Joshi N. Thomas v. State of Kerala & Others

## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** ## **THE HONOURABLE MR. JUSTICE ASHOK MENON** ## **TUESDAY, THE 25TH DAY OF AUGUST 2020 / 3RD BHADRA, 1942** ## **WP(C).No.19237 OF 2019(D)** ## **PETITIONER/S:** **JOSHI.N.THOMAS AGED 71 YEARS 8/68, RETEAT, NAMBIAPARAMBIL HOUSE, MOOKKANNOOR.P.O, ERNAKULAM DISTRICT, PIN683577** **BY ADVS. SRI.V.GANGADHARAN SRI.C.PAULOSE KUM.ALEENA JOLLY** ## **RESPONDENT/S:** - **1 STATE OF KERALA REPRESENTED BY ITS CHIEF SECRETARY, SECRETARIAT, THIRUVANANTHPAURAM-695001** - **2 STATE OF KERALA REPRESENTED BY ITS ADDITIONAL CHIEF SECRETARY HOME DEPARTMENT, SECRETARIAT, THIRUVANANTHAPURAM-695001** - **3 THE DIRECTOR CENTRAL BUREAU OF INVESTIGATION, GOVERNMENT OF INDIA, C.G.O COMPLEX, RAMAKRISHNAPURAM, NEW DELHI-110003** - **4 THE DIRECTOR GENERAL OF POLICE AND STATE POLICE CHIEF, POLICE HEAD QUARTERS SASTHAMANGALAM, THIRUVANANTHPAURAM-695014.** - **5 THE ADDITIONAL DIRECTOR GENERAL OF POLICE NORTH ZONE KOZHIKODE-673010** - **6 THE DEPUTY SUPERINDENTANT OF POLICE DIRECTOR CRIME BRANCH, THRISSUR (RURAL) STATION, AYYANTHOLE, THRISSUR-680003** WP(C) 19237/2019 2 **7 SUB DIVISIONAL MAGISTRATE CIVIL STATION, OFFICE OF THE S.D.M THRISSUR-680003** **R1-2, R4-7 BY GOVERNMENT PLEADER** ## **OTHER PRESENT:** ## **SRI.C.S.HRITHWIK SR PP** **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 17-01-2020, THE COURT ON 25-08-2020 DELIVERED THE FOLLOWING:** WP(C) 19237/2019 3 ASHOK MENON, J. -----------------------------------WP(C) No. 19237 of 2019 ------------------------------------Dated this the 25[th] day of August, 2020 ## J U D G M E N T The relentless efforts of a bereaved father continues. This is the third time he is approaching this Court with a Writ Petition seeking directions for proper investigation of the case that was registered consequent to the untimely and allegedly suspicious death of his son Jerin Joshy on 13/05/2011. In the alternative, the petitioner seeks a prayer to hand over the investigation to the Central Bureau of Investigation. 2. Jerin was a 22-year-old engineering graduate waiting to be inducted into his first job. While waiting for the placement, on 13/05/2011 he went to his mother's ancestral house at Thuravoor. His uncles, aunts, and cousins, planned a pleasure WP(C) 19237/2019 4 trip to a place called Aroormuzhi. They left for Aroormuzhi in two cars and reached there by afternoon. While they were picnicking on a riverbank, some of them attempted to get into the river for a bath. Jerin too did that and unfortunately tripped into the river. His cousin's wife Binsy who was among the few in the group who knew how to swim, made a valiant attempt to save him, in vain. Brother George, one of his uncles also tried to help, but he too failed. The undercurrent was strong and Jerin was pulled by it and drowned. The members of the party raised an alarm for help. Two persons from the locality namely Suresh, who was engaged in fishing nearby, and Deepu came to their assistance. Suresh succeeded in salvaging Jerin from the riverbed with the help of Deepu. Police were informed and Sijo Varghese, the Sub Inspector of Police, Athirappilly, and his party reached there by about 3:30 PM. Jerin was immediately taken to the St James WP(C) 19237/2019 5 Hospital, Chalakudy only to be declared dead by the doctor. Crime No. 172/2011 (Ext.P1) was registered at the Athirappilly Police Station for unnatural death based on the Ext.P2 First Information Statement given by Jerin's cousin Aji Thomas. An inquest was prepared, and the body was sent for autopsy to the Government Hospital, Chalakkudy, which was performed by Dr Sindhu Krishnan, the Assistant Surgeon and her report concluded that Jerin died due to asphyxia caused by accidental drowning. No other internal or external injuries noticed on his body . As there were no reasons to suspect anything about the death, and the deceased was at that time, accompanied by his near relatives, the Sub Inspector of Police concluded his investigation and filed a Final Report before the Sub Divisional Magistrate confirming that the death of Jerin was due to accidental drowning, and that there were no circumstances to investigate further. WP(C) 19237/2019 6 3. The petitioner was not satisfied and had his reasons to suspect his son's death. The profound grief of his only son's death prompted him to raise his objections before the Superintendent of Police, Thrissur Rural. Accordingly, further investigation was entrusted to Sri P. K. Rajan, the Deputy Superintendent of Police Chalakudy. All the alleged suspicious circumstances pointed out by the petitioner were taken into consideration by the Dy.SP but he too concluded that the death was due to accidental drowning and submitted his report before the Sub Divisional Magistrate on 25/08/2011. 4. Still not satisfied, the applicant made a representations before the Hon'ble Chief Minister of Kerala, and also the DirectorGeneral of Police. The grievance of the father who has lost his son was viewed with empathy, and Shri V.K. Raju, Detective Inspector, C.B.C.I.D., HHW, Kochi was entrusted to have a relook. He too did WP(C) 19237/2019 7 not find anything different. Yet another investigation was conducted by Sri K.V. Vijayan, Deputy Superintendent of Police, based on the directions issued by the Additional Director General of Police, South Zone. Yet, there was no result to the satisfaction of the petitioner. 5. The petitioner approached this Court by filing WP(C) No. 8872/2014 and this Court vide Ext.P3 order dt. 01/07/2014 directed the ADGP, South Zone to continue the investigation convincingly. Ultimately, vide Ext.P4 Judgment dated 18/07/2014 this Court directed further investigation by a Special Investigation Team (SIT) under the supervision of the ADGP, North Zone. Vide orders of the DGP, a special investigation team was constituted including seven officers comprising of CPOs, WCPO, Inspector, Dy.SP, ACP, and Superintendent of Police. And they conducted a thorough investigation under the supervision of the ADGP North WP(C) 19237/2019 8 zone. During the investigation by the SIT, 29 witnesses including the petitioner, were questioned and all suspicious circumstances pointed out by the petitioner probed into with the help of experts in the field. Ext.P5 is the statement given by the petitioner. However, the SIT also did not find any incriminating material sufficient to proceed. The death was again concluded as an accidental drowning, and a report was filed on 25/07/2015 before this Court to that effect, produced along with Ext.P6. However, by the time the applicant had filed WP(C) No. 22875/2015, and this Court left the matter to be decided in the fresh Writ petition filed by the petitioner vide Ext.P7 Order dated 13/08/2015. 6. In W.P. ( C ) No. 22875/2015, the petitioner appeared in-person to put forth his case before this Court and reiterated all his apprehensions and challenged the Ext.P6 report. This Court, WP(C) 19237/2019 9 Vide Ext.P8 Judgment dated 09/08/2017, holding that some doubts still linger in the mind of the petitioner on specific points, directed the present ADGP North Zone to comprehensively look into the entire aspects once again, and to consider whether any further action is liable to be taken. Three months’ time was stipulated to decide on the matter. In compliance with the aforesaid judgment, the ADGP North Zone issued Ext.P9 Order on 13/11/2017 constituting yet another Special Investigation Team under the supervision of the then Superintendent of Police, Thrissur Rural. The Thrissur Range I.G was directed to submit a status report every fortnight. 7. Since the petitioner did not hear anything from the newly constituted investigating team, he submitted Ext.P10 representation before the 6[th] respondent, DySP District Crime Branch. The petitioner realised that the DySP was hastening to WP(C) 19237/2019 10 close the investigation. The petitioner submitted Ext. P11 complaint on 21/01/2019 before the 5[th] respondent ADGP, with copies to all including the Chief Minister, requesting the investigating officer to be replaced. The petitioner received Ext.P12 reply from the office of the 5[th] respondent on 07/03/2019 informing him that his request to replace the investigating officer cannot be considered favourably. Thereafter, the petitioner also received Ext.P13 notice under Sections 157 (2) and 173 (1) (b) Cr.P.C stating that the final report has been filed before the Sub Divisional Magistrate reiterating the cause of death as accidental drowning. On receiving Ext. P13 notice on 30/03/2019, the petitioner filed a preliminary objection before the 7[th] Respondent Sub Divisional Magistrate. Ext.P14 is the acknowledgement that he received from the 7[th] respondent's office. On inquiry made by the petitioner’s counsel at the office of WP(C) 19237/2019 11 the Sub Divisional Magistrate, it was understood that the final report has not yet been filed by the 5[th] respondent as informed. Hence, the petitioner submitted Ext.P15 representation before the Hon’ble Chief Minister on 13/04/2019. He also filed Ext. P16 petition before the 4[th] respondent DGP with a copy to the 1[st] respondent ADGP on 24/04/2019. The petitioner received Ext.P17 information from the ADGP's office informing him about forwarding his complaint to the Range IG. 8. Under the circumstances, the petitioner had no other option but to approach this Court with the present Writ Petition praying that the records leading to Exts.P12 and P13 may be called for and quashed, and appropriate directions may be issued to the 6[th] respondent DySP to produce a report of investigation filed according to Ext.P13 and also issue a Writ of mandamus directing the proper investigation of Crime No. 172/2011 of WP(C) 19237/2019 12 Athirappilly Police Station or else, a direction may be issued to the 1[st] respondent State of Kerala to handover investigation of the case to the Central Bureau of Investigation. 9. The question as to whether the High Court could direct CBI to take over investigation in the facts of the present case, needs to be examined. The Constitution Bench in its judgment reported as State of West Bengal and Others v. Committee for Protection of Democratic Rights, West Bengal and Others, [2010 (3) SCC 571] has examined the question as to the rights of CBI to investigate a criminal offence in a State without its consent. After examining Entry 2 of List II of VII Schedule of the Constitution, it was held that the legislative power of the Union to provide for the regular police force of one State to exercise power and jurisdiction in any area outside the State can only be exercised with the consent of the Government of that particular State in WP(C) 19237/2019 13 which such area is situated. The Court held that though the Court had wide powers conferred by Art.32 and Art.226 of the Constitution, it must bear in mind certain self - imposed limitations on the exercise of these constitutional powers. This extraordinary power must be exercised sparingly, cautiously and in exceptional situations where it becomes necessary to provide credibility and instill confidence in an investigation or where the incident may have national or international ramifications or where such an order is necessary for doing complete justice and enforcing fundamental rights. The relevant extract from the judgment reads as under: " Before parting with the case, we deem it necessary to emphasise that despite wide powers conferred by Art.32 and Art.226 of the Constitution, while passing any order, the Courts must bear in mind certain self - imposed limitations on the exercise of these constitutional powers. The very plenitude of the power under WP(C) 19237/2019 14 the said articles requires great caution in its exercise. Insofar as the question of issuing a direction to CBI to conduct investigation in a case is concerned, although no inflexible guidelines can be laid down to decide whether or not such power should be exercised but time and again it has been reiterated that such an order is not to be passed as a matter of routine or merely because a party has levelled some allegations against the local police. This extraordinary power must be exercised sparingly, cautiously and in exceptional situations where it becomes necessary to provide credibility and instil confidence in investigations or where the incident may have national and international ramifications or where such an order may be necessary for doing complete justice and enforcing the fundamental rights. Otherwise, CBI would be flooded with a large number of cases and with limited resources, may find it difficult to properly investigate even serious cases and in the process lose its credibility and purpose with unsatisfactory investigations." 10. There is no dispute that the High Court under Art.226 of the Constitution can direct inquiry to be conducted by CBI but such power can be exercised only in cases where there is WP(C) 19237/2019 15 sufficient material to come to a prima facie conclusion that there is need for such inquiry. It is not sufficient to have such material in the pleadings alone. The Hon’ble Apex Court has held that the right to live under Art.21 of the Constitution includes the right of a person to live without being hounded by the police or CBI to find out whether he has committed any offence or is living as a law-abiding citizen. ( See Secretary, Minor Irrigation & Rural Engineering Services, U.P. and Others v. Sahngoo Ram Arya and Another, [2002 (5) SCC 521] ). 11. On examining the above-cited decisions, the Hon’ble Supreme Court has reiterated this in Shree Shree Ram Janki Ji Asthan Tapovan Mandir and Another v. State of Jharkhand and Others. (2019 KHC 6519 : 2019 (3) KHC SN 5 : 2019 (6) SCC 777 ) and held thus: “ It is seen from the above decision of this Court WP(C) 19237/2019 16 that the right to life under Art.21 includes the right of a person to live without being hounded by the police or CBI to find out whether he has committed any offence or is living as a lawabiding citizen. Therefore, it is clear that a decision to direct an inquiry by CBI against a person can only be done if the High Court after considering the material on record comes to a conclusion that such material does disclose a prima facie case calling for an investigation by CBI or any other similar agency, and the same cannot be done as a matter of routine or merely because a party makes some such allegations. In the instant case, we see that the High Court without coming to a definite conclusion that there is a prima facie case established to direct an inquiry has proceeded on the basis of "ifs" and "buts" and thought it appropriate that the inquiry should be made by CBI. With respect, we think that this is not what is required by the law as laid down by this Court in the case of Common Cause." 12. Keeping in view the decisions referred to above, it is to be decided whether investigation made thus far, in this case, is satisfactory and whether interference of this Court is necessary to hand over the investigation to another agency or to the CBI. The WP(C) 19237/2019 17 petitioner suspects that the death of his son is a homicide whereas the investigation conducted by the local Police as well as the Crime Branch including the Special Investigation Team constituted under directions of this Court, repeatedly concluded that it is a case of accidental death by drowning. The materials placed before this Court will have to be examined to decide whether those materials prima facie disclose a case of homicide as suspected by the petitioner. 13. Heard the learned counsel appearing for the petitioner Shri V. Gangadharan, and the learned Senior Public Prosecutor Shri C.S. Hrithik. Records perused. 14. The following are the points indicated by the learned counsel for the petitioner as the reasons for the basis of his suspicion about the Police investigation in this Crime. WP(C) 19237/2019 18 15. The statement of the SHO, Athirappilly Police station who reached the scene of occurrence on getting information is contradictory to the statement of Aji Thomas, the first informant. The SHO, Sijo Verghese, states that he reached the scene of occurrence on 13/05/2011 at 3:30 PM, noticed a gathering and Jerin was lifted from the river and brought to the southern river bank. Immediately he rushed him to the hospital in his jeep. The First Information Statement is to the effect that Jerin was taken to the hospital at 3:20 PM. The report collected from St. James Hospital is that the patient was brought by the Police at about 3 PM. These discrepancies, according to the learned counsel for the petitioner, are fatal. It is submitted that there is a procedural irregularity in registering the F.I.R only after the inquest. The F.I. statement was recorded from the hospital, but it is shown as recorded from the Police station. WP(C) 19237/2019 19 16. There is also a discrepancy in the FI statement wherein it is stated that the tour party reached Aroormuzhi about 1 PM and that Jerin entered the waters for bathing and tripped into the river, whereas the investigation revealed that they reached at 2:30 PM on 13/05/2011 and that almost all the members had entered the waters, and spread in different directions. The statement that Bincy tried to save Jerin cannot be believed because even admittedly, Jerin was away from the lot when he got into the water. The version of the members of the group that Jerin did not know how to swim also is proved to be a falsity. Bincy stated that Jerin had told her that he did not know swimming. The investigating agency had questioned the classmates of Jerin to gather the information that he knew swimming. They specifically stated that it was Jerin who rescued their classmate Aneesh when he fell into the pond near the WP(C) 19237/2019 20 college hostel. Despite getting this information, the investigating agency concluded that Jerin was not an expert swimmer. The petitioner points out that no one knowing how to swim could get drowned in a river with only 3.70 metres deep water. The petitioner contends that any person knowing how to swim would definitely have managed to stay afloat in such water, unless he was sucked by a whirlpool. No expertise is required to escape drowning in such situation. Two independent witnesses were fished out by the investigating team who allegedly stated about not witnessing anything suspicious. The petitioner would contend that those witnesses would have been too young at that point in time to make any assessment about the happenings at the scene of occurrence. 17. The petitioner has expressed suspicion regarding the position of the body when he saw it from the mortuary. The WP(C) 19237/2019 21 supine position with neck stretched backwards, is not explained. The explanations offered by the forensic expert Dr N.A. Balaram is not satisfactory. The possibility of application of pressure on his neck, presence of mud in the mouth and nose of the deceased were not properly investigated. An attendant in the post mortem team had expressed his doubts about presence of mud in the nostrils and mouth is contradictory to the autopsy report of Dr Sindhu Krishnan who does not state regarding the presence of such mud. Experts opinion in this regard relied upon by the investigation team is not proper. The petitioner states that human body consists of 72% water. This added with air in the lungs would have kept the body afloat. When he attempts to shout for help, water is drawn into the mouth, lungs and stomach. This enhances the body weight and sinks it. 18. The reasons for fainting of Sobha and Linto Pauly WP(C) 19237/2019 22 during funeral was not investigated. Had there been proper investigation in this regard, it would have unraveled the truth about Jerin's death. 19. The petitioner has received an SMS message on his mobile phone purportedly sent by his deceased son, consoling him and to dispel his doubts about his death. The investigating agency had traced the message to a phone from Madhya Pradesh. But further investigation about who had send it and the reason for such message, etc. were not investigated. 20. The investigating team has gone into all these doubts expressed by the petitioner in some detail, and offered explanations. The petitioner was however not satisfied with those explanations. The suspicious circumstances pointed out by the petitioner can be examined. 21. The petitioner saw the body of his son and found the WP(C) 19237/2019 23 head stretched backwards. This has given rise to his first suspicion. The forensic team did examine this suspicion anxiously. It is pointed out that rigor mortis sets in four hours after the death. It is indicated that after retrieving the body from the river, it was placed on a stretcher. There is possibility of neck being stretched backwards, and hence the position of the head. In case there was any scuffle preceding the death of Jerin, as suspected, there would have been external injuries on the body. No such injuries were noted during the autopsy. 22. The petitioner's mind got swayed away by an attender in the hospital informing him about his noticing mud in the nose and mouth of the deceased. Post mortem report does not mention about such mud. Finding of mud on the nose and mouth is not significant. The body would have been recovered from the river bed filled with mud. It may have been placed by the river WP(C) 19237/2019 24 side, where also possibility of mud is there. The experts have opined that presence of mud in the lungs alone would have lead to some conclusion regarding cause of death. The fact that the autopsy does not refer to such mud on the nose and moth of the body cannot therefore be given any undue importance. 23. Absence of water in the stomach is pointed out by the petitioner as a significant point to rule out death by drowning. This was investigated and the opinion is that death was caused by asphyxia, which is caused by air neither entering nor exiting the lungs due to water entering the lungs and it sides adhering and shrinking. The forensic team headed by Dr Balaram had clarified these suspicions raised by the petitioner. 24. The investigating team questioned each and every member of the touring team, which also included a child. None of them spoke about an altercation or scuffle involving the deceased WP(C) 19237/2019 25 with anyone present at the scene of occurrence. That apart, two independent witnesses also gave statements to the investigation team about nothing untoward involving the deceased happening on the fateful day. 25. Drowning is a form of death in which the air is prevented from entering the lungs by submersion of the body under water. It is contended by the petitioner that the deceased knew how to swim and hence could not have drowned. The relatives of the deceased who were with him, stated that the deceased had told them that he did not know swimming. The petitioner himself was not aware that his son could swim. In his statement to the Deputy Superintendent of Police, produced as Ext.P10, he came to know that his son could swim only after his death, when his son's friends said that he had saved a boy who fell into the pond near the college hostel. The fact regarding the WP(C) 19237/2019 26 deceased being a person who knew how to swim, is therefore doubtful. Swimming in a pond is different from swimming in a river with rapids, or strong under currents. The conclusion that the deceased died due to accidental drowning cannot therefore be doubted. 26. Suspicion however strong, cannot take the place of proof (See Subramania Swamy v. A Raja 2012(9) SCC 257 ). In criminal cases, an accused has to be proved to be guilty beyond reasonable doubt. The law does not permit the Court to convict the accused based on suspicion or on the basis of preponderance of probability (see Latesh@ Dadu Baburao Karlekar & Ors v.State of Maharashtra 2018(3)SCC66 ) . As stated by the Hon'ble Apex Court in the decisions Secretary, Minor Irrigation & Rural Engineering Services, U.P. and Shree Shree Ram Janki Ji Asthan Tapovan Mandir referred to above, persons cannot be hounded WP(C) 19237/2019 27 by ordering a CBI investigation merely for the asking. The two Special Investigation Teams have tried their best to dispel the suspicions of the petitioner. Yet, he was not satisfied. On going through the detailed reports submitted by the investigating teams, I find that there is no reason for any further investigation by any other agency or by the CBI. The grief of a father who has lost his son could be understood. The void created in his life due to the loss can never be filled. But ordering further investigation in this case appears to be exercising futility. The Writ Petition is dismissed. Sd/ASHOK MENON JUDGE jg WP(C) 19237/2019 28 ## **APPENDIX** ## **PETITIONER'S/S EXHIBITS:** **EXHIBIT P1 TRUE COPY OF FIR IN CRIME NUMBER 172/2011 REGISTERED BY THE SHO, ATHIRPPALLY POLICE STATION DATED 13.05.2011** **EXHIBIT P2 TRUE COPY OF F.I STATEMENT DATED 13.05.2011 GIVEN BY THE SAID AJI THOMAS** - **EXHIBIT P3 TRUE COPY OF ORDER DATED 01.07.2014 IN WP(C)NO.8872/2014(H) OF THIS HON'BLE COURT** **EXHIBIT P4 TRUE COPY OF JUDGMENT DATED 18.07.2014 IN WP(C)NO.8872/2014 OF THIS HON'BLE COURT** **EXHIBIT P5 TRUE COPY OF STATEMENT GIVEN BY THE PETITIONER DATED 17.09.2014** **EXHIBIT P6 TRUE COPY OF REPORT FILED BY THE 5TH RESPONDENT WITH MEMO DATED 18.07.2015 OF THE SENIOR GOVERNMENT PLEADER BEFORE THIS HON'BLE COURT** - **EXHIBIT P7 TRUE COPY OF ORDER DATED 13.08.2015 IN WP(C)8872/2014 OF THIS HON'BLE COURT** - **EXHIBIT P8 TRUE COPY OF JUDGMENT DATED 09.08.2017 IN WP(C)NO.22875/2015 OF THIS HON'BLE COURT.** **EXHIBIT P9 TRUE COPY OF ORDER NO.C1/17344/17 DATED 13.11.2017 OF THE DIRECTOR GENERAL OF POLICE, NORTH ZONE EXHIBIT P10 TRUE COPY OF SIGNED WRITTEN STATEMENT IN MALAYALAM SUBMITTED TO THE 6TH RESPONDENT BY THE PETITIONER EXHIBIT P11 TRUE COPY OF PETITION DATED 21.01.2019 ADDRESSED TO THE 5TH RESPONDENT, 2ND AND 4TH RESPONDENT BY THE PETITIONER** WP(C) 19237/2019 29 **EXHIBIT P12 TRUE COPY OF THE LETTER NO.A13944/2019/NZ DATED 07.03.2019 FROM STATE PUBLIC INFORMATION OFFICE, OFFICE OF THE 5TH RESPONDENT** - **EXHIBIT P13 TRUE COPY OF NOTICE NO.2/RC/DCB-RC/2019 DATED 23.3.2019 FROM THE 6TH RESPONDENT** - **EXHIBIT P14 TRUE COPY OF ACKNOWLEDGMENT B-4-6167/19 DATED 30.03.2019 RECEIVED FROM THE OFFICE OF THE 7TH RESPONDENT** - **EXHIBIT P15 TRUE COPY OF REPRESENTATION DATED 13.04.2019 SUBMITTED BEFORE THE HON'BLE CHIEF MINISTER OF KERALA BY THE PETITIONER** - **EXHIBIT P16 TRUE COPY OF PETITION DATED 25.04.2019 BEFORE THE 4TH RESPONDENT** - **EXHIBIT P17 TRUE COPY OF COMMUNICATION NO.B29619/2019/NZ DATED 2.05.2019 FROM THE 5TH RESPONDENT** - **EXHIBIT P18 TRUE COPY OF POST MORTEM CERTIFICATE DATED 14/05/2011 OF GOVT. HOSPITAL CHALAKUDY.** - **EXHIBIT P19 TRUE COPY OF ORDER NO. 18969/J2/2013/HOME DATED 05/05/2014.** - **EXHIBIT P20 LETTER DATED 6.11.2019 OF THE DEPUTY SUPERINTENDENT OF POLICE, CHALAKUDY** - **EXHIBIT P21 POSTAL COVER CONTAINING LETTER DATED 6.11.2019 OF DYSP CHALAKUDY**