Girish C. v Union of India & Others

## **`IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE RAJA VIJAYARAGHAVAN V THURSDAY, THE 7[TH] DAY OF SEPTEMBER 2023 / 16TH BHADRA, 1945 WP(C) NO. 13543 OF 2022`** ## **`PETITIONER/S:`** ``` GIRISHC., AGED45YEARS CISFNO.024090036HEADCONSTABLE/GENERALDUTY,CISF UNITBPCL-KRCOCHIN,RESIDINGATQUARTERNO.B-3, S-4,CISFCOMPLEX,IRUMAPANAM,ERNAKULAM,KERALA 682309. ``` ``` BYADVDINESHRAOA ``` ## **`RESPONDENT/S:`** - **`1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, MINISTRY OF HOME AFFAIRS, NORTH BLOCK, NEW DELHI 110001.`** - **`2 THE DIRECTOR GENERAL/ CENTRAL INDUSTRIAL SECURITY FORCE, CISF HQ, CGO COMPLEX, LODHI ROAD NEW DELHI 1003.`** - **`3 THE ADDITIONAL DIRECTOR GENERAL/ AIRPORT SECTOR, AIRPORT SECTOR HEAD QUARTERS, ADMIN BLOCK CISF COMPLEX, MAHIPALPUR, NEW DELHI 110037.`** - **`4 THE INSPECTOR GENERAL/CISF, SOUTH SECTOR HEAD QUARTERS, CHPT CAMPUS, CHENNAI, 600013.`** - **`5 THE DEPUTY INSPECTOR GENERAL/ CISF, CISF SOUTH ZONE HEAD QUARTERS, RAJAJI BHAVAN, BASANT NAGAR, CHENNAI 600090.`** - **`6 THE GROUP COMMANDANT, CISF GROUP HEAD QUARTERS, KENDRUYA BHAVAN, KAKKANAD, ERNAKULAM, KERALA 682 030.`** - **`7 THE DEPUTY COMMANDANT, CISF BPCL-KR, IRUMPANAM P.O., ERNAKULAM, KERALA 682 309. BY ADV MANU S., ASG OF INDIA`** ## **`OTHER PRESENT:`** ``` SRI.SMANU,DSGI ``` ``` THISWRITPETITION(CIVIL)HAVINGCOMEUPFORADMISSIONON 07.09.2023,ALONGWITHWP(C).13443/2023,THECOURTONTHESAME DAYDELIVEREDTHEFOLLOWING: ``` ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 2 ``` ## **`IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE RAJA VIJAYARAGHAVAN V THURSDAY, THE 7[TH] DAY OF SEPTEMBER 2023 / 16TH BHADRA, 1945 WP(C) NO. 13443 OF 2023`** ## **`PETITIONER/S:`** ``` GIRISHC. AGED46YEARS CISFNO.024090036,HEADCONSTABLE/GENERAL DUTY,CISFUNITBPCL-KRCOCHIN,RESIDINGAT QUARTERNO.B-3,S-4,CISF COMPLEX,IRUMBANAM.P.OERNAKULAM,PIN-682309 BYADVA.DINESHRAO ``` ## **`RESPONDENT/S:`** |**`1`**|**`UNION OF INDIA, REPRESENTED `**|**`BY ITS SECRETARY`**|**`BY ITS SECRETARY`**|**`BY ITS SECRETARY`**|| |---|---|---|---|---|---| ||**`MINISTRY OF HOME AFFAIRS, NORTH BLOCK, NEW`**||||| ||**`DELHI, PIN - 110001`**||||| |**`2`**|**`THE DIRECTOR GENERAL`**||||| ||**`CENTRAL INDUSTRIAL SECURITY `**|**`FORCE, CISF HQ,`**|||| ||**`CGO COMPLEX, LODHI ROAD, NEW DELHI, `**||**`PIN -`**||| ||**`110003`**||||| |**`3`**|**`THE ADDITIONAL DIRECTOR`**||||| ||**`GENERAL/AIRPORT SECTOR, AIRPORT SECTOR HEAD`**||||| ||**`QUARTERS, ADMIN BLOCK, CISF `**|**`COMPLEX,`**|||| ||**`MAHIPALPUR, NEW DELHI, PIN `**|**`- 110037`**|||| |**`4`**|**`THE INSPECTOR GENERAL/CISF`**||||| ||**`SOUTH SECTOR HEAD QUARTERS, `**|**`CHPT CAMPUS,`**|||| ||**`CHENNAI, PIN - 600013`**||||| |**`5`**|**`THE DEPUTY INSPECTOR GENERAL/CISF`**||||| ||**`CISF SOUTH ZONE HEAD QUARTERS, RAJAJI BHAVAN,`**||||| ||**`BASANT NAGAR, CHENNAI, PIN `**|**`- 600090`**|||| |**`6`**|**`THE GROUP COMMANDANT`**||||| ||**`CISF GROUP HEAD QUARTERS, KENDRIYA BHAVAN,`**||||| ||**`KAKKANAD, ERNAKULAM,, PIN - `**|**`682030`**|||| |**`7`**|**`THE DEPUTY COMMANDANT`**||||| ||**`CISF BPCL-KR, IRUMPANAM P.O., ERNAKULAM, `**|||**`PIN`**|| ||**`- 682309`**||||| |**`THIS`**|**`WRIT`**<br>**`PETITION`**<br>**`(CIVIL)`**<br>**`HAVING`**|**`COME`**<br>**`UP`**|**`FOR`**|**`ADMISSION`**|**`ON`**| |**`07.09.2023, ALONG WITH WP(C).13543/2022, THE `**|||**`COURT ON THE SAME`**||| |**`DAY `**|**`DELIVERED THE FOLLOWING:`**||||| ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 3 ``` ## **JUDGMENT** Both petitions are filed by the petitioner, a Head Constable attached to the Central Industrial Security Force (CISF). As issues are interrelated, both these petitions are taken up and disposed of by a common judgment. 2. The petitioner, a Head Constable in the Central Industrial Security Force (CISF), is presently posted in the unit attached to the BPCL, Cochin. On 28/3/2022, he received an order transferring him from Cochin. He challenged the order by filing W.P. (C) No. 13543/2022 before this Court. Before filing the writ petition, he had submitted a representation stating that his mother is a Cancer patient undergoing follow-up therapies and that his wife is a State Government Employee, and in view of the official memorandums and guidelines of the CISF, he is entitled to have his transfer deferred. He requested that he be retained at the BPCL Cochin station either by canceling the present posting order or by deferring the same by a period of one year. He also requested that he be granted a tenure at ASG Cochin or any other Kerala-based Airports. The petitioner's request was considered, and an order was passed on 11/5/2022, granting the prayer sought. His transfer order was deferred for a period of one year. After the completion of the above period of one year, on 12/3/2023, he was served with a letter (Ext. P7) informing him that he would be relieved from the unit on 30/4/2023 and transferred to CISF, ASG, Delhi. He was also directed to submit a Clearance ``` WP(C)NOS.13543OF2022& 13443OF20234 ``` Certificate on 29/4/2023 in the forenoon. On receipt of the said order, the petitioner has approached this Court and has filed W.P. (C) No.13443/2023 seeking the following reliefs:- - “i) To declare that the petitioner is eligible to be posted at CISF ASG Cochin or at any Airports in Kerala in the light of Ext’s P-2 service Certificate & P-4 Office Memorandum - ii) to direct the 6[th] , 5[th] , 4[th] & 3[rd] respondent to process Ext.P-5 representation at the earliest and also direct the 3[rd] respondent to consider and pass orders on Ext.P-5 representation in the light of ExtP-1 Medical Certificate, Ext P-2 service certificate and Ext.P-4 Office Memorandum issued by DoPT” - “i) Declare that the petitioner is eligible to continue in the present station namely BPCL, Kochi in the light of Exhibit P4 and P6 guidelines. - ii) Issue of writ of certiorari and other appropriate writ, direction or order quashing Exhibit P3 order of transfer and Exhibit P7 order requiring the petitioner to be relieved from duty on 30.04.2023 - iii) permit the petitioner to continue in the present unit at least for a period of one year from 30.04.2023. - iv) direct the 2[nd] respondent to favorably consider and pass orders on Exhibit P5 representation in the light of Exhibit P4 and P6 guidelines for transfer.” 2. Respondents 1 to 7 have submitted a counter affidavit, refuting the claims advanced by the petitioner. They raise the following contentions to assert that the prayer sought cannot be granted. It is stated that the petitioner is a soldier in the Central Industrial Security Force (CISF), a Principal Armed Force of the Union, mandated with the critical role of safeguarding numerous Government facilities and public sector enterprises. ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 5 ``` Pursuant to Section 15 of the CISF Act, 1968, all personnel of CISF are under a legal obligation to be assigned for duty anywhere within the country. Given that transfers are inherent to the service conditions, the petitioner, a service man, is not entitled to challenge his transfer, which has been conducted in the ordinary course of service. 3. It is further stated that the petitioner joined the ranks of CISF as a Constable/GD on 16.02.2002. Subsequently, he was promoted to the post of Head Constable at the CISF unit, BPCL, Cochin. The protocols concerning the transfer and positioning of CISF personnel (specifically Non-Gazetted officers) are dictated by Circular No. 22/2017 dated 25.09.2017, issued by the 2nd respondent. This directive mandates that during their 2nd tenure, the petitioner is obliged to serve for 12 years in a unit within his home sector. To ensure equitable allocation of manpower and fair representation throughout the force, the strength of each unit is apportioned in a manner where 30% consists of ''Home-State personnel'', another 30% are from the "Home Sector", and the remaining 40% are sourced from the “Out-of-Home sector”. Referring to the petitioner's service tenure, it's highlighted that he has rendered a cumulative service of 21 years and 05 months, including basic training in CISF. Out of this duration, 6 Years and 3 Months were spent in "Out-of-Home sector" postings, while 14 years and 3 months were dedicated to the "Home Sector". Notably, within his "Home Sector" tenure, he had a ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 6 ``` continuous stint of 10 years and 2 months across various units based in Cochin. Given that he has surpassed the 12-year threshold within his home-sector, he was accordingly considered for the inter-sector transfer-2022, resulting in a proposed relocation from BPCL, Cochin to the Airport Sector in New Delhi, a sector focused on Civil Aviation Security. Moreover, it has been pointed out that the petitioner previously approached this Court, challenging a transfer order on the grounds of his mother's medical condition and his wife's employment with the GST Department of the Kerala Government. He sought exemption from the transfer based on Exhibit P4. Preceding the writ petition was a representation, Ext. P5, where he specifically sought permission to remain at his current station, either by annulling the current posting or deferring it by a year. Acknowledging his plea, the competent authority granted a deferral of the transfer by a year as per Exhibit R6(a) order. Subsequently, after a year, Exhibit P7 order dated 12.03.23 was issued, instructing the 7th respondent to transition the petitioner from the CISF Unit BPCL, Cochin to CISF, ASG, Delhi. Having already availed the one-year deferral, the petitioner cannot invoke Clause 26 of Exhibit P6 Circular, which allows a one-year extension for Non-Gazetted Officers of CISF if their children are in the pivotal 10th or 12th academic year. This concession can be claimed only once. Therefore, any further request for extension based on a second child's academic year (10th or 12th) cannot be ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 7 ``` entertained. The respondents state that the petitioner is coming up with varied reasons sequentially, aiming to circumvent the transfer order, thereby enjoying the convenience of remaining in Kochi, to the detriment of other officers who are keen to return to their home sector post their out of Home Sector Service. The respondents further stated that the plea for an extension based on educational grounds cannot override operational and administrative imperatives. The CISF has formulated and adhered to broad guidelines to ensure equilibrium and afford all force members an opportunity to serve in their home sector. Transfers are routine and intrinsic to the service conditions. Such decisions are made after rigorous contemplation of factors such as vacancy availability, security considerations, and administrative and operational demands, all while prioritizing public interest. Granting concessions to one employee adversely impacts another awaiting a home sector or state posting. Given the petitioner's one-year grace period concluded on 30.4.2023, and in the absence of any allegations of malfeasance or violations of the statute, there exists no justification for judicial intervention. 3. I have heard of Sri. Dinesh Rao, the learned counsel appearing for the petitioner, and the learned DSGI who appeared for the respondents. 4. The petitioner has approached this Court seeking a declaration that the petitioner is eligible to continue in BPCL in the light of Exhibit P4 and ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 8 ``` P6 guidelines and also for quashing Exhibit P3 order of transfer and Exhibit P7 relieving order. The petitioner has also sought to permit him to continue working in the present unit for one year from 30.4.2023. 5. The contention of the petitioner is that he is entitled to carry on at the present station for the reason that a) his wife is working in the GST Department in the State of Kerala, and he is eligible for exemption from transfer in view of Exhibit P4 Original Memorandum b) his elder son is studying in the XII standard and as such he is eligible for extension in view of clause 26 of Exhibit P6. 6. Before adverting to the contentions, it would be profitable to understand the relevant clauses of Exhibit P6, which are the guidelines for the Posting/Transfer of CISF Personnel. OBJECTIVE: CISF is a Force with all India character. Personnel from all parts of the country are recruited in CISF. CISF would strive that each unit has a fair distribution of personnel from that region as well as from other regions. At least 40% of personnel in a unit must be from other Sectors. ## 10. SALIENT FEATURES - A) The Director General shall be the final authority for deciding all such transfers/postings. - B) All annual transfer orders shall normally be issued by the 31st of March and in any case, not later than 30th April of the year. - C) lt is again clarified that these guidelines would only serve as broad parameters for posting the personnel, but the final decision will rest with the competent authorities in CISF and will be governed by the operational and administrative necessities of the Force. ## 11. MANPOWER/DISTRIBUTION ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 9 ``` To have proper distribution of manpower and adequate representation in the Force, the posted strength of a Unit in each rank/category shall be as per the percentage given below, subject to availability of vacancies and other administrative/operational needs and public interest: - a) Home State Personnel 30% b) Home Sector Personnel -30% - c) Out of Home Sector Personnel 40 % ## 12. TENURE OF POSTING The Out of Home Sector (OHS) and Home Sector (HS) tenure for posting in respect of NGOs are subject to availability of vacancies, operational and administrative needs and new inductions. The details are as follows: ## OUT OF HOME SECTOR/HOME SECTOR TENURE FOR CONSTABLES. HCS, ASI’S, SI’s & INSPECTOR’s ,OF ALL SECTORS EXCEPT FOR EXCEPTIONS MENTIONED lN THIS CIRCULAR BASIC TRAINING PERIOD: NEITHER TO BE COUNTED lN HOME SECTOR NOR OUT OF HOME SECTOR a) 1st Tenure 07 Years in Units in Out of Home Sector (Excluding basic training) b) 2nd Tenure 12 Years in Units in Home Sector c) 3rd Tenure 06 Years in Out of Home Sector d) 4th Tenure (Remaining Service)- Home Sector 7. From the aforementioned details, it is evident that the Central Industrial Security Force (CISF) inducts personnel from various parts of India. The intent is to maintain a harmonious amalgamation of personnel from the local vicinity and those from different regions in each unit, ensuring that at least 40% of the personnel originate from regions other than the unit's location. The Director General stands as the paramount authority overseeing all transfers and postings. While the provided guidelines delineate broad ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 10 ``` parameters for postings, the final discretion rests with the competent authorities within the CISF, informed by operational and administrative exigencies of the force. With respect to the force's distribution, taking into account the availability of vacancies and operational requirements, the composition shall be 30% from the Home State, 30% from the Home Sector, and 40% from Out of Home Sector. Regarding the tenure of Non-Gazetted Officers, the first tenure spans approximately seven years in the Out of Home Sector, exclusive of basic training. The second tenure endures for twelve years in the Home Sector, the third for six years in the Out of Home Sector, and the fourth encompasses the remaining service period within the Home Sector. 8. Insofar as the petitioner is concerned, it is undisputed that the petitioner has rendered a total service of 21 years and 5 months, inclusive of the basic training period, within the Central Industrial Security Force (CISF). Of this duration, the petitioner has been posted in the Out of Home Sector for 6 years and 3 months and has served for 14 years and 3 months in the Home Sector. Notably, during his tenure in the Home Sector, he has consecutively served for 10 years and 2 months across various units located in Cochin, namely, the Cochin Port Trust, FACT/Udyogamandal, and BPCL, Cochin. 9. As the petitioner had crossed the 12-year threshold within his ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 11 ``` Home sector, he was accordingly considered for the inter-sector transfer. However, I find that the petitioner, contending that his mother is sick and his wife is stationed in Kerala, sought deferment of the transfer for one year and had also approached this Court with W.P.(C) No. 13543 of 2022. The respondents accepted his request, and the competent authority deferred the transfer by a year. After a year, Exhibit P7 order dated 12.03.23 was issued ordering the transfer to CISF, ASG, Delhi. After having availed the benefit of deferment of one year, it would not be open to the petitioner to invoke Clause 26 of Exhibit P6 Circular, which allows a one-year extension for Non-Gazetted Officers of CISF if their children are in the X or XII academic year. It is obvious that the petitioner's attempt is to circumvent the transfer order and remain in Kochi to the detriment of other officers. Transfers are routine and intrinsic to the service conditions. Such decisions are made after rigorous contemplation of factors such as vacancy availability, security considerations, and administrative and operational demands, all while prioritizing public interest. Granting concessions to one employee adversely impacts another awaiting a home sector or state posting. Given the petitioner's one-year grace period concluded on 30.4.2023, and in the absence of any allegations of malfeasance or violations of the statute,I find no reason to intervene in the order of transfer made in the case of the petitioner. ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 12 ``` 10. In **Shilpi Bose v. State of Bihar[1]** , the Supreme Court declared that transfer orders made in the public interest for administrative reasons should not face judicial interference unless in violation of statutory rules or due to mala fide intentions. A Government servant in a transferable position has no inherent right to stay at a particular location. The affected party should approach higher authorities rather than the courts for violations of executive instructions. Moreover, in **Major General J.K. Bansal v. Union of India[2]** , the Supreme Court has observed that there shall be limited judicial intervention in transfers within the Armed Forces, with the understanding that such decisions rest with higher military authorities. In **Divyamol R.S. Vs. Director General Industrial Security Force[3]** , this Court recognized the employer's prerogative to transfer employees based on service needs, especially in uniformed services. It was held that interference can be made only when the transfer is made violating the provisions of the statute, or made in a mala fide manner, or is a punitive measure without disciplinary proceedings. Such insistence is more stringent in disciplined forces like the CISF, which may require postings within or outside India. For maintaining equilibrium in CISF, transfer guidelines are in place. Such transfers are routine, taking into account factors like vacancies, security, and administrative needs. Retaining an individual at one location impacts others > 1 (AIR 1991 SC 532) > 2 (2005) 7 SCC 227 > 3 2022 (5) KHC 732 ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 13 ``` awaiting transfers. The petitioner's one-year grace period, as per Exhibit R6(a), ended on 30.04.2023. The transfer that has now been ordered follows the guidelines of the CISF. In that view of the matter no interference is made. 11. At this stage, the learned counsel appearing for the petitioner points out that the respondents had failed to comply with the interim order granted by this Court and had issued a movement order to Chennai. This aspect of the matter shows that the petitioner is being victimized. In response, the learned DSGi submitted that the movement order issued to the petitioner is a routine order and had nothing to do with the order of Transfer to ASG Delhi. It is submitted that the petitioner was expected to return to the home station. 13. The learned counsel submitted that the petitioner be granted time till the end of the month to comply with the directions. The learned DSGI submits that the petitioner can be granted 15 days time to obey the orders. While dismissing these petitions, I direct the respondents to grant the petitioner 15 days time from today to enable him to comply with Ext.P7 order. These petitions are dismissed with the above directions. **Sd/RAJA VIJAYARAGHAVAN V, JUDGE** SJ ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 14 ``` ## **`APPENDIX OF WP(C) 13443/2023`** |`PETITIONER EXHIBITS`|`PETITIONER EXHIBITS`| |---|---| |`Exhibit P1`|`A TRUE COPY OF THE SERVICE`| ||`CERTIFICATE OF SMT. PREEJA, WIFE OF`| ||`THE PETITIONER AND DATED 30.03.2021`| ||`ISSUED BY THE COMPETENT AUTHORITY`| |`Exhibit P2`|`TRUE COPY OF THE STUDY CERTIFICATE`| ||`AND REGISTRATION DETAILS OF THE`| ||`PETITIONER'S ELDER SON AND DATED`| ||`11.01.2023`| |`Exhibit P3`|`TRUE COPY OF AIRPORT SECTOR HQ`| ||`SERVICE ORDER NO.87/2022 DATED`| ||`09.04.2022`| |`Exhibit4`|`TRUE COPY OF THE OFFICE MEMORANDUM`| ||`ISSUED BY THE MINISTRY OF PERSONAL,`| ||`PUBLIC GRIEVANCE AND PENSION,`| ||`DEPARTMENT OF PERSONAL AND TRAINING`| ||`OFFICE MEMORANDUM DATED 30.09.2009`| |`Exhibit5`|`TRUE COPY OF THE REPRESENTATION`| ||`DATED 09.03.2023 SUBMITTED BY THE`| ||`PETITIONER BEFORE THE 2ND RESPONDENT`| |`Exhibit- P6`|`TRUE COPY OF THE CIRCULAR NO.22/2017`| ||`ISSUED BY THE 2ND RESPONDENT AND`| ||`DATED 25.09.2017`| |`Exhibit7`|`TRUE COPY OF THE OFFICE ORDER DATED`| ||`14.03.2023 ISSUED BY THE 7TH`| ||`RESPONDENT`| |`Exhibit P8`|`TRUE COPY OF THE ORDER DATED`| ||`27.6.2023 ISSUED BY THE ASSISTANT`| ||`COMMANDANT,CISF UNIT.`| |`Exhibit P9`|`TRUE COPYOF THE REPRESENTATION`| ||`SUBMITTED BY ME BEFORE THE ASSISTANT`| ||`COMMANDANT. DATED 29.6.2023`| |`RESPONDENT EXHIBITS`|| |`Exhibit R6(a)`|`True copy of the letter No.`| ||`V-3802305(Vol-02)RP/Extt-II/2022/212`| ||`8 dated 11.05.2022 issued by the 2nd`| ||`respondent`| ``` WP(C)NOS.13543OF2022& 13443OF2023 ``` ``` 15 ``` ## **`APPENDIX OF WP(C) 13543/2022`** ``` PETITIONEREXHIBITS ``` - `Exhibit P1 TRUE COPY OF TREATMENT CERTIFICATE DATED 06.11.2021 ISSUED BY THE MEDICAL OFFICER, EARLY CANCER DETECTION CENTRE KANJIKKOD , PALAKKAD.` - `Exhibit P2 TRUE COPY OF THE SERVICE CERTIFICATE OF THE WIFE OF THE PETITIONER DATED 30.03.2022 ISSUED BY THE COMPETENT AUTHORITY.` - `Exhibit P3 TRUE COPY OF RELEVANT PAGES OF INTER SECTOR TRANSFER -2022 AS PER ORDER NO. (207) DATED 28.03.2022.` - `Exhibit P4 TRUE COPY OF MINISTRY OF PERSONNEL, PUBLIC GRIEVANCE AND PENSION, DEPARTMENT OF PERSONNEL AND TRAINING OFFICE , MEMORANDUM DATED 30.09.2009.` - `Exhibit P5 TRUE COPY OF THE REPRESENTATION DATED 04.04.2022 SUBMITTED BY THE PETITIONER IN THE OFFICE OF THE 7TH RESPONDENT ADDRESSED TO THE 3RD RESPONDENT.` ``` RESPONDENTEXHIBITS ExhibitR6(a)AtruecopyoftheCircular No.22/2017dated25.09.2017issued bythe2ndrespondent ExhibitR6(b)TruecopyoftheletterNo. V-3802305(Vol-02)RP/Extt-II/2022/212 8dated11.05.2022issuedbythe2nd respondent ```