High Court of KeralaSingle Judge2023-01-17Writ petition allowed; Ext.P17 set aside.

M.V. Rajendran v. Joint Registrar of Co-operative Societies (General), Thrissur; Administrative Committee represented by the Convenor, Adat Farmers Service Co-Operative Bank Ltd., Thrissur District; Adat Farmers Service Co-Operative Bank Ltd. (Superseded) represented by the Managing Director

Case / Petition Number:WP(C) NO. 15859 OF 2018

Case Details & Bench

Court: High Court of Kerala
Hon'ble Judges: Devan Ramachandran
Judgment Date: 2023-01-17
Court Decision / Holding: Result: The writ petition is allowed and Ext.P17 is set aside. The court holds that the non-fulfilment of a hearing process nullifies the order of supersession, emphasizing the primacy of natural justice in administrative actions under the Kerala Co-operative Societies Act.
Final Disposition: Writ petition allowed; Ext.P17 set aside.

Parties to the Case

Appellants / Petitioners

M.V. Rajendran

Respondents

Joint Registrar of Co-operative Societies (General), Thrissur
Administrative Committee represented by the Convenor, Adat Farmers Service Co-Operative Bank Ltd., Thrissur District
Adat Farmers Service Co-Operative Bank Ltd. (Superseded), represented by the Managing Director

Legal Representation & Advocates

Counsels for Petitioners

• George Poonthottam (Senior Counsel)
• Nisha George
• Ann Maria Francis

Counsels for Respondents

• Smt. C.S. Sheeja (Senior Government Pleader)
• Sri. P.C. Sasidharan

Case Synopsis & Summary

This writ petition challenges Ext.P17, the order superseding the Adat Farmers Service Co-Operative Bank Ltd. The petitioner, M.V. Rajendran, is the President of the superseded Managing Committee of the Bank, who contends Ext.P17 was issued without affording him the opportunity of being heard and without compliance with Section 32 of the Kerala Co-operative Societies Act (KCS Act). He learned of the order through media reports, not via a proper show-cause process. The petition emphasizes that the statutory prerequisites under the KCS Act were not followed before supersession. The court treats the hearing objection as a preliminary issue and relies on Reji K. Joshy v. Registrar of Co-operative Societies (General), Kollam and Others (Full Bench), that an opportunity of hearing must be provided to all affected persons before action on inquiry or inspection reports, unless dispensing with the hearing is expressly permitted by statute. The petitioner also argues that Ext.R1(f), (g), (h) lack essential documents to the consultees, citing Sahadevan v. Padmanabhan to stress that not only the party’s explanations but all relevant materials must accompany tentative findings. The respondents claim Ext.P15 offered a hearing, that concurrence from consultees was obtained, and that the Joint Registrar followed statutory requirements. The court ultimately holds that the absence of a hearing vitiates Ext.P17 and sets aside the order, reinforcing natural justice principles in administrative action under the KCS Act.

Provisions of Law Cited

Kerala Co-operative Societies Act, Section 32Kerala Co-operative Societies Act, Section 68Kerala Co-operative Societies Act, Section 32(1)

Legal Doctrines & Maxims

Principle of natural justice (audi alteram partem) – right to hearing before administrative action
Show cause notice and disclosure of relevant materials to consultees (Sahadevan v. Padmanabhan)
Binding effect of Full Bench decisions such as Reji K. Joshy (Supra) on the necessity of hearing
Automotive Tyre Manufacturers Association v. Designated Authority and Others – natural justice applies to administrative/quasi-judicial actions unless dispensed with by statute

Submissions & Arguments

Contentions of Appellants / Petitioners

The applicant contends Ext.P17 was issued without granting an opportunity of hearing and without complying with Section 32 of the KCS Act. He relies on Reji K. Joshy (Full Bench) to assert that all affected persons must be heard before action on inquiry/inspection reports, unless dispensing with hearing is expressly allowed. The absence of a proper show-cause notice and accompanying materials, as argued with Ext.R1(f), (g), (h), is highlighted through Sahadevan v. Padmanabhan. The petitioners maintain that mere written explanations were invited, not a hearing, and that non-availability of the required documents to consultees vitiates the process. The petitioner urges setting aside Ext.P17 to uphold natural justice and statutory mandates.

Contentions of Respondents

Respondents submit that Ext.P15 afforded a hearing opportunity; the petitioner did not participate or seek further hearing; Ext.P17 was issued after obtaining mandatory concurrence from consultees. They argue that Section 32 does not automatically oblige hearing for every Managing Committee member and that the statutory framework was otherwise observed, including consultation with the Circle Co-operative Union and the Financing Bank. They contend that the process was conducted in a manner consistent with the statutory scheme and that the objections, explanations, and documents were appropriately considered.

Cited Precedents (3)

Case Name	Citation	Treatment	Explanation
Reji K. Joshy and Others v. Registrar of Co-operative Societies (General), Kollam and Others	2022 (3) KHC 317	Positive	Full Bench held that opportunity of hearing must be afforded to all affected persons before action on the report of inquiry or inspection, except where dispensing with hearing is expressly allowed.
Sahadevan v. Padmanabhan	2004 (1) KLT 192	Positive	Cited to support the proposition that the consultees must receive all relevant documents, not only the petitioner’s explanations.
Automotive Tyre Manufacturers Association v. Designated Authority and Others	(2011) 2 SCC 258	Positive	Supreme Court authority on natural justice applying to administrative/quasi-judicial action; supports requirement of hearing unless dispensation applies.

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Extracted Judgment Text

Exact text extracted from official judgment records.

# **`IN THE HIGH COURT OF KERALA AT ERNAKULAM`** ## **`PRESENT`** ``` THE HONOURABLE MR. JUSTICE DEVAN RAMACHANDRAN TUESDAY, THE 17[TH] DAY OF JANUARY 2023 / 27TH POUSHA, 1944 ``` ## **`WP(C) NO. 15859 OF 2018`** ## **`PETITIONER:`** ``` M.V. RAJENDRAN AGED 59 YEARS PRESIDENT, (SUPERSEDED),MANAGING COMMITTEE, ADAT FARMERS CO-OPERATIVE BANK LTD. NO. R 689, THRISSUR DISTRICT - 680 551. BY ADVS. SRI.GEORGE POONTHOTTAM (SR.) SMT.NISHA GEORGE SMT.ANN MARIA FRANCIS ``` ## **`RESPONDENTS:`** ``` 1JOINT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL), THRISSUR - 680 001. 2THE ADMINISTRATIVE COMMITTEE REPRESENTED BY THE CONVENOR, ADAT FARMERS SERVICE CO-OPERATIVE BANK LTD.NO.R.689,THRISSUR DISTRICT - 680 551. 3ADAT FARMERS SERVICE CO-OPERATIVE BANK LTD.NO.R.689 (SUPERSEDED),THRISSUR DISTRICT - 680 551, REPRESENTED BY THE MANAGING DIRECTOR. BY ADVS. GOVERNMENT PLEADER ADVOCATE GENERAL OFFICE KERALA ``` ``` SMT.C.S.SHEEJA -SR.GP SRI.P.C.SASIDHARAN ``` ``` THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 17.01.2023, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ``` ## **`WP(C) NO. 15859 OF 2018 2`** ## **`CR`** ## **JUDGMENT** The petitioner is stated to be the President of the Managing Committee of the 3[rd] respondent – 'Adat Farmers Service Cooperative Bank Ltd.' (Society, for short), which has now been superseded through Ext.P17 order. 2. The petitioner asserts that Ext.P17 was issued without affording him an opportunity of being heard – he having come to know of it only when it was published in the news media; and further that none of the statutory requirements under Section 32 of the Kerala Co-operative Societies Act ('KCS Act', for short) had been followed, before it had been issued. He thus prays that Ext.P17 be set aside. 3. I have heard Sri.George Poonthottam – learned Senior Counsel, instructed by Smt.Ann Maria Francis, appearing for the petitioner; Sri.P.C.Sasidharan – learned counsel for respondents 2 and 3 and Smt.C.S.Sheeja - learned Senior Government Pleader appearing for the 1[st] respondent. 4. Before I proceed further, I must record that, since the specific contention of the petitioner is that he was not heard before ## **`WP(C) NO. 15859 OF 2018 3`** Ext.P17 had been issued, it will be treated by me as a preliminary objection, because, if that is to be found in his favour, the said order will have no legs to stand on, going by various judicial precedents covering the field. I say so, since, in such event, the question whether there was proper consultation and if other requirements under the statutory Scheme had been followed, would be relegated to a second position in its rigour and consideration. 5. Sri.George Poonthottam – learned Senior Counsel, vehemently argued that his client was never given an opportunity of being heard and he pointed out to Ext.P15 notice issued by the Joint Registrar, under the provisions of Section 32 of the 'KCS Act'. He asserted that the aforesaid notice only offered his client and others an opportunity of furnishing their written explanations against the action proposed; and that it has now been well settled, through the judgment of a Full Bench of this Court in _**Reji K.Joshy and Others v. Registrar of Co-operative Societies (General), Kollam and Others**_ [2022 (3) KHC 317] that “ _the Act contemplates an opportunity of hearing to all affected persons before action is taken on the report of inquiry or inspection, whether it be under Section 32 or under Section 68, except in situations provided for in Section 32 where the Registrar is empowered to dispense with the opportunity_ ## **`WP(C) NO. 15859 OF 2018 4`** _of hearing._ “. He argued that, therefore, when no other notice has been issued to his client, Ext.P17 is rendered forensically incompetent. 6. After arguing as afore, and as his second limb of submissions, the learned Senior Counsel contended that the Circle Co-operative Union and the Financing Bank were apparently consulted by the Joint Registrar of Co-operative Societies by issuing to them Ext.R1(f) notice; but that this contained none of the documents which were statutorily required to be enclosed, as is evident from itself. He relied upon the judgment of a learned Division Bench of this Court in _**Sahadevan v. Padmanabhan** [2004 (1) KLT 192],_ to predicate that it is not merely sufficient that the explanation of his client alone be attached to the “tentative findings”, but that every other document mentioned therein ought to have been so. His singular argument was that, in the absence of such documents, even if the consultees had given their opinion, it can only be seen to be a futile formality, since it is clear that they had no idea on what basis the said findings had been entered into by the Joint Registrar. 7. As an adscititious argument, Sri.George Poonthottam, learned Senior Counsel, then contended that, even going by Exts.R1(f), R1(g) and R1(h) - which are the opinions placed on record ## **`WP(C) NO. 15859 OF 2018 5`** by the Circle Co-operative Union and the Financing Bank respectively - it is luculent that they were settled by Authorities who are much below the Joint Registrar; and that this is more so in the case of the Financing Bank, which was, concededly, under the management of the said Authority himself at the relevant time. The learned Senior Counsel thus prayed that Ext.P17 be set aside for all these reasons. 8. Smt.C.S.Sheeja – learned Senior Government Pleader, refuted the afore contentions of the petitioner saying that, before Ext.P17 order had been issued, the petitioner and others were served with Ext.P15 notice, (which is also produced as Ext.R1(i) by the 1[st] respondent), giving them an opportunity of offering explanation to the allegations contained therein. 9. Smt.C.S.Sheeja then argued that, even though the petitioner and others preferred Ext.P16 reply, they did not seek an opportunity of being heard; and therefore, that the Joint Registrar correctly went on to issue Ext.P17 order dated 06.04.2018, but only after obtaining the mandatory concurrence from the consultees, as is statutorily required. 10. The learned Senior Government Pleader further contended that the argument of the petitioner, that Exts.R1(g) and R1(h) concurrences given by the consultees are illegal solely because **`WP(C) NO. 15859 OF 2018 6`** they were settled by Officers below the Rank of Joint Registrar, cannot hold water because, as evident therefrom, competent officers were entrusted with the task of evaluating the “tentative opinion” of the Joint Registrar and to make their recommendations in terms of the statutory Scheme _qua_ Section 32 of the 'KCS Act'. 11. Pertinently, she conceded that the Financing Bank was, at the relevant time, under the management of the Joint Registrar, but pointed out that, as is manifest from the second page of Ext.R1(h), said Authority adopted a resolution relegating it to the General Manager of the Bank to take an apposite decision on the tentative findings entered by him in Ext.R1(f). She submitted that, therefore, in view of the peculiar circumstances which prevailed at the time when action was taken forward by the Joint Registrar, this is all that could have been done; and hence that the petitioner cannot be allowed to take advantage of a factual scenario, which was inevitable. 12. Smt.C.S.Sheeja thereafter, showed me that the allegations against the petitioner and others are so grave that no right thinking Authority could have permitted the Managing Committee to continue forward; and therefore, that Ext.P17 is irreproachable from that angle also. She thus prayed that this writ petition be dismissed. 13. I began this judgment saying that the primary question ## **`WP(C) NO. 15859 OF 2018 7`** which deserves this Court’s singular attention is whether the processes, as are statutorily mandated, have been followed by the Joint Registrar before Ext.P17 order had been issued. 14. In this regard, I am certainly bound and guided by the judgment of the learned Full Bench in _**Reji K.Joshy (Supra),**_ wherein, as rightly argued by Sri.George Poonthottam, the unanimous view was that an opportunity of hearing must be afforded to all affected persons before any action is taken on the report of enquiry or inspection, whether it be under Section 32 or Section 68 of the KCS Act, except in the situations provided in the former Section, under which, the Registrar has been given the power to dispense with such a hearing. 15. In the case at hand, the respondents have no contention that the provisions of Section 32 of the KCS Act, which empowered the Registrar to dispense with the opportunity of being heard to the petitioner, had been in any manner attracted. 16. On the contrary, it is expressly conceded that no such situation prevailed and this is evident from the fact that, in the counter affidavit filed on behalf of the 1[st] respondent dated 12.06.2019, his apodictic averment is to the effect that a notice of hearing had been afforded to the petitioner, but that he had not ## **`WP(C) NO. 15859 OF 2018 8`** availed of the same. Since there was no factual corroboration of the same, this Court had passed an order on 09.01.2023, asking the 1[st] respondent to clarify on what basis the afore assertion was made; and further that, if the same was maintained to be true by him, then to produce the said document on record. However, in response to this, an affidavit dated 13.01.2023 has been filed by the 1[st] respondent, wherein, he unambiguously admits that, what he meant through the averments in his earlier counter affidavit was that Ext.P15 notice had been issued to the petitioner and others, giving them an opportunity of furnishing their written explanation and that this should be construed to be a notice of hearing also, particularly when the petitioner did not seek any further opportunity through a separate request. 17. I am afraid that the afore stand of the Joint Registrar can never appeal to this Court, especially when the right to be afforded an opportunity of being heard is manifest and inviolable from the statutory scheme, as has been declared by this Court in _**Reji K.Joshy (Supra).**_ 18. That apart, when it comes to any action under Administrative Law, various judgments of this Court and that of the Hon’ble Supreme Court, particularly _**Automotive Tyre**_ ## **`WP(C) NO. 15859 OF 2018 9`** ## _**Manufacturers Association v. Designated Authority and Others**_ _**[(2011) 2 SCC 258],**_ render it ineluctable that unless a statutory provision, either specifically or by necessary implication, excludes the application of principles of natural justice, the requirement of giving reasonable opportunity of being heard is to be read in, particularly when the resultant order may have adverse civil consequences. The Hon’ble Supreme Court has, in fact, gone to the extent of saying _“this principle holds good, irrespective of whether the power conferred on a statutory body or Tribunal is administrative or quasi judicial and that it is equally trite that the concept of natural justice can neither be put in a straitjacket nor is it a general rule of universal application”_ . 19. Obviously, therefore, when it is now conceded that no opportunity of hearing had been afforded to the petitioner and others, before Ext.P17 had been issued, the same becomes incapable of being granted judicial favour. For this reason alone, said order is liable to be set aside. 20. Of course, before I conclude so, I am fully cognizant of the submissions of Smt.C.S.Sheeja – learned Senior Government Pleader, that Section 32 of the KCS Act, does not specify that an opportunity of being heard must be offered to the members of a Managing ## **`WP(C) NO. 15859 OF 2018 10`** Committee, which is sought to be superseded. She pointed out that Section 32 only mandates that the competent Authority may “ _after giving the Committee an opportunity to state their objections, if any, by order in writing, removed the Committee and appointed in its place an Administrator or an Administrative Committee”_ (sic). Her argument was that, therefore, an opportunity of being heard need not be offered. 21. As I have already concluded above, Smt.C.S.Sheeja is attempting to argue against the holdings of a learned Full Bench of this Court in _**Reji K.Joshy (Supra)**_ and against settled principles. The scope of law has been well expanded and explained through judicial pronouncements and binding precedents, which cannot be now sought to be read otherwise by the 1[st] respondent, which is a statutory Authority bound by it. 22. That apart, as I have already seen above, the 1[st] respondent has no case that he was not obligated to give a notice of hearing to the petitioner; but his stand in the counter affidavit is that he did so, with the latter refusing to accede to it. Though he now explains, through his additional affidavit, that what he intended was that Ext.P15 itself was a notice of hearing, the same is also belied by his own further averments to the effect that what was granted was only ## **`WP(C) NO. 15859 OF 2018 11`** the opportunity of furnishing written explanation, which is undoubted because, he then further attempts to explicate that the petitioner did not seek any opportunity of being heard thereafter. 23. Indubitably, refusal of the 1[st] respondent in even offering an opportunity of being heard to the petitioner, in spite of his assertions in the counter affidavit, surely robs Ext.P17 of all legal force. 24. With my conclusion as afore, obviously, I do not think that it will be necessary for this Court to enter into the merits of the contentions of the learned Senior Counsel – Sri.Geroge Poonthottam, regarding the worth of the consultation made by the Joint Registrar, as evident from Exts.R1(f), R1(g) and R1(h). However, I must record that going by _**Sahadevan (Supra),**_ the Joint Registrar was certainly obligated to furnish all the relevant materials, particularly the show cause notice under Section 32(1) of the KCS Act, as also the explanations and objections of the Committee, to the consultees. Going by Ext.R1(f) dated 22.03.2018, the Joint Registrar appears to have forwarded only the explanation of the Committee, but without being accompanied by the show cause notice under Section 32(1) of the KCS Act; and _prima facie_ , therefore, this Court cannot find favour with this either. 25. As regards the worth of the consultation by the consultees is ``` WP(C) NO. 15859 OF 2018 12 ``` concerned, I choose not to answer it because, the same is irrelevant and unnecessary, since Ext.P17 cannot be, in any case, granted imprimatur for the reasons already indited above. Resultantly I allow this writ petition and set aside Ext.P17. Sd/- ``` DEVAN RAMACHANDRAN JUDGE ``` ``` MC/18.1 ``` ## **`WP(C) NO. 15859 OF 2018 13`** ## **`APPENDIX OF WP(C) 15859/2018`** |`PETITIONER EXHIBITS`|| |---|---| |`EXHIBIT P1`|`COPY OF THE RELEVANT PORTION OF THE`| ||`BYELAWS OF THE ADAT FARMERS’ SERVICE CO-`| ||`OPERATIVE BANK.`| |`EXHIBIT P2`|`COPY OF THE ORDER PASSED BY THE HON'BLE`| ||`SUPREME COURT IN SLP(C)NO.17964/2014 DATED`| ||`24.03.2017`| |`EXHIBIT P3`|`COPY OF THE ORDER NO. C.R.P.4383/2016`| ||`DATED 09.09.2016 PASSED BY THE 1ST`| ||`RESPONDENT`| |`EXHIBIT P4`|`COPY OF THE ORDER NO. C.R.P 6845/11DATED`| ||`04.01.2012 PASSED BY THE 1ST RESPONDENT`| |`EXHIBIT P5`|`COPY OF THE ORDER IN W.P.(C)NO.38905/2016`| ||`DATED 13.12.2016 PASSED BY THIS HON'BLE`| ||`COURT`| |`EXHIBIT P6`|`COPY OF THE DECISION OF THE MANAGING`| ||`COMMITTEE OF THE BANK DATED 17.12.2016`| |`EXHIBIT P7`|`COPY OF THE DECISION OF THE MANAGING`| ||`COMMITTEE OF THE BANK DATED 28.12.2016`| |`EXHIBIT P8`|`COPY OF THE REQUEST FOR LOAN SUBMITTED BY`| ||`THE THRISSUR PADDY FARMER'S PRODUCERS`| ||`COMPANY DATED 27.01.2017`| |`EXHIBIT P9`|`COPY OF THE DECISION NO.22 OF THE MANAGING`| ||`COMMITTEE OF THE BANK DATED 28.01.2017`| |`EXHIBIT P9(A)`|`COPY OF THE DECISION NO.23 OF THE MANAGING`| ||`COMMITTEE OF THE BANK DATED 28.01.2017`| |`EXHIBIT P9(B)`|`COPY OF THE DECISION NO.24 OF THE MANAGING`| ||`COMMITTEE OF THE BANK DATED 28.01.2017`| |`EXHIBIT P10.`|`COPY OF THE ORDER NO. C.R.P.6567/2016`| ||`DATED 12.04.2017 PASSED BY THE 1ST`| ||`RESPONDENT`| |`EXHIBIT P11`|`COPY OF THE ORDER IN W.P.(C)NO.14016/2017`| ||`DATED 21.04.2017 PASSED BY THIS HON'BLE`| ||`COURT`| |`EXHIBIT P12`|`COPY OF THE AFFIDAVIT IN W.P.`| ||`(C)NO.14016/2017 DATED 28.07.2017 FILED`| ||`BEFORE THIS HON'BLE COURT`| |`EXHIBIT P13`|`COPY OF THE COUNTER AFFIDAVIT IN`| ||`W.P(C)NO.14016/2017 DATED 20.04.2017 FILED`| ||`BEFORE THIS HON’BLE COURT.`| |`EXHIBIT P14`|`COPY OF THE ORDER NO. C.R.P.6567/2016`| ||`DATED 10.10.2017 PASSED BY THE 1ST`| ||`RESPONDENT`| |`EXHIBIT P15`|`COPY OF THE NOTICE NO. C.R.P.821/2018`| ## **`WP(C) NO. 15859 OF 2018 14`** - `DATED 07.03.2018 ISSUED BY THE 1ST RESPONDENT` - `EXHIBIT P16 COPY OF THE REPLY TO SECTION 32(1) NOTICE DATED 13.03.2018 SUBMITTED BY THE PETITIONER AND OTHER MANAGING COMMITTEE MEMBERS OF THE BANK` - `EXHIBIT P17 COPY OF THE ORDER NO. C.R.P.821/2018 DATED 06.04.2018 PASSED BY THE 1ST RESPONDENT` - `EXHIBIT P18 COPY OF THE ORDER NO. C.R.P.821/2018 DATED 12.03.2018 PASSED BY THE 1ST RESPONDENT` - `EXHIBIT P19 COPY OF THE NOTICE ISSUED BY THE 1ST RESPONDENT UNDER SECTION 68(1) AGAINST THE ELECTED MANAGING COMMITTEE MEMBERS OF THE BANK DATED 19.3.2018` - `EXHIBIT P20 COPY OF THE COMMUNICATION DATED 23.03.2018 SENT BY THE PETITIONER TO THE ASSISTANT REGISTRAR (PLANING), FOR PRELIMINARY ENQUIRY FOR SURCHARGE PROCEEDINGS` - `EXHIBIT P21 COPY OF THE NOTICE NO. C.R.P.2613/2018 DATED 04.04.2018 ISSUED BY THE 1ST RESPONDENT ALONG WITH ENQUIRY REPORT` ``` RESPONDENT EXHIBITS EXHIBIT R1(A)A TRUE COPY OF THE ABOVE ORDER NO.C.R.P.6567/2016 DATED 12.04.2017. EXHIBIT R1(B)A TRUE COPY OF THE COMMUNICATION NO.CRP 6567/2016 DATED 15.05.2017. EXHIBIT R1(C)A TRUE COPY OF THE COMMUNICATION NO. SS/TEC/005/17-18 DATED 12.05.2017 GIVEN BY MESSERS, SESAME SOFTWARE SOLUTIONS PRIVATE LIMITED. EXHIBIT R1(D)A TRUE COPY OF THE REPORT DATED 04.05.2017 FROM THE 3RD RESPONDENT. EXHIBIT R1(E)A TRUE COPY OF THE REPORT NO.1852/17 DATED 09.05.2017. EXHIBIT R1(F)TRUE COPY OF THE CONSULTATION LETTER DATED 22-03-2018 ISSUED TO THE FINANCING BANK AND THE CIRCLE CO-OPERATIVE UNION EXHIBIT R1(G)TRUE COPY OF THE LETTER DATED 26.03.2018 OF THE THRISSUR CIRCLE CO-OPERATIVE UNION EXHIBIT R1(H)TRUE COPY OF THE LETTER DATED 26.03.2018 OF THE THRISSUR DISTRICT CO-OPERATIVE BANK, WHICH IS THE FINANCING BANK EXHIBIT R1(I)TRUE COPY OF THE NOTICE UNDER SECTION 32(1) DATED 07.03.2018 EXHIBIT R1(J)TRUE COPY OF THE ACKNOWLEDGEMENT CARD FOR PROOF RECEIPTS OF NOTICE ```