National Green Tribunal
Ahamed Kutty. T vs Central Pollution Control Board on 28 July, 2021
Bench: K Ramakrishnan, K. Satyagopal
Item No.8:-
BEFORE THE NATIONAL GREEN TRIBUNAL
SOUTHERN ZONE, CHENNAI
Original Application No.19 of 2021 (SZ)
(Through Video Conference)
IN THE MATTER OF:
Ahammed Kutty. T,
S/o. Beeran. T
Thekkan House,
Varakkulam, Manimooly Post,
Nilambur Taluk, Malappuram District.
...Applicant(s)
Versus
1) The Central Pollution Control Board,
Rep. by its Chairman,
Parivesh Bhavan, East Arjun Nagar,
Delhi - 110 032.
2) The District Collector,
Collectorate, Civil Station,
Malappuram - 676 505.
3) The Kerala State Pollution Control Board,
Rep. by its Member Secretary,
Pattom P.O., Thiruvananthapuram - 695 004.
4) The General Manager/ Executive Director,
Bharat Petroleum Corporation Limited,
Kochi Refinery, Ambalamugal, Cochin - 682 302.
5) The General Manager,
Nayara Energy Ltd. (Formerly Essar Oil Ltd.)
Divisional Manager, Retail - BD,
6B, 6th Floor, Noel Focus,
Seaport - Airport Road, Chittethukara,
Kochi - 682 037.
...Respondent(s)
For Applicant(s): Mr. S. Kamalesh Kannan.
For Respondent(s): Mr. R. Thirunavukarasu for R1.
Mr. E.K. Kumaresan for R2.
Mrs. V.K. Rema Smrithi for R3.
Mr. Abdul Saleem and
Mr. Saravanan for R4 & R5.
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Date of Judgment: 28th July, 2021.
CORAM:
HON'BLE MR. JUSTICE K. RAMAKRISHNAN, JUDICIAL MEMBER
HON'BLE MR. Dr. SATYAGOPAL, EXPERT MEMBER
JUDGMENT
1. The grievance in this application is regarding setting up a petrol pump by the respondents 4 and 5 in a residential area against the norms published by the Central Pollution Control Board (CPCB) for that purpose.
2. It was alleged in the application that respondents 4 and 5 are now attempting to establish a Fuel Station in Re-Survey No. 1087/1C and 1100/1 of Vazhikkadavu, Nilambur Taluk, Malappuram District against the objections raised by the public regarding the possible environmental issues that is likely to arise on account of the establishments of such units.
3. It was also alleged in the application that the unit is going to be established in violation of the existing norms prescribed by the respondents 1 and 3. Further, it is also proposed to be established adjacent to the river "Karakkodan Puzha" which is one of the main sources of drinking water to the villages. It is also against the directions issued by the Principal Bench of National Green Tribunal in O. A. No 147 of 2016 (PB) and other related matters. The authorities have not considered the question of volatile organic compounds that is likely to be emitted during the operation of this unit which has got vital impact on the health of the people in the locality.
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4. So, the applicant filed this application seeking the following reliefs:-
"The applicant most respectfully prays that this Hon‟ble Tribunal may be pleased to pass an order to permanently forebear the 4th and 5th respondents from establishing a Fuel 3 Station at Re- Survey Nos. 1087/1C and 1100/1 of Vazhikkadavu Grma Panchayat, in Malapuuram District, respectively, which is in violation of the existing laws, and pass such further orders in the interest of justice."
5. While admitting the matter, as per order dated 25.01.2021, this Tribunal had appointed a Joint Committee comprising of (i) District Collector, Malappuram District or a Senior Officer not below the rank of Assistant Collector/Revenue Divisional Officer to be deputed by the District Collector, (ii) a Senior Officer from the Central Pollution Control Board (CPCB), Regional Office, Bangalore and (3) a Senior Officer from the Kerala State Pollution Control Board (KSPCB) as nominated by its Chairman to inspect the area in question and submit a factual as well as action taken report, if there is any violation found.
6. The committee was directed to ascertain as to whether the establishment of the proposed petrol pump fuel station is in accordance with the guidelines issued by the Central Pollution Control Board (CPCB) in this regard after obtaining permission and other consents (if any) required from the authorities, complying with the pollution norms. If there is any violation found, the proposed action to be taken and if any damage caused to the environment, to assess the environmental compensation to be recovered from the respondents 4 and 5 and the Kerala State Pollution Control Board (KSPCB) was designated as the nodal agency for co-ordination and for providing necessary logistics for this purpose Page 3 of 14
7. The 1st respondent has filed a reply affidavit contending that the applicant is raising objection against two proposed Petrol Pumps/ Retail Outlets (ROs) in Vazhikkadavu Village, Nilambur Taluk, Malappuram District in Kerala. The State Highway 28 (SH-28) or the Nilambur Gudalur interstate road passed through the Vazhikkadavu village and is the gateway to the ghat roads leading to Gudalur, Tamil Nadu. Vazhikkadavu is the last town in Kerala side for interstate travellers towards Tamil Nadu and Karnataka. A Joint Committee has been constituted in this matter and Kerala State Pollution Control Board as the nodal agency. CPCB representative as a part of the joint committee visited the location of proposed Petrol Pumps/ROs in Vazhikkadavu, Nilambur Taluk, Malappuram District on 18.02.2021. The Joint committee inspected the site/locations and interacted with the proponents /land owners. The locations of the proposed petrol pumps are on the left side of the State Highway 28 (SH-28) towards Gudalur and a river/rivulet is flowing close to the proposed sites/locations. It was also observed during the visit that the proposed sites are near to the river/rivulet and the existing petrol pumps (M/s. Indian Oil Corporation Ltd.) in the area is also located on the left side of SH-28 toward Gudalur, close to the river. CPCB has already issued guidelines for setting up new petrol pumps in compliance of the directions of the Principal Bench of National Green Tribunal, New Delhi by order dated 18.01.2019 in O.A. No.86 of 2019 and the guidelines issued on the basis of the specific directions to prepare appropriate guidelines for setting up new petrol pumps in the country. The Expert committee constituted for this purpose framed the guidelines, which consists of specific criteria for siting of Petrol Pumps/Retail Outlets (RO), measures to be adopted for pollution prevention/control and spillage/leak Page 4 of 14 management. The draft guideline was placed in public domain for comments/suggestions/objections, and after reviewing the inputs received, the guideline was finalized, circulated to concerned stakeholders for implementation and placed in public domain on 7 th January, 2020. As per the guidelines issued, new petrol pumps/ROs shall not be located within a radial distance of 50 m (from fill point/dispensing unit/vent pipe whichever is nearest) from schools, hospitals (10 beds and above) and residential areas designates as per the local laws. It was also mandated that in case of constraints in complying with 50 m distance criteria, the petrol pump/RO shall implement additional safety measures as prescribed by the Petroleum Explosive Safety Organization (PESO).The guideline further insist at least 30 m distance criteria between new petrol pump/RO and schools/ hospitals/ residential areas designated by local laws. It is also understood that KSPCB further issued circular clarifying that the new petrol pumps/ROs shall be at a minimum 30m distance from residential buildings.
8. The 1st respondent has further contended that on the basis of the several representations received from the stakeholders, the CPCB issued clarification dated 29.01.2021 stating that above guidelines is applicable for petrol pumps/ROs, where construction commenced on or after 07.01.2020 and issued office memorandum dated 29.01.2021 made it clear that the siting criteria specified in the guideline dated 07.01.2020 is not applicable to petrol pumps/ ROs where prior clearance/initial approval has been obtained from PESO and construction started before 07.01.2020 subsequent to the approval. However, the proposed petrol pumps/ ROs inspected in this matter are not entitled to avail the siting criteria exemption as they Page 5 of 14 have secured the approvals from PESO only after the cut off date of 07.01.2020. They have not approached the Pollution Control Board for Consent to Establish/Operate the petro pumps/ROs and it is for them to consider as to whether necessary consent will have to be given or not.
9. The 3rd respondent/Kerala State Pollution Control Board also filed a reply in the form of report stating that complaint was received on 16.11.2020 by the Board submitted by one Mazrook Abdul Salam against the two proposed petro pumps in Survey No.1087/1C and 1100/1 of Vazhikkadavu Village, Nilambur Taluk. No application for consent to establish were received from the Board for the proposed petro pumps and as and when the applications were received, they will consider and issue appropriate orders, after considering the circulars issued in this regard.
10. The Joint Committee appointed by this Tribunal has filed a report dated 17.03.2021, e-filed on 20.03.2021 and received on 29.05.2021 which reads as follows:-
"REPORT FILED BY JOINT COMMITTEE CONSTITUTED BY HON‟BLE NGT AS PER ORDER DATED 25.01.2021 ON O.A .NO.19/2021 Back Ground in brief OA.No.19 of 2021 has been filed by Sri.Ahammed Kutty.T, Malappuram District, against setting up of Petrol pumps by Respondents 4 and 5 in a residential area, against the norms fixed by the Central Pollution Control Board for that purpose. The allegation is that the respondents 4 and 5 are attempting to establish a fuel station in Re-survey No. 1087/IC, and 1100/1 of Vazhikkadavu, Nilambur Taluk, Malappuram District against the objections raised by the public regarding the possible environmental issues that is likely to arise on account of the establishment of such units. It is also alleged that the unit is going to be established in violation of the existing norms issued by the 1st and 3rd respondents. Further it is also proposed to be established adjacent to the „Karakkodan Puzha‟ which is one of the main sources of drinking water to the Villages, and also against the directions issued by the Principal Bench of the National Green Tribunal in OA No.147 of 2016 and other related matters.
The Hon‟ble NGT vide its order dated 25.01.2021 appointed a joint Committee Comprising of (1) The District Collector or a senior officer not below Page 6 of 14 the rank of Assistant Collector or Revenue Divisional officer to be deputed by the District Collector (2) A Senior officer from the Central Pollution Control Board Regional Office Bangalore, (3) A Senior Officer from the Kerala State Pollution Control Board (KSPCB) as nominated by its Chairman to inspect the area in question and submit a factual as well as action taken report, if there is any violation found. The Committee is directed to ascertain as to whether the establishment of the proposed petrol pump fuel station is in accordance with the guidelines issued by the Central Pollution Control Board (CPCB) in this regard after obtaining permission and other consents if any required from the authorities, complying with the pollution norms. If there is any violation found the proposed action to be taken and if any damage caused to the environment to assess the environmental compensation to be recovered from the respondents 4 and 5. The committee is directed to submit the report to the Hon‟ble Tribunal on or before 25.02.2021.
It is humbly submitted that although the Joint committee inspection was conducted on 18.02.2020, due to other overloaded official works which were prescheduled, it was unable to complete and submit the Committee reports before the Hon‟ble Tribunal. Hence as per request this Hon‟ble Tribunal has adjourned the hearing to 31.03.2021. Accordingly the Joint Committee report is completed, approved by the Committee members and submitted herewith.
1) With respect to the Hon‟ble Tribunal‟s order dated: 25.01.2021, the Board Chairman had issued proceedings No.PCB/HO/EE4/NGT/OA.19/ 2021 (SZ), Thiruvananthapuram dated: 04.02.2021, nominating the Environmental Engineer, Kerala State Pollution Control Board, District Office, Malappuram to represent KSPCB in the Joint Committee. Copy of the proceedings is produced herewith and marked as Annexure- 1. Also vide letter no.PCB/HO/EE4/NGT/OA No.19/2021 dated: 04.02.2021, the Board Chairman authorized the Environmental Engineer Legal Cell, Regional Office, Ernakulam to represent the Board (3 rd Respondent) and to file a report on behalf of Board, after considering the report of the Joint Committee. Copy of the above letter and Authorization is attached herewith and marked as Annexure- 2. Dr.Deepesh.V, Scientist-C was nominated as the Central Pollution Control Board (CPCB) representative in the Joint Committee vide CPCB letter dated: 15.02.2021, by number F; Tech 39/Legal/RDS/2020-21/1182 from the CPCB Regional Director, Bengaluru. Copy of the nomination letter is produced herewith and marked as Annexure- 3.
2) It is respectfully submitted before the Hon‟ble Tribunal that site inspections were conducted by the following Joint Committee members on
18.02.2021, 1.30 PM.
1. Smt.Anju.K.S, IAS, Sub Collector, Perinthalmanna
2. Shri. Dr.Deepesh.V, Scientist.C, Central Pollution Control Board Regional Directorate, Bengaluru.
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3. Smt. Sauma Hameed, Environmental Engineer, Kerala State Pollution Control Board, District Office, Malappuram. (Member - Convener).
Attendance list of the Joint Committee members is produced herewith and marked as Annexure- 4. Besides the Joint Committee members, the following officials were also present during the inspection of the land under question.
1. Shri. Baburajan.P.R, Village Officer, Vazhikkadavu Village.
2. Shri. Muhammed Ashraf, Villlage Assistant, Vazhikkadavu Village.
3. Smt. Jyolsna Jerin, Assistant Engineer, Kerala State Pollution Control Board, District Office, Malappuram. The petitioner Shri.Ahammed Kutty was also present during the Site inspection.
3) It is respectfully submitted before the Hon‟ble Tribunal that the petitioner is raising objections against two proposed petrol pumps, one at Resurvey no. 1087/1C and second at Resurvey no. 1100/1 of Vazhikkadavu Village, Nilambur Taluk, Malappuram District in Kerala. The Nilambur - Gudallur Interstate Road (SH - 28) passes through the Vazhikkadavu Village and is the gate way to the Ghat roads leading to Gudallur, Tamilnadu. It is submitted that the Joint Committee had visited the locations of the proposed petrol pumps on 18.02.2021, inspected the sites/ Locations and interacted with the project proponents as well as the land owners. Both the locations are on the left side of the State Highway (SH28) towards Gudallur and a River called Karakkodan Puzha is following close to the proposed site locations.
Observations during Site Inspection
4) The details of site inspection conducted at the two proposed petrol pump locations are briefed below:
a) Proposed petrol pump at Vazhikkadavu Village Nilambur Taluk at Survey No. 1087/1C It is respectfully submitted before the Hon‟ble tribunal that this proposed site is 0.1224 hectares of land owned by Smt.Rosamma Thomas, KachamKodath House, Manimooly (PO), Vazhikkadavu Village, Nilambur Taluk, Malappuram District Kerala, given to Bharath Petroleum for establishing a petrol pump/petroleum out let. The eastern side of the plot is Nilambur-Gudallur State High way (SH 28), western side is Karakkodan Puzha, and the nearest residences are located at the northern and southern sides of the proposed location.
The geo-ordinate location of the proposed site is as follows:
Latitude - 110 22‟ 37.8" N Longitude - 760 20‟ 14.4" E The location photograph of the proposed petroleum out let obtained from Google satellite map is produced herewith and marked as Annexure-5. On measuring the distances, it was observed that the Smt.Kalathiparambil Tresiamma is residing at a distance of 26.7 meters from the proposed fuel dispensing point, and Sri.Pookodan Subair is residing at a distance of 24 meters Page 8 of 14 from the vent pipe position of the proposed petrol pump, which are the nearest residence measured from the proposed pump location.
b) Proposed petrol pump at Vazhikadavu Village, Nilambur Taluk, at Survey No. 1100/1.
It is respectfully submitted that this proposed petrol pump site is 0.1012 hectares of land owned by Smt.Sajna, W/o. Sri.Shanavas Pullanikkattil which is given for establishing a petrol pump/petroleum outlet for Nayara Energy Limited. The eastern side of the plot is Nilambur-Gudallur State High way (SH. 28); western side is a thodu, land owned by Shanavas on the north, and land owned by Naseeba on the south, as Boundaries of the proposed plot.
The geo ordinate location of this proposed site is as follows:
Latitude - 110 22‟ 37.8" N Longitude - 760 20‟ 14.4" E The geo ordinate location of the proposed site obtained from Google satellite map is produced herewith and marked as Annexure 6. The land is acquired on lease by Shri.Ummer.C.K and Shri. Muhammed Mustafa from Smt.Sajna, for establishing the petrol pump for Nayara Energy Ltd.
5) It is submitted that, on measuring the distances, it was observed that the nearest residence owned by Shri. Abdul Kareem is at a distance of 20.4 meters from the location of the proposed fuel dispensing point. Distance measured to the river bank on north side, from the boundary of petrol pump location is 7.1 meters and from the proposed fuel dispensing point to the river is measured as 24.1 meters. The approximate location of vent pipe is near to and running parallel to the river and Kattungal Road. Other residential buildings were seen located across the river (bridge) which is having a width of 35 meters.
However the proponent claimed that Shri. Abdul Kareem, the owner of the nearest residential building at 20.4 meters from the location of the fuel dispensing point had expressed his no objection to the proposed petrol pump.
6) Copy of the Report submitted from the office of the District Collector, Civil Station Malappuram, based on the Joint Committee Site inspection dated:
18.02.2021 is produced here with and marked as Annexure- 7 for reference. It is humbly submitted that, the officials from District Collectorate informed during inspection that no NOC has been granted for both the petroleum outlets so far from that office.
7) It is humbly submitted before the Hon‟ble Tribunal that the Central Pollution Control Board (CPCB) has issued clear guidelines vide CPCB office Memorandum No.B-13011/1/2019-20/AQM/0814 dated: 07.01.2020, and this office memorandum, as informed by the CPCB representative in the Joint Committee, has been prepared based on specific directions to prepare appropriate guidelines for setting up of new petrol pumps in the Country, and this guidelines consist of specific criteria for siting of petrol pumps/retail outlets (RO‟s), measures to be adopted for Pollution prevention/ Control and Spillage/ Leak management. The draft guidelines they had placed in the public domain for Page 9 of 14 comments/ suggestions/ objections and after reviewing the inputs received the guidelines were finalized, circulated to stakeholders for implementation and placed in the public domain on 07.01.2020. A copy of the CPCB guideline dated:
07.01.2021 is attached herewith and marked as Annexure- 8. It is humbly submitted that, following the Annexure- 8 CPCB guidelines, KSPCB had issued circulars on 24.02.2020 and 18.08.2021, specifying specific distance criteria for new petrol pumps starting after 24.02.2020. Copies of KSPCB circulars dated:
24.02.2020 and again on 18.08.2020 by number PCB/HO/HOW/RULES -
9/7/2019 are produced herewith and marked as Annexure- 9 and Annexure- 10.
8) As per the Annexure-8 guideline, and Annexure- 9 circular , petrol pumps shall not be located within a radial distance of 50 meters from Schools, Hospitals and Residential areas, designated as per local laws and in no case shall less than 30 meters. Annexure- 9 circular is again revised and issued revised circular by Board on 18.08.2020, vide Annexure- 10, according to which siting criteria for new retail outlet or petrol pumps from the „nearest residential building‟ may be considered instead of „Residential areas‟. Also Annexure- 10 circular made clear that if any requisite license other than Pollution Control Board Consent is obtained by the applicant for establishing the petrol pump prior to the date of Annexure- 9 circular dated: 24.02.2020, them for such projects the general siting criteria mentioned in Board circular dated:
09.08.2004 shall be applicable. Copy of the above circular dated: 09.08.2004 by No. PCB/TAC/18/2004 is produced herewith and marked as Annexure- 11.
9) Further CPCB has issued a Clarification on the guideline dated:
07.01.2020 vide Annexure- 8, on 29.01.2021. Copy of the same is produced herewith and marked as Annexure- 12 . This clarification says that, the guideline is applicable for petrol pumps/ retail outlets where constructions commenced on or after 07.01.2020. It is also made clear that the siting criteria specified in Annexure- 8 guideline is not applicable to petrol pumps/ retail outlets where prior clearance/ initial approval has been obtained from Petroleum & Explosive Safety Organization (PESO) and subsequently construction has been started before 07.01.2020.
10) It is further submitted that, following the Annexure- 12 clarification by CPCB, KSPCB has also issued a revised circular by no. PCB/HO/HOW/RULES-9/7/2019 dated: 04.02.2021. Copy of the same is produced herewith and marked as Annexure- 13. It is respectfully submitted before the Hon‟ble tribunal that, since the proponent of petrol pump at Survey No. 1087/1C has obtained initial approval of PESO only after 07.01.2020, there is no relaxation in the distance criteria. (Copy of the PESO initial approval, dated: 04.03.2020 is produced herewith and marked as Annexure- 14 and copies of layout/ site plan submitted by the respondent 4 and 5 for their projects are produced herewith and marked as Annexure -15. Hence the Proponent/ Bharath Petroleum Company have to re-align the layout to maintain the requisite distance criteria from the neighbouring residential buildings. Page 10 of 14
11) As for the Second case, for the petrol pump at Survey no.1100/1, they had not obtained PESO initial clearance. Hence here also there is no relaxation in the minimum siting criteria of 30 meters to nearest residences. The proponent has to check for the possibility of re-aligning the layout so as to maintain the requisite minimum distance from the neibouring residential buildings.
12) It is further submitted that, the proponents of the petrol pumps i.e.; respondents 4 and 5 have not submitted any application to Kerala State Pollution Control Board for obtaining Consent to Establish for their proposed petrol pumps till date.
CONCLUSION
13) The Joint Committee here by respectfully submits before this Hon‟ble Tribunal that, on the light of the detailed site inspection and onsite verification of distances as per the layout/ site plan and further based on the documents produced by the project proponents, the Joint Committee has observed that the proposed petrol pumps under allegation are not entitled to avail the siting criteria exemption, as they don‟t have obtained the PESO initial approval before 07.01.2020, which is the cutoff date and also no construction works started before 07.01.2020 at the site subsequent to such initial approval. The proposed layout of the petrol pumps inspected were not meeting the requisite minimum of 30m distance criteria measured between the proposed fill point/dispense point/vent pipe position, and the nearby residences. Hence this Joint Committee is of the opinion that for the Proponents and the Oil marketing companies to continue with their projects, they have to relook on to the site plan / layout of their proposals such that a minimum mandatory clearance of 30 meters could be maintained from the nearby residences, and there after submit application to obtain necessary clearances from the concerned departments.
Dated this 17th of March 2021."
11. They have also produced some annexures along with the report.
12. When the matter came up for hearing today through Video Conference, Mr. S. Kamalesh Kannan represented the applicant. Mr. R. Thirunavukarasu represented 1st respondent, Mr. E.K. Kumaresan represented 2nd respondent and Mrs. V.K. Rema Smrithi represented 3rd respondent and Mr. Abdul Saleem and Mr. Saravanan represented respondents 4 & 5.
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13. The learned counsel appearing for the applicant submitted that in view of the report of the Joint Committee, no Petrol Pumps / Retail Outlets can be constructed or established in the proposed site.
14. The learned counsel appearing for the Kerala State Pollution Control Board submitted that they have not received any application for this purpose and if any application is received, they will consider the same and pass appropriate orders only in accordance with the circulars issued.
15. The learned counsel appearing for the respondents 4 & 5 submitted that they will not proceed with the establishment of the proposed petrol pumps in those areas without getting necessary permissions and other consent (if any) required in the various laws / statutes.
16. It may be mentioned here that it is true that there was a proposal for respondents 4 & 5 to establish a petrol pumps in the proposed site, as alleged in the application and it is only in the premature stage. Before proceeding with the work of establishment of unit, they will have to obtain necessary permission/consent required under the respective statutes and if permitted as per rules also ensure strict compliance with the guidelines issued by the Central Pollution Control Board and State Pollution Control Board in this regard, which are issued on the basis of the directions issued by this Tribunal in O.A. No.86 of 2019 (SZ) and other connected matters.
17. Since statutory authorities as well as the project proponent have submitted before this Tribunal that they will strictly comply with the directions and also the guidelines provided for that purpose and pass appropriate orders in this regard, we feel that the application can be disposed of by directing the respondents 4 & 5 not to proceed with the construction of the proposed petrol pumps / Retail Outlets in the proposed area namely, Re-Survey No. Page 12 of 14 1087/1C and 1100/1 of Vazhikkadavu, Nilambur Taluk, Malappuram District without obtaining necessary permission or consent as required under the respective statutes.
18. So, the application is disposed of as follows:-
(i) The respondents 4 & 5 are restrained from establishing any Petrol Pumps or Retail Outlets without obtaining permission/consent from the concerned authorities as per the respective statues and also ensure strict compliance with the guidelines issued by the Central Pollution Control Board as well as Kerala State Pollution Control Board in this regard, if as and when permissions are granted.
(ii) Whenever applications are filed by the project proponent, the Kerala State Pollution Control Board and the respective State Departments are directed to consider those applications and pass appropriate orders strictly in compliance with the guidelines and circulars issued by the different departments in this regard.
(iii) The applicant, if aggrieved by any order(s) will be entitled to challenge the same before the appropriate forum in accordance with law.
(iv) Considering the circumstances, the parties are directed to bear their respective costs in the application.Page 13 of 14
19. With the above observations and directions, the application stands disposed of.
20. The Registry is directed to communicate this order to the official respondents for their information and also compliance for the direction.
Sd/-
.....................................J.M. (Justice K. Ramakrishnan) Sd/-
..............................E.M. (Dr. K. Satyagopal) O.A. No.19/2021 (SZ), 28th July, 2021. Mn.
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