Hariharan K vs State Of Kerala
2021 Latest Caselaw 1745 Ker

               IN THE HIGH COURT OF KERALA AT ERNAKULAM

                                  PRESENT

          THE HONOURABLE MR. JUSTICE DEVAN RAMACHANDRAN

     MONDAY, THE 18TH DAY OF JANUARY 2021 / 28TH POUSHA, 1942

                      WP(C).No.17659 OF 2020(F)


PETITIONER:

               HARIHARAN K.,
               AGED 50 YEARS
               S/O. BALAKRISHNAN NAIR, HARISREE, CHEMBRASSERI P.O.
               PANDIKKAD, MALAPPURAM DISTRICT 676 521, HEADMASTER
               (UNDER SUSPENSION), A.U.P. SCHOOL, CHEMBRASSERI P.O.
               CHEMBRASSERI 676 5216.

               BY ADVS.
               SRI.BIJU ABRAHAM
               SMT.LILIA JOHN

RESPONDENTS:

      1        STATE OF KERALA
               REPRESENTED BY SECRETARY TO GOVERNMENT, GENERAL
               EDUCATION DEPARTMENT, THIRUVANANTHAPURAM 695 001.

      2        DISTRICT EDUCATIONAL OFFCIER,
               MALAPPURAM, MALAPPURAM P.O. 676 505.

      3        ASSISTANT EDUCATIONAL OFFICER,
               MANJERI MALAPPURAM DISTRICT 676121.

      4        THE MANAGER,
               A.U.P. SCHOOL, CHEMBRASSERI P.O. CHEMBRASSERI,
               PANDIKKAD, MALAPPURAM DISTRICT 676 521.

      5        PRAVEEN MARANAT,
               REPRESENTATIVE OF THE MANAGEMENT) A.U.P. SCHOOL
               CHEMBARASSERY, CHEMBARASSERI P.O. PANDIKKAD,
               MALAPPURAM 676 521.

      6        VIDYA.K.,
               AGED 40 YEARS
               W/O.PRAVEEN MARANAT,
               U.P.S.T.,
               A.U.P. SCHOOL CHEMBARASSERY, CHEMBARASSERI P.O.
               PANDIKKAD, MALAPPURAM 676 521.
 WP(C).Nos.17659 & 29222 OF 2020(F)

                                     2




              BY ADV. SRI.S.KRISHNAMOORTHY
              BY ADV. SMT.NITHYA SUGUNAN

     THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
18.01.2021, ALONG WITH WP(C).29222/2020, THE COURT ON THE SAME
DAY DELIVERED THE FOLLOWING:
 WP(C).Nos.17659 & 29222 OF 2020(F)

                                     3




              IN THE HIGH COURT OF KERALA AT ERNAKULAM

                                 PRESENT

           THE HONOURABLE MR. JUSTICE DEVAN RAMACHANDRAN

     MONDAY, THE 18TH DAY OF JANUARY 2021 / 28TH POUSHA, 1942

                      WP(C).No.29222 OF 2020(C)

PETITIONER:

              HARIHARAN. K
              AGED 50 YEARS
              S/O.BALAKRISHNAN NAIR, HARISREE, CHEMBRASSERI P.O.,
              PANDIKKAD, MALAPPURAM DISTRICT 676 521
              HEADMASTER (UNDER SUSPENSION) A.U.P. SCHOOL,
              CHEMBRASSERI P.O., CHEMBRASSERI 676 521

              BY ADVS.
              SRI.BIJU ABRAHAM
              SMT.LILIA JOHN

RESPONDENTS:
       1     DISTRICT EDUCATIONAL OFFICER,
             MALAPPURAM, MALAPPURAM P.O., 676 505

       2      ASSISTANT EDUCATIONAL OFFICER
              MANJERI, MALAPPURAM DISTRICT 676 121

       3      THE MANAGER
              A.U.P.SCHOOL, CHEMBRASSERI P.O., CHEMBRASSERI,
              PANDIKKAD, MALAPPURAM DISTRICT 676 521

              BY ADV. SRI.S.KRISHNAMOORTHY
              BY ADV. SMT.NITHYA SUGUNAN

OTHER PRESENT:
             SRI. P.M.MANOJ - SR.GP

     THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
18.01.2021, ALONG WITH WP(C).17659/2020 THE COURT ON THE SAME
DAY DELIVERED THE FOLLOWING:
 WP(C).Nos.17659 & 29222 OF 2020(F)

                                     4




                            JUDGMENT

While the petitioner was working as the Headmaster of the

A.U.P.School, Chembrasseri, he was placed under suspension.

Subsequently, a charge sheet was issued to the petitioner by the

Manager of the said School; and in the meanwhile, the initial

period of suspension of 15 days, ordered by the Manager, was

extended by the jurisdictional Assistant Educational Officer

(AEO), through an order dated 02.09.2019, a copy of which is on

record as Ext.P12 in W.P.(C)No.17659/2020. The petitioner

approached the District Educational Officer (DEO) against this

order, which culminated in Ext.P16, produced along with W.P.

(C)No.17659/2020, setting it aside and directing that the

petitioner be proceeded against for dereliction of duty or

violation of the provisions of the Kerala Educational Act and

Rules (Act and KER respectively for short) only after following

due procedure.

2. It appears that the afore mentioned order of the DEO

was challenged by the Manager, by preferring a statutory

Revision before the Government, finally culminating in Ext.P25 WP(C).Nos.17659 & 29222 OF 2020(F)

order marked in W.P.(C)No.17659/2020, whereby, the directions

of the DEO were vacated and the enquiry against the petitioner

was directed to be completed within one month.

3. The petitioner challenges this order of the Government

on various grounds , but primarily that it does not disclose any

valid reason as to why he has been continued under suspension

beyond 15 days, as is required under the provisions of Rule 67 of

Chapter XIVA of the KER.

4. While so, since the petitioner was not able to obtain

any interdictory orders in W.P.(C)Nos.17659/2020, the Manager

continued with the enquiry proceedings, leading to Ext.P11

report in W.P.(C)No.29222/2020 and placed it for concurrence,

before the DEO, as is required under the provisions of Rule 71 of

Chapter XIVA of the KER, since he has proposed the reversion

of the petitioner to lower rank as punishment.

5. The petitioner thus challenges Ext.P19 notice in W.P.

(C)No.29222/2020, issued by the DEO, Malappuram, under

which he has been notified of a hearing scheduled on WP(C).Nos.17659 & 29222 OF 2020(F)

29.12.2020. The petitioner says that Ext.P19 is incompetent,

since the DEO, who is now going to conduct the enquiry, was the

same person, while he was an AEO, who ordered initiation of the

enquiry against him, and therefore, that any decision that he

may take will be vitiated by technical and actual bias. The

petitioner, therefore, prays that the entire proceedings against

him, as also the impugned orders in these writ petitions be set

aside.

6. In response to the submissions of Sri.Biju Abraham,

learned counsel for the petitioner as afore, Sri.Krishnamoorthy,

the learned counsel for the Manager, submitted that W.P.

(C)No.17659/2020 is no longer relevant because his client has

completed the enquiry under Rule 75 Chapter XIVA of the KER

and has placed his report before the DEO, under Rule 71

Chapter XIVA of the KER, for concurrence. He submitted that

since the petitioner has not sought to challenge the disciplinary

report of the Manager, namely Ext.P11 in W.P.

(C)No.29222/2020, but has confined his challenge only to

Ext.P19 notice issued to him by the DEO, both these writ WP(C).Nos.17659 & 29222 OF 2020(F)

petitions are not maintainable.

7. After saying as above, Sri.Krishnamoorthy submitted

that, in fact, on an earlier occasion, a learned Judge of this

Court had issued an interim order in W.P.(C)No.17659/2020 to

reinstate the petitioner, but that the same was vacated by a

Division Bench of this Court in W.A.No.1545/2020, wherein, the

Manager was directed to complete the enquiry proceedings

within a period of one month from the date of the said

judgment. He submitted that, thereafter, the petitioner filed

Review Petition No.944/2020 against the said judgment,

wherein, reiteratingly, the learned Division Bench concluded

that the proceedings before the DEO cannot be interfered at

this stage and that the said Authority must be allowed to

complete it as per law. Sri.Krishnamoorthy therefore, prayed

that both these writ petitions be dismissed and the DEO be

allowed to complete the proceedings, as initiated by him

through Ext.P19 notice in W.P.(C)No.29222/2020.

8. When I consider the afore submissions, it is without WP(C).Nos.17659 & 29222 OF 2020(F)

doubt that W.P.(C)No.17659/2020 has been filed by the

petitioner impugning Ext.P25 therein, which grants sanction for

the continuation of the petitioner's suspension beyond 15 days;

with a resultant direction therein that the enquiry proceedings

against him be concluded within a time frame. The petitioner's

specific contention is that the earlier order of the AEO, namely

Ext.P12 therein, allowing the extension of the suspension is

without recording any reason which would justify it and that the

DEO, through Ext.P16 order, has confirmed the same, again

without recording any justifiable cause. The petitioner asserts

that Ext.P25 order of the Government is also vitiated for the

same reason, because it also does not record the reason why

such an extension of suspension is warranted. The petitioner in

support, relies on a judgment of this Court in Balakrishnan M.

v. State of Kerala and Others [2016 (5) KHC 693], which

has affirmatively declared that no suspension can be extended

beyond the period of 15 days unless reasons are recorded and

unless the said reasons justify such a course.

9. I have, therefore, examined Ext.P25 order in W.P.

(C)No.17659/2020 very carefully.

WP(C).Nos.17659 & 29222 OF 2020(F)

10. The view of the Government is available in the

penultimate page of the said order, wherein, it has been

recorded that the allegations against the petitioner are

grievous, which will require a full fledged enquiry. The charge

sheets issued to the petitioner have been looked into in some

detail in the said order and the competent Secretary of the

Government has concluded that such charges require a proper

enquiry, before it can be held to be proved or otherwise.

11. Since the Government has taken a view that the

charges leveled against the petitioner are grievous and that an

enquiry is necessary, it is obvious that the same operate as the

reasons why the suspension of the petitioner should continue,

particularly because it is also stated therein that the

continuation of the petitioner as Headmaster of the School,

when he is being enquired into, would not auger well for the

institution and therefore, that it is better that he be kept away

from service during such process.

12. I cannot find the reasoning in Ext.P25 to be without

rationale and I therefore, cannot see any reason why the same

should be set aside at this stage.

WP(C).Nos.17659 & 29222 OF 2020(F)

13. That said, the challenge to Ext.P25 in W.P.

(C)No.17659/2020 is unnecessary at this distance of time

because, pending the said writ petition, the Manager was

allowed to continue with the enquiry proceedings, thus

culminating in Ext.P11 enquiry report, produced in W.P.

(C)No.29222/2020. This enquiry report will now have to be

given concurrence to by the competent Authority and unless

such an order is issued, there would be no prejudice caused to

the petitioner.

14. Of course, Sri.Biju Abraham, learned counsel for the

petitioner, argues that the present DEO will not be in a position

to dispassionately deal with the Manager's request for

concurrence of his enquiry report, because he had earlier issued

Exts. P3 & P4 order, produced in W.P.(C)No.17659/2020 against

his client. The allegation made, therefore, is that the DEO will

act with prejudice and that the petitioner will not be in a position

to obtain justice from him.

WP(C).Nos.17659 & 29222 OF 2020(F)

15. However, when I examine Exts.P3 and P4 in W.P.

(C)No.17659/2020, it is evident that the incumbent AEO has not

issued or made any detrimental orders or remarks against the

petitioner, but has only requested or directed him to act

responsibly as a Headmaster of the School, particularly taking

note of the fact that several teachers and non teaching staff had

made complaints against him. This by itself cannot persuade me

to hold that the said officer will only act against the interests of

the petitioner, even though Sri.Biju Abraham explains that it is

based on these orders that 37 Teachers had filed a subsequent

complaint seeking enquiry against his client. The tenor of

Exts.P3 and P4 in W.P.(C)No.17659/2020 is, in fact, conciliatory

in nature and the attempt of the AEO at that time was to make

the situation in the school less tense, so that the Teachers and

the Headmaster can co-exist and work together as a team.

16. I am therefore, of the firm opinion that merely

because the then AEO - who is the present DEO - had issued

Exts.P3 and P4 in W.P.(C)No.17659/2020, he would not consider

the relevant factors and inputs, including the Manager's report,

namely Ext.P11 in W.P.(C)No.29222/2020, in the manner that it WP(C).Nos.17659 & 29222 OF 2020(F)

deserves to be dealt with as per the provisions of the KER.

17. The above being said, the DEO must implicitly, keep

in mind that what is expected of him under the provisions of the

KER is that he dispassionately examine the report of the

Manager, in the light of all the other imputs that are available,

and decide whether concurrence for the proposed punishment

ought to be granted. The responsibility on the DEO is very acme

as far as the KER is concerned, because if the Manager's actions

are not in conformity with the extant provisions of law, then it is

for the said officer to ensure that it is set right at this stage

itself.

18. In that perspective, I am certain that the DEO must

hear the parties and arrive at a considered opinion - after closely

examining Ext.P11 enquiry report produced along with W.P.

(C)No.29222/2020 - as to whether the punishment as proposed

therein, should be concurred with or otherwise. I am sure if the

DEO takes a decision dispassionately and prudently, keeping in

mind the spirit and purpose of the statutory provisions that WP(C).Nos.17659 & 29222 OF 2020(F)

enable such an exercise under the KER, then the petitioner will

have no cause in feeling threatened.

In the afore circumstances, I dismiss W.P.(C)No.17659/2020

and dispose of W.P.(C)No.29222/2020, directing the DEO to hear

the petitioner, as also the Manager of the School, pursuant to

Ext.P19 notice in W.P.(C)No.29222/2020, on a fresh date to be

fixed by him, after appropriately notifying both sides; and to

complete the proceedings, keeping in mind my observations

above with respect to his responsibilities and duties as a

concurring officer under Rule 71 of Chapter XIVA of the KER.

The afore exercise shall be completed by the DEO as

expeditiously as possible but within the time frame fixed by the

Divison Bench in I.A.No.3/2020 in W.A.No.1545/2020, namely

within one month from 11.01.2021.

These writ petitions are thus disposed of.

SD/-

                                           DEVAN RAMACHANDRAN

rp                                                JUDGE
 WP(C).Nos.17659 & 29222 OF 2020(F)





                       APPENDIX OF WP(C) 17659/2020

PETITIONER'S/S EXHIBITS:

EXHIBIT P1                 A TRUE COPY OF THE NOTICE CIRCULATE BY THE MEMO
                           DATED 02.08.2018.

EXHIBIT P2                 A TRUE COPY OF THE NOTICE DATED 19.11.2018 ISSUED
                           BY THE PETITIONER TO THE TEACHERS.

EXHIBIT P3                 A TRUE COPY OF THE ORDER DATED 30.03.2019 OF THE
                           3RD RESPONDENT.

EXHIBIT P4                 A TRUE COPY OF THE ORDER DATED 30.05.2019 OF THE
                           3RD RESPONDENT.

EXHIBIT P5                 A TRUE COPY OF THE REPORT OF THE PETITIONER DATED

14.06.2019 OF THE ACADEMIC YEAR 2019-20.

EXHIBIT P6 A TRUE COPY OF THE STAFF FIXATION ORDER DATED 16.07.2019 OF THE 3RD RESPONDENT.

EXHIBIT P7 A TRUE COPY OF THE ORDER OF SUSPENSION DATED 21.08.2019 OF THE 4TH RESPONDENT TO THE PETITIONER.

EXHIBIT P8 A TRUE COPY OF THE ALLEGATION OF CHARGE SHEET DATED 21.08.2019 GIVEN BY THE 4TH RESPONDENT TO THE PETITIONER.

EXHIBIT P9 A TRUE COPY OF THE CHARGE MEMO ISSUED BY THE 4TH RESPONDENT DATED 21.08.2019 TO THE PETITIONER.

EXHIBIT P10 A TRUE COPY OF THE COMPLAINT ALLEGED TO HAVE BEEN GIVEN BY 31 TEACHERS TO THE 4TH RESPONDENT NIL DATED.

EXHIBIT P11 A TRUE COPY OF THE EXPLANATION GIVEN BY THE PETITIONER TO THE 4TH AND 3RD RESPONDENTS.

EXHIBIT P12 A TRUE COPY OF THE ORDER DATED 02.09.2019 OF THE 3RD RESPONDENT.

EXHIBIT P13 A TRUE COPY OF THE ORDER DATED 03.09.2019 OF THE 4TH RESPONDENT.

EXHIBIT P14 A TRUE COPY OF THE APPEAL FILED BY THE PETITIONER BEFORE THE 2ND RESPONDENT.

EXHIBIT P15 A TRUE COPY OF THE JUDGMENT DATED 01.10.2019 IN WPC NO. 24815/2019.

WP(C).Nos.17659 & 29222 OF 2020(F)

EXHIBIT P16 A TRUE COPY OF THE ORDER DATED 04.11.2019 OF THE 2ND RESPONDENT.

EXHIBIT P17 A TRUE COPY OF THE REQUEST SUBMITTED BY THE PETITIONER TO THE 3RD RESPONDENT.

EXHIBIT P18 A TRUE COPY OF THE JUDGMENT IN WPC NO. 30424/2019 DATED 12.11.2019.

EXHIBIT P19 A TRUE COPY OF THE COMMUNICATION SEND BY THE PETITIONER TO THE 1ST RESPONDENT DATED 23.11.2019.

EXHIBIT P20 A TRUE COPY OF THE REVISION FIELD BY THE 4TH RESPONDENT DATED 07.11.2019 BEFORE THE EDUCATIONAL MINISTER OF KERALA STATE.

EXHIBIT P21 A TRUE COPY OF THE ORDER OF STAY GRANTED BY THE 1ST RESPONDENT IN THE REVISION FIELD BY THE 4TH RESPONDENT DATED 27.11.2019.

EXHIBIT P22 A TRUE COPY OF THE WITHDRAWAL OF STAY ORDER DATED 18.12.2019 ISSUED BY THE 1ST RESPONDENT.

EXHIBIT P23 A TRUE COPY OF THE ARGUMENT NOTE SUBMITTED BY THE PETITIONER BEFORE THE 1ST RESPONDENT ON 04.01.2020.

EXHIBIT P24 A TRUE COPY OF THE GUIDELINES ISSUED BY THE 1ST RESPONDENT AS PER CIRCULAR DATED 28.06.19.

EXHIBIT P25 A TRUE COPY OF THE GOVERNMENT ORDER DATED 25.06.2020 RECEIVED BY THE PETITIONER ON 19.08.2020.

EXHIBIT P26 A TRUE COPY OF THE INTIMATION GIVEN BY THE 3RD RESPONDENT TO THE PETITIONER.

EXHIBIT P27 A TRUE COPY OF THE LAWYERS NOTICE SEND ON BEHALF OF THE PETITIONER TO THE 3RD RESPONDENT DATED 27- 08-2020.

EXHIBIT P28 A TRUE COPY OF THE LETTER GIVEN BY TEACHER K.P.

GIRIJA DATED 02/03/2019.

EXHIBIT P29 A TRUE COPY OF THE LETTER GIVEN BY TEACHER MANJO P TO THE PETITIONER DATED 02/03/2019.

EXHIBIT P30 A TRUE COPY OF THE REPORT GIVEN BY THE 3RD RESPONDENT DATED 22/09/2020 WITH COVERING LETTER. WP(C).Nos.17659 & 29222 OF 2020(F)

EXHIBIT P31 A TRUE COPY OF THE SHOW CAUSE NOTICE DATED 29/09/2020 OF THE 4TH RESPONDENT.

EXHIBIT P32 A TRUE COPY OF THE COMMUNICATION DATED 02/12/2020 OF THE MANAGER.

EXHIBIT P33 A TRUE COPY OF THE JUDGMENT IN WA NO.1545/2020 OF THIS HON'BLE COURT DATED 01/11/2020.

RESPONDENT'S/S EXHIBITS:

EXHIBIT R4(A) TRUE COPY OF THE SHOW CAUSE NOTICE DATED 30/11/2018 ISSUED BY THE 4TH RESPONDENT.

EXHIBIT R4(B) TRUE COPY OF THE COMPLAINT DATED 03/01/2019 GIVEN BY 37 TEACHERS.

EXHIBIT R4(C) TRUE COPY OF THE CHARGE SHEET ALONG WITH ALLEGATION OF CHARGES DATED 22/02/2019.

EXHIBIT R4(D) TRUE COPY OF THE CHARGE SHEET ALONG WITH ALLEGATION OF CHARGES DATED 18/03/2019.

EXHIBIT R4(E) TRUE COPY OF THE COMPLAINT DATED 15/08/2019 GIVEN BY THE TEACHERS.

EXHIBIT R4(F) TRUE COPY OF THE CHARGE SHEET ALONG WITH STAEMENT OF ALLEGATION DATED 21/08/2019.

EXHIBIT R4(G) TRUE COPY OF THE ORDER OF THE 3RD RESPONDENT DATED 02/09/2019.

EXHIBIT R4(H) TRUE COPY OF THE JUDGMENT DATED 12/12/2019 IN WPC NO.33977/2019.

EXHIBIT R4(I) TRUE COPY OF THE INTERIM ORDER DATED 29/01/2020 IN WPC NO.2480/2020.

EXHIBIT R4(J) TRUE COPY OF THE REPORT OF THE 3RD RESPONDENT DATED 22/09/2020.

EXHIBIT R4(K) TRUE COPY OF THE SHOW CAUSE NOTICE DATED 29/0992020 ISSUED BY THE 5TH RESPONDENT. WP(C).Nos.17659 & 29222 OF 2020(F)

APPENDIX IN WPC 29222/2020

PETITIONER'S/S EXHIBITS:

EXHIBIT P1 A TRUE COPY OF THE NOTICE DATED 19.11.2018 ISSUED BY THE PETITIONERS TO THE TEACHERS

EXHIBIT P2 A TRUE COPY OF THE ORDER OF SUSPENSION DATED 21.8.2019 ISSUED BY THE 3RD RESPONDENT TO THE PETITIONER

EXHIBIT P3 A TRUE COPY OF THE ALLEGATION OF CHARGE SHEET DATED 21.8.2019 ISSUED BY THE 3RD RESPONDENT TO THE PETITIONER

EXHIBIT P4 A TRUE COPY OF THE CHARGE MEMO ISSUED BY THE 3RD RESPONDENT DATED 21.8.2019 TO THE PETITIONER

EXHIBIT P5 A TRUE COPY OF THE ORDER DATED 4.11.2019 OF THE 1ST RESPONDENT

EXHIBIT P6 A TRUE COPY OF THE ORDER OF STAY GRANTED BY THE SECRETARY TO GOVERNMENT IN THE REVISION FILED BY THE 3RD RESPONDENT DATED 27.11.2019

EXHIBIT P7 A TRUE COPY OF THE WITHDRAWAL OF STAY ORDER DATED 18.12.2019 ISSUED BY THE SECRETARY TO GOVERNMENT

EXHIBIT P8 A TRUE COPY OF THE ORDER DATED 29.1.2020 OF THIS HON'BLE COURT IN W.P.(C) NO.2480/2020

EXHIBIT P9 A TRUE COPY OF THE ORDER DATED 25.6.2020 RECEIVED BY THE PETITIONER ON 19.8.2020

EXHIBIT P10 A TRUE COPY OF THE ORDER DATED 25.9.2020 IN W.P.

(C) NO.17659/2020 OF THIS HON'BLE COURT

EXHIBIT P11 A TRUE COPY OF THE ENQUIRY REPORT SUBMITTED BY THE 2ND RESPONDENT DATED 22.9.2020

EXHIBIT P12 A TRUE COPY OF THE SHOW CAUSE NOTICE DATED 29.9.2020 BY THE MANAGER TO THE PETITIONER

EXHIBIT P13 A TRUE COPY OF THE COMMUNICATION OF THE 3RD RESPONDENT TO THE PETITIONER DATED 7.10.2020

EXHIBIT P14 A TRUE COPY OF THE ORDER DATED 20.11.2020 OF THE LEARNED SINGLE JUDGE IN W.P.(C). 17659/2020 WP(C).Nos.17659 & 29222 OF 2020(F)

EXHIBIT P15 A TRUE COPY OF THE JUDGMENT IN WA. NO.1545/2020 OF THIS HON'BLE COURT DATED 1.12.2020

EXHIBIT P16 A TRUE COPY OF THE SHOW CAUSE NOTICE 2.12.2020 OF THE 3RD RESPONDENT TO THE PETITIONER

EXHIBIT P17 A TRUE COPY OF THE REPLY SUBMITTED BY THE PETTIONER 16.12.2020

EXHIBIT P18 A TRUE COPY OF THE CORRECTION PETITON FILED BY THE 3RD RESPONDENT BEFORE THIS HON'BLE COURT IN WA.NO.1545/2020 DATED 21.12.2020

EXHIBIT P19 A TRUE COPY OF THE HEARING NOTICE DATED 22.12.2020 OF THE FIRST RESPONDENT TO THE PETITIONER

EXHIBIT P20 A TRUE COPY OF THE NOTICE DATED 30.12.2020 GIVEN BY THE 1ST RESPONDENT TO THE PETITIONER