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Sr. Lucy Kalappura vs State Of Kerala
2021 Latest Caselaw 15300 Ker

Citation : 2021 Latest Caselaw 15300 Ker
Judgement Date : 22 July, 2021

Kerala High Court
Sr. Lucy Kalappura vs State Of Kerala on 22 July, 2021
WP(C) NO. 13764 OF 2020        1



              IN THE HIGH COURT OF KERALA AT ERNAKULAM
                              PRESENT
        THE HONOURABLE MR. JUSTICE RAJA VIJAYARAGHAVAN V
    THURSDAY, THE 22ND DAY OF JULY 2021 / 31ST ASHADHA, 1943
                      WP(C) NO. 13764 OF 2020
PETITIONER:

          SR. LUCY KALAPPURA
          AGED 55 YEARS
          D/O. SCARIA KALAPPURACKAL, F. C. CONVENT,
          KARAKKAMALA P. O., MANANTHAWADY,
          WAYANAD DISTRICT - 670 645.




RESPONDENTS:

    1     STATE OF KERALA
          REPRESENTED BY THE CHIEF SECRETARY TO GOVERNMENT,
          SECRETARIAT, TRIVANDRUM - 695 001.

    2     THE DIRECTOR GENERAL OF POLICE, KERALA
          POLICE HEAD QUARTERS, VAZHUTHACAUD,
          THIRUVANANTHAPURAM,
          PIN - 695 010.
    3     SUPERINTENDENT OF POLICE
          WAYANAD, CIVIL STATION, MADATHUMPADI, KALPETTA,
          PIN - 673 122.
    4     STATION HOUSE OFFICER
          VELLAMUNDA POLICE STATION, SH54, AREEKARA,
          VELLAMUNDA,
          PIN - 670 731.
    5     SR. ANN JOSEPH
          SUPERIOR GENERAL, FC CONGREGATION, GENERALATE,
          PORTINCULA, ASOKAPURAM, ALUVA P.O., ERNAKULAM,
          PIN - 680 101.
    6     SR. LIGI MARIA
          MOTHER SUPERIOR, F. C. CONVENT, KARAKKAMALA P. O.,
 WP(C) NO. 13764 OF 2020      2



          WAYANAD DISTRICT - 670 645.
    7     FR. NOBLE THOMAS
          P.R.O. MANANTHAWADY DIOCESE, BISHOP'S HOUSE, P. B.
          NO.1, MANANTHAVADY, PIN - 670 645.
    8     FR. STEPHEN KOTTACKAL, VICAR
          KARAKKAMALA CHURCH, KARAKKAMALA P.O.,
          WAYANAD DISTRICT - 670 645.
          BY ADVS.
          SRI.GEORGE POONTHOTTAM (SR.)
          SRI.JOHN VARGHESE
          SMT.NISHA GEORGE
          SRI.A.L.GEORGE




          SRI PP THAJUDEEN, GOVERNMENT PLEADER




     THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
22.07.2021, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
 WP(C) NO. 13764 OF 2020                       3



                                          JUDGMENT

The petitioner states that she is a Nun and a member of the Franciscan

Clarist Congregation ('FCC' for the sake of brevity). She has filed this Writ

Petition invoking Article 226 of the Constitution of India seeking the following

reliefs:

(i) to issue a writ of mandamus, order or direction commanding and compelling the respondents 2 to 4 to afford sufficient, effective and meaningful police protection to the life and property of the petitioner.

(ii) to issue a writ of prohibition, order or direction restraining the respondents 5 to 8 from interfering with the peaceful living and complete freedom inside the convent to access all the common areas and to be provided with food and water to survive the life of petitioner in F.C. Convent at Karakkamala in view of the pendency of O.S.209/2019 before the Munsiff Court, Mananthawady;

(iii) to issue a writ of mandamus, order or direction commanding and compelling the 3rd respondent to preserve and protect the CCTV visuals in and around the Vicar's Residence and FC Convent, Karakkamala starting from at least 45 days prior to 28.05.2020 to protect from it being tampered or destroyed;

2. Brief facts relevant and essential for disposal of this petition

are noted herein below:-

The petitioner states that while she was a member of the FCC, in

the exercise of her rights to freedom and expression, she joined in the

protests organised by various organisations to bring to justice Bishop

Franco Mullackal, who was accused of committing serious sexual

offences. Her activities did not augur well with respondents 5 to 7, who

are her superiors. With intent to silence the petitioner, the 5th

respondent initiated proceedings to terminate her which ultimately led to

her dismissal from the congregation. Challenging the procedure and the

finding, the petitioner preferred an appeal before the Grievance

Redressal Forum. The appeal was rejected against which the petitioner

preferred a review petition which is pending consideration before His

Holiness, the Pope. The petitioner contends that respondents 5 and 6

committed various acts to tarnish her image and reputation and to drive

her off from the convent. She was denied permission to venture out of

the convent and this led the petitioner to lodge a complaint before the

4th respondent. Ext.P2 crime was registered under Section 342 of the

IPC on 19.08.2019. Later, when the 7th respondent and his associates

spread canards against her, she lodged Ext.P3 complaint based on which

Ext.P4 F.I.R was registered.

3. Petitioner goes on to assert that she published a book

"Karthavinte Namathil" recounting the bitter experiences she faced in her

life. This stirred up quite a controversy and invited the ire of respondents

5 to 7. They intensified the harassment and threats towards the

petitioner. When the petitioner felt that she would be evicted pending

the appeal before the Vatican, she instituted O.S.No. 209/2019 before

the Court of the Munsiff, Manathavady and the learned Munsiff granted

an order of interim injunction restraining the defendants in the suit from

forcefully evicting the petitioner from the plaint schedule property till

01.01.2020. According to the petitioner, the injunction order could not be

extended as the courts were not fully functioning on account of the

restrictions imposed due to the pandemic. The petitioner asserts that the

respondentS 6 to 8 took the assistance of some hooligans to drive the

petitioner away and a horde of people assembled outside the convent

and openly declared that they would do away with the petitioner.

Immediately, the petitioner lodged a complaint before the 4threspondent

based on which Ext.P7 crime was registered. The petitioner contends

that the respondents are acting in clear violation of the fundamental

rights guaranteed to her under the Constitution of India. She contends

that though several complaints were lodged before the 4th respondent,

no effective action was taken. In the said circumstances, she lodged

Ext.P8 complaint before the 3rd respondent and requested that her life

and property be protected. However, no support was extended to her.

The petitioner contends that the harassment against the petitioner

escalated and she was prevented access to the common areas. CCTV

cameras have been installed in various places inside the convent to

monitor her activities. She has been asked to vacate the convent even

during the pendency of the Civil Suit instituted by her.

4. The petitioner further states that on 28.05.2020 she wanted

to meet the 6th respondent. When the 6th respondent did not return

after meeting the Vicar of the church, she went in search. She states

that when she went to the kitchen, she had occasion to witness the 6th

and 7th respondents engaged in sexual acts. When the petitioner

questioned them for indulging in immoral activities in the holy place, she

was allegedly threatened by them. On 02.06.2020, she is stated to have

lodged a complaint before the Station House Officer, Vellamunda Police

Station. According to the petitioner, she requested the police personnel

to conduct a detailed investigation and collect the CCTV visuals. The

Police, however, did not heed her request. The petitioner contends that

the party respondents would endanger her life if necessary directions are

not issued. It is in the above backdrop that she has approached this

Court seeking directions to the Police to afford her adequate protection

to the life and property and for incidental reliefs.

5. In the counter affidavit filed by the 5th respondent, it is

stated that the petitioner joined the FCC on 24.06.1982. She made her

first profession of religious vows in the same congregation on 22.05.1985

and her final profession on 21.05.1991. She was sent for University

studies by the congregation and she passed her B.Sc and B.Ed degrees.

At the time of filing the writ petition, she was working as a teacher in the

Sacred Heart Higher Secondary School, Dwaraka, Wayanad District. A

complaint was received against the petitioner on 03.08.2003 that she

had inflicted physical violence on another sister of the Congregation.

She was transferred from FCC Convent, Kommayad to FCC Convent,

Dwaraka as per the norms. She refused to obey the transfer order. She

refused to obey the canonical norms and the rules of the congregation

and her conduct was unbecoming of a member. She violated the law of

enclosure and travel and even permitted a layperson to stay in the

convent against all norms. There were other serious allegations as well.

Disciplinary action was initiated and a show-cause notice was issued by

the Superior General of the Congregation. Later, on 11.5.2019, after

following the procedure, the General Council held a meeting at the FCC

Generalate, Aluva and a decree of dismissal from the FCC was passed.

After her dismissal from the Congregation, the petitioner has no legal

right to continue in the convent as a nun. However, to rake up

controversy and for the sake of garnering publicity, the petitioner has

been creating issues one after the other to tarnish the image of the

congregation. The allegation that the Sisters of the congregation had

harassed and threatened the petitioner, that after the publication of her

book, she was victimized and harassed etc. are denied by the 5th

respondent. Insofar as the several crimes registered at the instance of

the petitioner is concerned, it is stated that the allegations are frivolous

and have no factual foundation. The fact that the order of injunction was

not extended after 28.01.2020 is also highlighted by the said respondent.

It is further stated that the order of the Council dismissing the petitioner

from the congregation was upheld by the Congregation for the Oriental

Churches. As per the Canon Law, the petitioner is entitled to file an

appeal in the Supreme Tribunal called 'Signatura Apostolica' at the

Vatican against the decision of the Congregation for the Oriental

Churches. The appeal preferred by the petitioner was also rejected. It is

further stated that the allegation that the petitioner was deprived of food

and water in the Convent is untrue. The inmates cook their own food

and the petitioner has been causing disturbances to other inmates. The

5th respondent has vehemently denied the allegations of ill-treatment

said to have been meted out to the petitioner and it was contended that

the writ petition is one without merit and do not warrant any

interference.

6. The respondent Nos. 6 to 8 have filed a counter-affidavit,

more or less reiterating the contentions raised by the 5th respondent.

They have denied the serious allegations of harassment and torture

made by the petitioner on them. It is stated that the allegation in para

12 of the writ petition that the petitioner had occasion to witness the

respondent Nos. 6 and 8 indulging in sexual activities are absolutely

baseless and false. They are on the verge of instituting proceedings to

sue the petitioner for defaming and ridiculing them. It is further

contended that this Court will not be justified in directing the police to

collect evidence in a writ petition seeking police protection. They have

denied that the Sisters of the congregation attempted to endanger the

life of the petitioner. It is further contended that the petitioner had a

monthly salary of more than Rs.60,000/- per mensem and that she has

not been contributing any amount for the running of the convent since

the month of December 2017. It is further stated that the FCC is a

Catholic Religious Congregation and a person who is not a member of

the Congregation cannot be permitted to live in the Convent.

7. I have heard Lucy Kalappura, the petitioner, who appeared

in person, Sri. George Poonthottam, the learned Senior Counsel, who

appeared for the 5th respondent, Sri. George Varghese, the learned

counsel who appeared for the respondent Nos. 6 to 8 and Sri P.P.

Thajudheen, the learned Government Pleader.

8. The petitioner contended that she was working as a school

teacher and she has retired from her service this year. A suit has been

instituted by the petitioner seeking to interdict the respondents from

evicting her, and respondents 6 and 7 have instituted a suit with a prayer

to evict her from the Karakkamala Convent. The 6th respondent has also

instituted another suit seeking to recover the retirement benefits and the

said suit is also pending. Disciplinary proceedings were initiated only

because the petitioner supported the cause of the nuns who were

victimised by Bishop Franco Mulakkal. The petitioner was singled out and

she was discriminated against as she had attempted to air her views in

the exercise of her rights under the Constitution of India. It is contended

that the petitioner is a nun and her status cannot simply be taken away

by the respondents. It was urged that her right to live in the Convent is

intertwined with her status as a nun and therefore, the respondent Nos.

5 to 8 are not justified in insisting that the petitioner should remove

herself from the Convent. Her right to live in the Convent is being

adjudicated by the Civil Court and until the said court takes a decision

one way or the other, the petitioner is entitled to reside and the police

are bound to ensure that her life and property are protected. It is also

contended that she has been defrocked pursuant to proceedings initiated

under the Canon Law and according to the petitioner, the provisions of

the Canon Law is directly in conflict with the law of the land. The

petitioner would contend that the order of dismissal passed against her is

unsustainable under law.

9. Sri. George Poonthottam, the learned senior counsel

appearing for the 5th respondent would refer to the findings of the

General Council in the Decree of Dismissal and it was argued that the

petitioner had repeatedly violated the vows of poverty and obedience

which she professed in the Franciscan Christ Congregation. She has also

violated the proper law of the FCC regarding religious habits and

enclosure. There is also a finding that the petitioner violated the norms

of the Syro-Malabar Church which prohibits the appearance of the

religious in TV shows. According to the learned senior counsel, by

joining a religious congregation of the catholic church, the petitioner is

required to faithfully observe the religious vows made in the FCC. The

petitioner has taken the vows of obedience, chastity and poverty to be

observed as per the proper law of the FCC which include 'The Rule and

Constitution of the FCC' and 'The Way of Life of the FCC'. He contends

that repeated warnings were issued to the petitioner to correct and

mend her ways and it was when all attempts failed that the competent

authority, with the consent of the Council, dismissed the petitioner from

the Congregation. It was contended that the other members of the

convent are living a life of renunciation and detachment from the world

and have been observing the Law regarding enclosure and religious

habits. The petitioner has been swimming against the tide and she has

managed to drastically unsettle the life of the other inmates of the

convent. Reliance is placed on the show cause notice issued to the

petitioner to substantiate that there were serious allegations against the

petitioner which were all found against her. It is submitted by referring

to paragraph No.12 of the writ petition that the petitioner has even

raised sexual allegations against the Mother Superior and the Vicar of the

Church. The learned counsel points out that numerous crimes were

registered at the instance of the petitioner and some of those crimes

have already been referred to as false. The learned senior counsel

would urge that it is beyond comprehension that the other nuns in the

Convent would go to the extent of harassing the petitioner. However,

according to him, if the petitioner continues to reside in the Convent

after her final dismissal from the Congregation, it would only lead to

continuous strife and conflicts.

10. Sri.John Varghese, the learned counsel appearing for the

respondent Nos. 6 to 8 supported the arguments of the learned senior

counsel. The learned counsel would contend that baseless and

untenable allegations have been raised against the Mother Superior and

Vicar and even the other inmates of the Convent. The learned counsel

would point out that at the time of filing of the writ petition, the

contention of the petitioner was that she had preferred a review petition

challenging the order passed by the Grievance Redressal Cell at the

Vatican. The learned counsel would refer to Ext.R6(a) and it was

pointed out that the Supremum Tribunal by decree dated 27.05.2021 has

rejected the review petition as well. According to the learned counsel,

the petitioner has also retired from the School where she was working.

After the final order of dismissal, the petitioner has no right to live in the

Convent and her further stay within the FC Convent is clearly unlawful.

It would cause serious disturbance to the other inmates who have taken

the vow of obedience, chastity and poverty.

11. Sri. P.P.Thajudheen, the learned Government Pleader on

instructions submitted that pursuant to the interim order passed by this

Court, the police have been maintaining a beat book and has been

regularly visiting the convent to ensure that law and order is

maintained. It is further submitted that numerous complaints have been

received and crimes have also been registered. The petitioner had

lodged a complaint before the 3rd respondent alleging that the police are

acting hand in glove with the party respondents. The said complaint was

investigated and it was found that there was no merit in the accusations

levelled by the petitioner and Ext.P11 communication was issued to her.

Insofar as her prayer to preserve and protect the CCTV visuals are

concerned, it is contended that investigation is in the domain of the

investigating officer and if the petitioner has any grievance, she is

required to move the learned Magistrate seeking directions instead of

this Court. Reliance is placed on Sakiri Vasu v. State of U.P. and

Others [2008 (2) SCC 409] and Aleque Padamsee and Others v.

Union of India and Others [2007 (6) SCC 171] and it is argued that

under Section 156(3) of the Cr.P.C., there is an implied power in the

Magistrate to direct the officer in charge of the concerned police station

to hold a proper investigation and take all such steps that may be

necessary for ensuring a proper investigation including monitoring the

same.

12. I have anxiously considered the submissions advanced and

have perused the materials produced by the contesting parties.

13. This writ petition was filed on 08.07.2020 and when this

matter had come up before this Court an order dated 09.07.2020 was

passed directing the 4th respondent to ensure that law and order is

maintained and if necessary, to afford adequate protection to the life and

property of the petitioner from any incursions by the respondent Nos. 5

to 8.

14. At the time of filing of the writ petition, Ext.R5(a) order

passed by the General Council, FCC ordering the dismissal of the

petitioner from the Congregation had been upheld in appeal by the

Congregation of the Oriental Churches. However, the petitioner had a

right to prefer a further appeal in the Segnatura Apostolica at the

Vatican. The said appeal had also been rejected. The petitioner had

then an opportunity to prefer a review petition before the Supreme

Tribunal. From Ext.R6(b), it is evident that the review petition preferred

by the petitioner has also been dismissed. As things stand now, the

petitioner is not a member of the Congregation. This fact however is

disputed by the petitioner.

15. A reading of the writ petition filed by the petitioner would

show that she has raised serious accusations against the inmates of the

convent, the Mother Superior as well as the Vicar of the Karakkamala

Church. She states that on 19.08.2019, she was illegally confined and

she had to lodge a complaint before the police leading to registration of

Ext.P2. Later, on 13.12.2019, she lodged another complaint and Ext.P7

crime was registered. She has also lodged Ext.P8 representation before

the 3rd respondent seeking the appointment of a neutral and impartial

investigating officer. Later, she lodged Ext.P9 complaint wherein it was

alleged that she was being denied access to all the common areas and

that the 5th respondent has installed cameras inside the convent to

monitor her activities. She alleges that she has been receiving

threatening calls which led her to lodge Ext.P10 complaint before the

police. The most serious allegation levelled by her is that on 28.05.2020,

she went in search of the 6th respondent to have interaction and she

alleges that the 6th and 8th respondents were found engaged in sexual

acts inside the kitchen. A perusal of the complaints lodged by the

petitioner would reveal that allegations have been raised against the

other inmates and nuns as well. In other words, much deliberation is

not required to come to a conclusion that the relationship between the

petitioner and the other inmates is quite embittered. The police are

required to visit the convent every now and then based on one allegation

or the other raised by the petitioner alleging wrongdoing by the other

inmates.

16. The contention of the learned counsel appearing for the

party respondents essentially is that there is no justification on the part

of the petitioner in insisting to live in the Convent. The order dismissing

the petitioner from the congregation has attained finality. She has retired

from the School as well. Some of the other inmates in the convent as

well as her superiors have been arrayed as either respondent or as

accused in the proceedings initiated by the petitioner. In that view of the

matter, the insistence of the petitioner that she should be permitted to

remain the convent till finality is attained in the suit instituted before the

learned Munsiff is not justifiable is essentially the contention. There

appears to be considerable merit in the submission of the learned

counsel appearing for the respondents. The continued presence of the

petitioner in the convent would only trigger the dispute and there will be

continued disharmony.

17. One of the prayers sought for by the petitioner is for a

direction to the respondents 5 to 8 from interfering with the peaceful

living and complete freedom inside the convent, to access all the

common areas and to be provided with food and water to survive the life

of petitioner in F.C. Convent at Karakkamala in view of the pendency of

O.S.209/2019 before the Munsiff Court, Mananthawady. However, I find

that the petitioner has already approached the Civil court seeking to

interdict the respondents from evicting her from the convent. It is borne

out from the submissions that O.S No.209 of 2019 is still pending

consideration of the Munsiff Court, Mananthawady. An interim order was

passed by the Munsiff Court on 18.12.2019 restraining the respondents

from forcefully evicting the petitioner from the plaint schedule property

until 01.01.2020. However, due to various factors which include the

restrictive functioning of the court owing to the pandemic, the interim

order was not extended.

18. The Apex Court as well as this Court has held in a catena of

decisions that in matters involving civil rights, or disputes regarding title

and possession over property, it would not be proper for this Court to

invoke the extraordinary powers under Article 226 of the Constitution

and order police protection. It is also equally settled that a writ of

mandamus directing the police authorities to give protection to the

person or property can be issued when the court is satisfied that there is

a threat to the person and the authorities have failed to perform their

duties. However, it is quite a different matter to grant relief to a person

either to allegedly protect his right to property especially when the

pleading themselves disclose that disputed questions are revolved. (See

State of M.P. and Ors. v. Bhailal Bhai and Ors. [AIR 1964 SC

1006], P.R.Muralidharan v. Swami Dharmananda Theertha Padar

[(2006) 4 SCC 501]. It is also trite that the special remedy provided

under Article 226 of the Constitution of India is not intended to

supersede completely the modes of obtaining reliefs by an action in a

civil court or to deny defences legitimately open in such actions. The

police will have no authority to adjudicate on such disputes nor would it

be proper for them to do so. Since the matter is in seisin of the civil

court, it would not be proper for this Court to enter into a finding with

regard to the right of the petitioner to reside in the convent as requested

by the petitioner or to order her eviction as sought for by the party

respondents. I am of the view that in the interest of justice, it would be

appropriate for the learned Munsiff to hear the interlocutory application

and take a decision expeditiously. If either of the parties moves the

jurisdictional Munsiff within a period of one week from the date of receipt

of a copy of the judgment, the interim application shall be heard and

disposed of within a further period of three weeks. The parties shall be

bound by the order passed by the Munsiff. If either of the parties violates

the orders passed as above by the Civil Court, they may move the court

and get the order enforced. For the reasons elucidated above, I am not

persuaded to order police protection to enable the petitioner to continue

to reside in the FCC convent, Karakkamala.

19. Prayer (i) sought for by the petitioner is for a direction

commanding and compelling the respondent Nos.2 to 4 to afford

sufficient, effective and meaningful police protection to the life and

property of the petitioner. I find from the various complaints lodged by

the petitioner that she is continuously being threatened with physical

harm by known and unknown persons. As stated earlier, the petitioner

has been swimming against the tide and her commissions and omissions

have created quite an amount of controversy. In this writ petition, this

Court is not called upon to decide on the truthfulness of the rival

versions. If the petitioner is residing elsewhere than at the FCC Convent

at Karakkamala and if she approaches either the 3rd or the 4th

respondent and lodges a complaint that the party respondents or any

other person have been raising threats or interfering with her peaceful

living, the said respondents shall ascertain the truthfulness of the

allegations and afford adequate protection to the petitioner.

20. Insofar as prayer (iii) is concerned, the petitioner seeks a

direction to the 3rd respondent to preserve and protect the CCTV visuals

in and around the Vicar's Residence and FC Convent, Karakkamala

starting from at least 45 days prior to 28.05.2020 to protect from it being

tampered or destroyed. As held by the Apex Court in Sakiri (supra) and

reiterated in Alyque ( supra) the jurisdictional Magistrate has very wide

powers to direct registration of an FIR and to ensure a proper

investigation. The Court is also empowered to monitor the investigation

to ensure that the investigation is done properly. If the petitioner has a

grievance that the investigation is not proper, it is for her to approach

the learned Magistrate and seek directions. Furthermore, investigation of

a crime is in the domain of the police and it would not be proper for this

Court to direct as to how and in what manner the investigation is to be

proceeded with.

With the above directions, this Writ petition will stand disposed of.

There will be no order as to costs.

Sd/-

RAJA VIJAYARAGHAVAN V JUDGE ps

APPENDIX OF WP(C) 13764/2020

PETITIONER'S EXHIBITS

EXHIBIT P1 TRUE COPY OF THE COMPLAINT FILED BY THE PETITIONER BEFORE THE 4TH RESPONDENT ON 19.08.2019.

EXHIBIT P2 TRUE COPY OF THE F.I.R. REGISTERED BY THE 4TH RESPONDENT AGAINST THE 6TH RESPONDENT AND HER ASSOCIATES NO.145/2019 DATED 19.08.2019.

EXHIBIT P3          TRUE COPY OF THE COMPLAINT SUBMITTED BY
                    THE PETITIONER BEFORE THE 3RD RESPONDENT
                    DATED 20.08.2019.

EXHIBIT P4          TRUE COPY OF THE F.I.R. REGISTERED BY THE
                    4TH RESPONDENT DATED 20.08.2019.

EXHIBIT P5          TRUE COPY OF THE INJUNCTION ORDER ISSUED
                    BY THE MUNSIFF COURT, MANANTHAWADY IN
                    O.A.NO.209/2019 DATED 18.12.2019.

EXHIBIT P6          TRUE COPY OF THE COMPLAINT PREFERRED BY
                    THE PETITIONER BEFORE THE 4TH RESPONDENT
                    DATED 13.12.2019.

EXHIBIT P7          TRUE COPY OF THE F.I.R. REGISTERED BY THE
                    4TH RESPONDENT NO.230/2019 DATED
                    14.12.2019.

EXHIBIT P8          TRUE COPY OF THE REPRESENTATION SUBMITTED
                    BY THE PETITIONER BEFORE THE THIRD
                    RESPONDENT DATED 21.12.2019.

EXHIBIT P9          TRUE COPY OF THE COMPLAINT SUBMITTED BY
                    THE PETITIONER BEFORE THE 1ST RESPONDENT
                    AND OTHERS DATED 26.1.2020.

EXHIBIT P10         TRUE COPY OF THE COMPLAINT SUBMITTED BY
                    THE PETITIONER BEFORE THE RESPONDENTS 3
                    AND 4 DATED 03.03.2020.

EXHIBIT P11         TRUE COPY OF THE COMMUNICATION ISSUED BY
                    THE THIRD RESPONDENT TO THE PETITIONER




                    DATED 02.03.2020.

EXHIBIT P12         TRUE COPY OF THE COMPLAINT SUBMITTED BY
                    THE PETITIONER BEFORE THE 3RD RESPONDENT
                    DATED 06.06.2020.

RESPONDENTS' EXHIBITS

EXHIBIT R-5(A)      TRUE COPY OF THE DISMISSAL ORDER DATED 11-
                    05-2019 ISSUED BY THE CONGREGATION AGAINST
                    THE PETITIONER.
EXHIBIT R-6(A)      TRUE COPY OF THE DECRETUM (DECREE) IN
                    ITALIAN DATED 27-05-2021 ISSUED BY THE
                    SUPREMUM TRIBUNAL OF SIGNATURAE
                    APOSTOLICAE.
EXHIBIT R-6(B)
                    TRUE ENGLISH TRANSLATION OF EXHIBIT R-6(A)
EXHIBIT R-6(C)      TRUE COPY OF THE LETTER DATED 13-06-2021
                    ISSUED BY THE 5TH RESPONDENT IN THE WRIT
                    PETITION TO THE PETITIONER IN THE WRIT
                    PETITION.
 

 
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