Kerala High Court
Mahatma Gandhi Trust vs Scheduled Caste And Scheduled Tribe ... on 7 January, 2022
Author: S. Manikumar
Bench: S.Manikumar, Shaji P.Chaly
W.P.(C) No. 453/2022 :1:
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE THE CHIEF JUSTICE MR.S.MANIKUMAR
&
THE HONOURABLE MR. JUSTICE SHAJI P.CHALY
TH
FRIDAY, THE 7 DAY OF JANUARY 2022 / 17TH POUSHA, 1943
WP(C) NO. 453 OF 2022
PETITIONERS:
1 MAHATMA GANDHI TRUST,
K.P.VALLON ROAD, KADAVANTHARA, KOCHI-20, REPRESENTED BY
ITS GNERAL SECRETARY, DR.M.K.MUKUNDAN.
2 KERALA FEDERATION OF SC/ST,
EZHIKKARA P.O., ERNAKULAM, REPRESENTED BY SECRETARY.
3 NANDHANA R.ANSERA,
D/O.RAKESH.N.G., ANCHERY NILAM NIKARTHIL, POONTHOPPU,
AVALOOKKUNNU P.O., ALAPPUZHA-688 006.
BY ADVS.
P.K.SANTHAMMA
JEEVA KUMARI P.S
MALINI M.A
SASI P.R
RESPONDENT/S:
1 SCHEDULED CASTE AND SCHEDULED TRIBE DEVELOPMENT
DEAPARTMENT,
GOVT. SECRETARIAT, THIRUVANANTHAPURAM-695 001,
REPRESENTED BY PRINCIPAL SECRETARY.
2 PRINCIPAL SECRETARY, REVENUE DEPARTMENT,
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001.
3 DIRECTOR, SCHEDULED CASTE DEVELOPMENT DEPARTMENT,
NANDAVANAM, VIKAS BHAVAN, THIRUVANANTHAPURAM-695 001.
4 DISTRICT COLLECTOR, CIVIL STATION,
PALAKKAD DISTRICT, PALAKKAD P.O., PIN-678 001.
5 DISTRICT SCHEDULED CASTE DEVELOPMENT OFFICER,
CIVIL STATION, PALAKKAD P.O., PIN-678 001.
6 THE INSTITUTE OF INTEGRATED MEDICAL SCIENCE,
(GOVT. MEDICAL COLLEGE), YAKKARA, KUNNATHUR MEDU P.O.,
PALAKKAD-678 013, REPRESENTED BY ITS DIRECTOR.
7 THE PRINCIPAL, THE INSTITUTE OF INTEGRATED MEDICAL SCIENCE,
YAKKARA, KUNNATHUR MEDU P.O., PALAKKAD-678 013.
8 SOCIETY FOR THE INSTITUTE OF INTEGRATED MEDICAL SCIENCE,
REG. NO.TVM/TC/586, 2015, AYYANKALI BHAVAN, KANAKA NAGAR,
VELLAYAMBALAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS
SECRETARY, PIN-695 010.
9 THE SECRETARY, HEALTH AND FAMILY WELFARE DEPARTMENT,
GOVT. OF KERALA, GOVERNMENT SECRETARIAT,
W.P.(C) No. 453/2022 :2:
THIRUVANANTHAPURAM-695 001.
10 THE DIRECTOR OF MEDICAL EDUCATION,
MEDICAL COLLEGE, KUMARAPURAM ROAD, CHALAKKUZHI,
THIRUVANANTHAPURAM-695 011.
11 CULTURAL DEPARTMENT,
REPRESENTED BY SECRETARY, GOVT. SECRETARIAT,
THIRUVANANTHAPURAM-695 001.
12 CHIEF SECRETARY, STATE OF KERALA,
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001.
SRI.TEK CHAND, SR. GOVERNMENT PLEADER
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
07.01.2022, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
W.P.(C) No. 453/2022 :3:
Dated this the 7rd day of January, 2022.
JUDGMENT
S. MANIKUMAR,CJ.
Petitioners, Mahatma Gandhi Trust, represented by its General Secretary Dr. M. K. Mukundan, Kerala Federation of SC/ST represented by its Secretary and Nandhana R Ansera, a second year MBBS student of IIMS Medical College, Palakkad, have filed this writ petition for a writ of mandamus directing the Cultural Department, represented by its Secretary, Government Secretariat, Thiruvananthapuram - 695 001, respondent No.11, to return 5 acres of land set apart for it, from 50 acres of land in Re. Sy. No. 4 in Block 181 Yakkara Village allotted strictly to the Palakkad Medical College Project.
2. They have also sought for a mandamus directing the Scheduled Caste and Scheduled Tribe Development Department, Government Secretariat, Thiruvananthapuram - 695 001, represented by the Principal Secretary, respondent No.1, to abstain from any further transfer of any extent of land out of the 50 acres of land earmarked for the Medical College in Yakkara, Palakkad to any other project than related to the Medical Education, and also to take all measures for starting an inpatient treatment unit with all infra structure facilities, labs and other necessary related units as offered in W.P.(C) No. 453/2022 :4: Ext. P2 for a full fledged Medical College at the earliest.
3. A further direction is also sought to the Scheduled Caste and Scheduled Tribe Development Department, Government Secretariat, Thiruvananthapuram - 695 001, represented by the Principal Secretary, Director, Scheduled Caste Development Department, Thiruvananthapuram, District Collector, Palakkad and District Scheduled Caste Development Officer, Palakkad, respondent Nos. 1,3, 4 and 5 respectively, to provide all the immediate necessary facilities, such as pure water supply, hostel kitchen, clean premise in the College and hostels, play grounds etc. to the students in the Medical College.
4. The grounds on the basis of which the prayers sought for as hereunder:
A.The Palakad Medical College is the prestigious institution, started and run under the Scheduled Caste Development department. It is the first Medical College started in India under the department. The 50 acres land was purchased with the Scheduled Caste Component Plan fund(SCP) itself and for the said reason alone, the land shall not be utilized for any other purpose than the IIMS Medical College, Palakad and SC welfare.
B. The entire 50 Acres land is fully needed for the Medical College, hospital, nursing and para medical units, hostels for both Men and women, play grounds, library and all other connected units. Therefore the 50 Acres purchased for the medical college is to be utilized fully for the medical college purpose alone.
W.P.(C) No. 453/2022 :5:C. The diversion from the main scheme of the Medical College project is not at all justifiable. The transfer of the 5 acres of land to the cultural centre is against the norms of the utilization of SCP fund. The future development of the college and other related projects for a full fledged medical college is so far not completed due to the non attendance of the SC development department.
D. For the future activities and infra structure development in the college, more land is necessary.
E.The College is managed by the 1 st respondent. The department had made an initial budgetary allocation of Rs.5 crores and the said special allotment by the 1st respondent is for developing the campus in the 77 Acre campus, initially. More than 343 crores has already been spent for the development of the college by the 1 st respondent, from the SCP fund.
F.The Palakad Medical College has been started with the pioneer objective to give more educational opportunities for the Scheduled Castes and for improving the basic living conditions of people from Scheduled caste communities .The Palakad Medical college was intended to be built with the 800 crores diverted from the fund, originally set apart. The objective emerged from the desire of the upliftment of SC/ST community , who were in the long and chequered history , continued battered due to marginalisation and severe exploitation, yearned for a medical college of their own. The objectives of Article 38(2) and 46 in the perspective of Article 14 are to be complied with by the respondents in this matter.
G. The Palakad Medical college intended to provide departments like General Medicine, Psychiatry, Obstetrics and Gynecology. Anesthology W.P.(C) No. 453/2022 :6: and ENT. The hospital has a department such as X-Ray, CT scan and ultra sonography etc. The Medical College mainly promotes the quality and health of the lives communities , serving through commitment, understanding concentrates the socio - economic Development of the Scheduled Caste and their respectful integration with the main stream and bringing them on par with the others .
H.The socio- Economic deprivation and disadvantages suffered by Scheduled Caste and Scheduled Tribes led to the decision to adopt measures to close the enormous gaps and reduce the development deficits between these two communities and rest of the Indian population. The need was explicitly recognized by the Constitution of India, which mandated special protection and provisions for SC/ST Development. It was in 1974 -75 in the 5 th five year plan period that the Govt. of India introduced the policy of the tribal sub plan (TSP) and later in 1979-80 in the 6th five year plan period the special component plan (SCP) which was renamed as scheduled Caste Sub Plan in April 2006 and renamed as allocation for the welfare of schedules castes (AWSE/SC) in 2017.
I. In order to support the stages SCP, the department of Social Justice and Empowerment has also implemented a centrally sponsored scheme of "special Central Assistance (SCA SC/SP since 1980 for the development of SC's who form the major chunk of the countrys' population living below the poverty line. Under the scheme, grand is given to the State Governments Administration as an additive to their SC/SP for the benefits of the SC/ST persons. Govt. intends that by providing better education and employment, the poverty among the target population will be reduced and bring them above the poverty W.P.(C) No. 453/2022 :7: lines. State Government court choose the better schemes out of special central assistance, within the over all frame work of the scheme. Government has to take special care and attention for the effective implementation of the schemes for the overall development of the Scheduled Caste community, with the fund allocated by the Centre and State Government.
J. Special Central Assistance (SCA) II Scheduled Caste Sub Plan (SC/SP) is a Central Scheme under which hundred percentage grand is given to the states/UTS as an additive to their SC Sub Plan. The State is duty bound to identify the viable schemes as per the developmental needs of SC's and identification of eligible beneficiaries. The State is also duty bound to create dedicated units for proper implementation and to see that the separate budget head/ sub heads for making funds non divertible and approval for plans for central ministries. The creation of opportunities for employment is a prime duty of the Government, with the resources available from both the Central Government and from its own side.
K. Inspite of the various sharp and strict project, the College is has not started an inpatient treatment unit till date, though 9 long years have passed from the commencement of the college. The students are facing several difficulties due to the lack facilities, which needed for the better functioning of a Medical College. The buildings are not completed, the units offered are not yet commenced. Due to the non starting of the inpatient , students are not getting practical experience for becoming a good and efficient doctor. The district hospital where their hospital visits are provided, is with limited opportunity. Even a bus facility is not provided for the students to go to the district hospital.
W.P.(C) No. 453/2022 :8:The experience, which a medical college provides is far away in a district hospital.
L. The under developed nature of Palakad with a large population of Scheduled castes and scheduled Tribes prompted the starting of the college in Palakad. But the construction of the Medical College without an inpatient treatment with necessary related units, infact defeats the very purpose of starting the Medical College.
M. The non availability of pure water, the hostel without a kitchen etc. are also adversely affecting the students to have a better education. The play grounds are though in the project, those are not yet started. The compound and premises with bushes and grass are not helpful for a pleasant mind. These are the matters affect the fundamental rights guaranteed under Article 14, 21 , 21 A and 46 of the Indian Constitution.
N. There is no adverse orders from the Apex court in the SLP filed by the Indian Telephone Industries Ltd., before the Hon'ble Supreme court against the verdicts of the writ petition and writ appeals filed by the Indian Telephone Industries."
5. Ms. P.K. Santhamma, learned counsel for the petitioners, advanced arguments on the basis of the above. Ext. P1 is the proceedings of the District Collector, Palakkad dated 11.07.2012, by which, an extent of land allotted to the Indian Telephone Industries Ltd, Kanjikode was resumed.
6. For convenience Ext. P1 is reproduced hereunder:
W.P.(C) No. 453/2022 :9:PROCEEDINGS OF THE DISTRICT COLLECTOR, PALAKKAD (Present: P.N. Ali Asgar Pasha I.A.S) Sub: Industrial land-Violation of provisions of Kerala Land Acquisition Act and agreement-Resumption of Unutilised land in various Survey Nos. of Block 25 & 90 in Yakkara Village, Palakkad Taluk under possession of Indian Telephone Industries Ltd., Kanjikode of Yakkara Village, Palakkad Taluk, Resumption of Land for Medical College, Palakkad-orders issued-reg.
LRG2-2012/36750/9 Date: 11.07.2012
------------------------------------------------------------------------------------------------ Read: 1. G.O.(Rt.) No. 259/87/ID dated 03.03.1987
2. Govt. Letter No. 38788/F1/97/1 D dated 21.11.1997
3. Govt. letter No. 24585/L1/12/RD dated 27.4.2012
4. Letter of even No.dated 14.05.2012
5. G.O.(MS) No. 72/12/SCSTDD dated 26.05.2012
6. Govt. Letter No. 24585/L1/12/RD dated 25.06.2012
7. G.O.(Rt.) No. 958/12/SCSTDD dated 06.07.2012
8. Proceedings No. Edn. C2-13167/12 dated 09.07.2012
9. Letter No. Edn.C2/13167/2012 dated 10.07.2012.
...............
ORDER An extent of 100 acres of land in Yakkara Village of Palakkad Taluk was acquired for Indian Telephone Industries Ltd., Kanjikode vide Government sanction read as first paper above. Out of the acquired land an extent of 72.77 acres of land remains unutilized till date. As per the letter 2 nd cited the District Collector, Palakkad was directed to issue notice for the resumption of W.P.(C) No. 453/2022 : 10 : unutilized land from Indian Telephone Industries. Based on this the District Collector, Palakkad issued a notice to the Managing Director, Indian Telephone Industries Ltd. As per letter No. LRG2-25564/95(4) dated 17.12.1997.
As per reference read as third paper above Govt. have forwarded a letter No.6874/B2/12/SCSTDD dated 22.03.2012 directing to take action and report to Govt. to get the land acquired for the Indian Telephone Industries reconveyed to Govt. for the setting up of Medical College and the balance for other productive purposes.
A proposal for setting up of a Medical College in Palakkad has been sent to the Govt. as per reference 4 th cited. As per the 5th reference cited sanction has been accorded for the setting up of Medical College in Palakkad District by the Government.
As per reference 6th read above Govt. have directed to take action to resume the unutilised 72.77 acres of land from the Indian Telephone Industries. The Tahsildar, Palakkad reported that an extent of 77.8085 acres (31.4887 Hec. of land in 160 survey numbers of Yakkara Village is still remains unutilized by the Indian Telephone Industries. As per the agreement dated 17.07.1987, under the provisions of Kerala Land Acquisition Act, 1894, Government have the right to resume the land, if the bounden i.e., Indian Telephone Industries does not use the land for the purpose for which it was acquired within a period of 2 years or such period as further extended by the Government from the date on which the Bounden was placed in possession of land.
The District Collector was directed to resume the unutilised land twice by the Government. First time Indian Telephone Industries authorities represented to give an extension for 5 years upto February, 2003 to fully implement the projects. Secondly, Indian Telephone Industries had extended their willingness to spare 50 acres for the establishment of a National Institute W.P.(C) No. 453/2022 : 11 : (Indian Institute of Information Technology and Tele Communications-IIITT) to boost the educational and socio economic development in the district, provided appropriate compensation is paid to the company. Meanwhile the Indian Telephone Industries authorities submitted a proposal for utilising the land, but the same has not been implemented till date and the land still remains unutilised.
As per the reference 7th read above Govt have sanctioned a sum of Rs.5,00,00,000/- (Rupees Five Crore only) for the allotment of land for the proposed Medical College and to ensure the infrastructural facilities for the Special Office of the Medical College Project, Palakkad. The Govt. have allotted a sum of Rs.1,70,47,719/- (Rupees One crore sevey lakhs forty seven thousand seven hundred nineteen only) by means of a Demand Draft in favour of the Indian Telephone Industries Limited, Kanjikode. Sanction has been issued as per the 8th reference cited by the Director (IC) SC/ST Development Department.
As per the 8th reference cited a Demand Draft No. 552841 dated 10.07.2012 for an amount of Rs.1,70,47,719/- (Rupees One Crore Seventy Lakh forty seven thousand seven hundred nineteen only) in favour of the Indian Telephone Industries Limited, Kanjikode has been received from Govt.
In the above circumstances, it is ordered to resume an extent of 77.8085 acres of unutilized land in various survey numbers of Block 25 & 90 of Yakkara Village in Palakkad Taluk under the possession of the Indian Telephone Industries Ltd. Kanjikode as per the provisions of Kerala Land Acquisition Act and as per the agreement with the District Collector and the Indian Telephone Industries Ltd. For the purpose of setting up of a Medical College subject to ratification by the Government. The Tahsildar, Palakkad is directed to take over the possession of the land immediately and hand over the W.P.(C) No. 453/2022 : 12 : same to the District Collector, Palakkad and report the action taken within one week.
District Collector"
7. Materials on record discloses that challenging the resumption, Indian Telephone Industries Ltd. has filed W.P.(C) No. 16951 of 2012, and the same was dismissed.
8. Being aggrieved, Indian Telephone Industries Ltd. has filed Writ Appeal No. 48 of 2013, which also came to be dismissed, which resulted in filing of SLP No. 38829 of 2013, and stated to be pending before the Hon'ble Apex Court,
9. The power of the Government, in resuming an extent of land already allotted to the Indian Telephone Industries Ltd. has been sustained by this Court.
10. Be that as it may, SC/ST Development Department has requested the Revenue Department to take action for transfer of 5 acres of land from the 50 acres of land given to the SC/ST Development Department, by the Revenue Department for the Medical College, Palakkad to the Cultural Department for construction of a Cultural Complex.
11. The Land Revenue Commissioner has also submitted a proposal furnished by the District Collector for transferring 5 acres of land. After considering the proposals, Government have issued G.O. W.P.(C) No. 453/2022 : 13 : (MS) No. 380/2019/Rev.D dated 19.12.2019, effecting transfer of possession of land to an extent of 5 acres in re-survey No. 4, Block No.181, Yakkara Village, Palakkad District, to the Cultural Department for the construction of a cultural complex.
12. Translated version of Ext.P6 Government Order is reproduced hereunder:
Government of Kerala Summary Revenue (L) Department- orders issued reg. Transfer of possession of 5 Acres (2.0235 Hector) of land in Re. Survey No. 4 in Block No. 181 of Yakkara Village, Palakkad Taluk, Palakkad District to Culture Department for the construction of V. T. Bhattathirippad Cultural Complex as per the conditions of land transfer between two service departments by retaining ownership of Land in Revenue Department on condition that the ownership of the land shall be subject to the final verdict of SLP No. 38829/13.
------------------------------------------------------------------------------------------------
Revenue (L) Department GO (M.S) number 380/2019 Rev. D Date: Thiruvananthapuram
------------------------------------------------------------------------------------------------
Reference: 19/12/2019 (1) Letter No. L.R.G9 2016-6 8728/9 dated 23.03.2018 by the District Collector.
(2)Letter No. L.R (K2)-16535/18 dated 23.03.2018 by the Land Revenue Commissioner (3)Letter No. 04-2894/17/ dated 2.2.2019 by Director Cultural Department.W.P.(C) No. 453/2022 : 14 :
ORDER (1) SC/ST Development Department has requested to take urgent action for the transfer of 5 Acres of land from the 50 Acres of land given to SC/ST Development Department, by Revenue Department for Medical College Palakkad, to Cultural Department for the construction of Cultural Complex. As per the reference No. 2, the Land Revenue Commissioner has submitted proposal furnished by the District Collector for transferring 5 Acres of land in Re. Survey No. 4 in Block No. 181 comprised in Yakkara Village, Palakkad Taluk in Palakkad District for constructing V.T. Bhattathiripad Cultural Complex. As per the report it is informed that 5 Acres of land in Block No. 181 Re. Sy No. 4 Yakkara Village, Palakkad Taluk in Palakkad District comes under the land resumed from Indian Telephone Industries and the market vaue of the land is fixed as 35,95,397/- (Rupees Thirty Five Lakhs Ninety Five Thousand Three hundred and Ninety seven only) per one Acre. Indian Telephone Industries Authorities filed a case before the Hon'bie High Court against the action of District Collector to resume land and favourable orders for Government were received and Indian Telephone Industries has filed SLP before the Hon'ble Supreme Court and the case is till pending. (2) It was recommended by the Cultural Department on the request of the Director Cultural Department as per reference 3 that the tender proceedings for the construction of the Cultural Complex are to be completed and therefore the transfer of property is to be done immediately.
(3) Orders are issued hereby to the effect of transferring the possession of the land in Re. Survey 4, Block No. 181, Yakkara Village, Palakkad Taluk, Palakkad to the Cultural Department for the construction of V.T BHattathripad Cultural Complex, considering the urgency of the immediate starting of the construction work on the conditions of land transfer between two service departments, by retaining ownership of land in Revenue Department and same W.P.(C) No. 453/2022 : 15 : shall be subject to the result of the SLP 38 829/13 and the conditions stated below.
I. Land shall be utilised only for the purpose for which the land is given. II. The land shall not be mortgaged or alienated to any financial institutions.
III. The land shall not be put to lease or sublease or misused. IV. The land shall be protected from all sorts of encroachment by the Cultural Department.
V. The trees in the land shall not be cut down and if any necessity comes it shall be done after obtaining the prior permission from the Revenue Department. Moreover 3 times of the trees saplings are to be planted and protected.
VI. The construction shall be started within one year from the date of allotment of the land.
VII. If any of the conditions are violated the land with improvements will be resumed to Revenue Department.
(4) The legal formalities connected to this matter shall be taken by the District Collector, Palakkad.
By Order of Governor, Venue V. Principal Secretary."
13. From the above narration, it could be deduced that power to assign by the Government has been upheld, and Revenue Department has retained the ownership of the land, and transferring of possession is subject to the conditions stated supra.
W.P.(C) No. 453/2022 : 16 :14. Even though the petitioners have alleged that the College does not have the required infrastructure facilities and not even the basic amenities, such as water supply, kitchen etc., there are no materials supporting the above contention.
15. From the averments, it could be deduced that the building was partly completed in the year 2015.
16. For any reason, if the hospital or the college premises lack the basic amenities or any of the infrastructure required to be provided by the hospital, certainly, the Medical Council of India, the Apex Body, for granting recognition and the concerned affiliating University, as the case may be, would have found the deficiencies and not allowed continuation of the recognition or affiliation, as the case may be. In the instant case, the Medical College, inaugurated in the year 2015 is functioning without any shortcomings noticed by the above said authorities.
17. In the absence of any proof of deficiencies as alleged, we are not inclined to accept the contention of the petitioners that the College lacks infrastructural facilities, lack of sufficient water supply, hostel kitchen etc. As stated supra, considering the materials on record, power of the Government to resume the land allotted to the Indian Telephone Industries Ltd. has been accepted by this Court. However, an SLP Is pending before the Hon'ble Apex Court.
W.P.(C) No. 453/2022 : 17 :18. In the case on hand, it could be deduced that SC/ST Department has requested to take action for transfer of 5 acres of land from 50 acres of land given to the SC/ST Department by the Revenue Department for the Medical College, Palakkad. Possession alone has been transferred to the Cultural Department for the construction of a cultural complex.
19. In the light of the above discussion, we are of the view that the petitioners have not made out a case for the issuance of a writ of mandamus as prayed for.
Accordingly, this writ petition is dismissed.
sd/-
S. MANIKUMAR, CHIEF JUSTICE.
sd/-
SHAJI P. CHALY, JUDGE.
Rv W.P.(C) No. 453/2022 : 18 : APPENDIX OF WP(C) 453/2022 PETITIONERS' EXHIBITS:
Exhibit P1 THE COPY OF PROCEEDINGS OF R4 DATED 11.07.2012 REGARDING RESUMPTION OF LAND.
Exhibit P2 THE COPY OF REGISTRATION CERTIFICATE WITH TRANSLATION ALONG WITH MEMORANDUM OF ASSOCIATION OF THE SOCIETY FOR IIMS PALAKAKD. Exhibit P3 THE COPY OF THE GUIDE LINES OF NITI AYOG FOR UTILIZATION OF FUNDS.
Exhibit P4 THE COPY OF LETTER DATED 28.06.2019 BY 3RD RESPONDENT WITH TRANSLATION.
Exhibit P5 THE COPY OF THE SKETCH OF PALAKD MEDICAL COLLEGE COMPLEX.
Exhibit P6 THE COPY OF THE TRANSFER ORDER DATED
19.12.2019 BY R2 WITH TRANSLATION.
Exhibit P7 THE COPY OF REPLY DATED 23.10.2021 BY R5 TO
APPLICANT MR.KUNCHAN.P. UNDER RI ACT WITH
TRANSLATION.
Exhibit P7 A COPY OF THE REGISTRATION CERTIFICATE OF 2ND
PETITIONER WITH TRANSLATION.
Exhibit P8 THE COPY OF THE REPRESENTATION DATED
10.08.2021 BY THE 1ST PETITIONER TO R1 AND
HON'BLE MINISTER FOR SC/ST BACKWARD CLASSES.
RESPONDENTS' EXHIBITS: NIL
/True Copy/
PS To Judge.
rv