, whereas the permit in the instant case was not a valid permit for operating on the entire route. The decision of the RTA, Palakkad, was challenged in a statutory appeal in MVAA No.515/2011, wherein by judgment dated 24.07.2004, the Tribunal set aside the decision of the RTA, Palakkad and directed reconsideration of the application for renewal on the route Palakkad - Pattambi through Ext.P4 judgment. The said judgment had become final in the absence of a challenge.
5. Pursuant to the said direction, the RTA, Palakkad, through Ext.P5 proceedings dated 24.10.2014, directed the Secretary, RTA, to 2025:KER:53342 WP(C).19863 OF 2025 6 obtain from the petitioner a fresh application for renewal of permit on the curtailed route Palakkad - Pattambi. The petitioner had also submitted Ext.P6 representation/undertaking to the Secretary, RTA on 02.06.2015 stating that the STAT had, through Ext.P4 judgment, directed a reconsideration of the renewal application on the curtailed route Palakkad - Pattambi. The petitioner gave up all other claims and confined her claims for renewal of the permit to the curtailed route alone, relinquishing all claims to the original route, Guruvayur - Palakkad. The petitioner thereafter filed W.P(C) No.33910/2014 producing Ext.P5 decision of the RTA, Palakkad and Ext.P6 representation submitted by the petitioner, and this Court by judgment dated 29.09.2015 directed the first respondent to consider the application treating the same as one for renewal of the existing permit on the modified route, through Ext.P7 judgment. Since no decision has been taken despite the directions of this Court, the petitioner again filed W.P(C) No.28037/2019, which was disposed of by the judgment dated 25.10.2019 directing RTA, Palakkad to decide on the application for renewal of permit on the modified curtailed route Palakkad - Pattambi in the light of Ext.P7 judgment.
6. The RTA, Palakkad, again rejected the renewal application, 2025:KER:53342 WP(C).19863 OF 2025 7 reiterating the very same grounds in the first order dated 29.07.2011, which was again set aside by the STAT in MVAA No.315/2011 through Ext.P9 proceedings. Ext.P9 also stated that the renewal of the permit can be considered only for the original route, namely Guruvayur - Palakkad and, therefore, where the renewal of the existing permit to curtail the area or route covered by the permit was not possible. Yet another reason stated to reject the request of the petitioner was that the stage carriage attached to Ext.P2 permit was issued with a clearance certificate on 12.10.2012 and was no longer attached to Ext.P2 permit. The said decision of the RTA was again challenged in a statutory appeal, MVAA 39/2020, which by Ext.P10 judgment dated 05.06.2020 found that the reasoning of RTA, Palakkad that the renewal application can be considered only for the original route cannot be sustained and that the denial of application for counter signature by the sister RTA does not invalidate the operation of the stage carriage within the jurisdiction of the primary authority. Accordingly, the STAT directed the RTA, Palakkad, to reconsider the application for renewal on the modified route Palakkad-Pattambi on merits and pass orders within two months.
7. Respondents 3 to 6, who are the existing operators and other 2025:KER:53342 WP(C).19863 OF 2025 8 rivals, filed W.P. (C) Nos. 14847/2020 and 15810/2020, which were dismissed by a common judgment dated 04.01.2021, as seen from Ext.P11. The learned Single Judge gave reasons as to why the petitioner's application had to be reconsidered, despite the contention of the contesting respondents that the petitioner did not file an application for the curtailing of the route. Ext.P11 judgment of the learned Single Judge was challenged by filing W.A. Nos 146/2021 and 153/2021, which were disposed of by a common judgment dated 05.09.2024, directing consideration of the maintainability of the application, as well, filed by the petitioner for renewal of the permit. The matter was again reconsidered by RTA, Palakkad, in its meeting dated 11.03.2025 and through Ext.P13 impugned order, the application was again rejected, finding that the same to be not maintainable.
8. No counter has been filed on behalf of the Government.
9. A counter affidavit has been filed on behalf of respondents 3 and 5, stating that the petitioner has an alternate remedy before the State Transport Appellate Tribunal. It is also contended that as per the request of the petitioner, the first respondent had granted a regular permit to operate services on the route Palakkad - Guruvayur via Kulappully, 2025:KER:53342 WP(C).19863 OF 2025 9 Pattambi, Ottappilavu and Kunnamkulam on 25.05.2006, which was issued on 20.06.2006, valid upto 19.06.2011. It is also stated that the petitioner operated on the entire route even without obtaining the counter signature of the authority and in violation of the conditions of the permit. Even after the rejection of the application for counter signature, the petitioner did not seek any modification of the route and continued illegal operation between Palakkad and Pattambi, having a distance of 59 Kms, though the permit is valid upto Ottappilavu, which is the district border, having a further distance of 14 Kms from Pattambi. It is also stated that the petitioner's application for renewal was beyond time.
10. It is also pleaded that since no statutory application for modifying the route was preferred by the petitioner, a request for renewal on the curtailed modified route on Palakkad - Pattambi was not maintainable, since no valid application for route modification by variation was filed in terms of the Act and the Rule, and therefore the application of the petitioner was rightly rejected through the order impugned. It is also stated that the vehicle was detached from the permit in 2012 itself, as evident from Ext.P9 and throughout there was no operation of the service on the permitted route, and the permit ceased to 2025:KER:53342 WP(C).19863 OF 2025 10 exist. Thus contending that the petitioner's application itself was not maintainable, the respondents prayed for dismissal of the writ petition.
11. Heard Sri.P. Deepak, learned Senior Counsel, instructed by Sri. Rilgin V. George, for the writ petitioner, Sri. K.V. Gopinathan Nair, learned counsel appearing for the contesting respondents and Sri. V.S. Sreejith, learned Government Pleader.
12. Sri. P. Deepak, the learned Senior Counsel for the petitioner, submits that the rejection through Ext.P13 is totally illegal and contrary to the earlier judgments passed by this Court, those of the Tribunal, as well as the orders of the transport authorities. It is also argued that what was directed to be considered by the STAT in Ext.P4 order of remand was a statutory application for renewal of permit on the entire route Guruvayur - Palakkad, as one in respect of the curtailed route Palakkad - Pattambi and the same was reiterated in Exts.P7 and P8 judgments. Ext.P6 representation/undertaking submitted by the petitioner only affirmed the petitioner's request to have the permit renewed in respect of the curtailed route Palakkad-Pattambi, which the RTA, Palakkad, was empowered to renew in exercise of the powers under Section 103(2) of the Motor Vehicles Act, even without any representation from the petitioner.
2025:KER:53342 WP(C).19863 OF 2025 11 It is submitted that the reasoning in Ext.P13 that the petitioner ought to have submitted a proper application for renewal of permit in the prescribed Form PRA and also applied for variation of conditions under Section 80(3) of the Act was wrong on the facts of the case. At no point in time did the official respondents contend about the maintainability of the application, nor had they taken the same as a ground, and it could not have been done given Ext.P5 whereby the petitioner was made to file an application which he complied with.
13. It is also argued that the curtailment of the route in the instant case was necessitated by the operation of law which occurred between the grant of the permit and the issuance. Referring to the provisions of the Act, in particular Section 103(2) and Section 72 of the Act, it is argued that the findings in Ext.P13 cannot stand the test of law. The second reason in Ext.P13 that there was no vehicle attached to the permit from 2012 to 2019 is equally wrong, as Ext.P2 permit was valid only till 19.06.2011, and there was no question of the permit "existing in vacuum without a vehicle attached to it" as stated in Ext.P13. He also relies on the judgments of the Hon'ble Supreme Court in Godrej Sara Lee Ltd. v. Excise and Taxation Officer - cum- Assessing Authority and 2025:KER:53342 WP(C).19863 OF 2025 12 Others [(2023) SCC OnLine SC 95], M/s. Bundelkhand Motor Transport Co. v. Behari Lal Chaurasia and Another (1966 KHC 450 SC), Abdul Gafoor, Proprietor, Shaheen Motor Service, Channaryaptna v. State of Mysore and Others [1961 KHC 735 SC] and of this Court in W.P(C) No.9012/2007, to support his contentions.
14. The learned counsel for the contesting respondent Sri. K.V. Gopinathan Nair, reiterating the contentions taken in the counter affidavit filed by them, argued that the writ petition is not maintainable because the petitioner has an alternate remedy. It is also submitted that the application was not maintainable and, therefore, the rejection under Ext. P13 is justified. It is also argued that even in Ext.P11 judgment, the learned single Judge of this Court had clearly found that the application preferred by the petitioner was not maintainable. He also relied on the judgment of this Court in Benny Mathew v. Alexander Joseph [2003 KHC 83].
15. Sri. Sreejith, the learned Government Pleader, also contended that the petitioner has an alternate remedy and that there was no valid application for curtailment of the route and sought to sustain the impugned order.
2025:KER:53342 WP(C).19863 OF 2025 13
16. On the argument that the petitioner has an alternate efficacious remedy, I am not inclined to accept the contention on behalf of the respondents, more so in the facts of the present case and that too after a series of directions binding on the Transport Authorities. Judicial review remains warranted in cases of perceived arbitrariness, regardless of contractual complexity or factual disputes. Article 226 does not, in terms, impose any limitation or restraint on the exercise of power to issue writs which turns on entertainability and not maintainability. Thus, the High Court will entertain petitions, especially when State agencies act arbitrarily or violate constitutional guarantees. The authority to issue writs under Article 226 is plenary, and limitations only arise where explicitly provided by the Constitution. Courts can, on occasion, assess disputed facts where justice demands, underscoring that the so-called "hands-off" approach is not absolute, but context-dependent. It is also to be noted that there is no disputed question of fact in this case and what is urged is an interpretation of the power under section 103(2) of the Motor Vehicles Act read with the other provisions, namely the power of the authority to grant a permit on a curtailed route as directed by the Court, the Tribunal and the authorities in the earlier instance.
2025:KER:53342 WP(C).19863 OF 2025 14
17. As regards the argument of the respondents that the petitioner could not have operated without complying with the conditions imposed in Ext P2 to obtain concurrence from RTA Thrissur, as held by the Supreme Court in M/s. Bundelkhand Motor Transport Co. v. Behari Lal Chaurasia and Another [1966 KHC 450], the permit granted by a competent authority for one region will not be valid in any other region unless the permit has been countersigned by the Regional Transport authority, but an inter regional permit when granted is valid for the region over which the authority granting the permit has jurisdiction and when it is countersigned by the Regional Transport Authority of the other region, the permit becomes valid for the entire route. Therefore, the contention that the permit has no validity, whatever, until it is countersigned by the Regional Transport Authority of the other region cannot be accepted.
18. As regards the judgment submitted by the learned counsel for the contesting respondents, viz: Benny Mathew v. Alexander Joseph [2003 KHC 83], the same also follows the principle in the judgment noticed above and had only held that a permit granted by one authority for operation of a vehicle within the region of another authority shall not 2025:KER:53342 WP(C).19863 OF 2025 15 be valid unless it is countersigned or prior concurrence has been obtained and in the facts of that case, though a permit was granted which was valid for operation within the region of RTA Kannur, it was not valid in the other regions because the permit was not countersigned by the authorities of the other regions. Under such circumstances, it was held that if a countersignature from the authority of a particular region is not obtained, it cannot be said that the permit is valid over that region, and thereby it is not a valid permit for operating on the entire route. This again is on the principle that an invalid permit cannot be renewed on the ground that a renewal application can be rejected only on the ground specified under Section 81(4) of the Act, as 81(4) can have application only when there is a valid permit submitted for renewal. The said judgment in no way goes against the case set up by the petitioner.
19. It is not in dispute that on 20.06.2006, the writ petitioner was issued with a regular permit for the interdistrict route Palakkad - Guruvayur, subject to the counter signature of the RTA, Thrissur and that since there was overlapping with the notified route, the RTA, Thrissur, refused counter signature. It is the petitioner's consistent case right from then that, consequent to the refusal, the stage carriage was operated 2025:KER:53342 WP(C).19863 OF 2025 16 between Palakkad and Pattambi. On the expiry of the permit on 19.06.2011, the petitioner's application for renewal was rejected by RTA, Palakkad, on the ground of refusal of counter signature by RTA, Thrissur, which was challenged in MVAA 315/2011, which was disposed of by directing the renewal application to be considered for the route Palakkad-Pattambi. Pursuant to the above direction, the RTA Palakkad had directed the petitioner to apply for renewal of the permit in the route Palakkad - Pattambi, which was complied with by the petitioner. On the directions of this Court in W.P(C) No.33910/2014, RTA was directed to consider the said application. Since no decision was taken, the petitioner again filed W.P(C) No.28037/2019, in which this Court again directed the authority to decide on the renewal application in the curtailed route.
20. The RTA decided on 24.12.2000, rejecting the application, which was again challenged in MVAA 39/2020, in which the appeal was allowed by orders dated 05.06.2020 and the RTA was again directed to reconsider the renewal application on the modified route Palakkad - Pattambi. Thus, it can be seen that it was based on the orders passed by the Tribunal and consequent to which the Transport Authorities had 2025:KER:53342 WP(C).19863 OF 2025 17 directed the petitioner to make an application in the Palakkad - Pattambi route which the petitioner applied and it was those applications which were directed to be considered by this Court in its judgment in W.P(C) No.33910/2014 and W.P(C) No.28037/2019. The rejection pursuant to the direction was again interfered with by the Tribunal directing a reconsideration of the renewal on the modified router Palakkad - Pattambi. The order of the STAT in MVAA 39/2020 was challenged by the contesting respondents by filing writ petitions 14847 and 15810 of 2020, which were dismissed notwithstanding the contention of the respondents that the proper remedy of the petitioner was to seek curtailment of the route and renewal on the curtailed/ modified route.
21. Though an appeal was carried against the judgment of the single Judge noticed above, in W.A.Nos.146/2021 and 153/2021, the Division Bench only directed the authority to consider the maintainability of the application while considering the question of renewal. The said judgment, in appeal, cannot be construed as one holding the renewal application to be not maintainable as the authority was directed to consider the same. For the reasons stated above, the application in the instant case was directed to be considered in the curtailed route and 2025:KER:53342 WP(C).19863 OF 2025 18 which has become final. That apart, there is no legal infirmity committed by the Transport Authorities in its meeting held on 25.10.2014, which directed the RTA Secretary to require the petitioner to apply for the curtailed route.
22. Reference can also be had to the provisions of Section 103 of the Motor Vehicles Act, which reads as follows:-
Section 103: Issue of permits to State transport undertakings.--
(1) Where, in pursuance of an approved scheme, any State transport undertaking applies in such manner as may be prescribed by the State Government in this behalf for a stage carriage permit or a goods carriage permit or a contract carriage permit in respect of a notified area or notified route, the State Transport Authority in any case where the said area or route lies in more than one region and the Regional Transport Authority in any other case shall issue such permit to the State transport undertaking, notwithstanding anything to the contrary contained in Chapter V. (2) For the purpose of giving effect to the approved scheme in respect of a notified area or notified route, the State Transport Authority or, as the case may be, the Regional Transport Authority concerned may, by order,--
(a) refuse to entertain any application for the grant or renewal of any other permit or reject any such application as may be pending;
(b) cancel any existing permit;
(c) modify the terms of any existing permit so as to--
2025:KER:53342 WP(C).19863 OF 2025 19
(i) render the permit ineffective beyond a specified date;
(ii) reduce the number of vehicles authorised to be used under the permit;
(iii) curtail the area or route covered by the permit in so far as such permit relates to the notified area or notified route.
23. A reading of Section 72 also shows that a grant of permit or a renewal can be with such modification as the authority deems fit, which enables the power to grant a permit on a curtailed/ shorter route in the route applied for. Thus, on the direction of the Transport Authorities, the petitioner had applied and which was permissible going by the relevant provisions of the Motor Vehicles Act mentioned above.
24. It is also to be noted that in the instant case, it was not the petitioner who wanted a change in the permit, but it was because of the operation of law that the petitioner had to limit the length of the route. In the first instance, concurrence was not received from the RTA, Thrissur, on account of the operation of law, which took place after the grant of permit and before the issuance, as a portion of the route was notified, which made it impossible for the petitioner to obtain concurrence as directed in Ext.P2 permit. The same being an impossibility created by the operation of law, this Court, the Tribunal and the Transport Authorities directed 2025:KER:53342 WP(C).19863 OF 2025 20 reconsideration on the curtailed route. It is also to be noticed that the petitioner has been seeking renewal from the year 2011, and after a series of litigations referred to above, to tell the petitioner in 2025 that her application was not maintainable, cannot be accepted factually or legally. Regarding the contention that the petitioner did not have a vehicle, it also cannot be a reason for not renewing the permit, as the law gives the petitioner time to produce the vehicle.
25. The contention of the contesting respondents that the petitioner ought to have conducted the service upto the district border cannot be accepted as no action was taken by the Transport Authorities alleging any violation of the permit conditions, during the currency of the operation of the stage carriage by the petitioner. It is surprising to note that the cancellation of the permit in the instant case is contrary to all decisions of the courts, the Tribunal and the authority to date.
Under such circumstances, I have no hesitation in holding that the rejection as per Ext. P13 is bad and contrary to the provisions of the Act. Accordingly, I am inclined to quash the impugned order and direct the official respondents to consider the renewal application submitted by the petitioner in the modified/curtailed route, Palakkad- Pattambi, in light of 2025:KER:53342 WP(C).19863 OF 2025 21 the findings/observations made above. Appropriate orders shall be passed in accordance with law, with notice to the parties, within one month from the date of receipt of a copy of the judgment.
The writ petition is allowed as above.
Sd/-
MOHAMMED NIAS C.P. JUDGE okb 2025:KER:53342 WP(C).19863 OF 2025 22 APPENDIX OF WP(C) 19863/2025 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE PROCEEDINGS OF THE 2ND RESPONDENT DATED 20.06.2006 Exhibit P2 TRUE COPY OF THE REGULAR PERMIT VALID TILL 19.06.2011 ISSUED TO KL-08-AJ-9550 Exhibit P3 A TRUE COPY OF THE JUDGMENT IN WA NO: 712 OF 2007 DATED 29.01.2009 Exhibit P4 A TRUE COPY OF THE JUDGMENT DATED 24.07.2014 IN MVAA NO: 315 OF 2011 Exhibit P5 A TRUE COPY OF THE DECISION OF THE RTA, PALAKKAD DATED 24.10.2014 Exhibit P6 TRUE COPY OF THE REPRESENTATION DATED 02.06.2015 Exhibit P7 TRUE COPY OF THE JUDGMENT DATED 29.09.2015 IN WPC NO: 33910 OF 2015 Exhibit P8 TRUE COPY OF THE JUDGMENT DATED 25.10.2019 IN WPC NO: 28037 OF 2019 Exhibit P9 A TRUE COPY OF THE DECISION OF THE RTA, PALAKKAD DATED 24.12.2019 Exhibit P10 A TRUE COPY OF THE JUDGMENT DATED 05.06.2020 IN MVAA NO: 39 OF 2020 Exhibit P11 TRUE COPY OF THE COMMON JUDGMENT DATED 04.01.2021 IN WPC NO: 14847 OF 2020 AND CONNECTED CASE Exhibit P12 A TRUE COPY OF THE COMMON JUDGMENT DATED 05.09.2024 IN WA NO: 146/2021 & CONNECTED CASE Exhibit P13 TRUE COPY OF THE PROCEEDINGS OF THE 1ST RESPONDENT DATED 11.03.2025 RESPONDENT EXHIBITS Exhibit R3(a) The true copy of the letter dated 1.6.2015 along with typed copy