Kerala High Court
The Thrippangottur Grama ... vs Pushparajan.T on 5 October, 2021
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE THE CHIEF JUSTICE MR.S.MANIKUMAR
&
THE HONOURABLE MR. JUSTICE SHAJI P.CHALY
TUESDAY, THE 5TH DAY OF OCTOBER 2021 / 13TH ASWINA, 1943
WA NO. 1189 OF 2021
AGAINST THE JUDGMENT IN WP(C) 28527/2020 DATED 16.07.2021 OF HIGH
COURT OF KERALA, ERNAKULAM
APPELLANT/S:
1 THE THRIPPANGOTTUR GRAMA PANCHAYAT,
KALLIKANDI P.O., KALLIKKANDI, PIN - 670 693, REPRESENTED
BY ITS SECRETARY.
2 THE SECRETARY,
THRIPPANGOTTOR GRAMA PANCHAYATH, KALLIKANDI P.O.,
KALLIKKANDI, KANNUR DISTRICT, PIN - 670 693.
BY ADV V. HARISH
RESPONDENT/S:
1 M.K. CHANDRAN,
AGED 45 YEARS,
S/O.KUMARAN, MADAPPURA KUNIYIL HOUSE, ELANGODE P.O.,
PANOOR, KANNUR DISTRICT - 670 692.
2 THE DIRECTOR OF MINING AND GEOLOGY,
DEPARTMENT OF MINING AND GEOLOGY, KESAVADASAPURAM,
THIRUVANANTHAPURAM - 695 004.
3 THE DISTRICT GEOLOGIST,
CIVIL STATION, KANNUR - 670 002.
4 STATE OF KERALA
REPRESENTED BY THE CHIEF SECRETARY, SECRETARIAT,
THIRUVANANTHAPURAM - 695 001.
R1 BY SRI.ALEX M.SCARIA
R2 TO R4 BY SRI. TEKCHAND V., GP
THIS WRIT APPEAL HAVING COME UP FOR ADMISSION ON 05.10.2021,
ALONG WITH WA.NOS. 1225/2021, 1240/2021, AND 1231/2021, THE COURT ON
THE SAME DAY DELIVERED THE FOLLOWING:
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
-2-
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE THE CHIEF JUSTICE MR.S.MANIKUMAR
&
THE HONOURABLE MR. JUSTICE SHAJI P.CHALY
TUESDAY, THE 5TH DAY OF OCTOBER 2021 / 13TH ASWINA, 1943
WA NO. 1240 OF 2021
AGAINST THE JUDGMENT IN WP(C) 17148/2020 DATED 16.07.2021 OF HIGH
COURT OF KERALA, ERNAKULAM
APPELLANT/S:
1 THE TRIPPANGOTTUR GRAMA PANCHAYAT,
KALLIKKANDI P.O., KALLIKKANDI, PIN-670 693, REPRESENTED
BY ITS SECRETARY
2 THE SECRETARY,
THRIPPANGOTTUR GRAMA PANCHAYATH, KALLIKKANDI P.O.,
KALLIKKANDI, PIN-670 693
BY ADV V.HARISH
RESPONDENT/S:
1 M.P.ABDULLA,
KANNAVAN P.O., KANNAVAN, KANNUR DISTRICT-670 650
2 THE DISTRICT DISASTER MANAGEMENT AUTHORITY,
KANNUR REPRESENTED BY ITS CHAIRMAN
R1 BY SRI. SANTHOSH MATHEW
R2 TO R4 BY SRI. TEKCHAND V., GP
THIS WRIT APPEAL HAVING COME UP FOR ADMISSION ON 05.10.2021,
ALONG WITH WA.NOS.1189/2021, 1225/2021, 1231/2021, THE COURT ON THE
SAME DAY DELIVERED THE FOLLOWING:
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
-3-
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE THE CHIEF JUSTICE MR.S.MANIKUMAR
&
THE HONOURABLE MR. JUSTICE SHAJI P.CHALY
TUESDAY, THE 5TH DAY OF OCTOBER 2021 / 13TH ASWINA, 1943
WA NO. 1231 OF 2021
AGAINST THE JUDGMENT IN WP(C) 27773/2020 DATED 16.07.2021 OF HIGH
COURT OF KERALA, ERNAKULAM
APPELLANT/S:
1 THE THRIPPANGOTTUR GRAMA PANCHAYAT,
KALLIKKANDI P.O, KALLIKKANDI, PIN-670 693, REPRESENTED
BY ITS SECRETARY.
2 THE SECRETARY,
THRIPPANGOTTUR GRAMA PANCHAYAT, KALLIKKANDI P.O,
KALLIKKANDI, KANNUR DISTRICT, PIN-670 693
BY ADV V.HARISH
RESPONDENT/S:
1 PUSHPARAJAN.T,
AGED 60 YEARS,
S/O.NANU, PARAYIL PARAMBATH HOUSE, CHERUPARAMBA P.O,
KANNUR-670 693
2 THE DIRECTOR OF MINING AND GEOLOGY,
DEPARTMENT OF MINING AND GEOLOGY, KESAVADASAPURAM,
THIRUVANANTHAPURAM, 695 004.
3 THE DISTRICT GEOLOGIST,
CIVIL STATION, KANNUR-670 002
4 STATE OF KERALA,
REPRESENTED BY THE CHIEF SECRETARY, SECRETARIAT,
THIRUVANANTHAPURAM-695 001
R1 BY ADVS.SARITHA THOMAS & ALEX.M.SCARIA
R2 TO R4 BY SRI. TEKCHAND V., GP
THIS WRIT APPEAL HAVING COME UP FOR ADMISSION ON 05.10.2021,
ALONG WITH WA.NOS.1189/2021, 1225/2021, 1240/2021, THE COURT ON THE
SAME DAY DELIVERED THE FOLLOWING:
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
-4-
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE THE CHIEF JUSTICE MR.S.MANIKUMAR
&
THE HONOURABLE MR. JUSTICE SHAJI P.CHALY
TUESDAY, THE 5TH DAY OF OCTOBER 2021 / 13TH ASWINA, 1943
WA NO. 1225 OF 2021
AGAINST THE JUDGMENT IN WP(C) 10534/2021 DATED 16.07.2021 OF HIGH
COURT OF KERALA, ERNAKULAM
APPELLANT/S:
1 THE THRIPPANGOTTUR GRAMA PANCHAYATH
KALLIKKANDI P.O., KALLIKKANDI,PIN-670 693, REPRESENTED
BY ITS SECRETARY
2 THE SECRETARY,
THRIPPANGOTTUR GRAMA PANCHAYAT, KALLIKKANDI P.O.,
KALLIKKANDI,PIN-670 693
BY ADV V.HARISH
RESPONDENT/S:
M.P.ABDULLA
AGED 63 YEARS
FASNAS, KANNAVAN P.O., KANNAVAM, KANNUR DISTRICT-670 650
BY SRI. SANTHOSH MATHEW
THIS WRIT APPEAL HAVING COME UP FOR ADMISSION ON 05.10.2021,
ALONG WITH WA.1189/2021, 1231/2021, 1240/2021, THE COURT ON THE SAME
DAY DELIVERED THE FOLLOWING:
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
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JUDGMENT
SHAJI.P.CHALY, J.
The captioned writ appeals are filed by respondent Nos. 1 and 2, in the writ
petitions i.e., The Thrippangottur Grama Panchayat and its Secretary,
challenging the common judgment of the learned Single Judge in W.P.C.Nos.
17148/2020, 27773/2020, 28527/2020, & 10534/2021, dated 16.07.2021,
whereby, the impugned orders passed by the Secretary of the Grama Panchayat
declining the D & O licence for conducting quarries to the writ petitioners were
quashed and the appellants were directed to issue D & O licence to the writ
petitioners, if the petitioners are otherwise eligible, within a period of four
weeks. However, it was made clear that, the issuance of licence to the
petitioners would be subject to any satellite mapping study that may be
conducted by the Disaster Management Authority, and the writ petitioners shall
permit the authorities to conduct any such study in the quarrying area, if
warranted, without any objection. It is thus challenging the legality and
correctness of the judgment of the learned Single Judge, the appeals are
preferred.
2. In the writ petition leading to Writ Appeal No.1189/2021, the challenge
made by the writ petitioners was against Ext.P8 order of the Secretary, whereby,
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
it was found that, within 500 meters of the proposed quarry of the writ
petitioner, the stone quarries of Abdulla and Jovin George are situated and
hence, it has be declared as a cluster, and since the extent of the cluster is more
than 5 hectares, the environmental clearance of the State authority is mandatory
as per the notification dated 15.01.2016, in order to understand the impact it has
on the environment. Further, the Secretary has pointed out that the area in
question has been identified as an area prone to landslides, by the Disaster
Management Authority, and therefore, in accordance with the Disaster
Management Master Plan, in order to give permission to conduct stone quarry in
localities like the one in question, prior permission of the Disaster Management
Authority is needed. However, no such permission has been submitted.
Therefore, according to the Secretary, the local body has the power to ensure
that the guidelines of the Disaster Management Authority are being complied
with and further that the panchayat has also the power to take a general
decision not to grant further licenses to establish quarries. Other aspects with
respect to the land slides, etc are also pointed out in Ext.P8.
3. Writ petitions leading to writ appeal Nos.1225/2021 and 1240/2021, are
filed by one and the same entrepreneur, challenging Ext.P10 order passed by the
Secretary dated 19.04.2021, whereby, the licence was declined stating that the
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
licence for conducting mining in Re.Sy.No.275/A of the village in question was
considered by the governing body on 17.04.2021, and since there are 9 quarries
already working in the area with licence, it has been decided not to give licence
to new quarries.
4. Writ petition leading writ appeal No.1231/2021, is filed basically
challenging Ext.P8 order dated 03.12.2019, which is a typical order passed by
the Secretary similar to the one in the writ petition leading to writ appeal
No.1189/2021.
5. The paramount contention advanced by the petitioners were that, the
order passed by the Secretary insisting the production of prior clearance from
the Disaster Management Authority and the authority under the Environmental
Protection Act and Rules and Regulations thereto, cannot be sustained, since as
per the provisions of the Panchayat Raj Act, 1994, in regard to grant of licence to
dangerous and offensive trades, and the rules prescribed for the said purpose,
the Secretary of the Panchayat/ the Panchayat ought to have taken an
independent decision as to whether the writ petitioners were entitled to secure
licence, in accordance with the provisions of the Act, 1994, and the Rules
thereto.
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
6. Learned Single Judge, taking into consideration the rival submissions
made, held that, though Sections 3, 3A and 3B of the Kerala Panchayat Raj Act,
1994, give wide powers to Grama Sabhas on matters relating to formulation,
prioritization and implementation of general schemes, beneficiary schemes and
developmental programmes, the Act, 1994, does not empower the Grama Sabhas
to interfere with the statutory exercise of various powers exercisable by the
Panchayat and its functionaries, and therefore, any decision taken by the Grama
Sabha cannot affect the powers and functions of the licencing authority under
the Act, 1994, including the power to issue a licence under Section 233 of the
Act, 1994. It was also found that, if the Grama Panchayat or the Secretary
decides not to consider or process or to issue D & O licence in exercise of the
powers under Section 233 of the Act, 1994, on the basis of resolution passed or
decision taken by Grama Sabha, it would amount to abdication of power which
is impermissible in law. It was on the basis of the said findings that the ist
appellant Grama Panchayat was directed to issue licence to the writ petitioners
by incorporating certain riders.
7. The appellants have filed the appeals basically contending that the
findings of the learned Single Judge is contrary to law especially due to the fact
that the quarries to which licences are sought are located in the high hazard
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
landslide prone area and the direction to issue the licence solely relying on a
report filed by a Recognized Qualified Person (RQP), cannot be sustained under
law. According to the appellants, the report was prepared by the RQP as per the
instructions given by the writ petitioners themselves and therefore the same has
no legal basis, and further that, the RQP has no power or authority under the
Disaster Management Act, 2005, to file a report and give a clean chit to the 1 st
respondent/petitioner to operate in the area. It is also contended that, since
quarries in question are situated in high hazard or moderate hazard landslide
prone areas, it was only appropriate on the part of the Secretary of the Grama
Panchayat to reject the licence assigning the said reason also. The sum and
substance of the contention advanced by the appellants is that, when the
Panchayat and the Secretary are vested with appropriate statutory powers under
the provisions of the Act, 1994, and the attendant rules, they are entitled as of
right to take independent decisions, which according to the appellants, is a
concluded legal position by virtue of the judgment of the Full Bench of this Court
in Tomy Thomas vs. State of Kerala 2019 (3) KLT 987. Therefore,
according to the appellants, unless and until the directions so issued to issue
licence to the writ petitioners are not interfered with, it would cause serious
prejudice and irreparable injury to the public at large residing in the areas in
question.
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
8. We have heard, Sri. Harish Vasudevan, appearing for the appellants, Sri.
Santhosh Mathew and Sri. Alex M.Scaria, appearing for the writ petitioners and
Sri. Tekchand V., appearing for the Disaster Management Authority, and
perused the pleadings and the materials on record.
9. Learned Counsel for the respective parties have addressed their
arguments based on the pleadings discussed above. The issue with respect to
grant of licence for dangerous and offensive trades and factories, is guided by
Sections 232 and 233 of the Kerala Panchayat Raj Act, 1994. Section 232(1)
clearly specifies that the Village Panchayat may notify that no place in the
Panchayat area shall be used for any of the purposes specified in the rules made
in that behalf, being purposes which in the opinion of the Government, are likely
to be offensive or dangerous to human life or health or property, without a
licence issued by the Secretary and except in accordance with the conditions
specified in such licence. The proviso thereto makes it clear that, if any such
notification was issued, it shall not take effect until the expiry of thirty days from
the date of its publication. Section 233 deals with permission for the
construction of factories and the installation of machinery; and sub-section (1)
thereto specifies that no person shall without the permission of the Village
Panchayat and except in accordance with the conditions specified in such
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
permission - (a) construct or establish any factory, workshop or workplace in
which it is proposed to employ steam power, water power or other mechanical
power or electrical power; or (b) install in any premises any machinery or
manufacturing plant driven by any power as aforesaid, not being machinery or
manufacturing plant exempted by the provisions of this Act or the rules made
thereunder. Sub-section (2) thereto makes it clear that, an application for
permission under sub-section (1) shall be submitted to the Village Panchayat
addressed to the Secretary in such form and with such details as prescribed. The
application is to be considered by the Panchayat in accordance with the
prescription contained under sub-section 3 to sub -section 5 of Section 233 as it
originally stood,reads thus:-
"233. Permission for the construction of factories and
the installation of machinery.-
(1) xxxxx
(2) xxxx
(3) The Secretary shall, as soon as may be after the
receipt of the application, enquire and report to the
Village Panchayat as to whether the establishment
of the factory, workshop or workplace or other
installation of machinery or manufacturing plant
for which permission is applied for is objectionable
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
by reason of density of population in the
neighbourhood and the possibility to cause nuisance
or pollution and the Village Panchayat after having
considered the application and the reports of the
Secretary,and of such other authorities as specified
in sub-section (4) may as expeditiously as possible,
at any rate within sixty days,-
(a) grant the permission either absolutely or
subject to such conditions as it thinks fit to impose;
or
(b) refuse the permission for the reasons to be
recorded.
(4) Before granting or refusing permission under
sub-section (3), the Village Panchayat, shall obtain
and consider;
(a) a report of the Inspector of Factories
appointed under the Factories Act, 1948 (Central Act
63 of 1948) or of an officer of the Industries
Department not below the rank of an Industries
Extension Officer having jurisdiction over the area
regarding the adequacy of ventilation, light etc. and
sufficiency of the height and size of the rooms and
doors and the suitability of exits to be used in case of
fire in the plan of factories, workshop, workplace or
premises if they came within the purview of the
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
Factories Act, 1948 (Central Act 63 of 1948) and
such other matters as may be prescribed;
(b) a report of the District Medical Officer
regarding the possibility of nuisance or pollution if
the connected load of the machinery proposed to be
installed exceeds 25 HP or if the nature of the
machinery and installation are such that it may
cause nuisance or pollution; and
(c) a report of the Divisional Fire Officer or
any other officer authorised by him regarding the
adequacy of fire prevention and fire fighting
measures planned if the proposed industry involves
the use of high tension power or inflammable or
explosive materials:
Provided that, no report under clause (b) shall
be called for in respect of any industry if the
applicant produces a declaration recommended by
an officer of the Industries Department authorised
in this behalf or by the Kerala State Pollution
Control Board to the effect that such industry would
not cause pollution.
(5) The grant of permission under this section,-
(a) Shall be subject to the conditions to be
observed in respect of the replacement of machinery
the levy of fees and to such restrictions and
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
conditions as may be prescribed;
(b) Shall not be deemed as exempted from
observing the provisions contained in section 235(F)
and 235 (H) or 235(P) and 235 (Q)"
10. However drastic amendments were brought to Section 233 of the Act,
1994, as per Act 14 of 2018, by which, in sub-section (2), after the word
"Secretary", the words "or officer authorised by the Secretary" was incorporated.
That apart, after subsection (2), sub-section (2A) was introduced, dealing with
the manner in which permission for construction of factories and installation of
machinery are to be considered, which reads thus:
"(2A) The Secretary or officer authorized by him shall issue an
acknowledgment to the applicant, on receipt of application
along with the supporting documents in the form, as may be
prescribed, and shall verify the application and all supporting
documents on the spot itself, and if any supporting document is
not found attached along with the application, the Secretary or
officer authorized by him shall, immediately inform the
applicant in writing the list of missing documents and allow the
applicant to submit the missing documents as early as possible,
but not later than five days from the date of receipt of
application."
11. The provisions of Sections 232 and 233 of Act 1994 are guided by the
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
Kerala Panchayat Raj Act (Issue of Licence to Dangerous and Offensive Trades
and Factories) Rules, 1996, which was also amended as per G.O.(P)
NO.80/2017, including in the long title, for the words and brackets as follows:
"(Issue of Licence to Factories, Trades, Entrepreneurship activities and
services)". Various provisions are contained under the Rules 1996, to tackle the
applications filed by any persons seeking permissions. As per Rule 3, as it
originally stood, the Government may for the purposes of Section 232, specify in
the First Schedule appended to these rules, the matters which, in the opinion of
Government, are likely to be offensive or dangerous to human life, health or
property; and as per Rule 4, the Village Panchayat may, by affixing notices in the
notice board of the Offices of the Panchayat and in conspicuous places of every
constituency in the Panchayat and by advertisement by way of pamphlets, loud
speakers, notify that no place in the Panchayat area shall be used for any
purpose or purposes specified in Schedule I without the licence issued by the
President and except in accordance with the conditions specified therein.
However , Rule 3 discussed above was substituted by G.O.(P)
No.80/2017/LSGD, which starts with the heading "3. Description of trades,
services and factories- The Government may for the purpose of Section 232, specify
in the First Schedule appended to these rules, the matters which, in the opinion of the
Government, shall be classified as factories, trades, entrepreneurship activities and
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
other services."
12. As per G.O.(P) No.80/2017, other amendments were also made to the
rules with respect to the receipt of the application, issuance of acknowledgment
and processing of the same by including rule 5A and adding a proviso to rule 6,
whereby, it is specified that "provided if the application is submitted along with
the requisite clearance from other departments stipulated under these rules for
grant of license along with the fee specified in the Schedule II, the President of
the Grama Panchayat shall issue the licence applied for within seven days
from the date of receipt of the application along with the requisite clearances".
In fact, consequent to the introduction of the proviso to rule 6, virtually the
power of the president under Rule 6 is circumscribed or watered down, if the
application is submitted with the requisite clearances from other departments
and complying with the other prescriptions contained under the proviso as
discussed above, especially due to the expression "shall" used in the added
proviso.
13. We have discussed the relevant provisions of the Act, 1994, and the
Rules, 1996 in detail, to emphasise that the Panchayat, the Secretary and the
President are endowed with requisite powers to consider any applications
received under Sections 232 and 233, independent of other clearances to be
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
issued by other statutory authorities under various other enactments, only if
such clearances are not produced along with the application in contemplation of
the afore proviso . This we also say because a report of an RQP is never a subject
matter of consideration for the Panchayat in the matter of grant of licence to an
entrepreneur. True, it may enable the Panchayat to identify certain situations
while processing the application, however, it cannot be said to be absolutely
binding on the Panchayat and its officers, or to put it straight the Panchayat and
its officers are guided by clear statutory provisions which alone they are bound
to follow . But,at the same time, the decision taken by the Grama Panchayat in
general not to grant licence for new quarries, cannot be sustained under law,
because the provisions of Sections 232 and 233 and the rules would make it clear
that each and every application submitted by an entrepreneur is to be
considered by the concerned statutory authority in accordance with the
provisions of law. In fact, the said question was considered by a Division Bench
of this Court in Kadaplamattom Grama Panchayat v. Johny Roy 2013
(3) KLT 1053, and held that, even though the Village Panchayat is vested with
powers to pass resolutions as permitted by the provisions of the Act, 1994, and
the rules framed thereunder, the mandatory and other functions enumerated in
the 3rd Schedule does not empower the Panchayat to take a general decision not
to grant permit/ license to establish a factory, workplace or other
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
establishments, and that an application cannot be summarily rejected by stating
that the Panchayat has taken a policy decision not to permit any such
establishments in the Panchayat area. It was also held that such an authority is
not vested with the Panchayat under the provisions of Sections 232, 233 or the
Rules, 1996.
14. Taking into account the above facts, circumstances and law, we are in
agreement with the judgment of the learned Single Judge to the extent
directions are issued to consider the applications submitted by the
entrepreneurs, in accordance with law. However, the direction contained in the
judgment to issue the licence, apparently based on the report of the RPQ that the
quarries in question have no adverse situations in accordance with the map
formulated by the disaster management authority in view of the legal aspects
discussed above cannot be sustained . Therefore, to that extent, the judgment of
the learned Single Judge has to be interfered with, and accordingly the findings
in the Judgment on the basis of the report of the RPQ would stand vacated.
However it is clear from the provisions of Rules, 1996, that a decision has to be
taken by the President, in accordance with the time stipulations contained under
the act and the Rules. In that view of the matter, there would be a direction to
the Secretary and the President of the Grama Panchayat, to process the
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
applications submitted by the writ petitioners, in accordance with the statutory
prescriptions contained under the Act 1994 and the Rules 1996 discussed above,
also adhering to the time stipulations contained thereunder.
The Writ Appeals are allowed partly and the common judgment of the
learned Single Judge is modified to the extent specified above.
Sd/-
S.MANIKUMAR
CHIEF JUSTICE
Sd/-
SHAJI P.CHALY
JUDGE
uu
07.10.2021
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
APPENDIX OF WA 1231/2021
PETITIONER ANNEXURE
Annexure A1 A TRUE PHOTOCOPY OF
MEMO FILED BY THE
GOVERNMENT PLEADER FOR
THE DDMA, KANNUR IN
W.P.C NO. 17148 OF
2020.
Annexure A2 A TRUE COPY OF THE
REPORT OF THE RQP
PRODUCED BY THE
PETITIONER IN W.P.C NO.
17148 OF 2020.
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
APPENDIX OF WA 1225/2021
PETITIONER ANNEXURE
Annexure A1 A TRUE PHOTOCOPY OF
MEMO FILED BY THE
GOVERNMENT PLEADER FOR
THE DDMA, KANNUR IN WPC
NO.17148 OF 2020
Annexure A2 A TRUE PHOTOCOPY OF THE
REPORT PREPARED BY THE
RQP ALONG WITH THE
HAZARD MAP
WA NOS. 1189, 1225, 1231 & 1240 OF 2021
APPENDIX OF WA 1189/2021
PETITIONER ANNEXURE
Annexure A1 A TRUE PHOTOCOPY OF
MEMO FILED BY THE
GOVERNMENT PLEADER FOR
THE DDMA, KANNUR IN WPC
NO.17148 OF 2020.
Annexure A2 A TRUE PHOTOCOPY OF THE
REPORT OF THE RQP
PRODUCED BY THE
PETITIONER IN WPC
NO.17148 OF 2020.
