Lourdes Hospital Pachalam, Ernakulam District v. State of Kerala, Corporation of Cochin, and Secretary, Corporation of Cochin

## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** ## **THE HONOURABLE MR. JUSTICE AMIT RAWAL** ## **TUESDAY, THE 29TH DAY OF SEPTEMBER 2020 / 7TH ASWINA, 1942** ## **WP(C).No.17961 OF 2020(U)** ## **PETITIONER:** **LOURDES HOSPITAL PACHALAM, ERNAKULAM DISTRICT, PIN-682012, REPRESENTED BY ITS DIRECTOR, FR.SHAIJU AUGUSTINE THOPPIL.** **BY ADVS.** **SRI.PAUL JACOB (P) SRI.ENOCH DAVID SIMON JOEL SRI.RONY JOSE SRI.GEORGE A.CHERIAN SRI.LEO LUKOSE** ## **RESPONDENTS:** - **1 STATE OF KERALA REPRESENTED BY THE SECRETARY, DEPARTMENT OF LOCAL SELF GOVERNMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.** - **2 CORPORATION OF COCHIN, COCHIN-682011, REPRESENTED BY ITS SECRETARY.** - **3 SECRETARY, CORPORATION OF COCHIN, COCHIN-682011.** **SRI SUDHEESH KUMAR SC , SR GP C K GOVINDAN** **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 29.09.2020, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** **WP(C).No.17961 OF 2020(U)** **2** ## **JUDGMENT** ## **Dated this the 29th day of September 2020** The petitioner, carrying on the business of Hospital under the name and style “Lourdes Hospital”, through instant petition has challenged Ext.P8 to P8(m) assessment orders along with Exts.P9 to Exts.P9(m) and Exts.P10 to P10(m) demand notices, by issuing declaration that the petitioner is entitled to be assessed for payment of property tax for newly constructed building only from the date of issuance of occupancy certificate dated 10.01.2020 Ext.P6. 2. In support of the aforementioned prayer it is averred that petitioner is a non profit oriented charitable hospital. In the year 2001 as a part of an expansion process, construction of additional buildings in the very same premises was started. It could not be completed as originally planned, on account of financial constraints, but completed in March, 2012 and the completion certificate was applied for before 2[nd] respondent ie., Corporation of Cochin. 3. In December, 2011, a notice of assessment was issued by the 3[rd] respondent purporting to assess property tax on the **WP(C).No.17961 OF 2020(U)** **3** new constructions made by the petitioner. Without hearing the petitioner the 3[rd] respondent confirmed the notice, imposing an extra ordinary and exorbitant liability as evident from assessment order dated 23.07.2012 (Ext.P1). The aforementioned order was challenged in this Court vide W.P.(C).No.19456/2012. It was disposed of by directing the petitioner to avail the alternative remedy under Section 509 of the Kerala Municipality Act, 1994 (hereinafter called '1994 Act'). The appeal was rejected on the ground of limitation. In the meantime petitioner received a notice dated 12.09.2012, which was challenged before this Court vide W.P.(C).No. 23206/2012. 4. Learned counsel appearing on behalf of the petitioner submitted that in the meantime the 3[rd] respondent issued several demand notices pursuant to the assessment order for recovering an amount of Rs.70,85,035/-. Again this Court vide interim order dated 01.10.2013 in W.P.(C).No.9292/2013 stayed the demand notices. However, tax for the period involved in the aforementioned petition has also been demanded by the impugned demand notices. It was further contended that the occupancy certificate in this case was issued on 10.01.2020 **WP(C).No.17961 OF 2020(U)** **4** Ext.P6. The law with regard to charging of the tax from the date of occupancy certificate is no longer _res integra_ as clarified by judgment of this Court in _**Sheela V. Kollam Municipal Corporation**_ [2017 (4) KLT 887] wherein this Hon'ble Court while referring to the provisions of Sections 239, 240 and 241 of 1994 Act categorically held that property tax of the newly constructed building has to be charged from the date of the occupancy and not from the date of competition. Reliance has been laid to the findings in paragraph 3 of the judgment cited above. 5. On the other hand the learned counsel for the respondents submits that reply is not ready and seeks the liberty of this Court to file a reply. However, it has been brought to the notice that reply in the pending writ petition has also not been filed, but, does not dispute the _ratio decidendi_ culled out in the judgment cited supra. The provisions of Section 237 of the 1994 Act that property tax to be liable is to be treated as a first charge on the property was relied. 6. I have heard the learned counsel for the parties and appraised the paper book, it would be in fitness of things to **WP(C).No.17961 OF 2020(U)** **5** ## extract Sections 239 and 240 of the 1994 Act: “239. Vacancy remission.— (1) When any building whether ordinarily let or occupied by the owner himself has been vacant and unlet for a half-year, the owner shall be entitled to a remission of tax for that half-year. (2) If the owner had already paid the tax in respect of a half-year in which a remission is due, he shall be entitled to get either refund or shall be entitled to get the amount adjusted in the tax for the succeeding half-year. (3)(a) No such remission shall be admissible unless the owner of the building or his agent has previously thereto delivered notice to the Secretary- (i) that the building is vacant and unlet, or (ii) that the building will be vacant and unlet from a specified date either in the half-year in which notice is delivered or in the succeeding half-year. (b) Every notice under clause (a) shall expire with the half-year succeeding the half-year during which it is so delivered and shall have no effect thereafter. 240. Obligation of transferor and transferee to give notice, of transfer.— (l)Whenever the title of any person primarily liable to the payment of property tax on any premises to or over such premises is transferred, the person whose title is transferred and the person to whom the same shall be transferred shall, within three months after the execution of the instrument of transfer or after its registration if it be registered or, after the transfer is effected, if no instrument be executed, give notice of such transfer to the Secretary. (2) In the event of the death of any person primarily liable as aforesaid, the person to whom the title of the **WP(C).No.17961 OF 2020(U)** **6** deceased shall devolve, as heir or otherwise, shall give written notice of such transfer to the Secretary within one year from the date of death of the deceased. (3) The notice to be given under this section shall be in such form as the Secretary may specify and the transferor, and the transferee or in the case of death of a person, the person to whom the title passes, as the case may be, shall if so required, be bound to produce before the Secretary any documents evidencing the transfer or succession. (4) Every person who makes a transfer as aforesaid without giving such notice to the Secretary shall, in addition to any other liability which, he may incur for such failure, be liable for the payment of property tax assessed on the premises so transferred until he gives notice or until the transfer is recorded in the registers of the Municipality, but nothing in this section shall be held to affect- (a) the liability of the transferee for the payment of the said tax, or (b) the prior claim of the Municipality under section 237. “ 7. On perusal of Section 239, it is admitted that where a building has been let or occupied by the owner and has been lying vacant, it is the duty of the owner to remit tax for the period for occupation. No remission shall be admissible unless the owner of the building or his agent has delivered notice to the Secretary with regard to the building being vacant. Provisions of **WP(C).No.17961 OF 2020(U)** **7** Section 241 envisages that it is the obligation of the owner to give notice of construction/reconstruction or demolition of the building to the Secretary. It is not the duty of the petitioner to inform the Secretary in view of the omitted provisions of Section 241 with regard to the additional construction. In my view, the office of the respondents were in obligation to take into consideration requests submitted for issuance of occupancy certificate in accordance with law ie., after conducting a survey/inspection of the building. No such steps had been taken. Issuance of an occupancy certificate Ext.P6 in January 2020, specifying the area of construction of various floors totalling to 35276 square meters, also reflected the state of construction as on 12.10.2012. This Court interdicted the aforementioned demand by holding in paragraph 3, as under: “On a consideration of the facts and circumstances of the case as also the submissions made across the bar, I find from a perusal of the provisions of Sections 233,239 and 241 of the Kerala Municipality Act, 1994 as they stood during the period prior to 07.10.2009, that while the statute contemplated a levy of property tax on buildings constructed within the territorial limits of the respective Municipalities, the levy of tax was to be based on the annual value of the buildings. The provisions of S.239 dealing with **WP(C).No.17961 OF 2020(U)** **8** vacancy remission contemplated that an owner of a building could apply to the Municipality concerned for remission of the tax payable in respect of the building if he give prior intimation to the Secretary to the effect that the building is vacant and unlet or that the building would be vacant and unlet from a specified date either in the half-year in which notices is delivered or in the succeeding half-year. The provisions also make it clear that every such notice would expire with the half-year succeeding the half-year, during which it was so delivered and would have no effect thereafter, S.241 as it then stood, no doubt contemplate an obligation on the part of the owner of the building to give notice of the completion of construction so as to enable the Municipality concerned to commence the process of assessment to property tax of the building in question. The notice to be given by the owner had to be given within fifteen days from the date of completion or occupation of the building whichever is earlier. In my view, a conjoined reading of the above mentioned provisions as they then stood, clearly contemplated that while the charge of property tax accrued in respect of a building immediately on the completion of t its construction, the liability to pay property tax depended entirely on whether the building was occupied or used for the purposes for which it was constructed. The vacancy remission provision under S.239 of the Kerala Municipality Act 1994 would be rendered meaningless, if the construction to be placed on the charging provisions is taken as intending a levy and collection of tax in respect of buildings with effect from the date of completion of construction, irrespective of whether they were occupied or not. In the instant case, the facts **WP(C).No.17961 OF 2020(U)** **9** would indicate that it was within the knowledge of the respondent Municipality that, although the construction of the building was completed on 22.08.2006, the petitioner had not obtained an occupancy certificate for which he had applied, and that as a consequences thereto, the petitioner had not occupied the building for commercial purposes till 16.06.2008 on which date the occupancy certificate was eventually granted. Under the circumstances, I am of the view that, despite the petitioner not having strictly complied with the procedural requirements contemplated under S.239 of issuing a prior notice to the respondent Municipality, the fact that the Municipality had refused the occupancy certificate pursuant to a request made for the same by the petitioner, would come to the aid of the petitioner in contending that the building was not used for the period from 22.08.2006 to 16.06.2008. I am therefore, of the view that, in the instant case, the liability of the petitioner to pay tax would arise only with effect from 16.06.2008, the date on which the occupancy certificate was issued to the petitioner. In arriving at the said conclusion I am fortified by the decision of this Court in M.C.George v. Moovattupuzha Municipality (1975 KLT 380).” According to the learned counsel for the petitioner this judgment is still holding field. On perusal of the judgment cited above, there is no doubt in the mind of this Court that the respondents cannot charge property tax from the date of construction of the building but it **WP(C).No.17961 OF 2020(U)** **10** has to be from the date of occupancy certificate in 2020. Accordingly this writ petition is allowed. The assessment order Ex.P8 series and the demand notices Ext.P9 series and Ext.P10 series are set aside. Respondents are directed to issue fresh assessment order after affording an opportunity of hearing to the petitioner in accordance with law in terms of the observations, hereinabove. **Sd/-** **AMIT RAWAL JUDGE** nak **WP(C).No.17961 OF 2020(U)** **11** ## **APPENDIX** ## **PETITIONER'S EXHIBITS:** **EXHIBIT P1** **A TRUE COPY OF THE ASSESSMENT ORDER DATED 23.07.2012 AND NUMBERED AS NO.PMR2/3980/11 ISSUED TO THE PETITIONER AND RECEIVED ON 07.08.2012.** - **EXHIBIT P2 A TRUE COPY OF THE NOTICE DATED 12.09.2012 AND NUMBERED AS PMR2/3980/11 ISSUED BY THE 3RD RESPONDENT.** - **EXHIBIT P3 A TRUE COPY OF THE ONE OF THE DEMAND NOTICE DATED 30.03.2013 AND NUMBERED AS 20751 ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P4 A TRUE COPY OF THE ORDER DATED 01.10.2013 IN W.P(C)NO.9292/2013 ON THE FILES OF THIS HON'BLE COURT.** - **EXHIBIT P5 A TRUE COPY OF THE LETTER NUMBERED AS NO.313/RBI/2019 AND DATED 02.08.2019 ISSUED BY THE 1ST RESPONDENT.** - **EXHIBIT P5(A) A TRUE COPY OF THE MINUTES DATED 06.08.2019, MENTIONED IN EXT.P5.** - **EXHIBIT P6 A TRUE COPY OF THE OCCUPANCY CERTIFICATE DATED 10.01.2020 ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P7 A TRUE COPY OF DEMAND NOTICE NUMBERED AS 4406 AND DATED 15.02.2020.** **EXHIBIT P8 A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7526 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P8(A) A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7527 AND DATED** **WP(C).No.17961 OF 2020(U)** **12** **15.02.2020 ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P8(B) A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7528 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P8(C) A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7529 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P8(D) A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7530 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P8(E) A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7531 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P8(F) A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7532 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P8(G) A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7519 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P8(H) A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7520 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P8(I) A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7521 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT.** **WP(C).No.17961 OF 2020(U)** **13** **NUMBERED AS NO.7522 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P8(K)** **EXHIBIT P8(K) A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7523 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT. EXHIBIT P8(L) A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7524 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P8(M) A TRUE COPY OF THE ASSESSMENT NOTICE NUMBERED AS NO.7525 AND DATED 15.02.2020 ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P9 A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8, ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P9(A) A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8(A), ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P9(B) A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8(B), ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P9(C) A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8(C), ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P9(D) A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8(D), ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P9(E) A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8(E), ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P9(F) A TRUE COPY OF THE DEMAND NOTICE DATED** **WP(C).No.17961 OF 2020(U)** **14** **15.02.2020 FOR EXT.P8(F), ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P9(G) A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8(G), ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P9(H) A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8(H), ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P9(I) A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8(I), ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P9(J) A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8(J), ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P9(K) A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8(K), ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P9(L) A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8(L), ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P9(M) A TRUE COPY OF THE DEMAND NOTICE DATED 15.02.2020 FOR EXT.P8(M), ISSUED BY THE 2ND RESPONDENT.** - **EXHIBIT P10 TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 I.** - **EXHIBIT P10(A) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 III.** - **EXHIBIT P10(B) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING** **WP(C).No.17961 OF 2020(U)** **15** **NUMBER 45/441 IV.** - **EXHIBIT P10(C) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 V.** - **EXHIBIT P10(D) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/443 IV.** - **EXHIBIT P10(E) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/443 III.** - **EXHIBIT P10(F) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/443 II.** - **EXHIBIT P10(G) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/443 I.** - **EXHIBIT P10(H) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 IA.** - **EXHIBIT P10(I)** - **TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 IB.** - **EXHIBIT P10(J) A TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 IC.** - **EXHIBIT P10(K)** - **A TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE** **WP(C).No.17961 OF 2020(U)** **16** **2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 ID.** - **EXHIBIT P10(L)** **A TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 IE.** **EXHIBIT P10(M)** - **A TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 IIA.** - **EXHIBIT P10(N) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 IIB.** - **EXHIBIT P10(O) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 IIC.** - **EXHIBIT P10(P) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 IID.** - **EXHIBIT P10(Q) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 IIE.** - **EXHIBIT P10(R) TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/443 IA.** - **EXHIBIT P10(S)** - **TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/445 I.** **WP(C).No.17961 OF 2020(U)** **17** **NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/446 I.** **EXHIBIT P10(U)** - **TRUE COPY OF THE UNNUMBERED DEMAND NOTICE DATED 16.12.2019 ISSUED BY THE 2ND RESPONDENT FOR BUILDING BEARING NUMBER 45/441 II.** - **EXHIBIT P11 A TRUE COPY OF THE LETTER DATED 20.02.2020 SUBMITTED BY THE PETITIONER BEFORE THE 2ND RESPONDENT.** - **EXHIBIT P12 A TRUE COPY OF THE LETTER NUMBERED AS PMR3/150/2020 AND DATED 27.05.2020.** - **EXHIBIT P12(A) A TRUE COPY OF THE LETTER NUMBERED AS PMR3/150/2020 AND DATED 29.05.2020.** - **EXHIBIT P13 A TRUE COPY OF THE CIRCULAR NUMBERED AS NO.R.C2/100/2020 AND DATED 03.05.2020 ISSUED BY THE 1ST RESPONDENT.** - **EXHIBIT P14 A TRUE COPY OF THE LETTER NUMBERED AS LH/DIR/2020-1117 AND DATED 06.06.2020.** - **EXHIBIT P15** - **A TRUE COPY OF THE ORDER NUMBERED AS ISO/PMR3/150/2020 AND DATED 03.08.2020 ISSUED BY THE 3RD RESPONDENT.** //TRUE COPY// P.A TO JUDGE