K. Pramod; K.B. Vijayakrishnan; M. Niaz Ahmed v. State of Kerala, Kerala Sports Council, Board of Control for Cricket in India, Kerala Cricket Association and District Cricket Associations (WP(C) Nos.13968/2011 & 5828/2012)

**W.P.(C) Nos.13968/2011 & 5828/2012** **-1-** ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE THE CHIEF JUSTICE MR.S.V.N.BHATTI** **&** **THE HONOURABLE MR.JUSTICE BASANT BALAJI THURSDAY, THE 8[TH] DAY OF JUNE 2023 / 18TH JYAISHTA, 1945** ## **WP(C) NO. 5828 OF 2012** ## **PETITIONER/S:** - 1 K.B.VIJAYAKRISHNAN AGED 50 YEARS S/O.V.M. BALACHANDRAN, 1/4612, 'NARAYANEEYAM', BILATHIKULAM, ERANHIPALAM P.O., CALICUT-673006. 2 M.NIAZ AHMED AGED 50 YEARS S/O.K.M.DAWOOD, SAJ MAHAL, T.K.M.COLLEGE P.O., KOLLAM691005. BY ADVS. SRI.C.UNNIKRISHNAN (KOLLAM) SRI.G.GANGADETHAN SREEJITH.S.NAIR SRI.S.HARIKRISHNAN SRI.D.JAYAKRISHNAN SRI.NIDHI BALACHANDRAN SRI.M.R.RAJENDRAN NAIR SR. SRI.V.VENUGOPALAN NAIR ## **RESPONDENT/S:** - 1 KERALA CRICKET ASSOCIATION REPRESENTED BY ITS HON. SECRETARY, AMARJYOTI APARTMENTS, IIIRD FLOOR, WOMENS COLLEGE ROAD, VAZHUTHACAUD, THYCAUD P.O., THIRUVANANTHAPURM-695014. - 2 MR.T.C.MATHEW HON.SECRETARY, AMARJYOTI APARTMENTS, IIIRD FLOOR, WOMENS COLLEGE ROAD, VAZHUTHACAUD, THYCAUD P.O., **W.P.(C) Nos.13968/2011 & 5828/2012** **-2-** ## THIRUVANANTHAPURM-695014. - 3 STATE OF KERALA REPRESENTED BY ITS CHIEF SECRETARY, SECRETARIAT, THIRUVANANTHAPURAM. - 4 THE SECRETARY TO THE GOVERNMENT OF KERALA DEPARTMENT OF SPORTS & YOUTH AFFAIRS, SECRETARIAT, THIRUVANANTHAPURAM. - 5 THE ADDL. CHIEF SECRETARY HOME GOVERNMENT OF KERALA, DEPARTMENT OF HOME, SECRETARIAT, THIRUVANANTHAPURAM. - 6 THE DIRECTOR GENERAL OF POLICE KERALA, POLICE HEAD QUARTERS, THIRUVANANTHAPURAM. - 7 THE DIRECTOR VIGILANCE AND ANTI CORRUPTION BUREAU, THIRUVANANTHAPURAM. - 8 THE CENTRAL BUREAU OF INVESTIGATION THIRUVANANTHAPURAM, REPRESENTED BY ITS SUPERINTENDENT OF POLICE. - 9 THE JOINT DIRECTOR DIRECTORATE OF ENFORCEMENT, GOVERNMENT OF INDIA, THARAKKANDAM CENTRE, BANERJI ROAD, ERNAKULAM. - 10 THE SECRETARY KERALA STATE SPORTS COUNCIL, THIRUVANANTHAPURAM. - 11 V.R.BIJU S/O.RAJAPPAN NAIR, AGED 42, VALIYAVEETTIL HOUSE, KOLANI.P.O., THODUPUZHA, PIN -685 608. IS IMPLEADED AS ADDITIONAL RESPONDENT NO.11 VIDE ORDER DATED 21/08/2014 IN IA.3977/2014. BY ADVS. SRI T K VIPINDAS SR GP; SRI K N ABHILASH SC KERALA CRICKET ASSOCIATON SMT.LATHA KRISHNAN, SC, KERALA STATE SPORTS COUNCIL SMT.LIJITTA G.MATHEW **W.P.(C) Nos.13968/2011 & 5828/2012** **-3-** SMT.P.K.RADHIKA SRI.S.SREEKUMAR SR. SRI.S.GOPAKUMAR SRI.P.MARTIN JOSE SRI.NIDHI SAM JOHNS SRI.P.PRIJITH SRI.G.SHRIKUMAR SR. SRI.SREEJITH S.NAIR SRI.R.SANJITH SREEJITH.S.NAIR THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 08.06.2023, ALONG WITH WP(C).13968/2011, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: **W.P.(C) Nos.13968/2011 & 5828/2012** **-4-** ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE THE CHIEF JUSTICE MR.S.V.N.BHATTI** ## **&** **THE HONOURABLE MR.JUSTICE BASANT BALAJI THURSDAY, THE 8[TH] DAY OF JUNE 2023 / 18TH JYAISHTA, 1945** ## **WP(C) NO. 13968 OF 2011** ## **PETITIONER/S:** ADVOCATE K.PRAMOD S/O.ADVOCATE.K.CHANDRASEKHARAN,FANTASY NAGAR, VADOOKKARA,THRISSUR. BY ADV SRI.RAJIT ## **RESPONDENT/S:** - 1 STATE OF KERALA SECRETARY,MINISTRY OF SPORTS,SECRETARIAT,, THIRUVANANTHAPURAM. - 2 KERALA SPORTS COUNCILBEHIND OLD SECRETARIAT,THIRUVANANTHAPURAM,REPRESENTED BY, SECRETARY. - 3 BOARD OF CRICKET CONTROL FOR INDIA "CRICKET CENTRE",WANKHEDE STADIUM,'D' ROAD,, CHURCHGATE,MUMBAI-400 020,REPRESENTED BY THE, SECRETARY. - 4 KERALA CRICKET ASSOCIATIONKCA COMPLEX SASTHAMKOVIL ROAD,THYCAUD.P.O,THIRUVANANTHAPURAM. - 5 T.C.MATHEWSECRETARYKERALA CRICKET ASSOCIATION,KCA COMPLEX,SASTHAMKOVIL ROAD,, THYCAUD.P.O,THIRUVANANTHAPURAM. **W.P.(C) Nos.13968/2011 & 5828/2012** **-5-** - 6 THIRUVANANTHAPURAM DISTRICT CRICKET ASSOCIATION,NEAR SHASTHAN KOVIL,THYCAUD.P.O,, THIRUVANANTHAPURAM,REPRESENTED BY THE SECRETARY. - 7 KOLLAM DISTRICT CRICKET ASSOCIATION THAZHATHOTTATHU BUNGALOW,K.S.PURAM(P.O),, KARUNAGAPPALLY,KOLLAM,REPRESENTED BY THE, SECRETARY. - 8 PATHANAMTHITTA DISTRICT CRICKET ASSOCIATION,POTHERICAN TRAVELS,POTHERICAN, BUILDINGS,NEAR KSRTC BUS STAND,THIRUVALLA,, REPRESENTED BY THE SECRETARY. - 9 ALAPPUZHA DISTRICT CRICKET ASSOCIATION CHANDRAMANGALAM,PAZHAVEEDU.P.O,ALAPPUZHA-9,, REPRESENTED BY THE SECRETARY. - 10 KOTTAYAM DISTRICT CRICKET ASSOCIATION NAGAMPADOM SPORTS COMPLEX,KOTTAYAM,, REPRESENTED BY THE SECRETARY. - 11 IDUKKI DISTRICT CRICKET ASSOCIATION MADATHIL PARAMBIL,RIVER VIEW ROAD,THODUPUZHA-, 686654,REPRESENTED BY THE SECRETARY. - 12 ERNAKULAM DISTRICT CRICKERT ASSOCIATION 43/712,POWER HOUSE EXTENSION ROAD,COCHIN-682018,, REPRESENTED BY THE SECRETARY. - 13 THRISSUR DISTRICT CRICKET ASSOCIATION AQUATIC COMPLEX,KARUNAKARAN NAMBIAR ROAD,, THRISSUR,REPRESENTED BY THE SECRETARY. - 14 PALAKKAD DISTRICT CRICKET ASSOCIATON FORT MAIDAN,OPP.MUNICIPAL OFFICE,PALAKKAD-1,, REPRESENTED BY THE SECRETARY. - 15 MALAPPURAM DISTRICT CRICKERT ASSOCIATION JAIGOVIND HOUSE,VALLUVANGAD SOUTH,PANDIKKAD(VIA),, MALAPPURAM,REPRESENTED BY THE SECRETARY. - 16 KOZHIKODE DISTRICT CRICKET ASSOCIATION CHANDER VILLES,NEAR BEM U P SCHOOL,PUTHIYANGADI, **W.P.(C) Nos.13968/2011 & 5828/2012** **-6-** ROAD,CALICUT-673004,REPRESENTED BY THE SECRETARY. - 17 WAYAND DISTRICT ASSOCIATONLAKSHMI BUSINESS CORPORATION,SULTHAN BATHERY-673592,, REPRESENTED BY THE SECRETARY. - 18 CANNANORE DISTRICT CRICKET ASSOCIATION 'BENGLA',NEAR MUNICIPAL STADIUM THALASSERY,, KANNUR,REPRESENTED BY THE SECRETARY. - 19 KASARAGOD DISTRICT CRICKET ASSOCIATON THALANGARA SHOPPING CENTRE,OLD PRESS CLUB, JUNCTION,CHANDRAGIRI ROAD,KASARAGOD-671121,, REPRESENTED BY THE SECRETARY. - 20 ANILKUMAR, S/O KRISHNANKUTTY,AGED 43 YEARS,SECRETARY GOLDEN WHEEL CRICKET CLUB, MEDICAL COLLEGE P.O, TRIVANDRUM-1. IS IMPLEADED AS ADDITIONAL RESPONDENT NO.20 VIDE ORDER DATED 02/08/2011 IN IA.12383/2011. BY ADVS. SRI T K VIPINDAS SR GP; SRI K N ABHILASH SC KERALA CRICKET ASSOCIATON SRI.R.SANJITH SMT.LATHA KRISHNAN, SC, KERALA STATE SPORTS COUNCIL SMT.P.K.RADHIKA SRI.G.SHRIKUMAR (SR.) SRI.A.V.THOMAS (SR.) SRI.N.RAGHURAJ SRI.C.N.SREEKUMAR SRI.P.B.KRISHNAN SRI.V.JAYAKUMAR SRI.K.RAMAKUMAR (SR.) SRI.P.K.SURESH KUMAR (SR.) SRI.C.UNNIKRISHNAN (KOLLAM) SRI.T.RAMPRASAD UNNI SMT.N.P.ASHA SMT.K.AMMINIKUTTY SMT.GEETHA P.MENON S.SHANAVAS KHAN SRI.K.P.SUDHEER SMT.SMITHA GEORGE SRI.PIRAPPANCODE.V.S.SUDHEER **W.P.(C) Nos.13968/2011 & 5828/2012** **-7-** SRI.T.R.HARIKUMAR SRI.NIDHI SAM JOHNS SMT.PREETHY KARUNAKARAN SRI.K.RAVI PARIYARATH SRI.K.V.SOHAN SRI.G.SREEKUMAR CHELUR SRI.S.SHANAVAS KHAN THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 08.06.2023, ALONG WITH WP(C).5828/2012, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: **W.P.(C) Nos.13968/2011 & 5828/2012** **-8-** ## J U D G M E N T [WP(C) Nos.5828/2012, 13968/2011] ## S V N Bhatti, C.J. Heard Adv Rajit for the petitioner, Mr T K Vipindas, Senior Government Pleader, and Mr K N Abhilash, Standing Counsel for the Kerala Cricket Association. W.P.(C) No.13968/2011 2. On 25.04.2011, Adv. K Pramod, a resident of Thrissur, filed the present writ petition in the public interest, complaining of several acts of commissions and omissions by the Kerala Cricket Association/ 4th respondent and the Associate Members of the State Body. The prayers read as follows: “a) Call for the records leading upto Ext-P12 and Issue a Writ of Certiorari or any other appropriate writ order or direction quashing Ext-P9 amendment brought out by the 4th respondent association. b) Issue a Writ of Mandamus or any other appropriate writ order or direction commanding the 4th respondent to direct the respondents 6 to 19 District Associations to conduct elections by ensuring that the office bearers of the District Association do not have double vote. **W.P.(C) Nos.13968/2011 & 5828/2012** **-9-** c) Issue a Writ of Mandamus or any other appropriate writ order or direction commanding the 4th respondent to direct the respondents 6 to 19 District Associations to entertain all applications for registration and grant or reject membership within a period of 30 days from date of receipt of the application. d) Issue a Writ of Mandamus or any other appropriate writ order or direction commanding the 3rd respondent to immediately look into the affairs and complaints as mentioned in Ext-P11regarding the functioning of the 4th respondent association and to take remedial steps in the matter. e) Issue a Writ of Mandamus or any other appropriate writ order or direction commanding the 4th respondent to immediately publish the Bylaw of the Kerala Cricket Association and the uniform By-law for the District Associations, which will have to be followed by the respondents 6 to 19 in a transparent manner. f) Issue a Writ of Mandamus or any other appropriate writ order or direction commanding the 4th respondent to ensure that all league matches in respondents 6 to 19 District Associations are conducted in the respective cricketing years. g) Issue a Writ of Mandamus or any other appropriate writ order or direction commanding the 2nd respondent to immediately look into the affairs and complaints as mentioned in Ext-P10 regarding the functioning of the 4th respondent association and to take remedial steps in the matter. h) Grant such other relief deemed fit to this Hon'ble court.” 3. The Supreme Court in _Board of Control for Cricket in_ _India v. Cricket Association of Bihar_ - 2018 (9) SCC 624 has issued several directions resulting in the constitution of Committees, **W.P.(C) Nos.13968/2011 & 5828/2012** **-10-** preparation of bylaws, mechanism for redressal, introducing and improving transparency in the affairs of the Cricket Boards like the 4[th] respondent and its constituents. 4. Adv Rajit appearing for the petitioner, informs the Court that the first two prayers, by virtue of the judgment of the Supreme Court in the _Board of Control for Cricket in India_ (supra), are substantially worked out. As regards the other prayers, Mr Rajith has argued that the three prayers are examined in the background of definite averments made in the petition, and a case is made out warranting suitable directions from this Court. He prays for firstly issuing directions on the residual prayers, and this Court continues to monitor the performance by the 4[th] respondent and its members. 5. Mr Abhilash, learned Standing Counsel for the 4[th] respondent, argues that with the comprehensive structure, both matter and men, put in place by the Supreme Court, the **W.P.(C) Nos.13968/2011 & 5828/2012** **-11-** petitioner is well advised to first avail the remedy in accordance with the principles laid down by the Supreme Court. Elaborated, the petitioner files a complaint before the Ombudsman through the 4[th] respondent. The writ petition at this stage ought not to be examined on merits. He argues that this Court need not consider the writ prayer. 6. By way of reply, Adv Rajith contends that routing a complaint and allowing a complaint to be vetted by the 4th respondent would be a misnomer to the very object an aggrieved party desires to have a remedy against the administration of the 4[th] respondent. If the petitioner is not allowed to proceed with the writ petition, the options available to the petitioner to move before the Ombudsman shall not be restricted or regulated as has been suggested by Adv Abhilash. 7. The above narrative leads to an admitted position, namely that the circumstances and the backdrop in which the **W.P.(C) Nos.13968/2011 & 5828/2012** **-12-** jurisdiction of this Court was invoked do not prevail as on date in view of the judgment of the Supreme Court in the _Board of Control for Cricket in India_ (supra). It is also admitted that the 4th respondent has an Ombudsman to look into the grievances brought to his notice about the affairs or the administration, commissions or omissions of the 4[th] respondent Association or in its activities. Therefore, the petitioner ought to be given the liberty to vindicate and contest all the alleged commissions and omissions the petitioner pursues against the 4[th] respondent by moving the Ombudsman of the 4[th] respondent Association. With the above observation and granting liberty, the writ petition stands disposed of. W.P.(C) No.5828/2012 8. The prayer reads as follows: “I. Issue a writ of mandamus or other appropriate order or direction commanding the respondents 3 to 7 to entrust all the investigations as evidenced by Exts. P5, P6 (Crime No. 769/2011 Thodupuzha Police Station), P40, P41, P43, P44, P48 and Ext. P49 to a specially constituted team of CBI. **W.P.(C) Nos.13968/2011 & 5828/2012** **-13-** II Issue a writ of mandamus order or directions commanding the 4th respondent to constitutes a fresh managing committee of KCA through election on the basis of original bye-law Ext. P15 and also the managing committee of all DCAs after eliminating all fake and paper clubs inducted during the tenure of the present managing committee headed by the 2nd respondent. III Declare that the office bearers of the present managing committee of KCA has no right to contest in the elections of KCA till all the investigations against the KCA are completed by the investigating agency. IV Declare that the existing managing committee of KCA has no right to continue in the management of KCA till the existing allegations and criminal cases are completed and therefore they are liable to vacate the office forthwith. V Issue a writ of mandamus or other appropriate order or direction commanding the investigating officer to handover the ceased documents and materials to 9 respondent also for investigation.” 9. We are of the view that the petitioner, in view of the changed circumstances, is of the view that the allegations on which the broader investigation was desired from this Court are continuing to occasion in the functioning of the 4[th] respondent Association would move the Ombudsman. We have no reason to doubt that the Ombudsman of the 4[th] respondent will look into such allegations and proceed as **W.P.(C) Nos.13968/2011 & 5828/2012** **-14-** per the extant procedure on the complaints received against the 4[th] respondent. The writ petitions are disposed of as indicated above. **Sd/-** **S.V.N.BHATTI CHIEF JUSTICE** Sd/- **BASANT BALAJI** **JUDGE** jjj **W.P.(C) Nos.13968/2011 & 5828/2012** **-15-** ## **APPENDIX OF WP(C) 13968/2011** PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE MEMORANDUM OF ASSOCIATION AND ARTICLE OF ASSOCIATION REGISTERED BY THE KERALA CRICKET ASSOCIATION. Exhibit P2 TRUE COPY OF THE LETTER SEND BY THE 5TH RESPONDENT DATED 24/06/2006. - Exhibit P3 TRUE COPY OF THE BYE-LAWS OF THE THRISSUR DISTRICT CRICKET ASSOCIATION. - Exhibit P4 TRUE COPY OF THE BYE-LAWS OF THE KOZHIKODE DISTRICT CRICKET ASSOCIATION. - Exhibit P5 TRUE COPY OF THE ORIGINAL BYE-LAW OF THE IDUKKI DISTRICT ASSOCIATION. - Exhibit P6 TRUE COPY OF THE BYE-LAW OF THE IDUKKI DISTRICT ASSOCIATION. - Exhibit P7 TRUE COPY OF THE LETTER DATED 26/08/2006 ISSUED BY THE SECRETARY OF THE 4TH RESPONDENT ASSOCIATION. - Exhibit P8 TRUE COPY OF THE REPORT FILED BY THE OBSERVERS OF THE KERALA CRICKET ASSOCIATION. - Exhibit P9 TRUE COPY OF THE AMENDMENT BROUGHT OUT BY THE 5TH RESPONDENT. - Exhibit P10 TRUE COPY OF THE LAWYER NOTICE DATED 18/11/2010 CAUSED TO BE ISSUED BY THE PETITIONER TO THE 2ND RESPONDENT. - Exhibit P11 TRUE COPY OF THE LAWYER NOTICE DATED 18/11/2010 CAUSED TO BE ISSUED BY THE PETITIONER TO THE 3RD RESPONDENT. **W.P.(C) Nos.13968/2011 & 5828/2012** **-16-** - Exhibit P12 TRUE COPY OF THE LETTER SENT BY THE 2ND RESPONDENT DATED 02/02/2011. - RESPONDENT EXHIBITS - Exhibit R4(a) TRUE COPY OF ORDER DATED 21/05/2008 IN IA NO.1929/2008 IN OP(ARBITRATION) NO.128/2008 OF THE DISTRICT COURT, THRISSUR. - Exhibit R4(b) TRUE COPY OF JUDGMENT DATED 08/07/2009 IN WPC NO.16984/2009 OF HIGH COURT OF KERALA. - Exhibit R4(c) TRUE COPY OF ORDER DATED 10/07/2009 IN IA NO.8449/2009 IN WPC NO.16984/2009 OF HIGH COURT OF KERALA. - Exhibit R4(d) TRUE COPY OF ORDER DATED 28/07/2009 IN ARB.O.P. NO.177/2008 PASSED BY THE DISTRICT COURT, THRISSUR. - Exhibit R4(e) TRUE COPY OF THE JUDGMENT DATED 29/06/2009 IN WPC NO.17867/2009 OF HIGH COURT OF KERALA. - Exhibit R4(f) TRUE COPY OF JUDGMENT DATED 11/03/2011 IN WPC NO.32410/2009 OF HIGH COURT OF KERALA. - Exhibit R4(g) TRUE COPY OF REPORT DATED 18/4/2011 SUBMITTED BY SRI.V.P. SRIKUMAR AND SRI.A. SIVAKUMAR, STATE UMPIRES. - Exhibit R4(h) ENGLISH TRANSLATION OF REPORT DATED 18/04/2011 SUBMITTED BY SRI.V.P. SRIKUMAR AND SRI.A. SIVAKUMAR, STATE UMPIRES. - Exhibit R4(i) TRUE COPY OF REPORT DATED 18/04/2011 SUBMITTED BY VICE-PRESIDENT OF KCA SRI.SYED ZIABUDEEN. - Exhibit R4(j) TRUE COPY OF JUDGMENT DATED 14/06/2011 IN CON.CASE (C) NO.444/2011 OF HIGH COURT OF KERALA. - Exhibit R4(k) TRUE COPY OF BYE-LAWS OF THE 4TH RESPONDENT TOGETHER WITH OF THE COMMON BYE-LAWS OF **W.P.(C) Nos.13968/2011 & 5828/2012** **-17-** ## DISTRICT ASSOCIATION. Exhibit R4(l) TRUE COPY OF THE APPROVAL DATED 10/11/2009 GRANTED BY COMMISSIONER OF INCOME TAX, TRIVANDRUM. Exhibit R4(m) TRUE COPY OF THE APPROVAL DATED 18/02/2010 GRANTED BY COMMISSIONER OF INCOME TAX, TRIVANDRUM. Exhibit R4(n) TRUE COPY OF THE STATEMENT DATED 31/07/2008 FILED BY THE KERALA SPORTS COUNCIL IN WPC NO.19994/2008 IN THE HIGH COURT OF KERALA. Exhibit R4(o) TRUE COPY OF THE JUDGMENT DATED 25/05/2011 IN WPC NO.13848/2011 OF THE HIGH COURT OF KERALA. **W.P.(C) Nos.13968/2011 & 5828/2012** **-18-** ## **APPENDIX OF WP(C) 5828/2012** PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LETTER DATED 20/02/2008 ISSUED BY THE PRESIDENT OF KCA TO THE SECRETRIES OF ALL DCAS. - Exhibit P2 TRUE COPY OF THE FORM 'E' FILED BEFORE THE IDUKKI DISTRICT SPORTS COUNCIL ON 31/07/2008 BY IDUKKI DCA. - Exhibit P3 TRUE COPY OF THE JUDGMENT OF THIS HONOURABLE COURT IN WPC NO.20851/2008 DATED 10/07/2008. - Exhibit P4 TRUE COPY OF THE JUDGMENT OF THIS HONOURABLE COURT IN AND RP NO.877/2008 DATED 19/08/2008. - Exhibit P5 TRUE COPY OF THE CRIMINAL COMPLAINT FILED BEFORE CJM COURT, THODUPUZHA BY MR.P.K. JACOB ON 31/05/2011 AND ENGLISH TRANSLATION. - Exhibit P6 TRUE COPY OF THE FIR IN CRIME NO.769/2011 REGISTERED BY THODUPUZHA POLICE. - Exhibit P7 TRUE COPY OF THE CMP NO.6974/2011 DATED 27/10/2011 SUBMITTED BY THE PETITIONER BEFORE THE CJM COURT, THODUPUZHA IN CRIME NO.769/2011 FOR PROPER INVESTIGATION. - Exhibit P8 TRUE COPY OF THE REPORT DATED 23/11/2011 FILED BY THE S.I. OF POLICE, THODUPUZHA IN CRIME NO.769/2011. Exhibit P9 TRUE COPIES OF THE STATEMENTS OF SECRETARIES OF CLUB NOS.20, 21, 24 & 25 IN EXHIBIT P2 RECORDED BY MR.K.V. JOSEPH, VIGILANCE DY. SP., IDUKKI UNIT IN QV 3/08/IDK PURSUANT TO AN ORDER DATED 10/11/2008 IN CMP NO.1983/2008 OF VIGILANCE COURT, THRISSUR, FILED K.K. ABBAS & ROOPESH KUMAR AND ITS ENGLISH TRANSLATION. **W.P.(C) Nos.13968/2011 & 5828/2012** **-19-** - Exhibit P10 - TRUE COPY OF THE NOTICE DATED 29/03/2008 OF THE CENTRAL COUNCIL MEETING OF KCA & SPECIAL GENERAL BODY OF KCA. - Exhibit P11 TRUE COPY OF THE MINUTES OF THE CENTRAL COUNCIL MEETING OF KCA & SPECIAL GENERAL BODY OF KCA DATED 06/04/2008. - Exhibit P12 TRUE COPY OF THE AWARD DATED 05/09/2011 ISSUED BY THE TRIBUNAL. - Exhibit P13 TRUE COPY OF THE COMPLAIN IN C.C. NO.60/2008 ON THE FILE OF JFMC-III, TVM. - Exhibit P14 TRUE COPY OF THE RELEVANT PAGES OF ANNUAL REPORTS OF KCA FOR 3 YEARS (2003-04, 2004-05 & 2005-06). - Exhibit P15 TRUE COPY OF THE ORIGINAL BYE LAW OF KCA. - Exhibit P16 TRUE COPY OF THE NOTICE DATED 08/04/2009 OF SPECIAL GENERAL BODY FOR AMENDMENT OF BYE LAW ALONG WITH A MASSIVE AMENDMENT PROPOSAL. - Exhibit P17 TRUE COPY OF THE ILLEGALLY AMENDED BYE LAW OF KCA. - Exhibit P18 TRUE COPY OF THE NOTICE DATED 07/06/2009 OF THE ANNUAL GENERAL BODY ON 27/06/2009 FOR ELECTION IN KCA. - Exhibit P19 TRUE COPY OF THE APPLICATION DATED 21/03/2011 UNDER RTI ACT SUBMITTED BY THE 2ND PETITIONER BEFORE THE COMMISSIONER OF I.T. - Exhibit P20 TRUE COPY OF THE REPLY DATED 19/04/2011 FURNISHED BY THE COMMISSIONER OF I.T. - Exhibit P21 TRUE COPY OF THE REPORT DATED 27/07/2007 BY VARMA & VARMA, INTERNAL AUDITORS OF KCA. **W.P.(C) Nos.13968/2011 & 5828/2012** **-20-** - Exhibit P22 TRUE COPY OF THE INTERNAL AUDIT REPORT DATED 20/06/2007 OF KCA CONDUCTED BY KCA OFFICE BEARERS. - Exhibit P23 TRUE COPY OF THE BYE LAW PRODUCED IN OS NO.1/2008 BEFORE THE DISTRICT COURT, THODUPUZHA BY THE RESPONDENTS 1 & 2. - Exhibit P24 TRUE COPY OF THE YET ANOTHER DIFFERENT BYE LAW PRODUCED IN OS NO.1/2008 BEFORE THE DISTRICT COURT, THODUPUZHA BY THE RESPONDENTS 1 & 2 WITHIN A SPAN OF 1 MONTH. - Exhibit P25 TRUE COPY OF THE ENTIRELY DIFFERENT BYE LAW PRODUCED BY THE RESPONDENTS 1 & 2 BEFORE THIS HONOURABLE COURT IN WPC 1099/2010. - Exhibit P26 TRUE COPY OF THE ANOTHER BYE LAW AS AMENDED UP TO DECEMBER 2009 CIRCULATED IN THE TRIVANDRUM DCA ELECTIONS IN JULY 2011. - Exhibit P27 TRUE COPY ADVERTISEMENT APPEARED IN MATHRUBHOOMI DAILY DATED 26/10/2008 REGARDING CONSTRUCTION OF INTERNATIONAL STADIUM. - Exhibit P28 TRUE COPY OF THE LETTER DATED 03/03/2009 SUBMITTED BY I.V.C. TO T.C. MATHEW SHOWING THEIR EXPRESSION OF INTEREST IN ASSOCIATING WITH KCA FOR THE STADIUM PROJECT. - Exhibit P29 TRUE COPY OF THE MINUTES OF THE SPECIAL GENERAL BODY MEETING DATED 15/03/2009 OF KCA DECIDING TO BUY THE LAND THROUGH I.V.C. IGNORING ALL THE CONCERNS AND OBJECTIONS RAISED BY THE MEMBERS. - Exhibit P30 TRUE COPY OF THE MOU 22/03/2009 BETWEEN KCA AND I.V.C. FOR THE STADIUM PROJECT. - Exhibit P31 TRUE COPY OF THE MOU DATED 09/03/2009 BETWEEN IVC & LAND OWNERS. **W.P.(C) Nos.13968/2011 & 5828/2012** **-21-** |Exhibit P32|SERIES|TRUE COPIES OF 6 NOS. OF AGREEMENTS FOR SALE OF| |---|---|---| |||LAND DATED 06/04/2009 BETWEEN KCA SECRETARY| |||T.C. MATHEW AND LAND OWNERS.| |Exhibit P33||TRUE COPY OF THE O.R. NO.28/2010 DATED 17/09/2010| |||REGISTERED BY FOREST DEPARTMENT, KERALA| |||AGAINST THE PROPERTY FOR DESTRUCTION OF| |||MANGROVES U/S. 6(5) & 7(1) OF THE PROMOTION OF| |||TREE GROWTH IN NON-FOREST AREA (AMENDMENT)| |||ACT 2007.| |Exhibit P34||TRUE COPY OF THE LETTER DATED 06/10/2010 OF| |||GOVERNMENT OF KERALA REJECTING THE PERMISSION| |||FOR CONSTRUCTION OF STADIUM AS DECIDED BY| |||STATE LEVEL COMMITTEE UNDER KERALA| |||CONSERVATION OF PADDY LAND AND WET LAND ACT| |||2008.| |Exhibit P35||TRUE COPY OF THE LETTER DATED 04/12/2009 ISSUED| |||BY JOSEPH VARGHESE, CEO OF I.V.C. TO T.C. MATHEW| |||ADVISING NOT TO PAY THE BALANCE MONEY OF| |||LAND.| |Exhibit P36||TRUE COPY OF THE REPORT DATED 25/11/2010 OF| |||DR.S.K. SUSARLA.| |Exhibit P37||TRUE COPY OF THE MINUTES OF THE ANNUAL| |||GENERAL MEETING OF THE KCA HELD ON 25/07/2010| |||CONTAINING AGENDA NO.9 APPOINTING M/S.| |||HOPKINS ARCHITECTS AT THE RATE OF 5.5% OF THE| |||GROSS STADIUM PROJECT OF RS.300 CRORES, WHICH| |||COMES TO RS.15.15 CRORES.| |Exhibit P38||TRUE COPY OF THE BALANCE SHEET OF KCA AS AT| |||31/03/2011 SHOWING RS.85,94,388/- AS CAPITAL| |||WORK IN PROGRESS OF EDAKOCHI STADIUM.| |Exhibit P39||TRUE COPY OF PARA 17 OF THE NOTES OF ACCOUNTS| |||IN THE ANNUAL REPORT OF KCA 2010-2011 SHOWING| |||RS.85,94,388/- WAS GIVEN AS CONSULTANCY/OTHER| |||EXPENSES TO M/S.HOPKINS ARCHITECTS.| **W.P.(C) Nos.13968/2011 & 5828/2012** **-22-** - Exhibit P40 TRUE COPY OF THE COMPLAINT DATED 13/06/2011 IN CMP NO.792/2011 FILED BY MR.JOY KAITHARATH, GENERAL SECRETARY, STATE HUMAN RIGHTS PROTECTION CENTRE, THRISSUR BEFORE THE COURT OF ENQUIRY COMMISSIONER AND SPECIAL JUDGE, THRISSUR AND ITS ENGLISH TRANSLATION. - Exhibit P41 TRUE COPY OF THE ORDER DATED 07/07/2011 OF THE COURT OF ENQUIRY COMMISSIONER AND SPECIAL JUDGE, THRISSUR FORWARDING THE COMPLAINT TO DIRECTOR OF VIGILANCE AND ANTI CORRUPTION BUREAU, THIRUVANANTHAPURAM FOR PRELIMINARY ENQUIRY. - Exhibit P42 TRUE COPY OF THE ORDER FOR FLOODLIGHTING OF JNI STADIUM DATED 02/01/2011 SUBMITTED BY G.E. INDIA INDUSTRIAL PVT. LTD. TO SECRETARY, KCA. - Exhibit P43 TRUE COPY OF THE COMPLAINT DATED 16/02/2011 IN CMP NO.318/2011 ON THE FILE OF THE COURT OF ENQUIRY COMMISSIONER AND SPECIAL JUDGE, THRISSUR FILED BY MR.P.K. JACOB, THODUPUZHA, ONE OF THE FOUNDER MEMBER OF KCA. - Exhibit P44 TRUE COPY OF THE ORDER DATED 06/09/2011 IN CMP NO.318/2011 OF THE COURT OF ENQUIRY COMMISSIONER AND SPECIAL JUDGE, THRISSUR FORWARDING THE COMPLAINT TO DIRECTOR OF VIGILANCE AND ANTI CORRUPTION BUREAU, THIRUVANANTHAPURAM FOR PRELIMINARY ENQUIRY WITH A DIRECTION THAT IF MATERIALS ARE COLLECTED WARRANTING INVESTIGATION, A CASE SHALL BE REGISTERED AND F.I.R. TO BE FORWARDED TO THE COURT AND CONDUCT INVESTIGATION. - Exhibit P45 TRUE COPY OF THE STATEMENT DATED 28/10/2009 FILED BY THE INVESTIGATING OFFICER MR.C.S. MAJEED, DY. S.P. BEFORE THIS HONOURABLE COURT IN CRL.MC.2726/2009. - Exhibit P46 TRUE COPY OF THE ORDER DATED 26/10/2010 IN CRL.M.C. 2726/2009 OF THIS HONOURABLE COURT. **W.P.(C) Nos.13968/2011 & 5828/2012** **-23-** - Exhibit P47 TRUE COPY OF THE DISMISSAL ORDER DATED 31/01/2011 OF THE HONOURABLE SUPREME COURT IN SLP (CRL) NO.10107/2010 & SLP (CRL) NO.10641/2010. - Exhibit P48 TRUE COPY OF THE DETAILED ORDER DATED 06/09/2011 IN CMP 320/2011 (OLD CMP 2777/08) OF THE VIGILANCE COURT, THRISSUR. - Exhibit P49 TRUE COPY OF THE COMPLAINT DATED 04/10/2008 FILED BY KERALA CRICKETERS FORUM BEFORE THE THEN HONOURABLE HOME MINSTER, KERALA. Exhibit P50 TRUE COPY OF THE G.O.NO.235/09 DATED 22/12/12009 ISSUED BY THE GOVERNMENT OF KERALA REMITTING STAMP DUTY EXEMPTION FOR KCA. - Exhibit P51 TRUE COPY OF THE ORDER DATED 15/10/2010 IN V.E. 03/08/IDK OF THE ENQUIRY COMMISSIONER AND SPECIAL JUDGE, KOTTAYAM.