M.P Jose vs The Land Revenue Commissioner
2021 Latest Caselaw 1959 Ker

          IN THE HIGH COURT OF KERALA AT ERNAKULAM

                            PRESENT

              THE HONOURABLE MR.JUSTICE N.NAGARESH

 TUESDAY, THE 19TH DAY OF JANUARY 2021/29TH POUSHA, 1942

                    WP(C).No.1820 OF 2019(B)


PETITIONER:

              M.P JOSE,
              AGED 46 YEARS,
              S/O.PURAVATH, MADATHIKUDIYIL HOUSE,
              KINGINIMATTAM.P.O., KOLENCHERRY,
              ERNAKULAM DISTRICT.

              BY SRI.K.DANDAPANI (SR.)
              BY ADV. SRI.SAJEEV KUMAR K.GOPAL

RESPONDENTS:

     1        THE LAND REVENUE COMMISSIONER,
              OFFICE OF THE LAND REVENUE COMMISSIONER,
              PUBLIC OFFICE COMPOUND, MUSEUM JUNCTION,
              THIRUVANANTHAPURAM-695009.

     2        THE JOINT LAND REVENUE COMMISSIONER,
              OFFICE OF THE LAND REVENUE COMMISSIONER,
              PUBLIC OFFICE COMPOUND, MUSEUM JUNCTION,
              THIRUVANANTHAPURAM-695009.

     3        THE DISTRICT COLLECTOR,
              (THE DISTRICT MAGISTRATE),
              MALAPPURAM-676505.

     4        SRI.K.D. DEVASSIYA,
              CONVENOR, VIDAVUMALA SAMRAKSHANA SAMITHY,
              MATTARAKKAL, THAZHEKODE,
              ARAKKUPARAMBU VILLAGE-679 322.

ADDL. 5       JOSEPH MATHEW,
              AGED 33 YEARS,
              S/O.MATHEW, KIZHAKKEVEETTIL (H),
              MATTARAYKKAL (P.O), ARAKKUPARAMBY VILLAGE,
              PERINTHALMANNA, MALAPPURAM DISTRICT-679 322.
 WP(C) No.1820/2019
                             :2 :


ADDL. 6       JOSEPH,
              AGED 39 YEARS, S/o ANTONY,
              KALAPPURAKKAL HOUSE, VIDAVUMALA,
              MATTARAYKKAL (P.O), ARAKKUPARAMBY VILLAGE,
              PERINTHALMANNA, MALAPPURAM DISTRICT-679 322

ADDL. 7       JOHNY,
              AGED 39 YEARS, S/o JOSEPH,
              KOLLIYIL (H), VIDAVUMALA, MATTARAYKKAL (P.O),
              ARAKKUPARAMBY VILLAGE, PERINTHALMANNA,
              MALAPPURAM DISTRICT-679 322.

ADDL. 8       BRIJI BIJU,
              AGED 39 YEARS,
              S/O.BIJU VARGHESE, THEKKEKARA(H),
              VIDAVUMALA, MATTARAYKKAL (P.O),
              ARAKKUPARAMBY VILLAGE, PERINTHALMANNA,
              MALAPPURAM DISTRICT-679 322.

              ADDITIONAL R5 TO R8 ARE IMPLEADED AS PER ORDER
              DATED 22/03/2019 IN IA NO.1/2019.

              R5-8 BY ADV. SRI.K.DILIP
              R1-3 BY GOVERNMENT PLEADER SMT DEEPA NARAYANAN

     THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD
ON 19-01-2021, THE COURT ON THE SAME DAY DELIVERED THE
FOLLOWING:
 WP(C) No.1820/2019
                                :3 :




                        JUDGMENT

~~~~~~~~~

Dated this the 19th day of January, 2021

The petitioner is one of the Managing Partners of

M/s.Thazhakode Sands, a partnership firm engaged in

manufacture and sale of granite, metals, rubbles, sand and

other allied products. The Firm is in absolute possession of 36

Acres of land in Perinthalmanna Taluk. The petitioner is

aggrieved by Exts.P19 and P24 orders of the District

Magistrate and Land Revenue Joint Commissioner

respectively, whereby the petitioner's application for NOC for

establishing an explosive magazine in the land of the

petitioner, stands cancelled.

2. The petitioner states that the land of the petitioner

is not a classified Ecologically Fragile Land (EFL) as

evidenced by Ext.P1. The Ext.P2 to P6 certificates would

show that the land in question is more than 500 m. away from WP(C) No.1820/2019

forest area. As the petitioner proposed to start a crusher unit

and to start quarrying operations in his land, the petitioner

applied for NOC for constructing an explosives storage

magazine. The Tahsildar, Perinthalmanna issued Ext.P7

communication to the District Collector stating that the

explosives magazine is not proposed to be constructed in

forest area and that there are no litigations in respect of the

land. The nearest residences are more than 300 m. far.

Therefore, licence can be granted to start explosives

magazine.

3. By Ext.P8, the Tahsildar informed the General

Manager of District Industries Centre that the land in question

is not included in the EFL and that landslide was reported in

the year 2004 at a place which is 300 m. far from the

petitioner's property. Certain persons filed W.P.(C) No.2548

of 2012 seeking to cancel the order of District Single Window

Clearance Board given to the petitioner. The petitioner filed

W.P.(C) No.20548 of 2016 seeking police protection. Both the

writ petitions were heard by a Division Bench of this Court. WP(C) No.1820/2019

The Division Bench of this Court rejected the contention of the

petitioners in W.P.(C) No.2548/2012 that the petitioner's land

is falling in EFL Zone.

4. The District Magistrate considered the application

of the petitioner for NOC for starting explosives magazine.

The District Magistrate considered the report of the District

Police Chief. The 3rd respondent-District Magistrate noticed

that the Tahsildar has recommended that NOC can be

granted for construction of magazine on certain conditions.

The Senior Geologist also has given NOC. The 3rd

respondent further found that this Court has held that the area

does not fall within EFL. The Fire and Rescue Divisional

Officer has granted NOC.

5. The 3rd respondent heard all parties including those

who made complaints against the proposed quarry. The 3rd

respondent caused inspection of the area by the Additional

District Magistrate. The 3rd respondent noted that the applicant

has 26 Acres of land in possession and the magazine and the

quarry will be within an area of hardly 2.5 Acres. Taking into WP(C) No.1820/2019

consideration all these facts, the 3rd respondent passed

Ext.P11 order dated 27.01.2016 permitting issuance of NOC

to the petitioner.

6. Ext.P11 was issued on condition that if the Director

of Centre for Earth Science Studies (CESS) gives an adverse

report, the NOC will be withdrawn and the licence will be

cancelled. The 3rd respondent further directed that the

petitioner should provide for adequate security arrangements

including service of watchmen. Accordingly, Ext.P12 NOC

dated Nil.01.2016 was issued to the petitioner granting licence

under Rules 102 and 103 of the Explosives Rules, 2008.

7. To the surprise and a predicament of the petitioner,

the 3rd respondent issued Ext.P16 order on 13.03.2017

cancelling Ext.P12 NOC granted to the petitioner. In Ext.P16,

it was stated that the Sub Collector, Perinthalmanna has

reported that the area is EFL, that tribals settlements and

Kodikuthy Mala Eco-tourism Project are existing nearby, that

there are Drinking Water Projects which will be contaminated

once quarry becomes operational, that law and order issues WP(C) No.1820/2019

are likely to arise and hence the NOC granted should be

reviewed. The Deputy Superintendent of Police, Vigilance

and Anti corruption Bureau has also reported in similar lines,

observed the 3rd respondent.

8. Aggrieved by Ext.P16, the petitioner filed W.P.(C)

No.9664 of 2017. This Court found that Ext.P16 was passed

violating principles of natural justice, set aside Ext.P16 and

directed the 3rd respondent to pass orders afresh. The 3rd

respondent again passed order cancelling the NOC, as per

Ext.P19 stating that the proposed magazine site is in a

landslide-prone area, and the construction is likely to result in

environmental pollution. Aggrieved by Ext.P19, the petitioner

filed Ext.P20 appeal before the Land Revenue Commissioner.

The 2nd respondent-Land Revenue Joint Commissioner who

considered Ext.P1 held that the cancellation of NOC by the 3rd

respondent is legal. But, at the same time, the 2nd respondent

noticed certain procedural irregularity in arriving at Ext.P19

and hence directed the 3rd respondent to pass orders afresh,

as per Ext.P21.

WP(C) No.1820/2019

9. The petitioner filed W.P.(C) No.34124 of 2018

against Ext.P21 order. The said writ petition was disposed of

by this Court as per Ext.P23 judgment finding that remand of

the issue by the 2nd respondent-Appellate Authority after

finding that the original order is legal, would not serve any

purpose and that in case the order is found to be bad for

procedural irregularity, the order passed by the District

Magistrate would have to go and the matter should be

remanded for fresh consideration. This Court accordingly set

aside Ext.P21 and directed the 2nd respondent-Land Revenue

Joint Commissioner to consider the appeal on its merits.

10. The 2nd respondent, who reconsidered the appeal,

held as per Ext.P24 order that it has been stated in a

Government Circular dated 30.08.2018 that the Government

proposes to conduct a scientific study on the impact of

construction activities in landslide-prone areas and has

informed that no construction activities can be allowed in

Ecologically Fragile Lands in landslide-prone areas, till the

completion of the study and therefore granting permission to WP(C) No.1820/2019

the petitioner to construct an explosives magazine in the area,

amounts to over reaching the government decision. Therefore,

there is no reason to interfere with the order passed by the 3rd

respondent.

11. The learned Senior Counsel assisted by the

counsel for the petitioner argued that the complainants are

residing far away from the proposed site and they are not

aggrieved in any manner. The petitioner has been pursuing

for NOC for long and the petitioner is being driven from pillar

to post, in spite of favourable reports given by all competent

authorities. Exts.P19 and P24 orders have been passed

without taking into account the procedure for issuance and

cancellation of NOCs contemplated under Rules 102 and 103

of the Explosives Rules, 2008.

12. The learned Senior Counsel submitted that this

Court has held in Ext.P15 judgment that the land of the

petitioner is not within EFL. The NOC has been declined on

an erroneous assumption that the petitioner's land is prone to

landslides. Landslide has not occurred anywhere in the large WP(C) No.1820/2019

extent of petitioner's property. A minor or rather trivial

landslide had occurred at a place more than 300 m. away and

that too in the year 2004. There were neither human or

animal casualties nor damage to structures due to the

so-called landslide of the year 2004. The alleged landslide is

only a ruse to decline NOC to the petitioner and it is only by

way of harassment. No competent authority has

found/declared that the area is landslide-prone. Ext.P27

quarrying lease was issued by the Geologist after considering

all aspects of the case. In the facts of the case, Exts.P19 and

P24 are liable to be set aside, permitting the petitioner to go

ahead with the work of constructing explosives magazine,

contended the Senior Counsel.

13. The 1st respondent contested the writ petition filing

counter affidavit. The 1st respondent stated that the land

where the granite crusher unit is proposed to be established

was never notified as EFL under Section 4 of the Kerala

Forest (Vesting and Management of Ecologically Fragile

Lands) Act, 2003. The 1st respondent further stated that WP(C) No.1820/2019

Ext.P2 Circular is intended to protect the ecologically fragile

and notified areas from alienation and bifurcations. The 1 st

respondent stated that the functioning of a granite crusher unit

will cause air-pollution and other inconvenience to the nearby

inhabitants.

14. The 3rd respondent filed a separate counter

affidavit. The 3rd respondent stated that as per Section 103 of

the Explosives Rules, satisfaction of public interest is one of

the prime factor to be considered while issuing explosives

licence. A number of complaints were received against

issuance of NOC to the petitioner. Proximity of the unit to

tourism place, and Scheduled Tribe Colony, drinking water

projects and other matters affecting the society, were taken

into account while cancelling the NOC issued to the petitioner.

15. The 4th respondent also resisted the writ petition.

The 4th respondent stated that the proposed land is on a

sloppy Hill having more than 40° slope. Kodikuthy Mala

Tourism destination is at the top of the hill. The southern

boundary of the land of the petitioner is forest land. The WP(C) No.1820/2019

quarry is likely to cause natural calamity including landslide.

Bidavu Mala water tank constructed under a drinking water

project would be contaminated as it is within hundred metres

radius of the proposed crusher unit. Landslides happened in

this area in the years 2004 and 2018 and the locals suffered

heavy loss. As evident from Ext.R4(A), the predecessor-in-

interest of the petitioner's land had also received

compensation from the Government for the loss suffered in

2004 landslide. Kundan Chola water stream which is a source

of drinking water would be affected by the proposed quarry

and crusher unit. The petitioner produced concocted

documents and played foul play to obtain Ext.P12 NOC.

16. Sri. K. Dilip, learned Counsel for the 4 th and

additional 5th to 8th respondents, brought to the notice of this

Court Ext.R4(B) award list to show that landslide had occurred

and a number of people in the area were compensated.

Comparing the same document numbers in Ext.P1 and

Ext.R4(E) documents, the learned counsel argued that Ext.P1

certificate produced by the petitioner is a forged document. WP(C) No.1820/2019

Relying on Ext.R4(H), the counsel contended that landslide

had occurred in the very same property. The learned counsel

pointed out that the proposed area is having more than 45°

slope and quarrying in the area may result in landslide and

heavy casualties.

17. I have heard learned counsel for the petitioner,

learned Government Pleader representing respondents 1 to 3

and learned counsel appearing for the 4 th respondent and

additional respondents 5 to 8.

18. The petitioner was initially issued with Ext.P12 NOC

based on Ext.P11 proceedings of the District Magistrate.

Ext.P11 proceedings would show that it was issued by the

District Magistrate after considering the reports of the District

Police Chief, Tahsildar, Senior Geologist and the Fire and

Rescue Divisional Officer. In Ext.P11, the District Magistrate

found that the proposed quarry is situated beyond the

prohibited distance from the explosives magazine and that the

quarry and explosives magazine will be in 2.5 Acres land

within a larger extent of 26 Acres of land held by the petitioner WP(C) No.1820/2019

and hence Explosives Licence can be granted.

19. However, the NOC was cancelled by the successor

District Magistrate as per Ext.P16, on the basis of certain

reports. Ext.P16 was set aside by this Court as per Ext.P17

judgment for violation of principles of natural justice. The

District Magistrate again passed Ext.P19 order cancelling the

NOC, stating that storage of explosives will be a threat to the

life and property of local populace. NOC was cancelled on the

grounds of public interest, peace and safety.

20. In Appeal, the Appellate Authority took an

altogether different stand for cancelling the NOC. The

Appellate Authority held that as per Government Circular

dated 30.08.2018, the Government is proposing to conduct a

scientific study in respect of construction work in landslide-

prone areas and hence construction activities cannot be

allowed in landslide-prone areas in EFL. The Appellate

Authority stated that the land in question is in a landslide-

prone area.

21. Ext.P24 order of the Appellate Authority is WP(C) No.1820/2019

unsustainable for more than one reason. In Ext.P24 order

itself, the Appellate Authority states that the instruction of the

Government is not to allow constructions in the

landslide-prone areas in ecologically fragile land zones. This

Court has categorically held in paragraph 9 of Ext.P15

judgment that the land in question cannot be treated as

ecologically fragile land. The said finding of the Division

Bench of this Court was based on an affidavit filed by the 1 st

respondent therein which stated that the land of the petitioner

is situated at a distance of 1 km. far from notified EFL. For the

very same reason, the Government Circular quoted in the

impugned Ext.P24 order cannot be applied to the facts of the

case.

22. Furthermore, the question whether a particular area

is landslide-prone or not, would depend upon various factors

such as geology, slope, landform, aspect, elevation etc. The

question therefore will have to be decided by an expert

agency having sufficient expertise in the subject. It has to be

noted that even the District Collector in Ext.P11 proceedings WP(C) No.1820/2019

made it clear that NOC granted will be cancelled if it is

reported by the Director of CESS (Centre for Earth Science

Studies) that the land is fragile.

23. For the aforesaid reasons, this Court finds that

Ext.P24 order of the Appellate Authority is unsustainable.

Ext.P24 is therefore set aside. The Appellate Authority is

directed to reconsider the matter in the light of the

observations made above, after obtaining a report as to the

landslide-proneness of the land in question from the CESS or

any other competent expert agency. Necessary steps in this

regard shall be taken by the appellate authority within two

weeks and final order shall be passed within two months from

the date of receipt of such report. The petitioner, the 4 th

respondent and additional respondents 5 to 8 shall be issued

with individual notices and be heard, before passing final

order.

The writ petition is disposed of as above.

Sd/-

N. NAGARESH, JUDGE

aks/11.01.2021 WP(C) No.1820/2019

APPENDIX PETITIONER'S EXHIBITS:

EXHIBIT P1 TRUE COPY OF THE CERTIFICATE ISSUED BY THE VILLAGE OFFICER, ARAKKUPARAMBA.

EXHIBIT P2 TRUE COPY OF THE CERTIFICATE NO.C1-

2166/10 DATED 11.05.2010 ISSUED BY THE DFO, NILAMBUR.

EXHIBIT P3 TRUE COPY OF THE CERTIFICATE NO.C1-

2165/10 DATED 11.5.2010 ISSUED BY THE DFO, NILAMBUR.

EXHIBIT P4 TRUE COPY OF THE CERTIFICATE NO.C1-

2164/10 DATED 11.5.2010 ISSUED BY THE DFO, NILAMBUR.

EXHIBIT P5 TRUE COPY OF THE CERTIFICATE NO.C1-

2163/10 DATED 11.5.2010 ISSUED BY THE DFO, NILAMBUR.

EXHIBIT P6 TRUE COPY OF THE CERTIFICATE NO.C1-

2162/10 DATED 11.5.2010 ISSUED BY THE DFO, NILAMBUR.

EXHIBIT P7 TRUE COPY OF THE COMMUNICATION FROM THE TAHSILDAR PERINTHALMANNA TO THE DISTRICT COLLECTOR MALAPPURAM DATED 23.12.2011.

EXHIBIT P8 TRUE COPY OF THE COMMUNICATION FROM THE TAHSILDAR, PERINTHALMANNA TO THE GENERAL MANAGER, DISTRICT INDUSTRIAL CENTRE, MALAPPURAM DATED 19.12.2011.

EXHIBIT P9           TRUE COPY OF REPORT OF THE VILLAGE
                     OFFICER,    ARAKKUPARAMBA   TO THE
                     TAHSILDAR DATED 16.12.2011.

EXHIBIT P10          TRUE COPY OF THE COUNTER AFFIDAVIT ON
                     BEHALF OF THE STATE OF KERALA IN
                     WP(C).NO.2548 OF 2012.
 WP(C) No.1820/2019



EXHIBIT P11          TRUE COPY OF THE ORDER ISSUED BY THE

DISTRICT MAGISTRATE MALAPPURAM VIDE NO.E7 11920/2011 DATED 27.1.2016.

EXHIBIT P12 TRUE COPY OF NO OBJECTION CERTIFICATE VIDE NO.E7/11920/DDIS. DATED 1.2.2016.

EXHIBIT P13          TRUE COPY OF THE CERTIFICATE ISSUED BY
                     THE        INDUSTRIAL        EXPLOSIVE
                     PVT.LTD.NAGPUR.

EXHIBIT P14          TRUE COPY OF THE APPLICATION SUBMITTED
                     BY THE APPELLANT IN FORM AE-3.

EXHIBIT P15          TRUE   COPY   OF   THE  JUDGMENT  IN
                     WP(C)NO.20548 OF 2012 OF THE HON'BLE
                     HIGH COURT OF KERALA.

EXHIBIT P16          TRUE COPY OF THE ORDER DATED 13.3.2017
                     ISSUED BY THE 3RD RESPONDENT.

EXHIBIT P17          TRUE   COPY   OF    THE    JUDGMENT   IN
                     WP(C)NO.9664/2017    OF   THIS   HON'BLE
                     COURT.

EXHIBIT P18          TRUE COPY OF THE WRITTEN SUBMISSION
                     MADE BY THE APPELLANT BEFORE THE 1ST
                     RESPONDENT.

EXHIBIT P19          TRUE   COPY  OF   THE   ORDER   NO.E-7-
                     11920/2011 DATED 22.1.2018.

EXHIBIT P20          TRUE COPY OF THE MEMORANDUM OF APPEAL

SUBMITTED BY THE PETITIONER BEFORE THE 1ST RESPONDENT.

EXHIBIT P21 TRUE COPY OF THE ORDER PASSED BY THE 2ND RESPONDENT DATED 19.7.2018.

EXHIBIT P22 TRUE COPY OF THE REPORT OF THE DISTRICT POLICE CHIEF MALAPPURAM VIDE NO.D2B-51222/2016MM.

EXHIBIT P23 TRUE COPY OF THE JUDGMENT IN WPC.NO.34124/2018 DATED 22.10.2018. WP(C) No.1820/2019

EXHIBIT P24 TRUE COPY OF THE ORDER VIDE LRA5-

4470/2018 DATED 6.12.2018.

EXHIBIT P25 TRUE COPY OF THE GOVERNMENT ORDER VIDE DB1-521/2018/LSGD DATED 30.8.2018.

EXHIBIT P26 TRUE COPY OF THE REPORT SUBMITTED BY THE VILLAGE OFFICER, ARAKKUPARAMBU BEFORE THE TAHSILDAR, PERINTHALMANNA VIDE NO.372/18 DATED 12.12.2018.

EXHIBIT P27 TRUE COPY OF THE PROCEEDINGS DATED 8.2.2012 OF THE DIRECTOR OF MINING AND GEOLOGY.

RESPONDENTS' EXHIBITS:

EXHIBIT R4(A) A TRUE COPY OF THE VILLAGE DIARY OF ARAKKUPARAMBA VILLAGE DATED 06.06.2004

EXHIBIT R4(B) A TRUE COPY OF THE COMPENSATION AWARD LIST PUBLISHED BY THE PRINCIPAL AGRICULTURAL OFFICER, MALAPPURAM DATED NIL

EXHIBIT R4(C) A TRUE COPY OF THE SKETCH DATED NIL

EXHIBIT R4(D) A TRUE COPY OF THE SKETCH/PLAN ISSUED BY THE V.O.,ARAKKUPARAMBA DATED 31.5.2016

EXHIBIT R4(E) A TRUE COPY OF THE CERTIFICATE NO.8797/2010 ISSUED BY THE VILLAGE OFFICER DATED NIL

EXHIBIT R4(F) A TRUE COPY OF THE REPORT OF THE VILLAGE OFFICER DATED 16.12.2011

EXHIBIT R4(G) A TRUE COPY OF THE REPORT OF THE VILLAGE OFFICER DATED 22-03-2011 EXHIBIT R4(H) A TRUE COPY OF THE REPORT OF THE TAHASILDAR DATED 19-12-2011

EXHIBIT R4(I) A TRUE COPY OF THE RELEVANT PAGES OF MALAYALA MANORAMA NEWS PAPER DATED 06- 06-2004 WP(C) No.1820/2019

EXHIBIT R4(J) A TRUE COPY OF THE ORDER NO-LR JI-7327 DATED 08.07.2009

EXHIBIT R4(K) A TRUE COPY OF THE ASSIGNMENT DEED NO-

486/1966 DATED 28-2-1966

EXHIBIT R4(L) A TRUE COPY OF THE PHOTOGRAPH SHOWING ACTUAL FACT SITUATION DATED NIL

EXHIBIT R4(M) A TRUE COPY OF THE ASSIGNMENT DEED NO-

4193/I/2010 DATED 30-8-2010 EXHIBIT R4(N) A TRUE COPY OF THE ASSIGNMENT DEED NO-

4194/I/2010 DATED 30-8-2010 EXHIBIT R4(O) A TRUE COPY OF THE ARTICLE PUBLISHED DATED 20.3.2014

EXHIBIT R4(P) A TRUE COPY OF THE INSPECTION REPORT OF THE KERALA STATE POLLUTION CONTROL BOARD DATED 2/5/2017 EXHIBIT R4(Q) A TRUE COPY OF THE REPORT DATED NIL

EXHIBIT R4(R) A TRUE COPY OF THE SKETCH SUBMITTED BY THE TALUK SURVEYOR DATED 08/02/2015 EXHIBIT R4(S) A TRUE COPY OF THE DOCUMENT NO.4558/2014 DATED 20.9.2014

EXHIBIT R6(A) A TRUE COPY OF THE PHOTOGRAPHS SHOWING THE ACTUAL FACT SITUATION DATED NIL.

EXHIBIT R6(B)        A TRUE COPY OF THE RELEVANT PAGES OF
                     MALAYALA MANORAMA DAILY NEWS PAPER
                     DATED 10/08/2019
EXHIBIT R6(C)        A TRUE COPY OF THE DATA RECEIVED FROM
                     THE   VILLAGE   OFFICE,    ARAKKUPARAMBA

INCLUDING THE INSPECTION REPORT OF THE VILLAGE OFFICER DATED 22/08/2019 EXHIBIT R6(D) A TRUE COPY OF THE REPORT OF THE DISTRICT SOIL CONSERVATION OFFICER, MALAPPURAM DATED NIL.

EXHIBIT R6(E)        A TRUE COPY OF THE REPORT OF THE
                     KERALA   STATE    DISASTER    MANAGEMENT
                     AUTHORITY DATED 23/08/2019.
SR