Kumari P. v. State of Kerala and others

**WP(C) NO. 25124 OF 2019** **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. 25124 OF 2019** **PETITIONER:** KUMARI P., AGED 69 YEARS W/O. LATE NARAYANA MENON, DEVI PARAMBIYATH HOUSE, PULASSERY P.O., KOPPAM, PATTAMBI, PALAKKAD DISTRICT. BY ADVS. C.M.MOHAMMED IQUABAL SMT.ANJALI G.KRISHNAN ## **RESPONDENT/S:** |1|STATE OF KERALA,| |---|---| ||REPRESENTED BY THE SECRETARY TO GOVERNMENT,| ||GENERAL EDUCATION DEPARTMENT, GOVERNMENT SECRETARIAT,| ||THIRUVANANTHAPURAM, PIN-695001.| |2|THE DIRECTOR OF PUBLIC INSTRUCTIONS,| ||OFFICE OF THE DIRECTOR OF PUBLIC INSTRUCTIONS,| ||THIRUVANANTHAPURAM, PIN-695014.| |3|THE DEPUTY DIRECTOR OF EDUCATION,| ||OFFICE OF THE DEPUTY DIRECTOR OF EDUCATION,| ||PALAKKAD, PIN-678001.| |4|THE DISTRICT EDUCATIONAL OFFICER,| ||OFFICE OF THE DISTRICT EDUCATIONAL OFFICE,| ||OTTAPALAM-679101.| |5|THE ASSISTANT EDUCATIONAL OFFICER,| ||OFFICE OF THE ASSISTANT EDUCATIONAL OFFICER, PATTAMBI,| ||PALAKKAD DISTRICT, PIN-679303.| |6|M.K. VISWANATHA MENON,| ||S/O. LATE K.K. NARAYANAN NAIR, MANU NIVAS,| ||MARAYAMANGALAM SOUTH, NELLAYA, PALAKKAD DISTRICT,| ||PIN-679335.| **WP(C) NO. 25124 OF 2019** **2** 7 SOUMINI M.K., D/O. LATE SANTHAKUMARI, MULLENGIL KIZHAKKEKARA HOUSE, PULASSERY P.O., PATTAMBI, PALAKKAD-679307. 8 M.K. SUNIL KUMAR, S/O. LATE SANTHAKUMARI, MULLENGIL KIZHAKKEKARA HOUSE, PULASSERY P.O., PATTAMBI, PALAKKAD-679307. 9 M.K. GANESH, S/O. LATE SANTHAKUMARI, MULLENGIL KIZHAKKEKARA HOUSE, PULASSERY P.O., PATTAMBI, PALAKKAD-679307. 10 SMT. M.K. KUNHILAKSHMI AMMA, D/O. LATE K.K. NARAYANAN NAIR, MULLENGIL KIZHAKKEKARA HOUSE, PULASSERY P.O., PATTAMBI, PALAKKAD-679307. 11 SRI. M.K. MOHANDAS, S/O. LATE JANAKI AMMA, “SOUBHAGYA”, MULLENGIL KIZHAKKEKARA HOUSE, PULASSERY P.O., PATTAMBI, PALAKKAD-679307. 12 SRI. M.K. DEVADAS, S/O. LATE JANAKI AMMA, “SOUBHAGYA”, MULLENGIL KIZHAKKEKARA HOUSE, PULASSERY P.O., PATTAMBI, PALAKKAD-679307. 13 SMT. M.K. GEETHA, D/O. LATE JANAKI AMMA, “SOUBHAGYA”, MULLENGIL KIZHAKKEKARA HOUSE, PULASSERY P.O., PATTAMBI, PALAKKAD-679307. 14 SMT. SATHYABHAMA V.K., W/O. LATE M.K. BALASUBRAMANIAN, “SOUBHAGYA”, MULLENGIL KIZHAKKEKARA HOUSE, PULASSERY P.O., PATTAMBI, PALAKKAD-679307. 15 SMT. SASIKALA V.K., D/O. LATE M.K. BALASUBRAMANIAN, “SOUBHAGYA”, MULLENGIL KIZHAKKEKARA HOUSE, PULASSERY P.O., PATTAMBI, PALAKKAD-679307. 16 SMT. BABY V.K., D/O. LATE M.K. BALASUBRAMANIAN, “SOUBHAGYA”, MULLENGIL KIZHAKKEKARA HOUSE, PULASSERY P.O., PATTAMBI, PALAKKAD-679307. **WP(C) NO. 25124 OF 2019** **3** 17 SMT. SUSHAMA V.K., W/O. LATE M.K. BALASUBRAMANIAN, “SOUBHAGYA”, MULLENGIL KIZHAKKEKARA HOUSE, PULASSERY P.O., PATTAMBI, PALAKKAD-679307. 18 SMT. N.K. VIJAYAKUMARI, W/O. LATE M.K. RADHAKRISHNAN, NEDUMBRAKKAD, KUNNATH, AMAYUR P.O., PATTAMBI, PALAKKAD-679303. 19 SRI. N.K. SURESH, S/O. LATE M.K. RADHAKRISHNAN, NEDUMBRAKKAD, KUNNATH, AMAYUR P.O., PATTAMBI, PALAKKAD-679303. 20 SRI. N.K. RAJESH, S/O. LATE M.K. RADHAKRISHNAN, NEDUMBRAKKAD, KUNNATH, AMAYUR P.O., PATTAMBI, PALAKKAD-679303. 21 SRI. N.K. JAYESH, S/O. LATE M.K. RADHAKRISHNAN, NEDUMBRAKKAD, KUNNATH, AMAYUR P.O., PATTAMBI, PALAKKAD-679303. 22 ANITHA P., D/O. LATE NARAYANA MENON, DEVI PARAMBIYATH HOUSE, PULASSERY P.O., KOPPAM, PATTAMBI, PALAKKAD-679307. 23 SHYLAJA P., D/O. LATE NARAYANA MENON, DEVI PARAMBIYATH HOUSE, PULASSERY P.O., KOPPAM, PATTAMBI, PALAKKAD-679307. 24 BINDU P., D/O. LATE NARAYANA MENON, DEVI PARAMBIYATH HOUSE, PULASSERY P.O., KOPPAM, PATTAMBI, PALAKKAD-679307. BY ADVS. SRI.ELVIN PETER P.J. SMT.N.S.SOUMYA MOL SRI.K.R.GANESH SMT. NISHA BOSE, SR. GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 23.09.2021, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: **WP(C) NO. 25124 OF 2019** **4** ## **JUDGMENT** By Exhibit P14 order, the 3rd respondent approved the bye-laws framed in respect of the Aided Lower Primary School (ALPS) Amayur North, an aided School established by a Late Narayanan Nair and by Exhibit P15 order, the 5th respondent approved the appointment of the 6th respondent, Sri.N.K.Viswanatha Menon, as the manager of the School in accordance with the bye-laws. The aforesaid orders are challenged in this Writ Petition filed under Article 226 of the Constitution of India. 2. The case of the petitioner as is borne out from the pleadings are as under: a) The ALP School, Amayur North is an aided school governed by the provisions contained in the Kerala Education Act and Rules. After the death of Narayanan Nair, his legal heirs relinquished their right over the management with the full understanding that Sri. Narayanan Menon was the owner of the school. He was accordingly appointed as the Manager. It is contended that the management continued as an Individual Educational Agency even thereafter. b) Sri. Narayanan Menon expired on 2.4.1993 as is evident from Ext.P2 death certificate and after his death, the management of the school devolved on the petitioner and her three children, who have been arrayed **WP(C) NO. 25124 OF 2019** **5** as respondents 22 to 24 and they constituted the Corporate Educational Agency. c) The respondents 22 to 24 decided to appoint the petitioner as the Manager of the school and the change of management was without change of ownership. The 5th respondent granted approval as per Ext.P3 order. d) While so, the 6th respondent raised a claim over the management contending that all the legal heirs of the founder had right over the school. e) Without the concurrence of the petitioner who was then managing the school, the 6th respondent prepared a bye-law and produced the same before the 3rd respondent for approval. The respondents 6 to 21 also produced Ext.P5 decision taken by them on 1.12.2017 wherein it is stated that the decision to frame bye-laws was with the concurrence of all the legal heirs except the petitioner and her daughters. The 5th respondent duly intimated the petitioner of the representations submitted by the 6th respondent and others, and sought her consent. Later, the 6th respondent approached this Court and filed a writ petition seeking directions to the respondents to consider their request. By Ext.P8 judgment, this court dismissed the Writ Petition. Later, one of the daughters of the founder approached this Court and filed a review petition which was allowed by Ext.P9 order and the writ petition was restored. Later, the said writ petition was dismissed as withdrawn. **WP(C) NO. 25124 OF 2019** **6** f) The petitioner contends that thereafter the 6th respondent prepared Ext.P11 constitution of ALPS, Amayur North and presented the same before the 5th respondent for approval. However, the consent of the petitioner was not obtained prior to submission of the same. g) Immediately thereafter, the 6th respondent approached this Court and filed a writ petition seeking directions to the 3rd respondent to consider the approval of the bye-law. However, the 3rd respondent rejected the request holding that there are irreconcilable disputes between the managing committee members as regards the constitution and that the bye-law produced was not attested by the entire members. h) The aforesaid order was challenged before this Court by filing W.P. (C) No.14502/2019 and by Ext.P13 judgment dated 16.7.2019, this Court directed reconsideration of the request made by the petitioner. i) Pursuant to directions so issued, the 3rd respondent heard the petitioner as well as the party respondents and issued Ext.P14 order approving the constitution and the rules. j) Consequent to the same, the 5th respondent passed Ext.P15 order appointing the 6th respondent as the Manager of the school. The aforesaid orders are under challenge in this writ petition. 3. The 6th respondent has filed a counter-affidavit. While admitting that the school was established and owned by late Sri. **WP(C) NO. 25124 OF 2019** **7** K.K.Narayanan Nair, it is submitted that on the death of the founder on 18.4.1976, the ownership of the school came to be vested with the legal heirs. Ext.R6(a) death certificate and Ext.R6(b) legal heirship declaration is relied on by the 6th respondent to bring home the point that the late founder was survived by his wife and six children. 4. It is stated that on the death of the founder, the individual agency became a corporate educational agency by operation of law. The legal heirs including the 6th respondent thereafter decided to nominate Narayana Menon, one of the sons of the founder, as the Manager. His appointment was approved by the AEO, Pattambi as per Ext.R6(c) order. Referring to Ext.R6(c), it is contended that even in the order approving Narayana Menon as the Manager, it has been stated that late Narayanan Nair was the Manager of the school and on his death, the properties and management of the school stands devolved on the legal heirs by way of inheritance. The name and details of the legal heirs have also been mentioned in the order. 5. According to the 6th respondent, the approval of the appointment of Narayana Menon was without transfer of ownership and without framing any bye-laws as laid down under Chapter III Rule 2 of the KER. While continuing as the Manager, Sri. Narayana Menon expired on 2.4.1993 as is evident from Ext.R6(d). On his death, the legal heirs of Sri. Narayana Menon and the co-owners including the 6th respondent decided **WP(C) NO. 25124 OF 2019** **8** to nominate the petitioner, wife of late Narayana Menon, as the Manager, of the school. On the basis of the request made by the co-owners, Ext.R6(e) order was passed approving the appointment of the petitioner as the Manager of the school. However, the appointment was without transfer of ownership. The fact however remained that even then, no rules were framed and approved by the Department for the management of the school. The 6th respondent would rely on Ext.R6(f) consent letter issued by the petitioner on 19.4.1993, the date on which she assume managership as per which she had undertaken that she would relinquish the office of managership as and when such request was made by the legal heirs of late Narayanan Nair. 6. It is further stated that even before the nomination of the petitioner as a Manager, the wife and two children of late Narayanan Nair had expired as is evident from Exts.R6(g) to (i). 7. While so, differences cropped up between the legal representatives of the founder who include the 6th respondent and the petitioner. The legal representatives were of the opinion that the functioning of the school was in a disarray. They convened a meeting on 1.12.2007 and expressed their dissatisfaction with the manner in which the school was being managed by the petitioner. The meeting was minuted and all the parties who took part in the meeting except the petitioner and her daughters affixed their signatures. According to the 6th respondent, on the **WP(C) NO. 25124 OF 2019** **9** death of the founder, as the school had become a corporate educational agency, it was mandatory to frame rules and get the same approved by the 3rd respondent. In the said circumstances, Ext.R6(m) bye-laws were prepared and the same was forwarded to the AEO, Pattambi, along with a consent letter issued by the entire staff seeking to approve the 6th respondent as the Manager. When no action was taken, the 6th respondent approached this Court and filed W.P.(C) No.13314/2018 and this Court by Ext.R6(q) judgment, took the view that the school continue to be an individual educational agency with the petitioner herein as the Manager and without the consent of the present Manager the request made by the 6th respondent cannot be entertained. Immediately thereafter, R.P.No.99/2019 was filed by M.K.Santhakumari, the sister of the 6th respondent and one of the legal heirs seeking to review the judgment. By Ext.R6(r) order, this Court taking note of the law laid down by this Court in **Somanatha Pillai v. State of Kerala** [2007 (1) KLT 127] and also noting the non-arraying of the other legal heirs allowed the review petition and the writ petition was restored back to file. Later, the said writ petition was dismissed as withdrawn. 8. Immediately thereafter, noting that there were some mistakes in Ext.R6(m) bye-laws, the legal representatives of late Narayanan Nair convened a meeting and framed a new set of bye-laws on 30.12.2018. The petitioner and her daughters did not participate. Ext.R6(t) is the bye-law so **WP(C) NO. 25124 OF 2019** **10** framed and it was later forwarded to the 3rd respondent. Pursuant to directions issued by this Court, the 3rd respondent considered the submissions of all the legal heirs and passed Ext.R6(v) order declining to approve the bye-laws for the management of the school on the ground that the petitioner and her daughters had not affixed their signatures in Ext.R6(t). This order was challenged by the 6th respondent in W.P.(C) No.14520/2019 and by Ext.R6(y) judgment, this Court directed the concerned authority to reconsider the matter and pass fresh orders. Pursuant to the directions so issued, the 3rd respondent issued Ext.P14 order approving the bye-laws submitted by the legal heirs. According to the 6th respondent, after the death of late K. Narayanan Nair, the management of the school has vested with all his legal heirs and has assumed the character of a Corporate educational agency. It is further contended that the assertion by the petitioner that the school continues as an individual educational agency cannot be sustained. 9. Sri. C.M.Mohammed Iqbal, the learned counsel appearing for the petitioner submitted that the husband of the petitioner has been managing the school since 1976 and after his death, the petitioner assumed the role of the Manager, with the consent of all the other legal heirs. It is contended that while approving the bye-laws, the 3rd respondent took the view that the petitioner had not produced any documents to prove a change of ownership. It is contended that it is for the respondents 6 to 21 to **WP(C) NO. 25124 OF 2019 11** produce documents to show that they have any right over the school. It is further contended that the petitioner has been managing the school as an Individual Educational Agency and it was after the death of Sri. M.K.Narayana Menon that the school became a Corporate Educational Agency with the petitioner and her daughters constituting the Corporate Educational Agency. It is further contended that the legal heirs of late Narayanan Nair had relinquished their right over the school and they cannot claim any right after several decades of relinquishment of whatever rights that they had over the school. 10. Sri. Elvin Peter, the learned counsel appearing for the 6th respondent submitted that there on the death of the founder, his rights not having devolved on a particular individual by way of testamentary dispossession or by way of any personal law and as the rights had devolved on more than one person, then the Educational Agency will transform itself into a Corporate Educational Agency. According to the learned counsel Ext. R6(c) order approving the managership of Narayana Menon would belie the contention of the petitioner that the property was owned by Narayana Menon exclusively as in the order itself it is stated that the property has devolved on the legal heirs of the founder by way of inheritance. The name and other details of the legal heirs have also been mentioned in the order. The learned counsel would also refer to Ext.R6 (e) order and R6(f) consent letter issued by the petitioner to hammer home his contention that the **WP(C) NO. 25124 OF 2019** **12** rights over the school did not exclusively vest in the petitioner or her children. 11. I have heard the learned Government Pleader and I have considered the submissions. 12. The first contention of the petitioner is that even on the death of the founder, the school was being run as an Individual Educational Agency with the husband of the petitioner as the Manager. Rule 1 of Chapter III of the KER states that Private Educational Institutions are classified into two categories as (a) those under individual Educational Agency and (b) those under Corporate Educational Agency. Where the right to conduct the school is vested in an individual in his own right or as the legal representative of a joint family, the Educational Agency shall be termed ‘Individual Educational Agency’, and in all other cases the Educational Agency shall be termed ‘Corporate Educational Agency’. It has been further clarified that “Corporate Educational Agency” shall include cases where the right is vested in (a) two or more persons jointly with written registered agreement (b) a Board or Society or Association or Company or institution registered under a statute or created by a statute (c) an institution of Trust and (d) an ecclesiastical office of any religious denomination. 13. In **Somanatha Pillai** (supra) while interpreting the relevant **WP(C) NO. 25124 OF 2019** **13** ## provisions of Chapter III of the Rules, a Division Bench of this Court had ## occasion to hold as follows in para 2 of the judgment: 2. The management of the School is vested with the 'approved' Manager as per rules. After the death of an individual who had the right to conduct the School in his own capacity, his rights are inherited by one or more of his legal representatives. If it is not devolved on a particular individual by way of testamentary deposition or by way of personal law and is devolved on more than one person, it will become a 'corporate educational agency'. Considering the provisions mentioned in Chapter III R.2 of the KER, view of the learned Single Judge in Mohamed Kutty's case that even after the death of an individual educational agency, when right of management devolves on more than one legal representative, it will continue as an individual educational agency is not contemplated under the Educational Rules. The word used in R.1 while differentiating a joint family is the 'legal representative' and not 'legal representatives', making it clear that if there are more than one legal representatives, it will not be an individual educational agency. All educational agencies other than 'individual educational agency' are termed as a 'corporate educational agency'. 14. In view of the provisions of the Rules and the law as interpreted by this Court, the contention advanced by the petitioner that even after the death of the founder, the individual educational agency continued as such cannot be accepted. Even otherwise, Exhibit P1 order which is emphatically relied on by the petitioner would tell a different story. In Exhibit P1 order conferring managership on the husband of the petitioner, it is stated that the properties and management of the ALP School, Mayur North devolved on the legal heirs of the deceased manager by way of inheritance. What was relinquished by the other legal heirs was their right to be the manager **WP(C) NO. 25124 OF 2019** **14** of the school in favor of Sri M.K. Narayana Menon, the husband of the petitioner, who incidentally was one of the legal heirs. Furthermore, I find from Exhibit P3 order dated 22.2.1994 issued by the AEO, Pattambi as per which the petitioner herein was approved as the manager, it is stated in unequivocal terms that the transfer of management does not involve a change of ownership. Exhibit P3 order has to be read in conjunction with Exhibit R6(f) consent letter issued by the petitioner on 19.4.1993 along with the application submitted by her for approving her appointment as manager on the death of her husband. It is stated in Exhibit R6(f) consent letter issued by the petitioner that her husband, Sri Narayana Menon who was acting as the manager of the ALP School had expired on 2.4.1993, that a meeting was held in the family home by all the co-owners of the school, that they have decided to appoint the petitioner as the manager without change of ownership and that she shall relinquish the post of manager if such decision is taken by the other co-owners without any demur and without raising any objection before the authorities concerned. The petitioner has no case that Exhibit R6(f) has not been submitted by her. 15. Even otherwise the contention of the petitioner that the petitioner and her family members are in exclusive ownership of the Schools cannot be accepted. As per Rule 3 of Chapter III of the KER, the Management of every aided school may be vested by the Educational Agency in a person who shall be referred to as the Manager and who shall **WP(C) NO. 25124 OF 2019** **15** be responsible to the department for the management of the institution. Sub Rule (3) states that in the case of aided institutions under Corporate management the proprietary body may choose the Manager in accordance with the rules in that behalf referred to in Rule 2. Rule 4 of Chapter III states that the Educational Officers shall be competent to approve the appointment of Managers by Educational Agencies and to approve changes in the personnel of the Managers. Rule 5A deals with change of management involving a change of ownership. It states that notwithstanding anything contained in the rules, no change of Management of any aided school involving a change of ownership shall be effected except with the previous permission of the Director. In the case on hand, the petitioner has no case that either the petitioner or her husband had approached the director with an application for a change of ownership. In view of the discussion above, I am of the considered opinion that the petitioner has not made out a case for interference with Exhibit P14 and P15 orders. This Writ Petition will stand dismissed. Sd/- ## **RAJA VIJAYARAGHAVAN V** ## **JUDGE** **ps23/9/2021** **WP(C) NO. 25124 OF 2019** **16** ## **APPENDIX OF WP(C) 25124/2019** PETITIONER(S) EXHIBITS : EXHIBIT P1 THE TRUE COPY OF THE ORDER ISSUED BY THE 5TH RESPONDENT DATED 18.10.1976. - EXHIBIT P2 THE TRUE COPY OF THE DEATH CERTIFICATE OF NARAYANA MENON DATED 16.03.2018. - EXHIBIT P3 THE TRUE COPY OF THE ORDER ISSUED BY THE 5TH RESPONDENT DATED 22.02.1994. - EXHIBIT P4 THE TRUE COPY OF THE BYE-LAW PRODUCED BY THE 3RD RESPONDENT DATED 03.02.2018. - EXHIBIT P5 THE TRUE COPY OF THE DECISION TAKEN BY THE RESPONDENTS 6 TO 21 DATED 01.12.2017. - EXHIBIT P6 THE TRUE COPY OF THE REPRESENTATION SUBMITTED BY THE 6TH RESPONDENT BEFORE THE 5TH RESPONDENT DATED 16.03.2018. - EXHIBIT P7 THE TRUE COPY OF THE COMMUNICATION ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER DATED 20.03.2018. - EXHIBIT P8 THE TRUE COPY OF THE JUDGMENT IN W.P.(C). NO.13314/2018 OF THIS HON'BLE COURT DATED 29.11.2018. - EXHIBIT P9 THE TRUE COPY OF THE JUDGMENT IN R.P.NO. 99/2019 IN W.P.(C). NO.13314/2018 OF THIS HON'BLE COURT DATED 29.01.2019. - EXHIBIT P10 THE TRUE COPY OF THE JUDGMENT IN W.P.(C). NO.13314/2018 OF THIS HON'BLE COURT DATED 05.03.2019. - EXHIBIT P11 THE TRUE COPY OF THE BYE-LAW FRAMED BY THE LEGAL HEIRS OF NARAYANAN NAIR DATED 30.12.2018. - EXHIBIT P12 THE TRUE COPY OF THE ORDER OF THE 3RD RESPONDENT DATED 03.04.2019. **WP(C) NO. 25124 OF 2019** **17** EXHIBIT P13 THE TRUE COPY OF THE JUDGMENT IN W.P.(C) NO.14520/2019 OF THIS HON'BLE COURT DATED 16-07.2019. EXHIBIT P14 THE TRUE COPY OF THE ORDER OF THE 3RD RESPONDENT DATED 30.07.2019. EXHIBIT P15 THE TRUE COPY OF THE ORDER ISSUED BY THE 5TH RESPONDENT DATED 27.08.2019. RESPONDENT(S)EXHIBITS : |EXHIBIT R6(a)|THE TRUE COPY OF THE DEATH CERTIFICATE DATED| |---|---| ||16/3/2018 OF LATE NARAYANAN NAIR ISSUED BY| ||KOPPAM GRAMA PANCHAYAT.| |EXHIBIT R6(b)|COPY OF THE NOTIFICATION NO.A4-8242/76 DATED| ||19/6/1978 APPEARED IN THE KERALA GAZETTE| ||DT.27/7/1976.| |EXHIBIT R6(c)|THE TRUE COPY OF THE ORDER DATED 18/10/1976| ||ISSUED BY THE AEO, PATTAMBI.| |EXHIBIT R6(d)|THE TRUE COPY OF THE DEATH CERTIFICATE DATED| ||16/3/2018 OF LATE NARAYANAN NAIR ISSUED BY| ||THE PERINTHALMANNA MUNICIPALITY.| |Exhibit R6(e)|TRUE COPY OF THE ORDER DATED 22/02/1994| ||ISSUED BY THE AEO, PATTAMBI.| |Exhibit R6(f)|TRUE COPY OF THE CONSENT LETTER DATED| ||09/04/1993 EXECUTED BY THE PETITIONER.| |Exhibit R6(g)|TRUE COPY OF THE DEATH CERTIFICATE DATED| ||16/03/2018 OF M.K. AMMALU AMMA ISSUED BY THE| ||KOPPAM GRAMA PANCHAYATH.| |Exhibit R6(h)|TRUE COPY OF THE DEATH CERTIFICATE DATED| ||16/03/2018 OF M.K. JANAKI KUTTY AMMA ISSUED| ||BY THE KOPPAM GRAMA PANCHAYATH.| |Exhibit R6(i)|TRUE COPY OF THE DEATH CERTIFICATE DATED| **WP(C) NO. 25124 OF 2019** **18** ||16/03/2018 OF M.K. RADHAKRISHNAN ISSUED BY| |---|---| ||THE KOPPAM GRAMA PANCHAYATH.| |Exhibit R6(j)|TRUE COPY OF THE NOTICE DATED 16/11/2017| ||ISSUED BY THE 6TH RESPONDENT.| |Exhibit R6(k)|TRUE COPY OF THE MINUTES OF MEETING OF| ||FAMILY MEMBERS DATED 01/12/2017.| |Exhibit R6(l)|TRUE COPY OF THE MINUTES OF MEETING OF| ||FAMILY MEMBERS DATED 03/02/2018.| |Exhibit R6(m)|TRUE COPY OF THE CONSTITUTION OF EDUCATIONAL| ||AGENCY ADOPTED IN THE MEETING HELD ON| ||03/02/2018.| |Exhibit R6(n)|TRUE COPY OF THE CONSENT LETTER DATED| ||15/03/2018 GIVEN BY THE STAFF OF ALPS,| ||AMAYUR NORTH.| |Exhibit R6(o)|TRUE COPY OF THE APPLICATION SUBMITTED BY| ||THE 6TH RESPONDENT BEFORE THE KOPPAM GRAMA| ||PANCHAYATH FOR FITNESS CERTIFICATE.| |Exhibit R6(p)|TRUE COPY OF THE COMMUNICATION DATED| ||20/03/2018 ISSUED BY THE AEO, PATTAMBI.| |Exhibit R6(q)|TRUE COPY OF THE JUDGMENT DATED 29/11/2018| ||IN WPC NO.13314/2018 OF THIS HON'BLE COURT.| |Exhibit R6(r)|TRUE COPY OF THE JUDGMENT DATED 29/01/2019| ||IN RP NO.99/2019 IN WPC NO. 13314/2018 OF| ||THIS HON'BLE COURT.| |Exhibit R6(s)|TRUE COPY OF THE JUDGMENT DATED 05/03/2019| ||IN WPC NO.13314/2018 OF THIS HON'BLE COURT.| |Exhibit R6(t)|TRUE COPY OF THE BY-LAWS FRAMED BY THE LEGAL| ||HEIRS OF LATE NARAYANAN NAIR.| |Exhibit R6(u)|TRUE COPY OF NOTICE DATED 05/03/2019 ISSUED| ||BY THE 3RD RESPONDENT.| |Exhibit R6(v)|TRUE COPY OF THE ORDER DATED 03/04/2019| ||ISSUED BY THE 3RD RESPONDENT.| |Exhibit R6(w)|TRUE COPY OF THE ORDER DATED 11/01/2013| **WP(C) NO. 25124 OF 2019** **19** ISSUED BY THE 3RD RESPONDENT. Exhibit R6(x) TRUE COPY OF THE JUDGMENT DATED 11/11/2009 IN WA NO. 2291/2008 OF THIS HON'BLE COURT. Exhibit R6(y) TRUE COPY OF THE JUDGMENT DATED 16/07/2019 IN WPC NO. 14520/2019 OF THIS HON'BLE COURT.