Kerala High Court
Rajamma vs State Of Kerala on 25 January, 2019
Author: V.G.Arun
Bench: V.G.Arun
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE V.G.ARUN
FRIDAY ,THE 25TH DAY OF JANUARY 2019 / 5TH MAGHA, 1940
WP(C).No. 8901 of 2016
PETITIONER:
RAJAMMA
W/O.MADHAVAN PILLAI, RESIDING AT RAHUL
BHAVAN,PULITHITTA KOYIKAL, THULAMPARAMBU,
THEKKUMMURI,HARIPAD. REPRESENTED BY POWER OF
ATTORNEY HOLDER 1.DAVOOD S/O.KOYAKKUTTI
RESIDING AT PAPPAN KULANGARAVEEDU, KADTHUMURI,
THAZHAVA VILLAGE, KARUNAGAPPALLYTALUK, KOLLAM
DISTRICT AND 2. JETTO AGED 45
YEARSS/O.MR.P.C.FRANCIS, RESIDING AT POOKODAN
HOUSE,VENDOR, ALAGAPPA NAGAR POST, THRISSUR
DISTRICT.
BY ADVS.
SRI.K.B.PRADEEP
SRI.MILESH.V.PAVIYALA
SRI.S.SREEKUMAR (SR.)
RESPONDENT/S:
1 STATE OF KERALA
REPRESENTED BY THE SECRETARY, LAND REVENUE,
GOVERNMENT OF KERALA, THIRUVANANTHAPURAM.
PIN - 695 001.
2 THE DIRECTOR
SURVEY AND LAND RECORDS, VAZHUTHACAUD,
THIRUVANANTHAPURAM. PIN - 695 001.
3 THE JOINT DIRECTOR OF SURVEY
GOVERNMENT OF KERALA, VANCHIYOOR,
THIRUVANANTHAPURAM, PIN - 695 001.
W.P.(C) No.8901 of 2016
2
*Addl. 4 KERALA FOREST WILDLIFE DEPARTMENT
REPRESENTED BY THE PRINCIPAL CHIEF CONSERVATOR
OF FOREST, GOVERNMENT OF KERALA, FOREST HEAD
QUARTERS, VAZHUTHACAUD, THIRUVANANTHAPURAM-
695014.
**Addl 5 DIVISIONAL FOREST OFFICER
RANNI DIVISION, DIVISIONAL FOREST OFFICE, RANNI
PO, PATHANAMTHITTA, PIN-689672.
" 6 DIVISIONAL FOREST OFFICER
KONNI DIVISION, DIVISIONAL FOREST OFFICE, KONNI
PO,PATHANAMTHITTA, PIN-689691.
*Addl.4th RESPONDENT WAS PLEADED AS PER ORDER DATED
11.10.2017 IN I.A 15925/2017.
*ADDL.R5 AND R6 WERE IMPLEADED AS PER ORER DATED 12.12.2017
IN I.A 19671/2017.
OTHER PRESENT:
SPL.GP.(FORESTS) S.SANDESH RAJA K.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
7.12.2019, THE COURT ON 25.01.2019, DELIVERED THE
FOLLOWING:
W.P.(C) No.8901 of 2016
3
ARUN, J.
-------------------------------
W.P.(C) No.8901 of 2016
------------------------------------
Dated this the 25th day of January, 2019
JUDGMENT
Petitioner is the wife of late Madhavan Pillai, who, according to the petitioner, was the owner of an extent of 432.50 Acres of land, comprised in Sy.No.283/1-A in Perumpetty Village in Mallappally Taluk of Pathanamthitta District. The factual aspects highlighted in the writ petition are to the following effect. That the property belonging to Madhavan Pillai was part of a larger extent of 1592.50 Acres of land in Perumpetty Village (old Ezhamattur Village), Thirvalla Taluk in Alappuzha District, which originally belonged to the Koikkal family. From out of the 1592.50 Acres, members of the Koikkal family had assigned a large extent of land to one W.P.(C) No.8901 of 2016 4 Oommen, S/o.Ponnoose of Eraviperoor Village; Oommen transferred an extent of 432.50 Acres to Madhavan Pillai, the predecessor-in-interest of the petitioner. Thereafter, Madhavan Pillai sought demarcation of the boundaries of his property and when timely steps were not taken on his request, Madhavan Pillai had approached this Court by filing O.P.No.6926 of 1982. By judgment dated 24.2.1983, this Court disposed the original petition, directing the Assistant Director of Survey and Land Records, Thrissur to conduct survey of the land covered by the Sale Deeds in favour of Madhavan Pillai. In spite of the time limit for conduct of the survey being extended by this Court, the direction was not complied with.
2. After the death of Madhavan Pillai, the petitioner approached this Court by filing O.P.No.34559 of 2002, which was disposed with a direction to the Secretary, Department of W.P.(C) No.8901 of 2016 5 Revenue to take up and dispose of the representations submitted by the petitioner. Consequent to the direction, Re- survey was conducted, demarcating a portion of the property comprised in Sy.No.283/1-A of Perumpetty Village as encroached portion comprised in Block No.34 in Sy.Nos.174 to 192 and the balance portion as reserve forest. Being aggrieved by the survey report, the petitioner filed Ext.P1 petition before the second respondent and alleging inaction on the part of the second respondent in considering her petition, the petitioner again approached this Court by filing W.P.(C) No.32189 of 2008, which resulted in Ext.P4 judgment, directing the third respondent to consider Ext.P1 and pass orders thereon, within three months from the date of production of a copy of the judgment.
3. Thereafter, the third respondent drew up Ext.P5 W.P.(C) No.8901 of 2016 6 report finding that the 432.50 Acres, which is the subject matter of the report, was purchased by Madhavan Pillai and that the said property did not have either 'pathivu' or 'pattayam', even as per the recitals in the Sale Deeds. It was stated in the report that, on inspection it was found that around 473 families were residing in the property and that steps were being taken at the Government level for issue of patta to those persons. That, in the Settlement Register, the property comprised in Sy.Nos.283/1A and 283/1B is described as 'purambokku' at Column No.4 and as reserve forest at Column No.18. The finding in the report is to the effect that after survey, the property is part of Re-Sy.No.193/1 and is in the possession of the Forest Department and therefore, it was not possible to conduct survey and demarcate the boundaries of the 432.50 Acres of land, in the W.P.(C) No.8901 of 2016 7 absence of appropriate orders from the Government. Therefore, along with the report, the third respondent submitted a computerised sketch of the 432.50 Acres.
4. Alleging that Ext.P5 is factually incorrect and was prepared without considering the petitioner's objection, Ext.P6 representation was submitted. Thereafter, the petitioner approached this Court yet again by filing W.P.(C) No.17257 of 2015, which was disposed of under Ext.P10 judgment, directing the second respondent to consider and pass orders on Ext.P1 representation within three months. In terms of the direction, the representation was considered, after affording an opportunity of hearing and for production of documents, to the petitioner. After hearing the parties concerned, the second respondent issued Ext.P12 proceedings dated 30.1.2016 with the following findings: W.P.(C) No.8901 of 2016 8
"(i) The property is comprised in old Sy.No.283/1 in Ezhumattur Village in Thiruvalla Taluk of Alappuzha District. Later, Perumpetty Village was constituted carving out the properties comprised in Sy.Nos.212 to 305 of Ezhumattur Village. Thereafter, when the Pathanamthitta District was found in the year 1983, Perumpetty Village was included in Pathanamthitta District.
(ii) On examination of the Settlement Register pertaining to Sy.No.283/1A, it was found that an extent of 1592.50 Acres was recorded as purambokku reserve. The property comprised in Sy.No.283/1B was also recorded as purambokku reserve, without showing the extent.
(iii) The Re-Survey of Perumpetty village was conducted and as stipulated under Section 13 of the Survey and Boundaries Act, the records were handed over to the Revenue Department on 1.8.1994, after due notification.
(iv) The property over which the petitioner stakes claim is included in the Valiyakavu Reserve Forest, which consists of a total extent of 2 Sq.miles and 491 Acres.
(v) During inspection, the representative of the petitioner was not able to point out the boundaries of the W.P.(C) No.8901 of 2016 9 property.
(vi) Neettu (Royal Grant) Nos.942 and 948, produced at the time of hearing, were not sufficient to establish the petitioner's title over the property.
(vii) Even as per the recitals in Document Nos.2627/1969 and 122/1970, under which the petitioner's husband became title holder of the property, it is stated that there is no 'pathivu' or 'pattayam' for the property. The petitioner was not able to produce any document from the Village or Taluk office to prove her possession and ownership.
(viii) Since the property, which is comprised in Re-
Sy.No.193/1 is dense forest, it has been surveyed and recorded as a minor circuit."
5. This writ petition is filed seeking to quash Ext.P12 and for the issue of a writ of mandamus directing the second respondent to consider and pass final orders on Ext.P1 petition, after affording the petitioner and all concerned opportunity to raise objections on Ext.P5 report, within a time frame fixed by the Court. The main contention urged in the W.P.(C) No.8901 of 2016 10 writ petition is that the survey authorities have committed a grave mistake in coming to the conclusion that the petitioner's property forms part of the property comprised in Re- Sy.No.193/1 in Perumpetty Village. It is pleaded that the property comprised in old Sy.No.283/1A of Perumpetty Village (old Ezhamattur) of Thiruvalla Taluk (now Mallappally Taluk) was never notified as Valiyakavu Reserve Forest. That the property covered by the notification is the property comprised in Ranni and Elanthur Villages, which are within Chengannur Taluk. Since the northern boundary of the property notified as Valiyakavu Reserve Forest, touches the boundary line separating Chengannur Taluk and Thiruvalla Taluk, both taluks happened to be mentioned in the notification declaring the land comprised in Sy.No.283/1-A as proposed reserve forest. That Ext.P7 Gazette notification W.P.(C) No.8901 of 2016 11 regarding constitution of Valiyakavu Forest Reserve clearly defines the territorial limits of the reserve to be within Ranni and Elanthur Villages of Thiruvalla Taluk, where as the petitioner's property is comprised in Ezhamattur Village, now renamed as Perumpatty Village. That vide Ext.P8 notification, Perumpetty Village was formed by carving out the area covered by Sy.Nos.212 to 305 from Ezhamattur Village. From the subsequent notification, Ext.P9, regarding the proposed Valiyakavu Reserve Forest, it is clear that only certain portions of Survey No.283/1 of Ezhamattur Village would come under the territorial limits of Valiyakavu Forest Reserve. That, the petitioner's property, which is comprised in old Sy.No.283/1A, is not included in Ext.P9 notification and therefore, that property does not form part of Valiyakavu Forest Reserve.
6. In the counter affidavits filed on behalf of W.P.(C) No.8901 of 2016 12 respondents, the Revenue, as well as the Forest Department and its officials, the consistent case put forward is that the property claimed by the petitioner clearly falls within the Valiyakavu Reserve Forest, which, as per Ext.R2(b) notification dated 25.12.1905, comprised of an extent of 6.75 Sq.miles, and was later reduced to 2.491 Sq.miles as per Ext.R2(c) notification dated 1.12.1959.
7. While the writ petition was pending, final judgment was rendered by a Division Bench of this Court as M.S.A No.1 of 1981. That case had originated from a challenge raised to the notifications issued under the Travancore Forest Act ('Act II') of 1068, proposing to declare the notified areas as Alapra, Valiyakavu and Karikattoor Reserves. The judgment was rendered by the Division Bench after a protracted litigation which had started prior to 1955. Three notifications had been W.P.(C) No.8901 of 2016 13 issued under the Travancore Forest Act ('Act II') of 1068, proposing to declare the notified areas, which were lying contiguous, as reserve forest. The notifications pertained to the proposed Alapra, Valiyakavu and Karikattoor reserves. Pursuant to the notifications, claims were raised challenging the right of the Government to notify the said areas as reserve forest. The claims were rejected by the Forest Settlement Officer. This was challenged in A.S.No.333 of 1955, before the District Court, Kottayam. The appeal was allowed and the matter was remanded to the Forest Settlement Officer, directing consideration of the claims on merits. The order of the District Court was affirmed by this Court in the judgment in C.M.A.Nos.118 to 122 of 1957. Thereafter, the claims were considered again and dismissed by the Forest Settlement Officer on merits. Yet again appeals were filed before the W.P.(C) No.8901 of 2016 14 District Court as A.S.Nos.159 of 1976 and 179 of 1976. The appeals were allowed and the District Court declared that the lands are not liable to be notified as reserve forest. As against the judgment of the District Court, the State preferred appeal before this Court as M.S.A.No.1 of 1981, which was allowed by this Court, thereby rejecting the claims of the objectors. The matter was taken up before the Apex Court in Civil Appeal No.2659 of 1997. The appeal was allowed setting aside the judgment of this Court and remanding the matter for fresh consideration. It was consequent to the remand by the Apex Court that M.S.A.No.1 of 1981 was elaborately heard and judgment rendered by a Division Bench of this Court on 10.1.2018.
8. The claimants in M.S.A No.1 of 1981 are members of Neythallur Koikkal and persons claiming title under them, as W.P.(C) No.8901 of 2016 15 assignees. The claims are based on the Neettu of 942 and 948, stated to have been granted to the Neythallur Koikkal by his highness the Maharaja of Travancore. This Court after elaborate consideration of the genuineness of the Neettu upheld the same and consequently the title to the properties covered thereunder. Thereupon, the Division Bench came to the conclusion that the notified lands were not lands at the disposal of the Government in terms of Section 2(g) of the Kerala Forest Act, 1961. It was found that there was no reason to interfere with the judgment of the learned District Judge, insofar as it relates to the proposed Alapra and Valiyakavu reserves. In the concurring judgment rendered by Chitambaresh, J., it is observed as follows:
"This does not however mean that the property claimed by the respondents in the Alapra and Valiyakavu reserves are liable to be restored to them consequently.W.P.(C) No.8901 of 2016 16
This is because, we have not considered as to whether the property has vested in the Government under two other acts, viz; the Kerala Private Forest (Vesting and Assignment Act, 1971 and the Kerala Forest (Vesting and Management of Ecologically Fragile Lands) Act, 2003."
After referring to the relevant portions of the aforementioned Acts, it was further observed as follows:
"The relevant dates for determining whether the property is a 'private forest' or and ecologically fragile land are 10.5.1971 and 2.6.2000 respectively. The nature of the property as on those dates would be relevant in order to decide as to whether the respondents are entitled to restoration either under the 1971 Act or the 2003 Act. The non-obstante clause contained in the aforesaid enactments whittles down the importance of the adjudication under the 1068 Act or the 1961 Act. The findings in the appeal in other words would at best advance the title claimed by the respondents till the date of vesting under the 1971 Act or the 2003 Act."
8. After the pronouncement of the judgment in M.S.A No.1 of 1981, as evident from the arguments advanced, the W.P.(C) No.8901 of 2016 17 petitioner did a complete volte face and tried to derive the benefit of the findings in the judgment in M.S.A No.1 of 1981, contrary to her repeated assertions in the writ petition that the property belonging to Madhavan Pillai does not form part of the proposed Valiyakavu reserve. The respondents on the other hand, took up the contention that the petitioner is bound by her pleadings and cannot be allowed to wriggle out of her contention and seek the benefit of the judgment in M.S.A.No.1 of 1981.
9. Heard Adv.Sri.S.Sreekumar, learned Senior counsel instructed by Adv.Sri.K.B.Pradeep, on behalf of the petitioner and Adv.Sri.Sandesh Raja, Special Government Pleader on behalf of the respondents.
10. The learned Senior Counsel contended that the entire issue raised in the writ petition has to be reconsidered W.P.(C) No.8901 of 2016 18 in the light of the judgment in M.S.A.No.1 of 1981, which completely covers the issue. The learned Government Pleader counters that contention on the ground that there cannot be any such consideration, deviating from the basic principle that the parties to the lis are bound by their pleadings. In this context, it will be appropriate to refer to a few decisions on the question of pleadings. In Ram Sarup Gupta (dead) by L.Rs. v. Bishun Narain Inter College and others [AIR 1987 SC 1242], the Apex Court had held that no party should be permitted to travel beyond its pleadings and that all necessary material facts should be pleaded by the party in support of the case set up by it. It was further held that in order to have a fair trial, it is imperative that the party should state the essential material facts so that other party may not be taken by surprise. It was also held that the pleadings W.P.(C) No.8901 of 2016 19 however should receive a liberal construction and that no pedantic approach should be adopted to defeat justice on hair splitting technicalities. Recently, a Full Bench of this Court in Viswambaran P.N. v. T.P.Sanu and others [ILR 2018 (3) Ker.30] has held as follows:
"Pleadings and particulars are necessary to enable the court to decide the rights of the parties in the trial. The parties would be bound by such pleadings, of course, subject to the right of amendment allowed in accordance with law. The contention of the parties must be culled out from the pleadings by reading the same as a whole. Whenever the question about lack of pleading is raised, the enquiry should not be so much about the form of the pleadings. Then the court must find out whether in substance the parties knew the case and the issues upon which they went to trial. Once it is found that in spite of deficiency in the pleadings the parties knew the case and they proceeded to trial on the issue by producing the evidence, it would not be open to a party to raise the question of lack of pleadings."
11. Analysing the case at hand, based on the principles W.P.(C) No.8901 of 2016 20 enunciated in the precedents mentioned above, both the petitioner as well as the respondents are bound by their pleadings. The petitioner having failed to seek amendment of the writ petition, even after the judgment in M.S.A.No.1 of 1981, cannot now put forward contentions which are completely at variance with her pleadings.
12. From the pleadings in the writ petition, it is discernible that the reasons stated by the petitioner for contending that the property of Madhavan Pillai is not within the notified, proposed Valiyakavu reserve is that the properties covered by Neettu Nos.942 and 948 are comprised in Ezhamattur Village and the property notified as Valiyakavu Forest is in Elanthur Village. That, at the time of bifurcation of villages, Ezhamattur Village was renamed as Perumpetty Village in Mallappally Taluk. That, misconstruing the name of W.P.(C) No.8901 of 2016 21 the village "Ezhamattur" covered by Neettu Nos.942 and 948, as "Elanthur Village", the Forest Department had taken steps to take over possession of the properties covered by the said Neettu. That, as per the Re-Survey records, a portion of the property covered by old Sy.No.283/1A, alleged to be the property falling within the proposed Valiyakavu reserve, is shown as Block No.34, Khandom (Parcel) No.10 in Re- Sy.Nos.174 to 192 of Perumpetty Village. That, the 432.50 Acres of land belonging to Madhavan Pillai, purchased from Sri.Oommen as per Sale Deed Nos.2627 of 1969 and 122 of 1970, is lying adjacent to the plots shown as Re-Sy.Nos.174 to 192 (Block No.34 and Khandom No.10). The said property lying on the north-eastern side of the properties comprised in Re-Sy.Nos.186, 182, 181, 180, 177, 176, 204, 203, 202, 201 and 200 of Perumpetty Village is the property covered by the W.P.(C) No.8901 of 2016 22 two sale deeds, which does not form part of Valiyakavu Reserve Forest.
13. The aforesaid contention is liable to be rejected for the sole reason that in Document Nos.2627 of 1969 and 122 of 1970 [Exhibit R2(e)], the clear recital is to the effect that Sri.Oommen, the predecessor-in-interest of Madhavan Pillai, had acquired right over the property, on the basis of Document Nos.3024 and 4040 of 1952 executed by Raghavaru Rama Varma Thamburan of Neythallur Koikkal. It is also specifically stated that the Neythallur Koikkal had acquired right over the property on the basis of Neettu Nos.942 and 948 granted in its favour by the Travancore Maharaja. The very basis of Madhavan Pillai's right over the property being Neettu Nos.942 and 948, the petitioner cannot be heard to contend that the property, which is part of the property W.P.(C) No.8901 of 2016 23 covered by the Neettu, which in turn has been notified as the proposed Valiyakavu Reserve Forest, does not form part of the property covered by the notification.
14. In this context, it may also be relevant to refer to the specific stand of the respondents, as reflected from the findings in Ext.P12. The specific finding in Ext.P12 is that the property forms part of a larger extent of land comprised in Old Sy.No.283/1 of Ezhamattur Village. The Settlement Register reveals that an extent of land covering 1592.50 Acres in Sy.No.283/1-A and that an unmeasured extent of land in Sy.No.283/1-B are recorded as purmbokku reserve. The property comprised in old Sy.No.283/1 in Ezhamattur Village along with the properties comprised in old Sy.Nos.49/1 and 35/1 of Ranni Village, having an extent of 2.491 Sq.miles has been notified as the proposed Valiyakavu Reserve Forest. W.P.(C) No.8901 of 2016 24 Survey has been conducted and concluded, with respect to the property over which the petitioner claims title. After survey, a total extent of 1345.7 Acres, including the 432.50 Acres over which the petitioner claims title, has been recorded as reserve forest comprised in Block No.34, Re-Sy.No.193/1 in Perumpetty Village.
15. The question as to whether the property covered by Neettu Nos.942 and 948 falls under Ext.P9 notification stands concluded by the judgment of this Court in M.S.A.No.1 of 1981. Therefore, it is no longer open for any person to contend that the property, over which he or she had acquired title on the strength of Neettu Nos.942 and 948, does not form part of Ext.P9 notification. The question as to whether the notified lands are lands at the disposal of the Government has also been considered and answered holding that they are not lands W.P.(C) No.8901 of 2016 25 at the disposal of the Government, in terms of Section 2 (g) of the Kerala Forest Act.
16. Even though the petitioner was not a party to M.S.A.No.1 of 1981, the judgment rendered by a Division Bench of this Court in the said case will definitely have an impact on the request made by the petitioner to conduct survey of her land. The impact of the findings in the judgment in M.S.A.No.1 of 1981 not having been available for consideration while issuing Ext.P12, it is only appropriate that the third respondent re-considers the request made under Ext.P1, in the light of the findings in M.S.A.No.1 of 1981.
In that view of the matter, Ext.P12 is quashed. The third respondent is directed to consider Ext.P1 representation, with reference to the findings in the judgment in M.S.A.No.1 of 1981 and pass appropriate orders thereon, after affording an W.P.(C) No.8901 of 2016 26 opportunity of hearing to the petitioner and the official respondents. Final orders on Ext.P1 representation shall be rendered within a period of three months from the date of receipt of a copy of this judgment.
The writ petition is disposed of with the above direction.
Sd/-
V.G.ARUN JUDGE Scl/ W.P.(C) No.8901 of 2016 27 APPENDIX PETITIONER'S/S EXHIBITS:
EXHIBIT P1 EXT.P-1: TRUE COPY OF THE PETITION DATED 3.3.2009 SUBMITTED BY THE PETITIONER TO THE 2ND RESPONDENT EXHIBIT P2 EXT.P-2: TRUE COPY OF THE ORDER DATED 21.4.2008 ISSUED BY THE 2ND RESPONDENT TO THE 3RD RESPONDENT EXHIBIT P3 EXT.P-3: TRUE COPY OF THE LAWYER NOTICE ISSUED BY THE 3RD RESPONDENT EXHIBIT P4 EXT.P-4: TRUE COPY OF THE JUDGEMENT DT.10.2.2009 EXHIBIT P5 EXT.P-5: TRUE COPY OF THE REPORT OF 2ND RESPONDENT DT.8.7.2009 ALONG WITH REPORT OF DEPUTY DIRECTOR AND THE ASSISTANT DIRECTOR OF SURVEY.
EXHIBIT P6 EXT.P-6: TRUE COPY OF THE PETITIONERS PETITION TO THE 3RD RESPONDENT DT.4.3.2009 EXHIBIT P7 EXT.P-7: TRUE COPY OF THE GAZETTE NOTIFICATION DT.19.5.1981 EXHIBIT P8 EXT.P-8: NOTIFICATION OF GOVT OF TRAVANCORE-COCHIN DT.28.9.1956 EXHIBIT P9 EXT.P-9: TRUE COPY OF THE KERALA GAZETTE DATED 1.12.1959 CONTAINING THE NOTIFICATION UNDER SECTION 6 OF THE TRAVANCORE-COCHIN FOREST ACT III OF W.P.(C) No.8901 of 2016 28 1952 DATED 25.11.1999 EXHIBIT P10 EXT.P-10: THE JUDGEMENT DT.11.8.2015 IN WPC NO.17257 OF 2015 EXHIBIT P11 EXT.P-11: HEARING NOTES OF 9.7.2015 EXHIBIT P12 EXT.P-12: TRUE COPY OF ORDER OF THE 2ND RESPONDENT REFUSING THE CLAIM.
EXHIBIT P13: TRUE COPY OF THE LETTER
F.NO.106/11/2012-53/1581 DATED ..9/2012
OF THE 2ND RESPONDENT
EXHIBIT P14: TRUE COPY OF THE LETTER F.N.31/01/2012
-VDP (AGT) (W/S) DATED 19.9.2012 OF
THE 3RD RESPONDENT.
EXHIBIT P15: TRUE COPY OF THE EXTRACT OF THE MINUTES
OF THE MEETING OF THE ELECTED
REPRESENTATIVES WITH THE 1ST RESPONDENT
ON 27.8.2014.
EXHIBIT P16: TRUE COPY OF THE LETTER
F.NO.5/4/AGSD/2012/823 DATED 23.12.2014 ISSUED BY THE 3RD RESPONDENT.