Dr. Jilse George and Dr. Krishna Mohan v. State of Kerala and others (W.P.(C).Nos. 25747/2017 & 26395/2017)

## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE DR. JUSTICE KAUSER EDAPPAGATH TUESDAY, THE 6[TH] DAY OF DECEMBER 2022 / 15TH AGRAHAYANA, 1944** ## **WP(C) NO. 25747 OF 2017** ## **PETITIONER:** DR. JILSE GEORGE, PROFESSOR IN GENERAL MEDICINE (NOW UNDER ORDER OF SUSPENSION),GOVERNMENT MEDICAL COLLEGE, KALAMASSERY,ERNAKULAM-683503,RESIDING AT MOOZHIYIL HOUSE,HOUSE NO.1, PALAKKATTU COLONY,K.K.ROAD, KOCHI-682017. BY ADVS.SRI.N.NANDAKUMARA MENON (SR.) SRI.DEEPU LAL MOHAN SMT.S.LEENA SRI.K.S.PRENJITH KUMAR ## **RESPONDENTS:** 1 THE STATE OF KERALA REPRESENTED BY THE ADDITIONAL CHIEF SECRETARY TO GOVERNMENT, HEALTH AND FAMILY WELFARE DEPARTMENT,GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. 2 THE STATE LEVEL Apex Body MEDICAL NEGLIGENCE REPRESENTED BY THE DIRECTOR OF HEALTH SERVICES (CONVENOR),DIRECTORATE OF HEALTH SERVICES,GENERAL HOSPITAL JUNCTION,THIRUVANANTHAPURAM-695035. 3 THE DIRECTOR OF MEDICAL EDUCATION DIRECTORATE OF MEDICAL EDUCATION,MEDICAL COLLEGE P.O., THIRUVANANTHAPURAM-695011. W.P.(C).No.25747 & 26395 of 2017 -:2:- 4 THE DEPUTY SUPERINTENDENT OF POLICE CRIME BRANCH (CRIMINAL INVESTIGATION DEPARTMENT),HURT AND HOMICIDE WING-II, THRIPUNITHURA,ERNAKULAM-682301. 5 DR.REMLA BEEVI A. DIRECTOR OF MEDICAL EDUCATION,MEDICAL COLLEGE P.O., THIRUVANANTHAPURAM-695011. *ADDL.R6 K.A.ABOOTY,AGED 51 YEARS, S/O. MANHU, ISHA MANZIL, PADUPARA, SIVAPURAM P.O., MATTANNOOR, (DIED) KANNUR DISTRICT. ***ADDL. R6 IMPLEADED AS PER ORDER DATED 28.9.17 IN IA NO.15055/17** *ADDL.R7 ADDL.R7. SHERIEFA P.K.(MOTHER OF DECEASED SHAMNA THASNEEM), AGED 47 YEARS, W/O LATE AHMED ABOOTY, AYSHA MANZIL, PADUPARA, SIVAPURAM, THALASSERY, KANNUR DISTRICT, KERALA-670702 ***ADDL.7TH RESPONDENT IS IMPLEADED FOR THE DECEASED ADDL. R6 AS PER ORDER DATED 2/12/2019 IN IA 1/19** BY ADVS.SHRI.P.NARAYANAN, SENIOR G.P. SRI. SANGEETHA RAJ, PP P.BIJIMON R.T.PRADEEP JACOB SAMUEL ABRAHAM JOSEPH B.RAMAN PILLAI (SR.) THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 06.12.2022, ALONG WITH WP(C).26395/2017, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P.(C).No.25747 & 26395 of 2017 -:3:- ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE DR. JUSTICE KAUSER EDAPPAGATH TUESDAY, THE 6[TH] DAY OF DECEMBER 2022 / 15TH AGRAHAYANA,** ## **1944** ## **WP(C) NO. 26395 OF 2017** ## **PETITIONER:** DR.KRISHNA MOHAN ASSISTANT PROFESSOR, DEPARTMENT OF MEDICINE, GOVT. MEDICAL COLLEGE, ERNAKULAM BY ADV SRI.P.B.SAHASRANAMAN ## **RESPONDENTS:** 1 THE STATE OF KERALA REP. BY THE ADDITIONAL CHIEF SECRETARY TO GOVERNMENT, HEALTH AND FAMILY WELFARE DEPARTMENT, GOVT. SECRETARIAT, THIRUVANANTHAPURAM- 695 001 2 THE STATE LEVEL Apex Body MEDICAL NEGLIGENCE REP. BY THE DIRECTOR OF HEALTH SERVICES, GENERAL HOSPITAL JUNCTION, THIRUVANANTHAPURAM- 695 035 3 THE DEPUTY SUPERINTENDENT OF POLICE CRIME BRANCH (CRIMINAL INVESTIGATION DEPARTMENT) HURT AND HOMICIDE WING-II, TRIPUNITHURA, ERNAKULAM- 682 301 W.P.(C).No.25747 & 26395 of 2017 -:4:- *ADDL.R4 K.A.ABOOTTY,(Legal Heir) AGED 51 YEARS (DIED) S/O.MANHU, ISHA MANZIL, PADUPARA, SIVAPURAM P.O,MATTANNOOR, KANNUR DISTRICT ***ADDL.R4 IS IMPLEADED AS PER ORDER DATED 13.10.2017 IN IA.NO, 15020 /2017** *ADDL.R5 A SHERIEFA P.K.,AGED 47 YEARS, W/O LATE AHAMED ABOOTTY, AYSHA MANZIL, PADUPARA, SIVAPURAM, THALASSERY, KANNUR DISTRICT-670702 ***ADDL.R5 IS IMPLEADED AS ADDL.R5 AS PER ORDER DATED 2/12/2019 IN IA NO.1/2018.** BY ADVS.SHRI.P.NARAYANAN, SENIOR G.P. P.BIJIMON R.T.PRADEEP SRI.ABRAHAM JOSEPH SRI.JACOB SAMUEL SMT.PRIYA SREEDHARAN N.SURESH KUMAR K.T.SEBASTIAN THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 06.12.2022, ALONG WITH WP(C).25747/2017, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P.(C).No.25747 & 26395 of 2017 ## -:5:- ## **J U D G M E N T** Dated this the 6[th] day of December, 2022 The petitioners, working as Professors at the Government Medical College, Ernakulam, are aggrieved by the registration of crime against them without following the mandate given by the Apex Court in _**Jacob Mathew v. State of Punjab & Another**_ (AIR 2005 SC 3180) and without following the Circular No.73304/SSB3/2007/Home dated 16.6.2008 issued by the Government of Kerala. 2. A second year medical student of the Government Medical College, Ernakulam by name Shamna Thesneem was admitted at the Medical College on 18.7.2016 with the complaint of fever and fatigue. She had a history of Bronchial Asthma. It is alleged that she was treated by the petitioners in these writ petitions. The petitioner in W.P.(C).No. 26395/2017 was working as an Assistant Professor and the petitioner in W.P.(C) No.25747/2017 was working as a Professor at that time in the Department of General Medicine at the Medical College. As part ## W.P.(C).No.25747 & 26395 of 2017 **==> picture [37 x 10] intentionally omitted <==** of the treatment, the patient was administered injection Ceftriaxone by the staff nurse around 3 pm, after giving a test dose. Within 3 minutes of administration of full dose, the deceased developed chest discomfort. The petitioner in W.P.(C) No. 26395/2017 who was on duty immediately attended the patient and at his advise injection Atropine and Adrenaline were administered. However, the condition of the patient worsened and she was shifted to the ICU. She was attended by the petitioner in W.P.(C).No. 25747/2017 as well as other doctors. Since the condition of the patient again worsened, at the request of the bystanders, the patient was shifted to the nearby superspeciality hospital namely Rajagiri Hospital, Aluva, where she was admitted at about 6.30 pm. However, unfortunately, at 8.29 pm, the patient was declared dead. 3. The father of the deceased gave a complaint to the Kalamassery Police alleging that her death was due to the medical negligence of the doctors and staff of Government Medical College, Ernakulam. On the basis of the said complaint FIR was registered against the petitioners as Crime No.976/2016 W.P.(C).No.25747 & 26395 of 2017 **==> picture [37 x 9] intentionally omitted <==** alleging offfence punishable under Section 304A of the IPC. Later, the investigation was transferred to Crime Branch(Criminal Investigation Department), Hurt and Homicide Wing-II, Ernakulam and renumbered as Crime No.152/CRHHW-II EKM/2016 as per the order of the State Police Chief. 4. The investigating officer in accordance with the direction of the Apex Court in _**Jacob Mathew**_ (supra) as well as the Circular dated 16.6.2008 issued by the Government of Kerala, made a request to the District Medical Officer, Ernakulam to constitute an Expert Panel and to give their views on the allegation of the medical negligence. Accordingly, a five member Expert Panel was constituted and the committee forwarded the report dated 3.10.2016. As one of the members of the panel opined that there was want of reasonable skill and care in the treatment of the deceased, the matter was referred to the State Level Apex Body. The Apex Body in its report dated 26.4.2017 opined that there was negligence on the part of the petitioners. Based on the said report, the investigating officer proceeded with the investigation. It was at that juncture, the petitioners ## W.P.(C).No.25747 & 26395 of 2017 **==> picture [37 x 10] intentionally omitted <==** approached this Court. The challenge in these writ petitions is mainly against the report of the Apex Body dated 26.4.2017. According to the petitioners, the very reference to the Apex Body was not in terms of the Circular dated 16.6.2008. It is further alleged that the said report is totally erroneous, vitiated, biased and has violated the principles of natural justice. The conclusion and findings of the said report has also been challenged. 5. I have heard Sri. N. Nandakumara Menon, the learned Senior counsel for the petitioner in W.P.(C).No.25747/2017, Sri. P.B. Sahasranaman, the learned counsel for the petitioner in W.P.(C).No.26395/2017, Sri. R.T. Pradeep, the learned counsel for the mother of the deceased and Sri. Sangeetha Raj, the learned Public Prosecutor. 6. The Apex Court in _**Jacob Mathew**_ (supra) specifically held that a private complaint alleging medical negligence may not be entertained unless the complainant has produced prima facie evidence before the court in the form of a credible opinion given by another competent doctor to support the charge of rashness or negligence on the part of the accused doctor. It was W.P.(C).No.25747 & 26395 of 2017 -:9:- further held that the investigating officer should, before proceeding against the doctor accused of rash or negligent act or omission, obtain an independent and competent medical opinion preferably from a doctor in government service qualified in that branch of medical practice who can normally be expected to give an impartial and unbiased opinion applying Bolam's test to the facts collected in the investigation. Again, the Apex Court in _**Martin F. D'Souza v. Mohd. Ishfaq**_ [2009 (3) SCC 1] held that whenever a complaint is received against a doctor or hospital by the Consumer Forum or by the Criminal Court, before issuing notice to the doctor or hospital against whom the complaint was made, the Consumer Forum or Criminal Court should first refer the matter to a competent doctor or committee of doctors, specialized in the field relating to which the medical negligence is attributed, and only after that doctor or committee reports that there is a prima facie case of medical negligence should notice be then issued to the concerned doctor/hospital. A Division Bench of this Court in _**Suvarna v. Dr. Reni Philip & Others**_ (2014 (1) KHC 112) has held that when a medical negligence is alleged W.P.(C).No.25747 & 26395 of 2017 **==> picture [44 x 10] intentionally omitted <==** against a doctor, the investigating officer shall immediately refer the case to an expert opinion and duty is cast upon the investigating officer to consider the views expressed by the Expert Panel before continuing further investigation. It was further held that the investigating officer can seek additional expert opinion, if situation demands. 7. The Government of Kerala have issued instructions as per Circular No.73304/SSB3/2007/Home dated 16.6.2008 in regard to the investigation of complaints against doctors in Government Service, private medical practitioners and doctors in private hospitals for acts of commission or omissions in the medical care of patients. In the Circular it is stated that, after registration of any case against doctors in Government service, private medical practitioners or doctors in private hospitals for criminal negligence, the investigating Deputy Superintendent of Police shall immediately refer the case to an Expert Panel consisting of the following four members: - The District Medical Officer of Health (Convener) - District Government Pleader/Public Prosecutor ## W.P.(C).No.25747 & 26395 of 2017 **==> picture [44 x 9] intentionally omitted <==** - Senior Government doctor in the concerned specialty as nominated by the respective District Medical Officer. - Forensic Expert from the nearest Medical College. Clause (2) of the Circular states that, in case the views of the members of the Expert Panel differ, they will immediately refer the issue for the opinion of the Apex Body consisting of the following four members: - The Director of Health Services (Convener) - The Director of Medical Education. - The Additional Director of Health Services (Vigilance) - The Director General of Prosecution. It is further stated that, the Apex Body can, depending on circumstances get expert opinion from specialists in the private sector also. The affected doctors are also free to approach the Apex Body with appeal. In clause (3) of the circular it is stated that it shall be the duty of the investigating officer to consider the views expressed by the Expert Panel/Apex Body and he will continue further investigation in the light of the view taken by the Expert Panel/Apex Body. In case the investigating officer is not satisfied with the views expressed by the Expert Panel/Apex W.P.(C).No.25747 & 26395 of 2017 **==> picture [44 x 9] intentionally omitted <==** Body or requires additional clarification, it would be open to him to seek additional expert opinion. 8. The Expert Panel was constituted on 26.9.2016. The panel consisted of the Convener who is the District Medical Officer of Health, two committee members who are the District Government Pleader/Public Prosecutor, Associate Professor and Forensic Surgeon, Government Medical College Alappuzha and two experts Anesthetist and Cardiologist, at the General Hospital Ernakulam. The two experts (Dr.Madhu V. Consultant Anesthetist, General Hospital, Ernakulam and Dr.Paul Thomas, Cardiologist, General Hospital, Ernakulam) opined that no medical negligence could be attributed to any of the Doctors who treated the patient as the patient was given standard treatment of care immediately following the complications. They further opined that there was possibility of complication which can occur in 0.1% of patients following Ceftriaxone injection. However, one of the expert committee members Dr. Liza John, Associate Professor, Department of Forensic Medicine, Government Medical College, Alappuzha opined that there was want of reasonable skill ## W.P.(C).No.25747 & 26395 of 2017 **==> picture [44 x 10] intentionally omitted <==** and care in the treatment of the deceased. The remaining committee members, District Government Pleader/Public Prosecutor and the Convenor (DMO) also opined that there was no medical negligence on the part of any doctors who treated the patient. 9. Thus, the four out of five doctors in the Expert Panel opined that there was no negligence on the part of any doctors who treated the patient. The matter was then referred to the Apex Body. There is dispute in the manner in which the matter was referred. The counsel for the petitioners submitted that the matter can be referred to the Apex Body either by Expert Panel or at the instance of the doctor concerned. However, it is a case where it was referred to the Apex Body at the instance of the investigating officer. At any rate, there is a report of the Apex Body before us. Hence, the manner in which it was referred does not assume much significance. The Apex Body consisted of Convener and three members. The Convener is the Director of Health Services and three members are Director General of Prosecution, Director of Medical Education and Additional Director ## W.P.(C).No.25747 & 26395 of 2017 **==> picture [44 x 9] intentionally omitted <==** of Health Services (Vigilance). They found that there was negligence on the part of the petitioners. 10. The purpose of referring the matter to Expert Panel/Apex Body, as the case may be, is to ensure and confirm that there is culpable negligence on the part of the doctor concerned so as to further proceed against him. A mechanism is provided under the Circular dated 16.6.2008 as to how the Expert Panel and Apex Body have to be constituted and to be functioned. In clause (2) of the circular it is clearly stated that the Apex Body can, depending on the circumstances, get expert opinion from the specialists in the private sector also and in clause (3) it is stated that it shall be the duty of the investigating officer to consider the views expressed by the Expert Panel/Apex Body and he should continue further investigation in the light of the view taken by the Expert Panel/Apex Body. The investigating officer is also free to seek for additional clarification if he is not satisfied with the views expressed by the Expert Panel/Apex Body. Thus, the investigating officer is supposed to go through both the report of W.P.(C).No.25747 & 26395 of 2017 **==> picture [44 x 10] intentionally omitted <==** the Expert Panel as well as the Apex Body and take a decision how to proceed further with the investigation. 11. As stated already, the Expert Panel consisted of two experts, an anesthetist and cardiologist apart from a forensic surgeon and both of them citing reasons stated that no negligence could be attributed against the doctors. However, there was no expert in the Apex Body. Even though the Apex Body was given power to get the expert opinion, such an option was not exercised. When two subject experts positively opined giving reasons that there was no negligence on the part of the doctors, the Apex Body could have sought for an expert opinion before arriving at a conclusion that there was negligence. In fact, the reference to Apex Body is contemplated only in a case where the views of the members of the Expert Panel differ. A close scrutiny of the Expert Panel report would show that even the forensic surgeon who gave a different opinion did not attribute any criminal negligence on the part of the doctor. On the other hand, what was opined by him was that there was lack of reasonable care and caution. I went through Ext.P9. No W.P.(C).No.25747 & 26395 of 2017 **==> picture [44 x 10] intentionally omitted <==** specific reasoning has been given by the Apex Body while arriving at a conclusion that there was medical negligence. As stated already, the duty of the investigating officer is to consider the views expressed by the Expert Panel as well as Apex Body and to take a decision, how to continue with further investigation. He is also free to call for any additional expert opinion. But, here, the investigating officer was simply carried away by the report of the Apex Body and continued with the investigation. There is one more aspect. The circular would show that the affected doctors can also approach the Apex Body with an appeal. The Expert Panel can also refer the matter to the Apex Body. Here, the matter was referred to the Apex Body at the instance of the investigating officer. Of course, it appears to be routed through the government channel. But in such a case, definitely before arriving at a conclusion by the Apex Body that there was negligence on the part of the doctors, the affected doctors could have been given an opportunity for hearing by the Apex Body. It is the fundamental principle of natural justice that before a decision is taken against a party, he should be given an W.P.(C).No.25747 & 26395 of 2017 **==> picture [44 x 9] intentionally omitted <==** opportunity for hearing. In these circumstances, I am of the view that the report of the Apex Body cannot be sustained. An Apex Body consisting of subject expert should look into the matter once again and submit a report. In the light of the above findings, the following order is passed: (i) The report of the Apex Body dated 26.4.2017 is set aside. (ii) The 1[st] respondent is directed to constitute an Apex Body consisting of the Director of Health Services (Convener), the Director of Medical Education, the Additional Director of Health Services (Vigilance), the Director General of Prosecution as well as an expert in the General Medicine. (iii) If the Apex Body feels that any other expert opinion is to be obtained, it is free to get an expert opinion from any other specialists as well. (iv) The Apex Body shall submit its report within three months from today. (v) The Apex Body shall give an opportunity for hearing to the petitioners herein as well as to the mother of the deceased. W.P.(C).No.25747 & 26395 of 2017 **==> picture [44 x 10] intentionally omitted <==** (vi) The investigating officer, after perusing the original Expert Panel report as well as the report of the Apex Body to be filed shall take a decision how to further continue with the investigation. (vii) If on receipt of the report of the Apex Body, the investigating officer decides to proceed with the investigation, it shall be completed within six months thereafter. Writ petitions are disposed of as above. **Sd/-** **DR. KAUSER EDAPPAGATH** **JUDGE** kp ## W.P.(C).No.25747 & 26395 of 2017 -:19:- ## **APPENDIX OF WP(C) 26395/2017** PETITIONER EXHIBITS - EXIT.P1 CIRCULAR MEMORANDUM FOR INVESTIGATION OF COMPLAINTS AGAINST DOCTORS ISSUED BY THE GOVERNMENT OF KERALA VIDE NO.73304/SSB3/2007/HOME.HOME (SSB) DEPARTMENT, THIRUVANANTHAPURAM DATED 1606-2008 - EXHIBITP2 COPY OF THE ENQAUIRY REPORT DATED 19-082016 - EXHIBIT P3 COP[Y OF THE REPORT DATED 3-10-2016 BY THE Expert Panel COMMITTEE - EXHIBIT P4 COPY OF THE ENQUIRY REPORT DATED 19-012017 - EXHIBIT P5 COPY OF THE ENQUIRY REPORT OF THE STATE LEVEL Apex Body NO.EC2-84352/2016/DHS DATED 26-04-2017 - EXHIBIT P6 PHOTO COPY OF HE POST-MORTEM REPORT DATED 3-6-2017 - EXHIBIT P7 COPY OF THE REVIEW PETITION DATED 21-072017 SUBMITTED BY THE PETITIONER BEFORE THE STATE LEVEL Apex Body - EXHIBIT P8 COPY OF THE INTERIM ORDER DATED 3-8-2017 IN I.A NO.12400/2017 IN WPC NO.25747/2017 W.P.(C).No.25747 & 26395 of 2017 -:20:- ## **APPENDIX OF WP(C) 25747/2017** PETITIONER EXHIBITS EXHIBIT P1 - THE PHOTOCOPY OF THE PRELIMINARY ENQUIRY REPORT DATED 19.07.2016 SUBMITTED BY THE COMMITTEE TO THE 3RD RESPONDENT AND MADE MOVER TO THE 2ND RESPONDENT. - EXHIBIT P2 THE PHOTOCOPY OF ORDER NO.K3/21603/2016/DME DATED 21.07.2016 OF THE 2ND RESPONDENT. - EXHIBIT P3 THE REPORT DATED 19.08.2016 SUBMITTED BY THE ENQUIRY COMMITTEE PURSUANT TO EXHIBIT P2. - EXHIBIT P4 THE PHOTOCOPY OF CIRCULAR NO.73304/SSB3/2007/HOME DATED 16.06.2008. - EXHIBIT P5 THE PHOTOCOPY OF THE REPORT DATED 03.10.2016 OF THE Expert Panel COMMITTEE. - EXHIBIT P6 THE PHOTOCOPY OF THE REPORT DATED 20.02.2017 OF THE ENQUIRY COMMITTEE. - EXHIBIT P7 THE PHOTOCOPY OF G.O. - (RT)NO.1120/2017/H&FWD DATED 20.04.2017. - EXHIBIT P8 THE PHOTOCOPY OF THE ORDER OF THE HON'BLE SESSIONS COURT ERNAKULAM DATED 09.05.2017 IN CRL.M.C.NO.919/2017. - EXHIBIT P9 THE PHOTOCOPY OF THE REPORT OF THE STATE LEVEL Apex Body NO.EC2-84352/2016/DHS DATED 26.04.2017. ## W.P.(C).No.25747 & 26395 of 2017 -:21:- |EXHIBIT P10|THE PHOTOCOPY OF THE POST MORTEM| |---|---| ||CERTIFICATE P.M.NO.496/16 DATED| ||03.06.2017 OF SHAMNA THESNEEM.| |EXHIBIT P11|THE PHOTOCOPY OF THE CASUALITY TICKET OF| ||SHAMNA THESNEEM WITH REGISTRATION| ||NO.361999.| |EXHIBIT P12|THE PHOTOCOPY OF THE RELEVANT PAGES OF| ||THE CASE RECORD OF SHAMNA THESNEEM WITH| ||INPATIENT NO.38264.| |EXHIBIT P13|THE PHOTOCOPY OF THE CERTIFICATE NO.H| ||11-9008/GMCH/2019 DATED 04.12.2019 OF| ||THE MEDICAL SUPERINTENDENT OF THE| ||COLLEGE ISSUED AT THE REQUEST THE| ||PETITIONER.| |EXHIBIT P14|THE PHOTOCOPY OF THE PAGE 153 OF| ||I.P.REGISTER (INPATIENT REGISTER) OF "S"| ||WARD OF THE COLLEGE.| |EXHIBIT P15|THE PHOTOCOPY OF THE CERTIFICATE NO.H| ||11-9008/GMCH/2019 DATED 04.12.2019 OF| ||THE MEDICAL SUPERINTENDENT OF THE| ||COLLEGE.| |Exhibit P16|TRUE COPY OF THE G. O(RT) NO.| ||2697/2016/H&FWD DATED 04/10/2016| |Exhibit P17|TRUE COPY OF THE| ||G.O(RT)NO.3165/2016/H&FWED DATED| ||23/11/2016| |Exhibit P18|TRUE COPY OF THE ORDER DATED 13/10/20-17| ||OF THE KERALA ADMINISTRATIVE TRIBUNAL,| ||ERNAKULAM BENCH IN O.A (EKM) 1007/2017| |Exhibit P19|TRUE COPY OF THE G.O(RT) NO. 3203/2017| ||DATED 13/11/2017| ## W.P.(C).No.25747 & 26395 of 2017 -:22:- Exhibit P20 TRUE COPY OF THE G.O(RT) 2541/2018/H&FWD DATED 10/08/2018 Exhibit P21 TRUE COPY OF THE ENQUIRY REPORT DATED 16/02/2019 SUBMITTED BY DR.M.K.AJAYKUMAR Exhibit P22 TRUE COPY OF THE G.O(RT) NO. 42/2021/H&FWD DATED 05/01/2021