Kerala High Court
Albin Paul vs The Kerala Financial Corporation on 17 September, 2025
2025:KER:69518
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE VIJU ABRAHAM
WEDNESDAY, THE 17TH DAY OF SEPTEMBER 2025 / 26TH BHADRA, 1947
WP(C) NO. 3175 OF 2021
PETITIONER:
ALBIN PAUL
AGED 29 YEARS
S/O. POULOSE T.A., THEKKUMPARAMBIL HOUSE, M.T.M.JUNCTION,
PAMPAKUDA P.O., MUVATTUPUZHA, ERNAKULAM DISTRICT, PIN-686667.
BY ADVS.
SHRI.M.V.S.NAMPOOTHIRY
SHRI.SHINTO THOMAS
RESPONDENTS:
1 THE KERALA FINANCIAL CORPORATION
REPRESENTED BY ITS CHAIRMAN AND MANAGING DIRECTOR, OFFICE OF
THE KFC, VELLAYAMBALAM P.O., THIRUVANANTHAPURAM-695010.
2 THE BRANCH MANAGER,
KERALA FINANCIAL CORPORATION, SNDP SHOPPING COMPLEX, P.P.ROAD,
PERUMBAVOOR (P.O.), ERNAKULAM-683542.
3 THE DISTRICT COLLECTOR,
COLLECTORATE, CIVIL STATION, KAKKANAD, ERNAKULAM-682030.
4 THE DEPUTY TAHSILDAR (REVENUE RECOVERY),
KERALA FINANCIAL CORPORATION, VAZHAPPALLY EAST (P.O.),
ERNAKULAM-686673.
5 THE VILLAGE OFFICER,
MELMURI VILLAGE OFFICE, MELMURI P.O., ERNAKULAM-686667.
6 THE VILLAGE OFFICER,
ONAKKOOR VILLAGE OFFICE, ONAKKOOR P.O., ERNAKULAM-686667.
7 STATE OF KERALA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF
FINANCE, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.
BY ADVS.
SHRI.M.R.VENUGOPAL, SC, KFC
WP(C) Nos.3175 of 2021 & 11895 of 2020 -2-
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SMT.DHANYA P.ASHOKAN (SR.)
GP - NIMA JACOB
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
17.09.2025, ALONG WITH WP(C).11895/2020, THE COURT ON THE SAME DAY
DELIVERED THE FOLLOWING:
WP(C) Nos.3175 of 2021 & 11895 of 2020 -3-
2025:KER:69518
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE VIJU ABRAHAM
WEDNESDAY, THE 17TH DAY OF SEPTEMBER 2025 / 26TH BHADRA, 1947
WP(C) NO. 11895 OF 2020
PETITIONER:
JOMON K.J.,
AGED 38 YEARS
S/O.K.K.JOHN, KUNNUMPURATH HOUSE, PAMBAKKUDA, ERNAKUALM
DISTRICT-686667.
BY ADVS.
DR.ABRAHAM P.MEACHINKARA
SHRI.JAYAKRISHNAN P.R.
RESPONDENTS:
1 THE MANAGER, KERALA FINANCIAL CORPORATION,
SNDP SHOPPING COMPLEX, P P ROAD, PERUMABVOOR, PERUMBAVOOR P
O, ERNAKULAM -683542.
2 THE TAHSILDAR
TALUK OFFICE, MUVATTUPUZHA P O, MUVATTUPUZHA, ERNAKULAM-
686673.
3 SUB REGISTRAR
SUB REGISTRY OFFICE, PIRAVOM P O, KOTTAYAM-686664.
4 THE VILLAGE OFFICER,
MEMURI VILLAGE OFFICE, MEMURI P O, KOTTAYAM-686667.
5 THE VILLAGE OFFICER,
ONAKKOOR VILLAGE OFFICE, ONAKKOOR P O, KOTTAYAM-686667.
BY ADVS.
SRI.M.R.VENUGOPAL
SMT.DHANYA P.ASHOKAN (SR.)
GP - NIMA JACOB
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
17.09.2025, ALONG WITH WP(C).3175/2021, THE COURT ON THE SAME DAY
DELIVERED THE FOLLOWING:
WP(C) Nos.3175 of 2021 & 11895 of 2020 -4-
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JUDGMENT
Dated this the 17th day of September, 2025
Since both these writ petitions challenge the very same
proceedings they are heard and disposed of by a common judgment.
2. The petitioner along with two others started a firm in the
year 2015. A financial assistance to the tune of Rs.16,94,000/- was
availed from the Kerala Financial Corporation, which is an interest
free loan for a period of five years. The remittance of the principal
amount was defaulted by the petitioner. Recovery proceedings were
initiated and Ext.P1 order of attachment was effected on the
properties hypothecated by the petitioner. While so, Ext.P2 notice
was issued intimating that the persons who intend to settle the loan
by way of one time settlement has to reach the concerned branch
before 18th April to 21st April. Pursuant to Ext.P2 notice the managing
partner of the firm has sent Ext.P3 letter informing that he will be
appearing before the adalath to be held on 08.05.2018.
Subsequently in July 2018 the 2nd respondent contacted the
managing partner to meet him in the office. Thereupon the
petitioner appeared before the 2nd respondent and the 1st respondent
directed the petitioner to pay an amount of Rs.1,40,000/-, as
compromise settlement advance and the same was deposited on
28.07.2018. Again as contacted by the 2 nd respondent the managing
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partner and one Mr.Binoy K. Mani appeared before him on
08.11.2018 and submitted a request as per Ext.P4 letter intimating
their option to clear the loan amount either by one time settlement
or in instalments. The exact amount to be paid under the OTS
scheme was not informed to the petitioner by any written
communication, but they orally directed the petitioner to deposit an
amount of Rs.12,02,500/-. While the partners of the firm were
awaiting for a written reply to the letter, Ext.P5 communication was
issued stating that, since the firm was not prepared to remit the
minimum amount for compromise settlement and hence the amount
of Rs.1,40,000/- deducting 7.5% as R.R. commission will be adjusted
against the loan account. On receipt of Ext.P5 the 2 nd respondent
was again contacted, and issued Ext.P6 letter intimating that they
are ready to settle that loan under one time settlement and by
remitting an amount of Rs.12,15,053/-. Subsequently as instructed
by the 2nd respondent an amount of Rs.10,75,053/- was paid thus
making a total remittance of Rs.12,15,053/- which is inclusive of 1%
collective charge. Thereafter respondents 2 and 4 contacted the
managing partner and directed him to make a demand draft for an
amount of Rs.12,310/- in favour of SBI account, Government of
Kerala towards collection charges as provided under Rule 5(3) of the
Revenue Recovery Rules. Pursuant to the said direction demand
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draft was taken as evident from Exts.P7 and P8, and Ext.P9 note file
would reveal that the amount due including 1% revenue recovery
commission has been paid by the petitioners towards compromise
settlement. Thereupon petitioner requested respondents 2 and 4 to
lift the attachment and issue NOC as the entire amount due to the
KFC has been repaid under one time settlement. As the attachment
was not lifted the managing partner again submitted Ext.P10
representation before the KFC and Ext.P11 representation before the
Government. The District Legal Service Authority was also moved.
Ultimately Ext.P14 representation was given to the 3 rd respondent
requesting to take steps to lift the attachment and drop all revenue
recovery proceedings.
3. Subsequently properties of one of the managing director
was lifted as evident from Ext.P15. Thereafter the 5 th respondent
issued Ext.P17 letter to the managing partner showing that
attachment over the property of Binoy K. Mani was lifted as the
entire loan is closed. A perusal of Ext.P17 would reveal that the
Deputy Tahsildar (RR), KFC, Ernakulam as per Letter No.OTE
59/2017-RR-KFC has intimated that the loan has been closed, and
therefore attachment has been lifted. While so, by Ext.P18 the KFC
intimated the managing partner of Ext.P18 communication that
Rs.87,000/- more is required for settling the amount as per the one
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time settlement scheme. Later, Ext.P19 communication was issued
intimating that since the amount of Rs.87,000/- was not paid the
benefit of one time settlement is lost and therefore the petitioner
has to remit an amount of Rs.3,78,658/- towards loan account.
Petitioner would submit that the entire act of the KFC and its officers
are absolutely, arbitrary, illegal and unreasonable. After having paid
the whole amount as per the one time settlement scheme, issuance
of Exts.P18 and P19 are arbitrary and unjust, wherein further
amounts were demanded by the Kerala Financial Corporation. The
specific case of the petitioner is that the total amount due under the
one time settlement is Rs.12,15,053/- which was remitted in full as
final settlement including 1% collection charge and that the
subsequent demand for Rs.87,000/- as per Ext.P18 and the demand
for Rs.3,78,008/- as per Ext.P19 is absolutely arbitrary and unjust.
Petitioner would submit that the District Collector as per Exts.P20
and P24 has sought for clarification from the Deputy Tahsildar, KFC
as to how 1% collection charge was collected from the petitioners if
there was no compromise settlement. But no answer has been given
by the authorities till date.
4. A detailed counter affidavit has been filed by the Kerala
Financial Corporation, wherein it is admitted that the borrower
remitted an amount of Rs.1,40,000/- as compromise settlement
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advance on 28.07.2018, but delayed further payment by submitting
representation after representation, and thereupon they lost the
benefit of the one time settlement. Therefore they will have to pay
the amount actually due, and thereupon Ext.P19 communication was
issued. It is further submitted that since the amount due as per the
one time settlement was not paid in full by the petitioner, the
revenue recovery proceedings has not been withdrawn and the
proceedings are still in force. It is true that the petitioner has
approached the Government by filing a complaint, and an
explanation was called for, and Ext.R1(f) reply was given stating
that, towards one time settlement an amount of Rs.87,000/- more is
to be paid. It is further stated that during the pendency of the writ
petition the petitioner has preferred another complaint before the
respondents regarding the lifting of the attachment over the
personal properties in view of the petitioner's remittance towards
the compromise settlement. After hearing the 4 th respondent and
petitioner, the 3rd respondent passed Ext.R1(i) order directing the 4 th
respondent to retain the attachment over 7.29 ares of property
belonging to the petitioner in view of the balance outstanding, and
ordered to lift the attachment in respect of his other properties. On
the basis of the same, it is submitted that the contention of the
petitioner that the amount has been settled for an amount of
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Rs.12,15,053/- as per one time settlement scheme is without any
basis. It is further submitted that the balance amount due as per the
one time settlement scheme is Rs.87,000/- as on 05.02.2019 and
this was intimated to the petitioners as per Ext.P18, but since the
said amount was not remitted the benefit of one time settlement is
lost to the petitioner and the petitioners are liable to pay the actual
amount due under the loan account.
5. Similar contention was raised by the learned Counsel for the
petitioner in WP(C) No.11895 of 2022.
6. I have heard the rival contentions on both sides.
7. Though the Kerala Financial Corporation has taken a stand
that the one time settlement request made by the petitioner has not
been approved yet by the Corporation, and that the contention of
the petitioner that the amount has been settled for an amount of
Rs.12,15,053/- is without any basis, it is to be seen that by Ext.P8
1% collection charge was remitted by the Deputy Tahsildar, Revenue
Recovery attached to the Kerala Financial Corporation and not by the
petitioners. So when the Deputy Tahsildar (RR) attached to the
Kerala Financial Corporation remits the said amount of 1% of the
collection charge, naturally, it has to be presumed that the same has
been remitted after the matter has been settled in the one time
settlement scheme. Further a perusal of Ext.P17 reply under the
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Right to Information Act also would reveal that as per
Communication No.OTE.59/2017-RR-KFC issued by the Deputy
Tahsildar (RR) KFC the loan account has been closed. Going by Rule
5(3) of the Kerala Revenue Recovery Rules, when revenue recovery
proceedings have been initiated, but the matter has been settled,
and the amount has been recovered pursuant to a settlement, the
collection charge to be paid is only 1%. When Exts.P8, P9 and P17
are considered along with Rule 9(3) of the Kerala Revenue Recovery
Rules, especially taking note of the fact that the collection charge of
1% was remitted to the Government treasury not by the petitioner,
but by the Deputy Tahsildar (RR) attached to the Kerala Financial
Corporation, it gives an indication that the amount has been settled
between the parties under one time settlement scheme. Though
there is no formal orders issued, it is the contention of the
petitioners that they have remitted the amount as directed by the
Kerala Financial Corporation. Rule 5(3) of the Kerala Revenue
Recovery Rules reads as follows:-
"Rule 5(3) - Institutions except Government Departments
accepting defaulted payments directly from the defaulter
after initiating Revenue Recovery Proceedings under the
Kerala Revenue Recovery Act, 1968 (15 of 1968) and filing the
certificate by the District Collector under sub-section (3) of
Section 69 of the said Act shall be liable to pay 1% of the
amount so collected towards service charge for the initiation
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of Revenue Recovery Proceedings against the defaulter [and
to intimate the fact] of such acceptance to the District
Collector concerned at once.]"
8. The Division Bench of this Court in Malabar Organics Ltd.
v. State of Kerala [2009 (4) KLT 328] has considered the role of
the Deputy Tahsildar (RR) attached to KFC and held as follows:-
"6. As far as K.F.C and K.S.F.E are concerned, it is brought to
our notice that those institutions have their own machinery of
recovery, by utilizing the service of officers on deputation from
the Government. It is submitted that the entire expenses
including salary and maintenance of the establishment are met
by the Corporation and the Enterprises. If that be so, there is
no justification in realizing the service charges from K.F.C or
K.S.F.E in terms of R.5(3). What is permissible is only recovery
of the expenses provided under Items (i) to (viii) in the table
under R.4."
Therefore, as regards the recovery process of KFC and KSFE are
concerned, those institutions have their own machinery for recovery
by utilising the service of the officers on deputation from the
Government, and the entire expenses including salary and
maintenance of the establishment are met by the Corporation and
the Enterprises. It is in this context, Exts.P8 and P9 assumes
importance, inasmuch as it is issued by the Deputy Tahsildar,
Revenue Recovery who is attached to the KFC itself, unlike in the
other cases of recovery proceedings invoking Section 71 of the
Revenue Recovery Act.
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9. Yet another aspect to be noted is that in Ext.P9 the Deputy
Tahsildar (LR), Kerala Financial Corporation has entered in the file
note that the amount due towards one time settlement has been
remitted by the petitioners i.e. Rs.1,40,000/- remitted on 28.07.2018
towards compromise settlement, Rs.10.75 lakhs remitted on
27.12.2018 and RR commission for an amount of Rs.12,12,310/-. It is
also to be noted is that, even in the communications issued by the
Kerala Financial Corporation, especially Ext.P18 in WP(C) No.3175 of
2021 the intimation issued itself would reveal that only an amount of
Rs.87,000/- is due towards "one time settlement". Similar
communication is produced as Ext.P8 in WP(C) No.11895 of 2020,
wherein also the KFC has stated that the amount due is as per the
"one time settlement". When the Kerala Financial Corporation in its
communication itself used the word 'the amount due towards the
one time settlement', only for the reason that they have not issued a
formal order, this Court is not inclined to accept the contention of
the KFC that there is no one time settlement, especially after
receiving the amounts from the petitioners including 1% collection
charge which is remitted to the Government by the Tahsildar,
Revenue Recovery attached to the Kerala Financial Corporation. It is
also pertinent to note that the communication issued by the District
Collector as Exts.P23 and P24 addressed to the Kerala Financial
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Corporation specifically regarding the fact as to how 1% collection
charge was accepted without a compromise settlement with the
petitioners. The petitioners contend that the same has not been
answered by the KFC to the District Collector yet.
In view of the rival contentions raised by both sides, wherein the
Kerala Financial Corporation has taken a stand that there is no
approved order under the one time settlement scheme, and the claim
of the petitioners based on the records produced in their writ petitions
that one time settlement was accepted by the KFC, and as directed
by them they have remitted the amount in full, I am of the view that
the matter requires consideration in detail by a competent authority.
Since revenue recovery proceedings have already been initiated and
the District Collector has issued Exts.P23 and P24 communications to
KFC, I am of the view that the District Collector, Ernakulam, the 3 rd
respondent in WP(C) No.3175 of 2021 should independently consider
the claim raised by the petitioner as well as the KFC in this regard and
finalise the same. In view of the above facts and circumstances, I am
inclined to dispose of the writ petition as follows:-
Petitioners shall file appropriate complaint in this regard before the
3rd respondent, District Collector, Ernakulam producing all the
relevant documents and judgments in their support within a period
of three weeks from the date of receipt of a copy of this judgment.
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On receipt of the same, the 3rd respondent shall after hearing the
petitioner and the Kerala Financial Corporation including the Deputy
Tahsildar, Revenue Recovery attached to the Kerala Financial
Corporation and any other necessary parties shall take a decision on
the complaint to be filed by the petitioners as directed above, in
accordance with law, without any delay, at any rate within an outer
limit of four months thereafter. Till a decision is taken as directed
above, the interim order granted in WP(C) No.3175 of 2021 staying
all further proceedings pursuant to Exts.P18 and P19 shall continue.
Sd/-
VIJU ABRAHAM
JUDGE
sbk/-
2025:KER:69518
APPENDIX OF WP(C) 3175/2021
PETITIONER EXHIBITS
EXHIBIT P1 TRUE COPY OF THE ATTACHMENT ORDER NO.DTE-
59/2017-RR-KFC DATED 2.2.2018 ISSUED BY
THE 4TH RESPONDENT.
EXHIBIT P2 TRUE COPY OF THE NOTICE NO.KFC-204/2018
DATED 4.4.2018 ISSUED BY THE 1ST
RESPONDENT TO THE MANAGING PARTNER
MR.JOMON K.J.
EXHIBIT P3 TRUE COPY OF THE LETTER DATED 20.4.2018
ISSUED BY THE MANAGING PARTNER OF THE
PETITIONER'S FIRM TO THE 2ND RESPONDENT.
EXHIBIT P4 TRUE COPY OF THE LETTER DATED 8.11.2018
SUBMITTED BY THE MANAGING PARTNER OF THE
PETITIONER'S FIRM TO THE 2ND RESPONDENT.
EXHIBIT P5 TRUE COPY OF THE LETTER NO.739/18 DATED
14.11.2018 ISSUED BY THE MANAGER, KERALA
FINANCIAL CORPORATION TO THE MANAGING
PARTNER OF THE PETITIONER'S FIRM.
EXHIBIT P6 TRUE COPY OF THE LETTER DATED 22.12.2018
SUBMITTED BY THE MANAGING PARTNER OF THE
PETITIONER'S FIRM TO THE 2ND RESPONDENT.
EXHIBIT P7 TRUE COPY OF DD DATED 27.12.2018 OF
FEDERAL BANK FOR RS.12,310/- DRAWN IN
FAVOUR OF SBI A/C GOVERNMENT OF KERALA.
EXHIBIT P8 TRUE COPY OF CHALLAN DATED 22.1.2019 FOR
RS.12,310/-.
EXHIBIT P9 TRUE COPY OF THE FILED NOTE OF THE 4TH
RESPONDENT.
EXHIBIT P10 TRUE COPY OF THE REPRESENTATION DATED
13.3.2019 SUBMITTED BY JOMON K.J.,
MANAGING PARTNER OF THE PETITIONER'S FIRM
TO THE EXECUTIVE DIRECTOR OF KFC.
EXHIBIT P11 TRUE COPY OF THE REPRESENTATION DATED
18.3.2019 SUBMITTED BY JOMON K.J.,
MANAGING PARTNER OF THE PETITIONER'S FIRM
TO THE HON'BLE FINANCE MINISTER, GOVT. OF
KERALA.
EXHIBIT P12 TRUE COPY OF THE COMPLAINT DATED 4.9.2019
SUBMITTED BY THE MANAGING PARTNER OF THE
PETITIONER'S FIRM TO THE DISTRICT LEGAL
SERVICES AUTHORITY, ERNAKULAM.
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EXHIBIT P13 TRUE COPY OF THE NOTICE ISSUED BY THE
DISTRICT LEGAL SERVICES AUTHORITY,
ERNAKULAM TO THE 2ND RESPONDENT.
EXHIBIT P14 TRUE COPY OF THE REPRESENTATION DATED
13.10.2020 SUBMITTED BY THE MANAGING
PARTNER OF THE PETITIONER'S FIRM TO THE
3RD RESPONDENT.
EXHIBIT P15 TRUE COPY OF THE APPLICATION SUBMITTED BY
THE MANAGING PARTNER OF THE PETITIONER'S
FIRM BEFORE THE 2ND RESPONDENT ON
27.12.2018.
EXHIBIT P16 TRUE COPY OF THE LETTER DATED 29.12.2018
ISSUED BY THE 4TH RESPONDENT.
EXHIBIT P17 TRUE COPY OF THE LETTER DATED 29.8.2019
ISSUED BY THE 5TH RESPONDENT TO THE
MANAGING PARTNER OF THE PETITIONER'S FIRM.
EXHIBIT P18 TRUE COPY OF LETTER NO.KFC/66/2019 DATED
5.2.2019 ISSUED BY THE 2ND RESPONDENT TO
THE MANAGING PARTNER OF THE PETITIONER'S
FIRM.
EXHIBIT P19 TRUE COPY OF LETTER NO.KFC/451/2019 DATED
31.8.2019 ISSUED BY THE 2ND RESPONDENT.
EXHIBIT P20 TRUE COPY OF THE REPRESENTATION DATED
19.9.2020 SUBMITTED BY THE MANAGING
PARTNER OF THE PETITIONER'S FIRM TO THE
1ST RESPONDENT.
EXHIBIT P21 TRUE COPY OF THE MINUTES OF THE ZONAL
MEETING OF THE KFC HELD ON 17.1.2019.
EXHIBIT P22 TRUE COPY OF THE COUNTER AFFIDAVIT FILED
BY THE 1ST RESPONDENT IN WP(C)
NO.25899/2020 BEFORE THIS HON'BLE COURT.
Exhibit P25 TRUE COPY OF THE APPLICATION FILED BY
PETITIONER'S FIRM UNDER THE RTI ACT BEFORE
THE 4TH RESPONDENT ON 16.03.2020.
Exhibit P26 TRUE COPY OF THE REPLY LETTER DATED
08.04.2020 ISSUED BY THE INFORMATION
OFFICER ATTACHED TO THE 4TH RESPONDENT'S
OFFICE.
RESPONDENT EXHIBITS
Exhibit R1(f) TRUE COPY OF THE LETTER DATED 10/07/2019
ISSUED TO THE PRIVATE SECRETARY TO HON'BLE
FINANCE MINISTER
Exhibit R1(g) TRUE COPY OF THE LETTER DATED 03/11/2020
ISSUED BY THE 4TH RESPONDENT
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Exhibit R1(h) TRUE COPY OF THE REPLY DATED 5/11/2020
ISSUED BY THE 2ND RESPONDENT
Exhibit R1(i) RUE COPY OF THE PROCEEDINGS DATED
08/10/2021 OF THE 3RD RESPONDENT
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APPENDIX OF WP(C) 11895/2020
PETITIONER EXHIBITS
EXHIBIT P1 TRUE COPY OF THE LETTER ISSUED BY THE 1ST
RESPONDENT CORPORATION DATED 4.4.2018 TO
THE PETITIONER ALONG WITH TRUE ENGLISH
TRANSLATION.
EXHIBIT P2 TRUE COPY OF THE ACCOUNT STATEMENT ISSUED
BY THE KERALA FINANCIAL CORPORATION TO THE
PETITIONER.
EXHIBIT P3 TRUE COPY OF THE LETTER ISSUED BY THE
DEPUTY TAHSILDAR(RR) KFC DATED 29.12.2018.
EXHIBIT P4 TRUE COPY OF THE ACCOUNT STATEMENT OF THE
PETITIONER ISSUED BY BANK.
EXHIBIT P5 TRUE COPY OF THE REPLY DATED 29.08.2019
ISSUED BY VILLAGE OFFICER, MEMURI VILLAGE
ALONG WITH TRUE ENGLISH TRANSLATION
EXHIBIT P6 TRUE COPY OF THE REQUEST MADE BY THE
PETITIONER BEFORE THE FIRST RESPONDENT
DATED 13.3.2019 ALONG WITH TRUE ENGLISH
TRANSLATION.
EXHIBIT P7 TRUE COPY OF THE LETTER ISSUED BY THE 1ST
RESPONDENT DATED 05.02.2019 TO THE
PETITIONER ALONG WITH TRUE ENGLISH
TRANSLATION.
EXHIBIT P8 TRUE COPY OF THE REPLY LETTER GIVEN TO THE
PETITIONER BY THE CHIEF MANAGER K.F.C.
DATED 27.12.2018 ALONG WITH TRUE ENGLISH
TRANSLATION.
EXHIBIT P9 TRUE COPY OF THE LETTER ISSUED BY THE
FIRST RESPONDENT DATED 31.08.2019 ALONG
WITH TRUE ENGLISH TRANSLATION.
EXHIBIT P10 TRUE COPY OF THE MEDICAL CERTIFICATE
ISSUED TO PETITIONERS MOTHER ANIAMMA FROM
MEDICAL MISSION HOSPITAL, KOLENCHERY.
RESPONDENT EXHIBITS
EXHIBIT R1(A) TRUE COPY OF THE LETTER DATED 14.11.2018.
EXHIBIT R1(B) THE TRUE COPY OF THE LETTER DATED
31.08.2019.
