Fr. Somy Mathew v. State of Kerala and Others; Fr. Joseph E.J. v. State of Kerala and Others

**WP(C)Nos.9658 & 9540 OF 2021 1** ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE MR. JUSTICE RAJA VIJAYARAGHAVAN V THURSDAY, THE 23[RD] DAY OF SEPTEMBER 2021 / 1ST ASWINA, 1943 WP(C) NO. 9658 OF 2021** ## **PETITIONER:** FR. SOMY MATHEW AGED 52 YEARS S/O.K.M.MATHEW, KUTTIYANICKAL HOUSE, TEEKOY P.O., KOTTAYAM-686 580, (HIGHER SECONDARY SCHOOL TEACHER (JUNIOR- SYRIAC), HOLY CROSS HIGHER SECONDARY SCHOOL, CHERPUNKAL. BY ADV S.SUBHASH CHAND ## **RESPONDENT/S:** 1 THE STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF GENERAL EDUCATION(T), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. 2 THE DIRECTOR OF GENERAL EDUCATION (FORMERLY DIRECTOR OF HIGHER SECONDARY EDUCATION), OFFICE OF THE DIRECTOR OF GENERAL EDUCATION, THIRUVANANTHAPURAM-695 014. 3 THE REGIONAL DEPUTY DIRECTOR, HIGHER SECONDARY EDUCATION, OFFICE OF THE REGIONAL DEPUTY DIRECTOR, KOTTAYAM-686 001. 4 THE CORPORATE MANAGER, THE CORPORATE EDUCATIONAL AGENCY, DIOCESE OF PALAI, SHALOM PASTORAL CETNRE, PALA-686 575, KOTTAYAM DISTRICT. **WP(C)Nos.9658 & 9540 OF 2021 2** 5 THE PRINCIPAL, HOLY CROSS HIGHER SECONDARY SCHOOL, CHERPUNKAL-686 584, KOTTAYAM DISTRICT. BY ADVS. S.JAYAKRISHNAN GOVERNMENT PLEADER, SMT NISHA BOSE SR GP. THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 23.09.2021, ALONG WITH WP(C).9540/2021, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: **WP(C)Nos.9658 & 9540 OF 2021 3** ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** ## **THE HONOURABLE MR. JUSTICE RAJA VIJAYARAGHAVAN V** **THURSDAY, THE 23[RD] DAY OF SEPTEMBER 2021 / 1ST ASWINA, 1943** ## **WP(C) NO. 9540 OF 2021** ## **PETITIONER:** FR. JOSEPH E.J., AGED 53 YEARS S/O.JOSEPH CHACKO, EZHUPARAYIL HOUSE, POOVARANY PO, PAIKA, KOTTAYAM-686 577 (HIGHER SECONDARY SCHOOL TEACHER (JUNIOR-SYRIAC), ST.MARY'S HIGHER SECONDARY SCHOOL, BHARANANGANAM). BY ADV S.SUBHASH CHAND ## **RESPONDENT/S:** 1 THE STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF GENERAL EDUCATION (T), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. 2 THE DIRECTOR OF GENERAL EDUCATION (FORMERLY DIRECTOR OF HIGHER SECONDARY EDUCATION), OFFICE OF THE DIRECTOR OF GENERAL EDUCATION, THIRUVANANTHAPURAM-695 001. 3 THE REGIONAL DEPUTY DIRECTOR, HIGHER SECONDARY EDUCATION, OFFICE OF THE REGIONAL DEPUTY DIRECTOR, KOTTAYAM-686 001. 4 THE CORPORATE MANAGER, THE CORPORATE EDUCATIONAL AGENCY, DIOCESE OF PALAI, SHALOM PASTORAL CENTRE, PALA-686 575, KOTTAYAM DISTRICT. **WP(C)Nos.9658 & 9540 OF 2021 4** 5 THE PRINCIPAL, ST.MARY'S HIGHER SECONDARY SCHOOL, BHARANANGANAM-686 578, KOTTAYAM DISTRICT. BY ADVS.S.JAYAKRISHNAN GOVERNMENT PLEADER, SMT. NISHA BOSE SR.GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 23.09.2021, ALONG WITH WP(C).9658/2021, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: **WP(C)Nos.9658 & 9540 OF 2021 5** **“CR”** ## **JUDGMENT** Two Higher Secondary School Teachers (Jr. Syriac) working in aided school managed by the 4th respondent Corporate Educational Agency have approached this Court, being aggrieved by the refusal on the part of the 2nd respondent in effecting upgradation of their post to Higher Secondary School Teachers (Syriac). According to the petitioners, as per the provisions of the Kerala Education Rules and the law laid down by this Court in **State of Kerala and Ors. v. K.V.Sreejith and Ors.** [2019 (2) KLT 253] interpreting the provisions, a Higher Secondary School Teacher (Jr.) has to be upgraded to the post of Higher Secondary School Teacher once the workload exceeds 15 periods per week. Since identical issues are raised by teachers working under the same corporate management, these writ petitions are taken up and disposed of by a common judgment. 2. The petitioners contend that during the academic year 20122013, while the petitioner in W.P.(C) No.9658/2021 was working at the Holy Cross Higher Secondary School, Cherupungal and the petitioner in W.P.(C) No.9540/2021 was working at the St. Mary’s Higher Secondary School, Bharananganam, the number of periods/workload for Higher Secondary School Teacher (Jr. Syriac) had exceeded 15 periods per week. Reliance is placed on the staff fixation orders pertaining to St. Mary’s Higher Secondary **WP(C)Nos.9658 & 9540 OF 2021 6** School, Bharananganam, (Exts.P2 to P4(a) in W.P.(C) No.9540/2021) and the staff fixation orders pertaining to Holy Cross HSS, Cherupunkal (Exts.P2 to P5(a) in W.P.(C) No.9658/2021) and it is contended that the periods for Syriac in the respective schools had clearly exceeded 15 periods per week. 3. It is contended that in view of the mandate under Rule 3 of Chapter XXXII of the KER the 2nd respondent was statutorily bound to carry out the upgradation. 4. Exhibits P7 and P8 are the requests submitted before respondents 2 and 3 seeking the upgradation of the post of HSST (Jr.Syriac) to HSST. On his part, the 4th respondent manager had also submitted a request for upgradation. 5. The 3rd respondent verified the request made by the Corporate Manager and after perusing the staff fixation orders issued a recommendation wherein it is mentioned that the post of HSST (Jr. Syriac) deserves upgradation with effect from 2012-2013 academic year onwards. According to the petitioners, despite Ext.P11 no action was taken. 6. In the said circumstances, the petitioners approached this Court and filed W.P.(C) No.27200/2019 and 27526/2019, complaining of inaction by the 2nd respondent and seeking directions. 7. This Court, by Ext.P13 judgment dated 12.3.2020, directed respondents 1 and 2 to consider the issue of upgradation of the post in the **WP(C)Nos.9658 & 9540 OF 2021 7** light of the law laid down in **K.V.Sreejith** (supra) and take a decision within three months. 8. In purported compliance with the directions issued by this Court, the 1st respondent passed Ext.P14 order holding that the request for upgradation of the post of HSST (Jr.Syriac) to HSST in the respective schools was allowable. However, instead of passing consequential orders, it was stated in the order that the upgradation could not be granted as the details pertaining to the number of students, the number of students who have taken Syriac as a sub-language, and the total number of posts for the academic year 2018-2019 to 2020-2021, were not produced by the ICT cell. The DGE was directed to submit a report regarding the additional financial commitment to the Government if the posts are upgraded. 9. The petitioners contend that Ext.P14 produced in both the writ petitions is untenable and the attempt of the 1st respondent is to protract and delay the matter and nothing more. According to the petitioners, as the upgradation depends on the increase in the workload of a teacher beyond 15 periods it can never be a matter of policy of the Government. According to the petitioners, the order passed by the Government has resulted in grave injustice. Since the posts of the petitioners have not been upgraded, several of their juniors in other languages and subjects have been promoted to higher posts and even as Principals of various Higher Secondary Schools under the 4th respondent management. Reliance is placed on Ext.P15 and it is **WP(C)Nos.9658 & 9540 OF 2021 8** contended that the 4th respondent has invited applications from the eligible candidates in the category of HMs/HSSTs under the management for filling up of 4 vacancies in the cadre of Principal in the management. In view of the inaction on the part of the respondents, the petitioners are prevented from filing applications to the post of Principal and they are detained in the post of HSST (Jr. Syriac) for almost a decade. It is in the afore circumstances that the petitioners are before this Court seeking the following reliefs. i) to issue a writ in the nature of certiorari or any other appropriate writ or order quashing Ext.P14 order to the extent of its blatant violation of Ext.P5 ruling and to the extent of further protracting and delaying the upgradation of the post of Higher Secondary School Teacher(Jr)(Syriac) to the post of Higher Secondary School Teacher(Syriac)with effect from the academic year 2012-2013 onwards in Holy Cross Higher Secondary School, Cherpunkal. ii) To issue a writ in the nature of mandamus or any other appropriate writ or order directing respondent No.2 to upgrade the post of Higher Secondary School Teacher(Junior-Syriac) in Holy Cross Higher Secondary School, Cherpunkal to Higher Secondary School Teacher (Syriac) with effect from the academic year 2012-13 onwards forthwith or within such time as this Hon’ble Court may deem fit and proper in the interest of justice. iii) To issue a writ in the nature of mandamus or any other appropriate writ or order directing respondent No.2 to upgrade the post of Higher Secondary School Teacher (Junior-Syriac) in Holy Cross Higher Secondary School, Cherpunkal to Higher Secondary School Teacher(Syriac) with effect from the academic year 2012-13 onwards in the light of the law laid down by this Hon’ble Court in Exhibit P5 ruling and Exhibit P10 recommendation made by respondent No.3 within such time as this Hon’ble Court may deem fit and proper in the interest of justice. ## 10. On 2.9.2021, when the matter had come up, it was submitted before this Court by the learned Government Pleader that the DGE has **WP(C)Nos.9658 & 9540 OF 2021 9** forwarded the report as requisitioned by the Government by Ext.P14 order. This Court, by order dated 2.9.2021, directed the learned Government Pleader to place the report before this Court and the same has been produced along with a memo. After detailing the ICT cell report showing the student strength of each batch for the previous years, the students enrolled for Syriac and also the existing posts in both the schools, it has been reported by the DGE as follows: “The Director of General Education examined the matter in detail and it is found that as per the reference read 6th above, the post held by Fr. E.J. Joseph, HSST (Jr.) was awarded Selection Grade of Higher Secondary. Similarly, as per reference read 7th above, Fr. Somy Mathew, HSST (Jr.Syriac) was also awarded Selection Grade of Higher Secondary. The scale of pay for HSST (Jr.) Selection Grade is above the scale of pay for an HSST in Higher Secondary. In this circumstance, it is found that there will be no financial burden to the Government if the post of the petitioners are upgraded to HSST from HSST (Jr.). And it is evident as per the pay revision order read 8th above. 11. Sri. Subhash Chand, the learned counsel appearing for the petitioners submitted that in view of the staff fixation orders produced by the petitioners and also the report of the DGE, there is no justification in denying upgradation to the petitioners from 2012-2013 onwards. It is urged by the learned counsel that despite specific directions issued by this Court in judgment dated 12.3.2020 to consider the request for upgradation in the light of the law laid down in **K.V.Sreejith** (supra), Ext.P14 order was passed **WP(C)Nos.9658 & 9540 OF 2021 10** stating untenable reasons. According to the learned counsel, there was no justification on the part of the 1st respondent to call for a report from the 2nd respondent in the matter of upgradation. 12. Smt. Nisha Bose, the learned Senior Government Pleader submitted that pursuant to directions issued by this Court in Ext.P13 judgment, a report was called for from the DGE calling for certain information. Now that the report has been submitted, it is for the 1st respondent to take a decision. ## 13. I have considered the submissions. 14. Rule 3 of Chapter XXXII governs the manner in which posts are to be sanctioned to Higher Secondary Schools. Rule 3 states that the service of every aided Higher Secondary School shall consist of all or any of the following categories of posts as the Director may sanction. In other words, the authority to sanction posts is the Director of Higher Secondary Education. Rule 1(d) of Chapter XXXII of the KER defines a Higher Secondary School Teacher to mean a Higher Secondary School Teacher of an aided school whose workload is 15 or more periods per week per subject. Higher Secondary School Teacher (Junior) has been defined under Rule 1 (e) to mean a Higher Secondary School Teacher of an aided school whose workload is less than 15 periods per week per subject. A Division Bench of this Court in **K.V.Sreejith** (supra) had occasion to hold while interpreting the provisions of the Rules that upgradation cannot be a matter of policy of the Government **WP(C)Nos.9658 & 9540 OF 2021 11** and would depend on an increase in the workload of a teacher beyond 15 periods. The upgradation would depend on the parameters contained in Chapter XXXII K.E.R., referred to above. After examining the statutory provisions, it was held as follows in paragraph 7 of the judgment. 7. ……………………...In the above context, it is necessary to notice that Rule 3 of Chapter XXXII governs the manner in which posts are to be sanctioned to Higher Secondary Schools. Rule 3 to the extent relevant reads as under:- 3. The Kerala Aided Higher Secondary Education Service-- The service of every aided Higher Secondary School shall consist of all or any of the following categories of posts as the Director may sanction. 8. What is necessary to be noticed from the above provision is that, the service of every aided Higher Secondary School is directed to consist of all or any of the categories of posts mentioned therein “as the Director may sanction”. Therefore, the authority to sanction posts, going by Rule 3 above is the Director of Higher Secondary Education. In the above context, the definitions in Rule 1(d) and (e) being relevant are extracted herein below:- - (d) ‘Higher Secondary School Teacher’ means a Higher Secondary School Teacher of an aided school whose work load is 15 or more periods per week per subject. - (e) ’Higher Secondary School Teacher (Junior)’ means a Higher Secondary School Teacher of an aided school whose work load is less than 15 periods per week per subject. The above Rules stipulate that a Higher Secondary School Teacher (Junior) means a Higher Secondary School Teacher whose workload is less than 15 periods per week. **WP(C)Nos.9658 & 9540 OF 2021 12** The above Rules stipulate that a Higher Secondary School Teacher (Junior) means a Higher Secondary School Teacher whose workload is less than 15 periods per week. A Higher Secondary School Teacher means a Higher School Teacher whose workload is 15 or more periods per week per subject. It therefore follows that, a Higher Secondary School Teacher (Junior) has to be upgraded to the post of Higher Secondary School Teacher, once the workload exceeds 15 periods per week. The above exercise has to be done by the Director of Higher Secondary Education, going by Rule 3 of Chapter XXXII. It is only in the matter of creation of posts that the State has power. As per Exhibit P2, posts of H.S.S.T. (Junior) were sanctioned by the Government with effect from 06.08.2011 onwards. The question as to whether the said posts were to be upgraded to H.S.S.T. would depend on whether the workload had exceeded 15 hours per week. The authority to assess the said situation and to sanction such upgradation is the Director of Higher Secondary Education. In the present case, the Director of Higher Secondary Education had recommended for such sanction to the Government. The Government accepted the said recommendation and has issued Exhibit P3 Government Order upgrading the posts but subject to the condition that such upgradation shall take effect only prospectively from the date of the order. Though we have tried to ascertain the basis for fixing the date of the Government Order as the date from which such upgradation has been directed to take effect, the only explanation is that since the matter involved financial commitments, it was part of the policy of the Government to do so. We find no other explanation. Since going by the Rules, the upgradation has to depend on increase in the workload of a teacher beyond 15 periods, it cannot be said that upgradation is a matter of policy of the Government. The policy of the Government would end when posts are sanctioned by it. Thereafter, upgradation would have to depend on the **WP(C)Nos.9658 & 9540 OF 2021 13** parameters contained in Chapter XXXII K.E.R., referred to above. In these cases, as the Higher Secondary Schools were sanctioned during the year 2010, it is not in dispute that the courses had continued to be conducted thereafter, without any break. Therefore, the students who were admitted in the year 2010-11, would certainly have come to the second year of the course during 2011-12. The teachers who were appointed initially as guest lecturers have been accommodated in the newly sanctioned posts of H.S.S.T.(Junior), with effect from 06.08.2011 onwards. The question as to whether they were entitled to be upgraded as H.S.S.T.would depend on the workload of each one of them, as indicated above. …………………………... 15. As held by this Court, a Higher Secondary School Teacher (Junior) has to be upgraded to the post of Higher Secondary School Teacher once the workload exceeds 15 periods per week and the said exercise has to be done by the Director of Higher Secondary Education as per the mandate under Rule 3 of Chapter XXXII. It can only be in the matter of the creation of posts that the State has power. The question as to whether the said posts are to be upgraded to H.S.S.T. would depend on the solitary question as to whether the workload had exceeded 15 hours per week. Upgradation cannot be regarded as a matter of policy of the Government as the policy of the Government would end when posts are sanctioned by it. Furthermore, the spectre of the Government incurring additional financial commitment if upgradation is carried out cannot be a reason if the conditions as mandated in the statute are satisfied. Insofar as the case of the petitioners are concerned, the incurring of additional financial commitment has no relevance as the DGE **WP(C)Nos.9658 & 9540 OF 2021 14** has reported that the scale of pay for HSST (Jr.) Selection Grade is above the scale of pay for an HSST in Higher Secondary and there will be no financial burden to the Government if the posts are upgraded. 16. In that view of the matter, the petitioners are entitled to succeed. There will be a direction to the 2nd respondent to upgrade the post of Higher Secondary School teacher (Jr. Syriac) to Higher Secondary School Teacher in the St. Mary’s Higher Secondary School, Bharananganam, and Holy Cross Higher Secondary School, Cherupungal with effect from academic Years 20122013 and pass orders to that effect within a period of one month from the date of production of a copy of this Judgment. These writ petitions are disposed of. **SD/-** **RAJA VIJAYARAGHAVAN V** **JUDGE** ps **WP(C)Nos.9658 & 9540 OF 2021 15** ## **APPENDIX OF WP(C) 9658/2021** PETITIONER'S EXHIBITS |EXHIBIT P1||TRUE COPY OF THE ORDER OF APPROVAL DATED| |---|---|---| |||15.06.2003 THUS ISSUED BY RESPONDENT NO.2.| |EXHIBIT P2||TRUE COPY OF THE STAFF FIXATION ORDER| |||PERTAINING TO HOLY CROSS HIGHER SECONDARY| |||SCHOOL, CHERPUNKAL FOR THE ACADEMIC YEAR| |||2006-07 TO 2012-13.| |EXHIBIT P3||TRUE COPY OF THE STAFF FIXATION ORDER| |||PERTAINING TO HOLY CROSS HIGHER SECONDARY| |||SCHOOL, CHERPUNKAL FOR THE ACADEMIC YEAR| |||2013, 2013-14 TO 2014-15.| |EXHIBIT P4||TRUE COPY OF THE STAFF FIXATION ORDER| |||PERTAINING TO HOLY CROSS HIGHER SECONDARY| |||SCHOOL, CHERPUNKAL FOR THE ACADEMIC YEAR| |||2015-2016 TO 2016-17.| |EXHIBIT P5||TRUE COPY OF THE STAFF FIXATION ORDER| |||PERTAINING TO HOLY CROSS HIGHER SECONDARY| |||SCHOOL, CHERPUNKAL FOR THE ACADEMIC YEAR| |||2017-2018 TO 2018-19.| |EXHIBIT P5|A|TRUE COPY OF THE STAFF FIXATION ORDER| |||PERTAINING TO HOLY CROSS HIGHER SECONDARY| |||SCHOOL, CHERPUNKAL FOR THE ACADEMIC YEAR| |||2019-2020.| |EXHIBIT P5|B|TRUE COPY OF THE GOVERNMENT ORDER DATED| |||22.01.2021.| |EXHIBIT P6||TRUE COPY OF THE RULING OF THIS HON'BLE| |||COURT IN STATE OF KERALA AND OTHERS V.| |||K.V. SREEJITH AND OTHERS (2019(2) KHC| |||686).| |EXHIBIT P7||TRUE COPY OF THE REQUEST DATED 13.09.2012| |||BY THE RESPONDENT NO.5 BEFORE RESPONDENT| |||NO.3.| **WP(C)Nos.9658 & 9540 OF 2021 16** EXHIBIT P8 TRUE COPY OF THE REQUEST DATED 25.10.2014 BY THE RESPONDENT NO.5 BEFORE RESPONDENT NO.3. EXHIBIT P9 TRUE COPY OF THE REPRESENTATION DATED 08.12.2014 SUBMITTED BY RESPONDENT NO.4 BEFORE RESPONDENT NO.3. - EXHIBIT P10 TRUE COPY OF THE REPRESENTATION DATED 08.05.2015 SUBMITTED BY RESPONDENT NO.4 BEFORE RESPONDENT NO.3. - EXHIBIT P11 TRUE COPY OF THE REPRESENTATION DATED 10.06.2015 SUBMITTED BY THE RESPONDENT NO.3 BEFORE RESPONDENT NO.2. - EXHIBIT P12 TRUE COPY OF THE REPRESENTATION DATED 16.01.2016. - EXHIBIT P12 A TRUE COPY OF THE REPRESENTATION DATED 07.09.2019. - EXHIBIT P12 B TRUE COPY OF THE REPRESENTATION DATED 05.03.2020. - EXHIBIT P13 TRUE COPY OF THE JUDGMENT DATED 12.03.2020 PASSED BY THIS HON'BLE COURT IN WPC NO.27526/2019(M). - EXHIBIT P14 TRUE COPY OF THE ODER DATED 15.03.2021 PASSED BY RESPONDENT NO.1 IN PURPORTED COMPLIANCE OF EXT.P13. - EXHIBIT P15 TRUE COPY OF THE NOTICE DATED 15.03.2021 ISSUED BY RESPONDENT NO.4. **WP(C)Nos.9658 & 9540 OF 2021 17** ## **APPENDIX OF WP(C) 9540/2021** PETITIONER'S EXHIBITS: |EXHIBIT P1||TRUE COPY OF THE ORDER OF APPROVAL DATED| |---|---|---| |||19.07.2002 ISSUED BY RESPONDENT NO.2.| |EXHIBIT P2||TRUE COPY OF THE STAFF FIXATION ORDER| |||PERTAINING TO ST. MARYS HIGHER SECONDARY| |||SCHOOL, BHARANANGANAM FOR THE ACADEMIC| |||YEARS 2012-2013 TO 2014-2015.| |EXHIBIT P3||TRUE COPY OF THE STAFF FIXATION ORDER| |||PERTAINING TO ST. MARYS HIGHER SECONDARY| |||SCHOOL, BHARANANGANAM FOR THE ACADEMIC| |||YEARS 2015-2016 TO 2016-2017.| |EXHIBIT P4||TRUE COPY OF THE STAFF FIXATION ORDER| |||PERTAINING TO ST. MARYS HIGHER SECONDARY| |||SCHOOL, BHARANANGANAM FOR THE ACADEMIC| |||YEARS 2017-2018 TO 2018-2019.| |EXHIBIT P4|(A)|TRUE COPY OF THE STAFF FIXATION ORDER| |||PERTAINING TO ST. MARYS HIGHER SECONDARY| |||SCHOOL, BHARANANGANAM FOR THE ACADEMIC| |||YEARS 2018-2019 TO 2019-2020.| |EXHIBIT P4|(B)|TRUE COPY OF THE GOVERNMENT ORDER DATED| |||22/1/2201 ISSUED BY RESPONDENT NO. 1.| |EXHIBIT P5||TRUE COPY OF THE RULING OF THIS HONBLE| |||COURT IN STATE OF KERALA AND OTHERS V K.V.| |||SREEJITH AND OTHER (2019 (2) KH 686).| |EXHIBIT P6||TRUE COPY OF THE REQUEST DATED 07.09.2012| |||BEFORE THE REGIONAL DEPUTY DIRECTOR HIGHER| |||SECONDARY EDUCATION, ERNAKULAM.| |EXHIBIT P7||TRUE COPY OF THE REPRESENTATION DATED| |||08.12.2014 SUBMITTED BY RESPONDENT NO. 4| |||BEFORE RESPONDENT NO. 3.| |EXHIBIT P8||TRUE COPY OF THE REPRESENTATION DATED| |||08.5.2015 SUBMITTED BY RESPONDENT NO. 4| |||BEFORE RESPONDENT NO. 3.| |EXHIBIT P9||TRUE COPY OF THE REPRESENTATION DATED| **WP(C)Nos.9658 & 9540 OF 2021 18** 08.5.2016 SUBMITTED BY RESPONDENT NO. 4 BEFORE RESPONDENT NO. 3. EXHIBIT P10 TRUE COPY OF THE RECOMMENDATION DATED 19.06.2017 MADE BY RESPONDENT NO. 3 TO RESPONDENT NO. 2. - EXHIBIT P11 TRUE COPY OF THE RECOMMENDATION DATED 07.02.2019 SUBMITTED BY RESPONDENT NO. 4 TO RESPONDENT NO. 1. - EXHIBIT P12 TRUE COPY OF THE DECLARATION DATED 5/3/2020 SUBMITTED BY RESPONDENT NO. 4. - EXHIBIT P13 TRUE COPY OF THE JUDGMENT DATED 12/3/2020 PASSED BY THIS HONBLE COURT IN WPC NO. 27526/2019. EXHIBIT P14 TRUE COPY OF THE ORDER DATED 15/3/2021 PASSED BY RESPONDENT NO. 1 IN PURPORTED COMPLIANCE OF EXT. P13. EXHIBIT P15 TRUE COPY OF THE NOTICE DATED 15/3/2021 ISSUED BY RESPONDENT NO. 4. //True copy//