Public Interest Protection ... vs State Of Kerala & Ors
2021 Latest Caselaw 3660 Ker

W.P.(C) No. 21045/2007                 :1:




                    IN THE HIGH COURT OF KERALA AT ERNAKULAM

                                     PRESENT

                THE HONOURABLE THE CHIEF JUSTICE MR.S.MANIKUMAR

                                        &

                     THE HONOURABLE MR. JUSTICE SHAJI P.CHALY

            TUESDAY, THE 02ND DAY OF FEBRUARY 2021 / 13TH MAGHA,1942

                            WP(C).No.21045 OF 2007(S)


PETITIONER/S:

                 PUBLIC INTEREST PROTECTION ASSOCIATION
                 REG.NO.1-7/84, MUNNAR, REPRESENTED BY ITS SECRETARY,
                 V.MOHANKUMAR, ENGAN HOUSE,, HRC ROAD, MUNNAR,
                 KERALA-685 612.

                 BY ADV. SRI.P.RAMAKRISHNAN

RESPONDENT/S:

        1        STATE OF KERALA & ORS.
                 REPRESENTED BY THE CHIEF SECRETARY,, GOVERNMENT SECRETARIAT,
                 THIRUVANANTHAPURAM.

        2        THE PRINCIPLE SECRETARY
                 DEPARTMENT OF REVENUE,, GOVERNMENT SECRETARIAT,,
                 THIRUVANANTHAPURAM.

        3        THE LAND BOARD,
                 THIRUVANANTHAPURAM.

        4        THE DISTRICT COLLECTOR,
                 IDUKKI.

        5        THE DIRECTOR
                 SURVEY AND LAND RECORDS DEPARTMENT,,
                 THIRUVANANTHAPURAM-695 014.
 W.P.(C) No. 21045/2007                  :2:


        6        ADDL. R6 R7 IMPLEADED:
                 KANNAN DEVAN HLLS PLANTATION CO.PVT. LTD,
                 KDHP HOUSE, MUNNAR-685 612, REPRESENTED BY ITS ASSISTANT
                 MANAGER (SIED) MR.C. SREEKUMAR.

                 IS IMPLEADED AS ADDITIONAL 6TH RESPONDENT AS PER ORDER DATED
                 20/09/2007 IN IA.12593/2007.

        7        TATA TEA LIMITED,
                 SPECIAL PROJECTS OFFICE, GENERAL HOSPITAL COMPLEX,
                 MUNNAR-685 612, REPRESENTED BY ITS MANAGER-ADMINISTRATION
                 MR.PRATAP RAMDAS.

                 [ADDL. R7 IMPLEADED AS PER ORDER DATED 20/09/2007 IN
                 IA.12436/2007.]

                 R1   TO R5 BY SRI. MOHAMMED ANZAR, SPL. GOVERNMENT PLEADER
                 R1   BY ADV. SRI.JOSEPH KODIANTHARA
                 R1   BY ADV. SRI.JOSEPH MARKOSE SR.
                 R1   BY ADV. SRI.MATHEWS K.UTHUPPACHAN

                 R6 & R7 BY SRI. ISAAC THOMAS

      THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 02.02.2021, THE
      COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
 W.P.(C) No. 21045/2007                 :3:


                     Dated this the 2nd day of February, 2021.

                                   JUDGMENT

SHAJI P. CHALY, J.

The petitioner Association, which is a Social Service Organisation

registered under the Travancore Cochin Literary, Scientific, Cultural and

Charitable Societies Registration Act, 1955, has filed this writ petition as a

Public Interest Litigation seeking the following reliefs:

1. Issue a writ of certiorari or other appropriate writ or order quashing

and setting aside Ext.P13.

2. Issue a writ of mandamus or other appropriate writ or order directing

respondents 1, 4 and 5 to carryout a land survey as envisaged under

Section 6 of the KDH (Resumption of Lands) Act, 1971 and demarcate

the boundaries of each parcel of land vested with the Government

under Section 3(1) and restored under Section 4 forthwith.

3. Issue a writ of mandamus or other appropriate writ or order directing

respondents 1 and 4 to assign land in KDH village as envisaged in

Section 9 of the KDH (Resumption of Lands) Act, 1971.

4. Issue a writ of mandamus or other appropriate writ or order directing

respondents 1 and 4 not to evict persons in possession of land prior to

21/1/1971 and those who have been possession certificates issued

under Ext.P6 and further regularise their possession by assignment of

land in their possession.

2. The basic contention is that Ext.P13 order issued by the State of

Kerala for the detection of bogus pattas and eviction of encroachers in

Kannan Devan Hills Village of Devikulam Taluk, is illegal and arbitrary.

According to the petitioner, such an exercise would be futile as the survey

records in respect of the Village dates back to nearly a hundred years. It is

submitted that no survey of the region, except in respect of the inter party

boundaries, had been conducted after independence. So also, it is submitted

that the State of Kerala had enacted Kannan Devan Hills (Resumption of

Lands) Act, 1971 ('Act, 1971' for short) more than 3 decades ago and as per

Ext. P1 award under Section 4 of the Act, the Land Board had decided the

extent of land that would vest with the Government, that would not be

vested with the Government and that would be restored to Kannan Devan

Hill Produce Company.

3. The grievance of the petitioner is that despite the mandate of

Section 6 of Act, 1971, the land vested with the Government and restored to

the Company has been demarcated, and though Section 9 of the Act

envisages for the reservation of land for agricultural purposes, reservation of

land for the welfare of the Agricultural population and assignment of

remaining lands to agriculturists and agricultural labourers, no effective

steps are taken by the State in contemplation of the said laws.

4. The sum and substance of the contention advanced is that the State

Government has failed to implement the requirements of Section 9 of Act,

1971 and therefore, Ext. P13 Government Order has no manner of co-

relation to the purpose sought to be achieved by the Act, 1971.

5. The petitioner has also narrated the facts, figures and data in

respect of the total extent of land that is held by the Kannan Devan Hill

Produce Company and other facts and figures towards the attempt to

establish the contention that unless and until necessary survey is conducted

in accordance with the provisions of Act, 1971, no purpose would be served

by issuing peremptory directions by the State Government in Ext. P13.

6. A detailed counter affidavit is filed by the State Government refuting

the allegations made in the writ petition and objecting to the reliefs sought

for by the petitioner stating that the writ petitioner and the alleged

predecessors in interest are claiming huge extents of land in Munnar on the

basis of sham and fraudulent documents of title namely Document

Nos.380/1976 and 381/1976 of SRO Devikulam. As per Document No.380 of

1976 dated 31.12.1976, a Deed of Transfer was made between the Kannan

Devan Hills Produce Company Limited, a Company registered under the

Companies Act of the United Kingdom and having its Registered Office at

Hellenic House, 87-97 Bath Street, Glasgow 02 202 Scotland and a place of

business in India at 2, Netaji Subhash Road, Calcutta on one part (Vendor)

and Tata Finlay Limited, a Company incorporated under the Companies Act,

1956 and having its Registered Office at Bombay House, Bombay

(purchaser) on the other part to sell all the immovable properties of the

Vendor in the State of Kerala and the goodwill of business carried on by the

Vendor in India, at the consideration of 1,58,41,825/- and Re. 1/- for the

goodwill of the said business. The said document of title has been executed

by the foreign company namely KDHP Ltd., which is registered in U.K.

purporting to transfer huge extents of Government lands to the prejudice of

the State's interest and public interest.

7. Reliance has been placed in respect of the recitals in Ext.R1(a),

document No.380/1976 dated 31.12.1976 of SRO, Devikulam, and it reads

thus:

"(6) in terms of the Exchange Control Act, 1947 and or Section 482 of the Income and Corporation Taxes Act, 1970 of the United Kingdom the consent of the Bank of England and her Majesty's Treasury in the United Kingdom has been obtained by the Vendor for the sale of the undertaking including the entire assets and liabilities in India of the Vendor as aforesaid".

According to the first respondent, the recitals are liable to be held as fraud

perpetrated on the Constitution of India by a foreign company over the lands

in India in 1976. This shows that the foreign company had indulged in

transferring immovable properties in India after getting approval of the

British authorities. The recitals mentioned are a direct affront to the

sovereignty of independent India and the Constitution of India.

8. It is also submitted that the claim of the writ petitioner that Tata

Tea Limited is a successor in interest of the KDHP Co. Ltd. and Anglo Indian

Direct and Amalgamated Tea Company, which were Sterling Companies

incorporated in England, cannot have any legal backing, since the alleged

succession is not as per Sections 391 to 395 of the Companies Act, 1956.

Moreover, the said succession has not been approved by the Reserve Bank of

India under Section 31 of the Foreign Exchange Regulation Act, 1973. It is

further submitted that the order of the Land Board dated 29.03.1974

relating to an extent of 57359.14 acres, wherein the lands were exempted

and restored to KDHP Co. Ltd., if at all done, is liable to be held as not

binding on the Government, since the order has been issued in favour of a

foreign company incorporated in England, which is not entitled to hold or

possess any lands in the territory of Union of India.

9. It is further submitted that the deed itself expressly recites that no

sanction of the State Government or the Central Government in any manner

has been obtained for the transfer of various estates situated in Kerala by

the foreign company. The consideration part also reveals that the entire

consideration was treated as an unsecured loan to be repaid after collecting

the entire amount through public issue and collecting the said amounts from

the public to be paid to the foreign company within a period of 5 years on

annual instalment basis.

10. According to the first respondent, a foreign company had, thus,

indulged in illegal transfer of huge extents of Government land including

"Munnar Town" as described in the schedule with scant regard to the entire

sovereign system of Independent India, which has been illegally grabbed by

the company based on the said fraudulent document. Since the entire

transaction is based on fraud, misrepresentation and grabbing of the

Government lands, the Government is raising serious objections in granting

reliefs to the writ petitioners.

11. In respect of the land covered by Ext.R1(a) Document, the land

transferred was by the Anglo American Direct Tea Trading Company Limited

in favour of Tata Finlay Limited. The said document also reveals recitals that

are anti national, anti sovereign, thereby constituting fraud on the

Constitution of India. The recitals are illegal, fraudulent and unconstitutional.

The vendor of the document has transferred an extent of 5250.06 àcres in

gross violation of the Kerala Private Forest (Vesting and Assignment) Act and

the Kerala Land Reforms Act, and has even transferred Kuthakapattom lands

and encroached lands. The recitals read thus:

"The schedule above referred to: All those pieces or parcels of land measuring 4575. 18 acres approximately in possession of the vendor (but according to title deeds, an area of 5250.06 acres approximately) known as Devikulam Periya Kanal and Pallivasal Estates, (which includes an area of 3.87 acres in Periya Kanal Estate and 12.39 acres in Pallaivasal Estate held under Kuthakapattaom grants, an area measuring 369.92 acres approximately in Periya Kanal Estate and 176.70 approximately in Pallivasal Estate having been declared to vest in the Government under the Kerala Private Forest Vesting and Assignment Act, 1971 and in dispute before the Palghat Tribunal constituted under the said Act, an encroached area measuring 4.84 acres in Pallivassal Estate and an area measuring 42.94 acres in Periakanal Estate declared by the Land Board as surplus under the Kerala Land Reforms Act 1963)".

Therefore, it is contented that the recitals in Document No.381/1976 of SRO

Devikulam, which is produced as Ext.R1(b) also is a direct challenge to the

sovereignty of India and the Constitution of India.

12. Thus, it is submitted that an amount of Rs.14,25,771/- has been

paid in the Central Stamp Depot, Thiruvananthapuram under Sl. No.

41080/29/12/76 and the same has been engrossed on the paper, which

shows that no procedure contemplated under the Kerala Stamp Rules for

presentation of documents for adjudication of stamp value on instruments by

the proper officer, who is the Collector, has been done in respect of the deed

which has been executed outside the Kerala State. The deed has been

executed on 31.12.1976 in Calcutta as is revealed from the recitals in the

deed. Hence, as per Rule 12 of the Kerala Stamp Rules, 1960, the affixing of

impressed stamp can be effected only after a duly executed instrument is

received in the State of Kerala which can only be after 31.12.1976. Since

gross violation of proper stamping of the documents has been resorted to by

the executants, the same amounts to an invalid document, which cannot be

recognized in any Courts in India. The same invites appropriate penal action

against the Company. The very same procedure has been adopted in respect

of the document executed on 31.12.1976 and registered as document

No.381/1976, wherein no power of attorney or duly constituted attorney as

envisaged under Section 28 of FERA for executing documents is seen

effected. The common seal of the vendor company is also significantly

missing. The impression of stamp as per the Kerala Stamp Rules has been

grossly violated inviting appropriate penal action.

13. It is further submitted that the registration procedure adopted in

registering both the documents with the Sub Registrar of Devikulam reveals

shocking state of affairs which throws more and more light on the fraudulent

nature of the documents and the conduct of the writ petitioner Company and

the predecessor in interest in grabbing Government lands. It is submitted

that a scrutiny of the Powers of Attorney said to have been presented on

behalf of the executants of the documents shows that the Powers of Attorney

have not been executed at all as required under the Rules. Ext. R1(d) is the

copy of the relevant pages of Power of Attorney executed by S.K. Mehera in

favour of P. Somasundaram Pillai on behalf of the KDHP Company bearing

registration No. 1977 dated 05.04.1977 and presently available in the Office

of the Sub Registrar, Devikulam. Ext.R1(e) is the copy of the relevant pages

of Power of Attorney executed by S.Puri in favour of P. Somasundaram Pillai

on behalf of the KDHP Company registered as No. 1977 dated 05.04.1977

and presently available in the Office of the Sub Registrar, Devikulam.

Ext.R1(f) is the relevant pages of a similar Power of Attorney executed by

the Purchaser (S. Puri) in respect of the sale of immovable property by the

Anglo American Direct Tea Trading Company Limited. Ext.R1(g) is the copy

of the relevant pages of similar Power of Attorney executed by the Purchaser

(S.K. Mehera) in respect of the sale of immovable property by the Anglo

American Direct Tea Trading Company Limited. The revenue stamps

appended in the Powers of Attorney are not even seen cancelled. A scrutiny

of the Thumb Impression Register also showed that the Powers of Attorney

holders had not affixed their thumb impression and there is no signature of

one of the presenters. This also casts doubt on the authenticity of the

documents relied on and the procedures adopted, it is contended. Ext.R1(h)

is the relevant page of the Thumb Impression Register. It is pertinent to note

that both the purchaser and the vendor belong to the same address, namely,

2 Netaji Subhash Chandra Bose Road, Calcutta in the Powers of Attorney. It

shows that the entire operation of registration of the documents is clouded in

mystery, fraudulent in nature and intended to grab precious Government

lands, it is contended. Therefore, the documents of title dated 31.12.1976

registered as deed Nos.380/1976 and 381/1976 are fraudulent and sham

documents which do not create any right, title, interest, possession or

otherwise over the lands covered by the document. The foreign company

had indulged in the illegal transfer of huge extents of Government land

including "Munnar Town '' as described in the schedule with scant regard to

the entire sovereign system of Independent India. Since the entire

transaction is based on fraud, misrepresentation and grabbing of

Government lands, the respondents raise serious objections in granting

reliefs to the writ petitioners. It is submitted that respondents are raising the

very question of title of the writ petitioner, maintainability of the writ petition

and eligibility of the petitioner to challenge the various executive actions

undertaken as per the law by the respondents. It is also submitted that the

very same issue was considered by this Court in W.P.(C) Nos. 14242, 21864

& 27662 of 2010 and it was dismissed as infructuous as per judgment dated

07.12.2015. Ext.R1(i) is the argument note submitted by the Special

Government Pleader (Revenue) in the aforesaid cases.

14. Therefore, it is the case of the respondents that the very question

of title based on fraudulent and sham documents as claimed by the writ

petitioners is liable to be considered by this Court as a preliminary issue. It

is contended that without considering the issue raised by the respondents,

any consideration of the subsequent issue or contentions raised by the writ

petitioner will have a serious prejudice on the interests of the Government.

Hence, the respondents seek consideration of the issue of eligibility and

legality of the claims of the writ petitioner over large extent of lands now

illegally occupied and prayed that the contentions raised in the writ petition

may be considered only after settling the primary issue of question of title of

the writ petitioner.

15. Heard the respective counsel appearing on either side, and

perused the pleadings and material on record .

16. At the outset it is made clear that, the issues raised in this writ

petition and the counter affidavit regarding title etc narrated as above was

the subject matter of various other writ petitions in different contexts and

therefore, we make it clear that if there are any specific directions issued in

any writ petitions by this Court, the same shall alone be followed while

considering the directions hereinafter issued.

17. Anyhow, as per the order of this Court dated 13.07.2007, the

petitioner was permitted to delete prayer Nos. V(a) and V(d), and notices

were issued to the respondents only in regard to the prayer Nos. V(b) and

V(c) and therefore, the legality of Ext P13 order of the State Government is

not a subject matter of consideration before us. The rival submissions made

by the parties in the writ petition and the counter affidavit would make it

clear that the petitioner is aggrieved by the inaction on the part of the State

Government to conduct a survey in terms of the Act, 1971. Therefore,

according to the petitioner, unless and until the survey is conducted, the

requirements contained under Section 9 of Act, 1971 is unable to be

implemented by the Government and until such time, no fruitful purpose

would be served by implementing Ext. P13 order of the State Government

dated 17.02.2007.

18. We are not going into the details in respect of the rival

submissions, since we propose to dispose of the writ petition, in view of the

present state of affairs submitted before this Court on the basis of the

instructions imparted by the Survey Director, Thiruvananthapuram to the

Advocate General stating that the survey in respect of the Kannan Devan Hill

Village was prepared in the year 2007, however it has not been finalised,

and now steps are being taken to finalise the same. It is also specified

thereunder that 525 appeals were received after the publication of the

notification in regard to the Kannan Devan Hills Village as per the provisions

of the Kerala Survey and Boundaries Act, 1961 and out of which, 426

complaints were finalised and steps are being taken to finalise the remaining

99 applications by verifying the title documents produced by those persons.

It is also stated thereunder that an Advisory Committee with the Sub

Collector, Devikulam as the Chairman is authorized to verify the title

documents of such persons. It is also undertaken thereunder that as and

when the files are received from the Advisory Committee, steps would be

taken to finalise the survey proceedings in accordance with the Act, 1971.

19. In that view of the matter, we are of the considered opinion that

no purpose would be served by keeping this writ petition pending before this

Court and it can be disposed of issuing appropriate directions.

Therefore, after evaluating the submissions made by learned counsel

for the petitioner Sri. Pratap and the learned Special Government Pleader

Sri. Mohammed Anzar, we dispose of the writ petition directing the State

Government to secure necessary reports from the Advisory Committee in

regard to the pending complaints as specified above, finalise the proceedings

in regard to the measurements stated to be carried out in accordance with

the Act, 1971, and take a final decision in the matter after providing

necessary notice of hearing to all stakeholders at the earliest and, at any

rate, within three months from the date of receipt of a copy of this

judgment.

sd/-

S. MANIKUMAR, CHIEF JUSTICE.

sd/-

SHAJI P. CHALY, JUDGE.

Rv

APPENDIX OF WP(C) 21045/2007

PETITIONER'S EXHIBITS:

EXHIBIT P1 TRUE COPY OF ORDER OF THE LAND BOARD DATED 29-03-

1974.

EXHIBIT P2 TRUE COPY OF ORDER DATED 4-08-1975 ISSUED BY THE 1ST RESPONDENT.

EXHIBIT P3 TRUE COPY OF COMMUNICATION FROM THE 4TH RESPONDENT TO THE DIVISIONAL FOREST OFFICER, MUNNAR DATED 11-04-1980.

EXHIBIT P4 TRUE COPY OF REPRESENTATION DATED 9-2-1994 SUBMITTED BY THE PETITIONER.

EXHIBIT P5 TRUE COPY OF GO DATED 17-05-1996 ISSUED BY THE 1ST RESPONDENT.

EXHIBIT P6 TRUE COPY OF GOVERNMENT ORDER DATED 7-7-1997 ISSUED BY THE 2ND RESPONDENT.

EXHIBIT P6 A TRUE ENGLISH TRANSLATION OF GO DATED 7-07-1997 ISSUED BY THE 2ND RESPONDENT.

EXHIBIT P7 TRUE COPY OF REPRESENTATION DATED 25-08-1998 SUBMITTED BY THE PETITIONER BEFORE THE 4TH RESPONDENT.

EXHIBIT P8 TRUE COPY OF THE NOTE PUT UP BY THE 4TH RESPONDENT.

EXHIBIT P9 TRUE COPY OF PROCEEDINGS DATED 1-8-2001 OF THE 4TH RESPONDENT.

EXHIBIT P10 TRUE COPY OF GOVERNMENT ORDER DATED 17-12-04

EXHIBIT P11 TRUE COPY OF COMPLAINT DATED 8-09-2006 FILED BEFORE THE LOK AYUKTHA, THIRUVANANTHAPURAM, NUMBERED AS C. 2326/06.

EXHIBIT P12 TRUE COPY OF ORDER DATED 30-11-2006 ISSUED BY THE 2ND RESPONDENT.

EXHIBIT P13 TRUE COPY OF GO DATED 17-2-007 ISSUED BY THE GOVERNMENT OF KERALA.

EXHIBIT P13(a) TRUE ENGLISH TRANSLATION OF GO DATED 17-2-2007 ISSUED BY THE GOVERNMENT OF KERALA.

EXHIBIT P14 TRUE COPY OF REPRESENTATION DATED 5-3-2007 SUBMITTED BY THE PETITIONER BEFORE THE 2ND RESPONDENT.

EXHIBIT P15 TRUE COPY OF REPRESENTATION DATED 14-3-2007 SUBMITTED BY THE PETITIONER BEFORE THE 2ND RESPONDENT.

EXHIBIT P16 TRUE COPY OF REPRESENTATION 4-5-2007 SUBMITTED BY THE PETITIONER BEFORE THE 2ND RESPONDENT.

EXHIBIT P17 TRUE COPY OF NOTICE DATED 10-05-2007 ISSUED TO ONE S AYYADURAI PILLAI.

EXHIBIT P17(a) TRUE ENGLISH TRANSLATION OF NOTICE DATED 10-05-2007 ISSUED TO ONE S. AYYADURAI PILLAI.

RESPONDENT'S/S EXHIBITS:

EXHIBIT R1 (a) A TRUE COPY OF THE SALE DEED NO. 380/1976 OF SRO DEVIKULAM CONTAINING RELEVANT PAGES ONLY

EXHIBIT R1(b) A TRUE COPY OF THE SALE DEED NO. 381/1976 OF SRO DEVIKULAM CONTAINING RELEVANT PAGES ONLY.

EXHIBIT R1(c) A TRUE COPY OF THE LICENSE ISSUED TO THE FOREIGN COMPANY NAMELY KANNAN DEVAN HILLS PRODUCE COMPANY LIMITED , 22 WEST NILE STREET, GLASGOW, U.K TO HOLD IMMOVABLE PROPERTY IN INDIA.

EXHIBIT R1(d) A TRUE COPY OF THE RELEVANT PAGES OF POWER OF ATTORNEY EXECUTED BY S.K MEHERA IN FAVOUR OF P.

SOMASUNDARAM PILLAI DATED 05-04--1977 AND RPESENTLY AVAILABLE IN THE OFFICE OF THE SUB REGISTRAR, DEVIKULAM.

EXHIBIT R1 (e) A TRUE COPY OF THE RELEVANT PAGES OF POWER OF ATTORNEY EXECUTED BY S.PURI IN FAVOUR OF P.

SOMASUNDARAM PILAI ON BEHALF OF THE KDHP COMPANY

REGISTERED AS NO. 1977 DATED 05-04-1977 AND PRESENTLY AVAILABLE IN THE OFFICE OF THE SUB REGISTRAR, DEVIKULAM.

EXHIBIT R1(f) A TRUE COPY OF THE RELEVANT PAGES OF A SIMILAR POWER OF ATTORNEY EXECUTED BY THE PURCHASER (S PURI) IN RESPECT OF THE SALE OF IMMOVABLE PROPERTY BY THE ANGLO AMERICAN DIRECT TEA TRADING COMPANY LIMITED

EXHIBIT R1(g) A TRUE COPY OF THE RELEVANT PAGES OF SIMILAR POWER OF ATTORNEY EXECUTED BY THE PURCHASER (S.K MEHERA) IN RESPECT OF THE SALE OF IMMOVABLE PROPERTY BY THE ANGLO AMERICAN DIRECT TEA TRADING COMPANY LIMITED.

EXHIBIT R1(h) A TRUE COPY OF THE RELEVANT PAGE OF THUMB IMPRESSION REGISTER.

EXHIBIT R(i) A TRUE COPY OF THE ARGUMENT NOTE SUBMITTED BY THE SPECIAL GOVERNMENT PLEADER (REVENUE) IN W.P.(C) NO 14242/2010, W.P(C) NO 21864/2010 AND W.P(C) NO. 27762/2013.

EXHIBIT R1 AFFIDAVIT FILED BY THE SIXTH RESPONDENT, SUB INSPECTOR OF POLICE, DEVIKULAM FILED IN W.P(C) NO. 29463/2015 ON 02-12-2015.

EXHIBIT II A TRUE COPY OF THE RELEVANT PAGES OF THE DOCUMENT NO. 381/1977 OF SRO DEVIKULAM (EXHIBIT R 6(J).

EXHIBIT III TRUE COPY OF THE DOCUMENT NO. 380/77 OF SRO DEVIKULAM (EXHIBIT R6 (K).

EXHIBIT RIV TRUE COPY OF THE DOCUMENT NO. 3704/1994 EXECUTED UNDER THE GUISE OF RECTIFICATION DEED (EXHIBIT R6(l).

EXHIBIT V TRUE COPY OF INTERIM ORDER DATED 29-09-2015 IN W.P(C) NO. 29463/2015.

EXHIBIT VI TRUE COPY OF INTERIM ORDER DATED 07-10-2015 IN W.P(C) NO 29463/2015.

EXHIBIT VII TRUE COPY OF INTERIM ORDER DATED 09-11-2015 IN W.P(C) NO. 29463/2015.

EXHIBIT VIII TRUE COPY OF INTERIM ORDER DATED 02-12-2015 IN W.P(C) NO. 29463/2015.

EXHIBIT R6(j): TRUE COPY OF THE RELEVANT PAGES OF THE DOCUMENT NO.381/1977 OF SRO, DEVIKULARM.

EXHIBIT R6(k): TRUE COPY OF THE DOCUMENT NO.380/77 OF SRO, DEVIKULAM.

EXHIBIT R6(l): TRUE COPY OF THE DOCUMENT NO. 3704/1994 EXECUTED UNDER THE GUISE OF RECTIFICATION DEED.

/True Copy/

P.S To Judge.

rv