Legal Document View

Unlock Advanced Research with PRISMAI

- Know your Kanoon - Doc Gen Hub - Counter Argument - Case Predict AI - Talk with IK Doc - ...
Upgrade to Premium
[Cites 4, Cited by 0]

Kerala High Court

Jomon K.J vs The Manager, Kerala Financial ... 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-




                                                              2025:KER:69518


             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-




                                                               2025:KER:69518


                                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 WP(C) Nos.3175 of 2021 & 11895 of 2020 -5- 2025:KER:69518 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 WP(C) Nos.3175 of 2021 & 11895 of 2020 -6- 2025:KER:69518 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 WP(C) Nos.3175 of 2021 & 11895 of 2020 -7- 2025:KER:69518 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 WP(C) Nos.3175 of 2021 & 11895 of 2020 -8- 2025:KER:69518 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 WP(C) Nos.3175 of 2021 & 11895 of 2020 -9- 2025:KER:69518 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 WP(C) Nos.3175 of 2021 & 11895 of 2020 -10- 2025:KER:69518 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 WP(C) Nos.3175 of 2021 & 11895 of 2020 -11- 2025:KER:69518 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.

WP(C) Nos.3175 of 2021 & 11895 of 2020 -12-

2025:KER:69518

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 WP(C) Nos.3175 of 2021 & 11895 of 2020 -13- 2025:KER:69518 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.
WP(C) Nos.3175 of 2021 & 11895 of 2020 -14-
2025:KER:69518 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/-
WP(C) Nos.3175 of 2021 & 11895 of 2020 -15-
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.

 WP(C) Nos.3175 of 2021 & 11895 of 2020           -16-




                                                          2025:KER:69518


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 WP(C) Nos.3175 of 2021 & 11895 of 2020 -17- 2025:KER:69518 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 WP(C) Nos.3175 of 2021 & 11895 of 2020 -18- 2025:KER:69518 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.