Kerala High Court
Sindhu P.K vs Biju Kurian on 5 January, 2021
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE ALEXANDER THOMAS
&
THE HONOURABLE MR. JUSTICE T.R.RAVI
TUESDAY, THE 05TH DAY OF JANUARY 2021 / 15TH POUSHA, 1942
OP(KAT).No.450 OF 2020
AGAINST THE ORDER/JUDGMENT IN OA 718/2020 DATED 18-12-2020 OF
KERALA ADMINISTRATIVE TRIBUNAL, THIRUVANANTHAPURAM
PETITIONERS/3RD PARTY TO THE ORIGINAL APPLICATION:
1 SINDHU P.K.
AGED 46 YEARS, W/O. LATE SALILKUMAR N.,
INDUSTRIES EXTENSION OFFICER,
THODUPUZHA MUNICIPALITY,
DISTRICT INDUSTRIES CENTRE,
IDUKKI, PIN - 685602,
RESIDING AT POTTANANICKAL (HOUSE),
MOOLAKKADU P. O., MOOLAKKAD,
UDUMBANNOOR, IDUKKI DISTRICT, PIN - 685 595.
2 RESHMA G.
AGED 41 YEARS, W/O. MANOJKUMAR V. B.,
INDUSTRIES EXTENSION OFFICER,
THODUPUZHA BLOCK, DISTRICT INDUSTRIES CENTRE,
IDUKKI, PIN - 685602,
RESIDING AT MADHAVAM KWA QUARTERS NO.5,
KERALA WATER AUTHORITY,
SIVANKUNNU, MUVATTUPUZHA,
ERNAKULAM DISTRICT, PIN - 686661.
3 BINCYMOL T.
AGED 43 YEARS, D/O. MARIAMMA JOSEPH,
INDUSTRIES EXTENSION OFFICER,
RANNI BLOCK, DISTRICT INDUSTRIES CENTRE,
PATHANAMTHITTA, PIN - 685602,
RESIDING AT THENKALLUMKAL HOUSE,
MUNDAKKAYAM P. O.,
OLD MUNDAKKAYAM, KOTTAYAM DISTRICT,
PIN - 686513.
OP(KAT).No.450 OF 2020
2
SRI.K.M.SATHYANATHA MENON
SMT.KAVERY S THAMPI
RESPONDENTS/APPLICANT & RESPONDENTS IN ORIGINAL APPLICATION:
1 BIJU KURIAN
AGED 49 YEARS, S/O. C. G. KURIAN,
GENERAL MANAGER, DISTRICT INDUSTRIES CENTRE,
IDUKKI, PIN - 685602,
RESIDENT OF BABYS BUNGLOW, AMPALATHUMKALA P. O.,
EZHUKONE, KOLLAM, KERALA, PIN - 691 505.
2 STATE OF KERALA
REPRESENTED BY SECRETARY TO GOVERNMENT,
INDUSTRIES DEPARTMENT, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695 001.
3 DIRECTOR OF INDUSTRIES AND COMMERCE
DIRECTORATE OF INDUSTRIES AND COMMERCE,
VIKAS BHAVAN, 3RD FLOOR, UNIVERSITY OF KERALA,
SENATE HOUSE CAMPUS, PALAYAM,
THIRUVANANTHAPURAM, PIN - 695 033.
4 P. S. SURESH KUMAR
AGED 52 YEARS, S/O. SUKUMARAN K. N. (LATE),
JOINT DIRECTOR / GENERAL MANAGER,
INDUSTRIES AND COMMERCE DEPARTMENT,
WAYANAD DISTRICT,
RESIDING AT PADITHIRAPPALLIL, MOOLAVATTOM P. O.,
KOTTAYAM, PIN - 686 012
(IMPLEADED AS ADDITIONAL RESPONDENT NO.3 IN OA 718
OF 2020 AS PER ORDER DATED 24.06.2020 IN MA
868/2020.)
R1 BY ADVS. SRI.P.NANDAKUMAR
BY ADV. SMT.AMRUTHA SANJEEV
BY ADV. SHRI.VIVEK VIJAYAKUMAR
BY ADV. SHRI.SREEKUMAR K.R.
SRI.ANTONY MUKKATH, GOVT.PLEADER
THIS OP KERALA ADMINISTRATIVE TRIBUNAL HAVING BEEN FINALLY
HEARD ON 05.01.2021, THE COURT ON THE SAME DAY DELIVERED THE
FOLLOWING:
OP(KAT).No.450 OF 2020
3
ALEXANDER THOMAS & T.R. RAVI, JJ.
===========================
O. P. (KAT) No. 450 of 2020
(Arising out of order dated 18.12.2020
in O.A. No.718 of 2020 of the Kerala Administrative
Tribunal, Thiruvananthapuram)
===========================
Dated this the 5th day of January, 2021
JUDGMENT
ALEXANDER THOMAS, J.
The aforecaptioned Original Petition is filed under Articles 226 & 227
of the Constitution of India with the following prayers:
"(i) To call for the records leading to the order dated 18.12.2020 in
O.A.No.718/2020 on the file of the Kerala Administrative Tribunal at
Thiruvananthapuram [Exhibit P1] and set aside the same.
(ii) To issue such other orders or directions as this Hon'ble Court may deem fit and
proper in the circumstances of the case."
2. Heard Sri.K.M.Sathyanatha Menon, learned counsel appearing
for the petitioners in the O.P./applicants in the O.A. filed before the
Tribunal, Sri.P.Nandakumar, learned counsel appearing for the 1 st
respondent herein (original applicant before the Tribunal) and Sri.Antony
Mukkath, learned Senior Government Pleader appearing for R2 & R3-State
Government and Director of Industries and Commerce. In the nature of
the orders proposed to be passed in this original petition, notice to the 4 th
respondent herein is dispensed with.
3. The petitioners in this Original Petition are not parties to the
OP(KAT).No.450 OF 2020
proceedings in the Original Application O.A. No.718/2020 on the files of
the Kerala Administrative Tribunal, Thiruvananthapuram. According to
the petitioners herein, they are highly aggrieved by the impugned Ext.P1
order dated 18.12.2020 rendered by the Kerala Administrative Tribunal,
Thiruvananthapuram in O.A.No.718/2020 filed by the 1 st respondent
herein. The said O.A.No.718/2020 was filed by the 1 st respondent herein
impugning the order issued by the competent authority-State Government
ordering to place R1 herein under suspension from service on the basis of
the allegations mentioned therein. The Tribunal as per the said impugned
order as Ext.P1 dated 18.12.2020 has interfered with the said impugned
suspension order and has set aside and quashed the impugned suspension
order. According to the petitioners herein, they are some of the persons
who have made complaints against the functioning of R1 herein as Joint
Director of Industries and Commerce at Idukki and that the 1 st and 2nd
petitioners herein are working as Industries Extension Officer at the local
bodies in Idukki District and the 3 rd petitioner herein is now working as an
Industries Extension Officer in a local body at Pathanamthitta District and
that she was earlier working in Idukki District.
4. After hearing all the parties concerned, this Court is of the
considered view that it may not be right and proper for this Court to
entertain this Original Petition on merits at this stage. The matter in issue
OP(KAT).No.450 OF 2020
is covered by the judgments of the Apex Court in Rajeev Kumar and
another V. Hemaraj Singh Chauhan and others [2010 (4) SCC 554]
= [AIR 2010 SC 1679] as well as the judgments of the Division Bench of this
Court as in the judgment dated 12.07.2010 in WP(C) No.20979/2010, as
well as the judgment of the Division Bench rendered on 19.06.2013 in
OP(KAT) No.1286/2013 (Gireesh Babu M.B. and others V.
Pavithran T.T.V. and others reported in [2013 (3) KHC 165]. The Apex
Court in the decision in Rejeev Kumar's case supra [2010 (4) SCC 554]
has held in paragraph 16 thereof that the remedy of a person, who is a third
party to the proceedings of the Tribunal, who is aggrieved by the order of
the Tribunal would lie before the Tribunal in the form of an application of
review. In paragraph 11 of the decision in Rajeev Kumar's case supra
[2010 (4) SCC 554] the Apex Court had held that going by the legal position
already settled by the 7-Judge Bench of the Apex Court in
L.Chandrakumar V. Union of India [(1997) 3 SCC 261], two things are
clear and that (a) the Tribunals will function only as the Court of first
instance in respect of the areas of law for which they have been constituted
and (b) where any challenge is made to the vires of legislation, excepting
the legislation under which the Tribunal has been set up. In such cases
also, the litigant will not be able to approach the High Court overlooking
the jurisdiction of the Tribunal. Further, the said legal position has also
OP(KAT).No.450 OF 2020
been reiterated by the Larger Bench of the Apex Court in the aforecited
L.Chandrakumars' case supra [(1997) 3 SCC 261] in paragraph 99
thereof, wherein it has been held that the Tribunal cannot act like Court of
first instance in respect of the areas of law for which they have been
constituted and it will not therefore be open for litigants to directly
approach the High Court, even in cases where they question the vires of
statutory legislations, (except where the legislation which creates the
particular Tribunal is challenged) by overlooking the jurisdiction of the
Tribunal concerned. Hence it was held by the Apex Court in Rajeev
Kumar's case supra [2010 (4) SCC 554] , that the third parties to the
proceedings before the Tribunal, cannot seek to approach the High Court
by treating it as a court of first instance, etc. The Division Bench of this
Court in the judgment dated 19.06.2013 in OP(KAT) No.1286/2013 in
Gireesh Babu M.B. and others V. Pavithran T.T.V and others
[2013 (3) KHC 165 (DB)], has explained the legal position in that regard
and has held in paragraph Nos. 5 to 7 thereof as follows:
"5. Faced with the discussions in paragraphs 7 to 14 of Rajeev Kumar
(supra) and the pointed conclusions arrived at in paragraph 11 of that
judgment, on the basis of the ratio of L.Chandra Kumar v. Union of India
[(1997) 3 SCC 261], the learned counsel for the petitioners attempted to
distinguish Rajeev Kumar by saying that while in that case, the employees -
Rajeev Kumar and another, had applied for impleadment in a petition pending
before the High Court against the decision of the Central Administrative
Tribunal, while the petitioners herein have come directly to this Court invoking
Article 227 of the Constitution. Though the learned counsel for the petitioners
thus tried to draw a distinction between original petitioners and impleading
OP(KAT).No.450 OF 2020
petitioners, we do not see any room for classification of the parties on that
basis. We say this because, in Rajeev Kumar, the categoric statement of the
Apex Court is that "the approach made to the High Court for the first time by
these appellants in respect of their service disputes over which CAT has
jurisdiction, is not legally sustainable." It was also held that the Division Bench
of the High Court fell into an error by allowing to treat the High Court as a
court of first instance in respect of their service disputes for adjudication for
which CAT has been constituted. In Rajeev Kumar, the Apex Court had pointed
out that in view of the clear law laid by the Constitution Bench in L.Chandra
Kumar (supra), the approach of the High Court treating itself as the court of
first instance overlooking the jurisdiction of the Tribunal was unacceptable.
Those principles apply on all fours to matters arising from decisions of all
Tribunals constituted under the Administrative Tribunals Act, 1985, including
the Kerala Administrative Tribunal.
6. Incidentally, the Apex Court had also noted in Rajeev Kumar that the
Tribunal has also the power of review. We do not see that expression, as
excluding any other mode available before the Tribunal, for grant of relief, to
persons who were entitled to be heard, if found so; yet, not heard before the
verdict was handed down by it.
7. The learned counsel for the petitioners also made reference to Shama
Prashant Raje v. Ganpatrao [(2000) 7 SCC 522)] to argue that notwithstanding
that the jurisdiction of the High Court under Articles 226 and 227 is supervisory
and not appellate; if perusal of the order of an inferior tribunal leads to the
conclusion that one among the four conditions enumerated in that precedent
exists, the High Court would be fully justified in interfering with the findings of
the inferior tribunal. We see that such law was laid in consonance with the
existing precedent law and that was applied to decisions arising under the rent
control laws. The principles laid down by the Constitution Bench in L. Chandra
Kumar were not adverted to while deciding Shama Prashant Raje (supra),
which dealt with a different jurisdictional zone. L. Chandra Kumar was
pointedly adverted to, considered and applied by the Apex Court while deciding
Rajeev Kumar. We are, therefore, of the view that Rajeev Kumar directly
applies as the precedent to the case in hand while the ratio in Shama Prashant
Raje does not apply to the context in hand."
5. The Full Bench of this Court in a recent decision rendered in the
case in Haris K.M. V. Jahfar K. [2020 (4) KLJ 846], has held in
paragraph Nos.9, 11 and 27 thereof, as follows:
"9. On a consideration of the totality of these circumstances,
the principles laid down in Rajeev Kumar (Supra) and Gireesh
Babu (Supra) will not in any way affect the rights of persons who
OP(KAT).No.450 OF 2020
were parties in one or other O.A.'s, to get impleaded in the original
petition, even though they were not parties in the particular original
application from which the original petition arises. The rights of such
persons cannot be treated at par with the rights of persons who were
strangers to the proceedings. None of these persons can or need to
approach the Tribunal with a review petition or any other petitions,
since they are beneficiaries of the judgment of the Tribunal. Even the
strangers to the O.A's who would stand affected by the decision of this
Court in the O.P. would have a right to seek for impleadment since the
respondents before the Tribunal were impleaded in a representative
capacity and every person similarly situated is deemed to have been
represented before the Tribunal. Hence Haris too has a right to be
impleaded and heard, in defense of the order of the Tribunal.
xxxxxxxxx xxxxxxxxxx xxxxxxxxxx xxxxxxxxxx
11. We are not considering the merits of the claim for impleadment
alone, but a reference of a Division Bench as to whether the cited
decisions of this Court and of the Hon'ble Supreme Court would act as
an inviolable rule that none who are parties before the Tribunal could
approach this Court, either as petitioners or seek impleadment as
respondents; in the latter case for resisting or supporting the order of
the Tribunal. We do not and cannot contemplate all of the situations
that may arise. For clarity we consider a few, which could in normal
circumstances arise, which only occur when there is outright rejection
or acceptance of the claims raised in the Original Application, before
the Tribunal.
(a) When the Original Application is dismissed by the Tribunal:
The applicants before the Tribunal can no doubt approach this Court and
challenge the decision of the Tribunal. All the same, persons seeking
similar reliefs as the Applicants, are not entitled to get themselves
impleaded in the original petition filed by the Applicants, merely to ensure
that they too get the benefit of the order of this Court, if there is reversal of
the order of the Tribunal. Such persons have to necessarily approach the
Tribunal with a review or a fresh original application and only thereafter
can they approach the High Court, based on the decision of the Tribunal.
At the same time, persons identically situated to the respondents in the
above said illustration, who were not parties before the Tribunal, will not
be entitled to seek impleadment in the original petition filed by the
Applicants, to support the dismissal of the Original Application, since that
is a case covered by Rajeev Kumar (supra).
(b) When the Original Application is allowed by the Tribunal:
The respondents in such cases can approach this Court and file an original
petition to challenge the judgment of the Tribunal. However, in such
original petitions, persons similarly placed like the successful applicants
before the Tribunal cannot seek impleadment and claim the same relief as
the Applicants. Nor can they get impleaded, for the purpose of supporting
OP(KAT).No.450 OF 2020
the order of the Tribunal. The remedy available to such persons is either to
approach the Tribunal with a fresh original application or to wait for the
result of the original petition, since they cannot be allowed to bypass the
Court of first instance. Whether they choose to file an original application
while the original petition is pending or they file it after the original
petition is dismissed, it would be for the Tribunal to consider whether they
are guilty of delay or laches. As regards, persons similarly situated as
respondents, their remedy is not to approach this Court and get impleaded
in the original petition filed by the respondents. They will have to seek a
review of the judgment before the Tribunal. Such situation is similar to the
one in Gireesh Babu(supra).
(c) A unique situation that may arise is the one which has occasioned this
reference, the facts of which have already been detailed earlier. In such
situations, we are of the opinion that all persons who were respondents
before the Tribunal in any of the original applications, which has been
jointly dismissed by a common judgment, are entitled to get themselves
impleaded in an original petition filed against the judgment in one such
original application, since they are all persons entitled to be treated as
parties to the "proceedings" and are not persons who have bypassed the
court of first instance. This would also apply to persons who are interested
and are affected, but were not physically present before the Tribunal, since
they are deemed to be represented by those respondents impleaded, in a
representative capacity, that too after a paper publication. So also, those
petitioners in I.A.1294 of 2018, who are similarly situated to such
respondents, who also had approached the Tribunal for similar reliefs and
have either succeeded before the Tribunal or their original application is
pending consideration, are also persons entitled to get themselves
impleaded, to support the decision in the original application, since such
persons cannot be treated as having bypassed the court of first instance
and at the same time are likely to be affected by the decision in the original
petition.
xxxxxxxxx xxxxxxxxxx xxxxxxxxxx xxxxxxxxxx
27. In the manner in which we have understood the decisions
in Rajeev Kumar (supra) and Gireesh Babu (supra), we are not in a
position to accept the propositions of law laid down in S.Prabha
(supra) and Rajesh (supra) and we overrule the judgments in so far as
they hold that that the original petition was maintainable directly to
the High Court at the instance of third parties. With all due respect to
the Division Bench, we are of the opinion that entertaining the original
petition at the instance of third parties, was against the dictum laid
down in Rajeev Kumar (supra) and Gireesh Babu (supra). We are of
the considered opinion that both the Division Benches in S.Prabha
(supra) and Rajesh (supra), if they were in disagreement with the
judgment of the Division Bench in Gireesh Babu (supra) ought to have
referred the matter to a Full Bench." (emphasis supplied)
6. Taking note of the facts and circumstances of the case, it has
OP(KAT).No.450 OF 2020
only to be held that the case of the present O.P. will not come within the
exceptional factual scenario envisaged in paragarph No.9 of the decision of
the Full Bench of this Court in Haris's case supra [2020 (4) KLJ 846].
7. Their Lordships in the Full Bench have held in paragraph 11 of
the decision in Haris's case supra [2020 (4) KLJ 846] that persons who
are not parties before the Tribunal will not be entitled to seek impleadment
in the revision petition filed by the applicants in support of the dismissal of
the original application since that is a case covered by the decision of the
Apex Court in Rajeevkumar's case supra [2010 (4) SCC 554] and when
the original application is allowed by the Tribunal.
8. Hence, this Court is constrained to take the view that the facts
of this case would be covered by the dictum laid by the Apex Court in the
decision as in Rajeevkumar's case supra [2010 (4) SCC 554] as well as
in the aforecited judgments of the Division Bench of this Court in WP(C).
No.20979/2010 dated 12.07.2010 and O.P.(KAT) No.1286/2013 [reported
in Gireesh Babu M.B. and others V. Pavithran T.T.V and others
[2013 (3) KHC 165)].
9. Hence it is for the petitioners to immediately approach the
Kerala Administrative Tribunal by filing appropriate review application, in
case they are seriously aggrieved by the impugned Ext.P1 order dated
18.12.2020 rendered by the Kerala Administrative Tribunal,
OP(KAT).No.450 OF 2020
Thiruvananthapuram in O.A.No.718/2020 without any further delay. If
the Rules of Procedure of the Tribunal stipulate that in such cases, third
parties will have to also secure leave for filing such review application and
delay condonation application is also to be filed if delay is involved, then it
is for the petitioners herein to ensure that such procedural formalities are
also complied with. However, it is made clear that the present OP(KAT)
No.450/2020 was filed by the petitioners before this Court on 21.12.2020 is
not maintainable. It is also ordered that the petitioners herein will be at
liberty to raise the plea before the Tribunal that the period spent by them
before this Court in this Original Petition may be excluded for the purpose
of computing the period of limitation, as envisaged in Section 14 of the
Limitation Act. If such a plea is so made, then the Tribunal may consider
such plea, after hearing both sides and in accordance with law. To avoid
further delay, it is ordered that if the petitioners choose to file any review
applications along with any accompanying miscellaneous applications for
third party leave, delay condonation, stay etc., it shall be ensured that
advance copies of such review application and miscellaneous applications
should be duly served by them to Sri.P.Nandakumar, learned counsel
appearing for R1 herein/original applicant and counsel for the petitioners
may also notify in advance Sri.P.Nandakumar, learned counsel about the
listing and consideration of the case before the Tribunal, so that the
OP(KAT).No.450 OF 2020
Tribunal may not have to spend more time for issuing notice to the original
applicant and decision may be rendered on such miscellaneous
applications and review applications, after hearing the counsel for the
original applicant, learned Government Pleader, etc. In the light of these
aspects, it is only to be ordered that the present original petition is not
maintainable before this Court. Hence, it is also ordered that interim stay
order granted by this Court on 29.12.2020 will also stand vacated. The
Tribunal may consider and decide the matter independently untrammeled
and uninfluenced in any manner by the observations and orders made by
this Court hereinabove.
The Registry will forward a copy of this judgment to the Kerala
Administrative Tribunal, Thiruvananthapuram Bench for necessary
information. These observations and directions and with the said liberty to
the petitioners, the above original petition is dismissed as not maintainable
at this stage.
Sd/-
ALEXANDER THOMAS, JUDGE
Sd/-
T.R.RAVI, JUDGE
Pn
OP(KAT).No.450 OF 2020
APPENDIX
PETITIONER'S/S EXHIBITS:
EXHIBIT P1 TRUE COPY OF THE COMMON ORDER DATED
18.12.2020 IN O.A.NO.718 OF 2020 AND
O.A.NO.403 OF 2020 ON THE FILES OF THE
KERALA ADMINISTRATIVE TRIBUNAL,
THIRUVANANTHAPURAM AS AVAILABLE FROM THE
WEBSITE OF THE KERALA ADMINISTRATIVE
TRIBUNAL.
EXHIBIT P2 TRUE COPY OF THE WRITTEN COMPLAINT
SUBMITTED BY THE 1ST PETITIONER BEFORE THE
ADDITIONAL DIRECTOR, DEPARTMENT OF
INDUSTRIES AND COMMERCE DATED NIL.
EXHIBIT P3 TRUE COPY OF THE WRITTEN COMPLAINT
SUBMITTED BY THE 2ND PETITIONER BEFORE THE
DIRECTOR, DEPARTMENT OF INDUSTRIES AND
COMMERCE DATED 13.03.2020.
EXHIBIT P4 TRUE COPY OF THE WRITTEN COMPLAINT
SUBMITTED BY THE 3RD PETITIONER BEFORE THE
ADDITIONAL DIRECTOR, DEPARTMENT OF
INDUSTRIES AND COMMERCE DATED NIL.
EXHIBIT P4 (a) READABLE AND TYPED COPY OF EXT. P4.
EXHIBIT P5 TRUE COPY OF THE COMMUNICATION ISSUED BY
THE DIRECTOR, DISTRICT INDUSTRIES AND
COMMERCE TO THE GENERAL MANAGER, DISTRICT
INDUSTRIES CENTER, IDUKKI DATED 01.01.2018.
EXHIBIT P6 TRUE COPY OF THE EMAIL COMMUNICATIONS DATED
18.03.2020 AT 10.43 A.M.
EXHIBIT P7 TRUE COPY OF THE EMAIL COMMUNICATIONS DATED
18.03.2020 AT 15.16.59 HRS.
EXHIBIT P8 TRUE COPY OF THE MINUTES OF THE MEETING
HELD AT THE CHAMBER OF THE GENERAL MANAGER
DISTRICT INDUSTRIES CENTER ON 4.1.2020.
EXHIBIT P9 TRUE COPY OF ANNEXURE A4 ORDER OF
SUSPENSION (GO (RT) NO.345/2020/INDUSTRIES
DATED 25.05.2020) ISSUED AGAINST THE 1ST
RESPONDENT / APPLICANT BY THE 2ND
RESPONDENT.
OP(KAT).No.450 OF 2020
EXHIBIT P10 TRUE COPY OF THE COMPLAINT SUBMITTED BY THE
1ST PETITIONER BEFORE THE 3RD RESPONDENT
DATED 18.12.2020.
EXHIBIT P11 TRUE COPY OF THE COMPLAINT SUBMITTED BY THE
2ND PETITIONERS BEFORE THE 3RD RESPONDENT
DATED 18.12.2020.
EXHIBIT P12 TRUE COPY OF THE COMPLAINT SUBMITTED BY THE
3RD PETITIONER BEFORE THE 3RD RESPONDENT
DATED 21.12.2020.
EXHIBIT P13 TRUE COPY OF THE COMPLAINT DATED 03.06.2020
FILED BY THE 1ST PETITIONER BEFORE THE
KERALA WOMEN'S COMMISSION AND RECEIVED ON
THEIR FILE AS COMPLAINT NO.P4/1815/2020.
EXHIBIT P14 TRUE COPY OF THE COMPLAINT DATED 03.06.2020
FILED BY THE 2ND PETITIONER BEFORE THE
KERALA WOMEN'S COMMISSION AND RECEIVED ON
THEIR FILE AS COMPLAINT NO.P4/1816/2020.
EXHIBIT P15 TRUE COPY OF THE COMPLAINT DATED 03.06.2020
FILED BY THE 3RD PETITIONER 1 TO 3 BEFORE
THE KERALA WOMEN'S COMMISSION AND RECEIVED
ON THEIR FILE AS COMPLAINT
NO.P4/1764/KTM/2020.
