Kerala High Court
Mar Gregorios Educational Society vs State Of Kerala on 8 October, 2020
Author: Anu Sivaraman
Bench: Anu Sivaraman
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MRS. JUSTICE ANU SIVARAMAN
THURSDAY, THE 08TH DAY OF OCTOBER 2020 / 16TH ASWINA, 1942
WP(C).No.28731 OF 2018(N)
PETITIONERS:
1 MAR GREGORIOS EDUCATIONAL SOCIETY
REP. BY ITS SECRETARY
UNITY BUILDING
K. K. ROAD
KOTTAYAM
686002
2 KERALA ARTS AND SCIENCE UNAIDED COLLEGE
MANAGEMENT ASSOCIATION
(REPRESENTED BY ITS SECRETARY), YELDO MAR
BASELIOS COLLEGE CAMPUS, KOTHAMANGALAM - 686 673
BY ADVS.
KURIAN GEORGE KANNANTHANAM
SRI.TONY GEORGE KANNANTHANAM
SRI.THOMAS GEORGE
RESPONDENTS:
1 STATE OF KERALA
REP. BY ITS SECRETARY TO GOVERNMENT
HIGHER EDUCATION DEPARTMENT
GOVT.SECRETARIAT
TRIVANDRUM
695001
2 MAHATMA GANDHI UNIVERSITY
(REPRESENTED BY ITS REGISTRAR), PRIYADARSHINI
HILLS, KOTTAYAM - 686 560
3 THE VICE CHANCELLOR
MAHATHMA GANDHI UNIVERSITY, PRIYADARSHINI HILLS,
KOTTAYAM - 686 560
R2-3 BY SRI.ASOK M. CHERIAN, SC, M.G. UNIVERSITY
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
29.09.2020, ALONG WITH WP(C).16431/2020(D), THE COURT ON
08.10.2020 DELIVERED THE FOLLOWING:
WP(C).No.28731/2018 & WP(C).No.16431 OF 2020
2
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MRS. JUSTICE ANU SIVARAMAN
THURSDAY, THE 08TH DAY OF OCTOBER 2020 / 16TH ASWINA, 1942
WP(C).No.16431 OF 2020(D)
PETITIONERS:
1 ALL KERALA PRIVATE ARTS AND SCIENCE UNAIDED COLLEGE
MANAGEMENT ASSOCIATION
(REG.NO.K.84/08), YELDO MAR BASALIOS COLLEGE
CAMPUS, KOTHAMANGALAM-686 673, (REPRESENTED BY ITS
SECRETARY).
2 THE MANAGER, K.M.E.A. COLLEGE,
KUZHIVELIPPADY, ALUVA-682 021.
BY ADVS.
SRI.KURIAN GEORGE KANNANTHANAM (SR.)
SRI.P.M.SANEER
SRI.TONY GEORGE KANNANTHANAM
SRI.THOMAS GEORGE
SHRI.SIVASHANKAR PANICKER
SRI.ALEX GEORGE (CHAMAPPARAYIL)
RESPONDENTS:
1 MAHATMA GANDHI UNIVERSITY
(REPRESENTED BY ITS REGISTRAR), PRIYADARSHINI
HILLS, KOTTAYAM-686 560.
2 THE REGISTRAR,
MAHATMA GANDHI UNIVERSITY, PRIYADARSHINI HILLS,
KOTTAYAM-686 560.
3 THE STATE OF KERALA,
REPRESENTED BY THE PRINCIPAL SECRETARY TO
GOVERNMENT, HIGHER EDUCATION DEPARTMENT,
SECRETARIAT, THIRUVANANTHAPURAM-695 001.
R1-2 BY SRI.ASOK M. CHERIAN, SC, M.G. UNIVERSITY
R3 BY GOVERNMENT PLEADER
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
29.09.2020, ALONG WITH WP(C).28731/2018(N), THE COURT ON
08.10.2020 DELIVERED THE FOLLOWING:
WP(C).No.28731/2018 & WP(C).No.16431 OF 2020
3
ANU SIVARAMAN, J.
------------------------------------------
W.P.(C) Nos.28731 of 2018 and
16431 of 2020
-------------------------------------------------------
Dated this the 8th day of October 2020
JUDGMENT
These writ petitions are filed by a registered Association of Managements of private unaided Arts & Science Colleges and one private educational agency each, challenging the steps taken by the University for admitting students to such colleges through the Centralised Allotment Process.
2. W.P.(C) No.28731 of 2018 is filed challenging Ext.P3 letter dated 26.4.2016 of the 1 st respondent and Ext.P4 order of the 2 nd respondent and seeking a declaration that the University is incompetent to take over admission to seats in private unaided Arts & Science Colleges except through a law made under Article 19(6) of the Constitution of India. Directions are sought to the University to permit the unaided Arts & Science Colleges to fill up the vacant seats on their own.
3. The prayers in W.P.(C) No.16431/2020 are as follows :-
"(i) To issue a writ of certiorari or other appropriate order or direction to quash Cl:2 on page 6 of Ext.P7 Prospectus reserving 50% of seats in unaided colleges for CAP by the University.
(ii) To issue a writ of certiorari or other appropriate order or WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 4 direction to quash Cl:3(ix)(c) on page 15 of Ext.P7 Prospectus.
(iii) To issue a writ of mandamus or other appropriate order or direction to direct the 1st respondent University, not to allot any students through the CAP, except without entering into a proper agreement with the managements."
4. Heard Sri.Kurian George Kannanthanam, the learned Senior Counsel appearing for the petitioners, Sri.M.A.Asif, the learned Special Government Pleader as well as Sri.Ashok M. Cherian, the learned Standing Counsel appearing for the Mahatma Gandhi University.
5. It is submitted by the learned Senior Counsel that the present grievance of the petitioners is against the University taking over admissions to 50% of the seats in Self Financing Colleges, in the guise of Centralized Allotment Process. It is submitted that there is no statutory provision enabling the University to take over the admission to unaided Arts & Science Colleges. Even if seats are vacant in the 50% seats taken over by the University, the Managements cannot fill up those seats. It is submitted that in the absence of any statutory provision enabling the University to conduct the admissions in affiliated unaided Arts & Science Colleges, the entire exercise is incompetent. Complaints are raised with regard to the time taken to complete the allotment and it is submitted that several seats in the management quota are left vacant even after the entire admission procedure.
WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 5
6. It is submitted that the powers of the University are stated in Section 5 of the M.G. University Act and the provision does not give power to the University to make allotments for admission in unaided affiliated colleges. Section 73A of the M.G.University Act provides power to the Government to determine the admission and selection of and the fees payable by students in unaided colleges. It is submitted that there has been no such determination by the Government and therefore the University cannot place any reliance upon a recommendation of the Committee constituted under Section 73A. It is further stated that neither the State nor the University has any power under Section 73A to determine any quota system between the University and the management as far as private unaided colleges are concerned and therefore the determination of the present Centralised Allotment Process system is arbitrary and violative of Article 14 of the Constitution of India.
7. Relying on a judgment of this Court in Manager, Mar Augusthinose College and another v. Mahatma Gandhi University [2011 (3) KHC 241], it is submitted that Section 73A is the only enabling provision for framing regulations with regard to admission to unaided colleges and that the regulations have to be framed by the State and not by the University. It is therefore submitted that the steps taken by the University to conduct WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 6 admissions is completely illegal and unsustainable.
8. A counter affidavit has been placed on record by the 2 nd respondent in W.P.(C) No.16431/2020. It is stated at paragraphs 4, 7, 9 and 10 of the counter affidavit as follows :-
"4. It is true that the 1st respondent University started providing affiliation to SFCs and to courses offered by them, since 1995. Affiliation to each of such colleges and courses offered by them was granted only after ascertaining the views of Government and in accordance with the conditions the Government prescribed in Government Orders expressing its consent on each application. One condition the Government always insisted for granting affiliation to UG Courses is that "the Educational Agency shall set apart 50% of the seats of the course for being filled up by the Government or such authority determined by the Government on the basis of merit and reservation principles followed by the Government and remaining 50% filled by the Educational Agency on the basis of merit." Such Government Orders also prescribe that the management of concerned educational agency shall execute an agreement with the Government as per the conditions therein prescribed in the Order. A true copy of the Order issued by Government of Kerala, dated 05-07-2014 granting sanction for starting the College of the 2nd petitioner is produced herewith and marked as Exhibit R2(a).
7. It is true that the affiliated colleges including SFCs were allowed by the Government to make admissions against the Government Quota, by themselves, from among the applicants till 2006 strictly on the basis of merit-cum-reservation, recognizing them as the agency authorized by the Government for the purpose. The system was not going well as claimed in paragraph 12 of the writ petition. Under the said system, a student had to make applications in various colleges without knowing where he would WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 7 get a seat according to his/her choice-cum-merit. The students who aspired for getting admission to a college for a course of his choice were compelled to rush to submit applications in several colleges within a short period and go after searching his chance from college to college. Further there were widespread complaints that the private colleges were not making admissions to the Government Quota of seats transparently. There were widespread complaints among public that the students who were eligible to get admission in the said quota were denied admissions. Hence the Government of Kerala issued GO (MS) No.144/2006/Edn dated 03- 11-2006 authorizing the universities in the State to allot students to the Government Quota for the courses for which the Commissioner for Entrance Examinations was not conducting Common Entrance Test. A true copy of GO(MS) No.144/2006/Edn dated 03-11-2006 is produced herewith and marked as Exhibit R2(b).
9. Though the Court interfered with the system of CAP to be followed in the case of SFCs. the University could continue with the system as agreed to by the managements of SFCs in the meeting convened at the instance of Government, wherein the Managements accepted the proposal placed by the Principal Secretary of Higher Education Department to continue carrying out admissions to Government Quota seats in SFCs by CAP, till the committee stipulated under Section 73A of the Act comes out with their decision. The Centralized Allotment Process was thus continued to be carried out without any objections from the affiliated SFCs till 2016.
10. The Government of Kerala, by Exhibit P4 order dated 05-04-2016, constituted a Committee under Section 73A of the Act. The Committee thus constituted, submitted its decision to Government. The Government accepted the same and communicated to Vice-Chancellors and Registrars of all the Universities in the State by a letter dated 26-04-2016, for WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 8 implementing. Pursuant thereto, the 2nd respondent Vice- Chancellor, exercising powers of the Syndicate under Section 10(17) of the Act decided to implement the decision of the Committee and thus Exhibit P5 University Order was issued."
It is stated that W.P.(C) No.37211/2016 was filed by the Association of Managements challenging Section 73A of the M.G.University Act and seeking completion of the admission procedure without delay. The above said Writ Petition was heard and decided by a learned Division Bench of this Hon'ble Court on 13-12-2016 by Ext.R2(c). In the judgment, the Court took note of the fact that the Committee contemplated under Section 73A had already been constituted by the Government and that the committee had submitted its recommendations, based on which action had already been taken. The challenge to Section 73A of the M.G.University Act was found to be not maintainable at the instance of the Association. It is further contended that the allegations regarding seats in the merit quota remaining vacant are unsubstantiated allegations. It is further submitted that the Centralised Allotment Process is the most effective mechanism to ensure that the students are able to secure admissions to courses of their choice in a transparent manner and that the system has received judicial approval at all stages. The judgment of this Court in a batch of writ petitions regarding Centralised Allotment Process to Plus One Courses is also relied on.
WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 9
9. A statement has been placed on record by the Special Government Pleader on behalf of the 3 rd respondent. Paragraphs 4, 5 and 6 of the statement read as follows :-
"4. It is submitted that the Centralized Allotment Process was introduced in the undergraduate level under the 1 st Respondent University with effect from 2011. Before 2011, the colleges were permitted by the Government to conduct admission to the 50% merit quota by themselves along with the remaining 50% management quota seats. It is submitted that wide spread complaints were received in Government about the non-adherence of merits and lack of transparency and maladministration in the merit quota admissions conducted by the managements directly. Therefore, in the interest of the student community and the society at large, the Government in G.O. (MS.) No.144/2006/H.Edn. dated 03.11.2006, authorized the University in the State of Kerala to allot students to the 50% Government quota for which admissions were not conducted by the Commissioner for Entrance Examinations. The above Government Order was issued to ensure fair, transparent and non exploitative procedure in conducting admission. It is submitted that allotment of 50% seats through CAP in self financing colleges is being followed in a most commendable manner for the past over 10 years. It is submitted that the CAP is introduced to ensure the twin object of transparency of merits besides being non exploitative. Besides the above objects the CAP saves the student community from harassment and exploitation. It is submitted that there is no reason for management to be aggrieved over the single window system adopted for regulating admissions in self financing institutions as it does not cause any dent in the right of the unaided institution whether minority or non minority to admits students of their choice the fee for all admissions being the same.
WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 10
5. It is submitted that the experience over the years in the conduct of CAP had proved to be a total success for aspiring students to get admission to their desired choice of both subject and institution and on the other hand, the institutions are benefited by getting more meritorious students.
6. It is submitted that while filing the W.P.(C) No.22530/2010, the contention of the 1 st petitioner was that so far as the unaided colleges affiliated to the 1 st Respondent University are concerned, power to make regulations on admission is only on the Government, which is to be exercised on the basis of the recommendations of a committee appointed by the Government consisting of the members mentioned in Section 73 A of the M.G. University Act. The said writ petition was filed complaining that the Government has not even though had constituted the committee as contemplated under Section 73A and the recommendations are not obtained and hence the CAP based on regulations framed by the 1 st respondent University is not enforceable unless Government issues orders as required under Section 73A. Therefore, the 1st Respondent had not disputed as to the powers of the Government under Section 73A of the M.G. University Act to regulate admissions. The individual colleges having agreed to share 50% of seats with the Government in such admissions, the present writ petition is without any basis.
10. The learned Government Pleader has also placed reliance on a Government Order, G.O.(Ms)No.311/2020/HEDN dated 7.9.2020, by which the Government had accepted the recommendation of the Committee constituted under Section 73A of the M.G.University Act and has directed the conduct of the admissions under the Centralised Allotment Process. It is further stated that the Government Order dated 12.10.2015 extending the provisions for spot admission to aided WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 11 and self-financing Arts & Science Colleges also had been upheld by this Court by judgment dated 19.10.2015 in W.P.(C) No.22708/2015. Reliance is placed on the decisions of the Apex Court and this Court with regard to the Centralised Allotment Process for professional courses in support of the contentions.
11. I have considered the contentions advanced. The contention in W.P.(C) No.28731/2018 that there can be no fetter placed on the admissions to unaided colleges through executive orders cannot survive in the light of Section 73A of the M.G.University Act. This Court, by judgment dated 12.7.2011 in W.P. (C) No.14553/2011 and connected cases had considered a challenge to the Centralised Allotment Process Rules and Regulations, 2010 framed by the Mahatma Gandhi University. It was the specific contention that Section 73A of the Mahatma Gandhi University Act, 1985 empowers the Government to determine from time to time the admission, selection and fees payable by students of self financing colleges under the University. Referring to the provisions of Sections 39 and 73A, it was found that Section 73A is the only enabling provision for regulating admissions to unaided colleges affiliated to the University. It was held that only the Government was empowered to determine matters with regard to admission and fees of unaided colleges. The Centralised Allotment Process Rules and Regulations, WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 12 2010 and the Centralised Allotment Process for undergraduate courses Regulations were therefore held to be inapplicable to unaided colleges affiliated to the Mahatma Gandhi University. The contention therefore is that Ext.P7 prospectus and the orders passed by the University with regard to allotment of students through the Centralised Allotment Process are inapplicable in respect of colleges, which have not entered into any seat sharing agreement with the Government or the University. It is contended that without a determination of the modalities of admission by the Government as provided in Section 73A there can be no interference at the instance of the Government or the University into the procedure of admission to affiliated unaided colleges.
12. The contention of the Government and the University is that the Centralised Allotment Process is resorted to by all the Universities in the State to enable students to apply at a single point for admission to undergraduate courses in any college under the University. In view of the fact that the system of individual colleges conducting separate admission procedure was found to be detrimental to the interest of the students. It is contended that while granting NOC for institutions in the self financing sector, the institutions have entered into individual agreements with the Government agreeing to part with 50% of the seats to make WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 13 admissions on merit basis. It is stated that affiliation is being granted from year to year and the setting apart of 50% of seats for filling up through general merit is a condition for the grant of affiliation and the extension thereof. It is stated that the Government has, during the pendency of this writ petition, also considered the issue and has passed G.O.(Ms)No.311/2020/HEDN dated 7.9.2020 issuing the guidelines for conduct of the Centralised Allotment Process in all unaided Arts and Science Colleges affiliated to the Universities within the State. It was specifically determined by the Government that the admission to the undergraduate and postgraduate programmes conducted in all unaided Arts & Science Colleges affiliated to the Universities within the State shall be done through the single window system, that is, the Centralised Allotment Process. Consequential directions with regard to conduct of the Centralised Allotment Process were also issued. It is contended that the petitioner Association cannot seek to represent the unaided colleges since it is only an association and no rights of the association are infringed in any manner. It is stated that the members of the petitioner Association have either entered into agreements with the Government agreeing for seat sharing as also for conducting admissions through the Centralised Allotment Process and that as such, the writ petition itself is not maintainable. It is submitted that the Centralised WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 14 Allotment Process had been challenged at various points in time by individual managements as well as by the petitioner Association and this Court as well as the Apex Court had declined to interfere with the procedure which is adopted in public interest and in the interest of the students who wish to avail higher education in the State. During the pendency of the writ petitions, orders have also been issued by the Government under Section 73A of the M.G.University Act.
13. Having considered the contentions advanced, I am of the opinion that the challenge raised in these writ petitions against the reserving of 50% seats in unaided colleges for filling up through the Centralised Allotment Process and the challenge raised against the process itself is not maintainable. It is the specific case of the respondents that the individual managements including the 2 nd petitioner have entered into specific agreements with the Government for seat sharing. It is stated that the provision with regard to sharing of the seats is specifically a condition for the grant of affiliation to these colleges.
14. In the above view of the matter, the inconvenience faced by the managements of unaided private colleges affiliated to the University is not sufficient to hold that the Centralised Allotment Process is illegal or cannot be resorted to in the case of such unaided colleges. In view of the fact that the Centralised Allotment Process WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 15 has been functioning in a transparent manner, I find that the prayers sought for in these writ petitions are not liable to be allowed. In case, the petitioner Association or its members has any grievance with regard to the manner in which the Centralised Allotment Process is carried out by the University, it is for them to raise such grievances before the Government, who is empowered to determine the manner of conduct of admissions. If such grievances are addressed before the Government by the members of the petitioner Association, such grievances shall be considered by the Government.
These writ petitions are ordered accordingly.
Sd/-
ANU SIVARAMAN JUDGE Jvt/6.10.2020 WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 16 APPENDIX OF WP(C) 28731/2018 PETITIONERS EXHIBITS:
EXHIBIT P1 TRUE COPY OF THE ORDER DATED 25.04.2011 ISSUED BY THE 2ND RESPONDENT.
EXHIBIT P2 TRUE COPY OF THE ORDER DATED 05.04.2016 ISSUED BY THE 1ST RESPONDENT.
EXHIBIT P3 TRUE COPY OF THE LETTER DATED 26.04.2016 ISSUED FROM THE 1ST RESPONDENT.
EXHIBIT P4 TRUE COPY OF THE ORDER DATED 12.05.2015 ISSUED BY THE 2ND RESPONDENT.
EXHIBIT P5 TRUE COPY OF THE JUDGMENT DATED 01.08.2016 IN WP(C) NO. 19729/2016 OF THIS HON. COURT.
EXHIBIT P6 TRUE COPY OF THE REPRESENTATION DATED 24.07.2017 TO THE 3RD RESPONDENT.
EXHIBIT P7 TRUE COPY OF THE LETTER DATED 21.08.2017 ISSUED BY THE 2ND RESPONDENT.
EXHIBIT P8 TRUE COPY OF THE PROSPECTUS OF ADMISSION TO U.G.PROGRAMMES - 2018 CENTRALIZED ALLOTMENT PROCESS (CAP).
EXHIBIT P9 TRUE COPY OF THE ORDER DATED 28.07.2018 ISSUED BY THE M.G. UNIVERSITY.
EXHIBIT P10 TRUE COPY OF THE LIST OF MEMBERS OF THE 2ND PETITIONER ASSOCIATION.
WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 17 APPENDIX OF WP(C) 16431/2020 PETITIONER'S/S EXHIBITS:
EXHIBIT P1 COPY OF THE LIST OF MEMBERS HAVING COLLEGES AFFILIATED TO THE M.G.UNIVERSITY.
EXHIBIT P2 COPY OF THE ORDER DATED 04.09.2002 ISSUED BY THE 2ND RESPONDENT.
EXHIBIT P3 COPY OF THE ORDER DATED 25.04.2011 ISSUED BY THE 2ND RESPONDENT.
EXHIBIT P4 COPY OF THE ORDER DATED 05.04.2016 ISSUED BY THE GOVERNMENT.
EXHIBIT P5 COPY OF THE ORDER DATED 12.05.2015 ISSUED BY THE 2ND RESPONDENT.
EXHIBIT P6 COPY OF THE INTERIM ORDER DATED 11.09.2018 IN WPC NO.28731/2018 OF THIS HON'BLE COURT.
EXHIBIT P7 COPY OF THE RELEVANT PAGES OF THE
PROSPECTUS OF ADMISISON TO UG PROGRAMMES
2020.
EXHIBIT P8 COPY OF THE NOTIFICATION DATED 27.07.2020
ISSUED BY THE M.G.UNIVERSITY.
EXHIBIT P9 COPY OF THE ORDER DATED 16/10/2018 ISSUED
BY THE 2ND RESPONDENT.
EXHIBIT P10 THE LIST OF SEAT MERIT STATUS IN SOME
MEMBER COLLEGES SHOWING THE VACANT SEATS IN
THE MERIT QUOTA
EXHIBIT P11 A TRUE COPY OF THE AFFILIATION ORDER ISSUED
TO SOME MEMBER COLLEGES BY ORDER NUMBER U O
NO AC.A1/1/AFFI/94-95 DTD 30/9/1994
EXHIBIT P12 A TRUE COPY OF THE AFFILIATION ORDER ISSUED
TO MEMBER COLLEGES BY ORDER NUMBER U O
NO.AC.A1/1/AFFL/94-95 DTD 10/3/1995
EXHIBIT P13 A TRUE COPY OF THE AFFILIATION ORDER DTD
15/7/2005 GRANTING AFFILIATION TO SOME
MEMBER COLLEGES
EXHIBIT P14 A TRUE COPY OF THE AFFILIATION ORDER ISSUED
TO NIRMALA ARTS AND SCIENCE COLLEGE DTD
7/8/2006
WP(C).No.28731/2018 & WP(C).No.16431 OF 2020 18 RESPONDENT'S/S EXHIBITS:
EXHIBIT R2 A A TRUE COPY OF THE ORDER ISSUED BY
GOVERNMENT OF KERALA, DATED 5/7/2014
GRANTING SANCTION FOR STARTING THE COLLEGE
OF THE 2ND PETITIONER
EXHIBIT R2 B A TRUE COPY OF GO(MS) NO.144/2006/EDN DATED
3/11/2006
EXHIBIT R2 C A TRUE COPY OF THE JUDGMENT OF CAP HON'BLE
HIGH COURT OF KERALA IN WPC 37211/16 DATED
13/12/2016
EXHIBIT R2 D A TRUE COPY OF THE ORDER OF HON'BLE HIGH
COURT OF KERALA DATED 29/5/2008 IN WPC
NO.14321/2008 AND CONNECTED CASES WITHOUT
HEAD NOTE
EXHIBIT R3 ANNEXURE A1: TRUE COPY OF THE G.O(MS)
NO.300/2020/H.EDN DATED 21.08.2020
EXHIBIT R3 ANNEXURE A2: TRUE COPY OF THE G.O (MS)
NO.311/2020/H.EDN DATED 07.09.2020