O/E/N India Limited v. Director General of Police & State Police Chief, Kerala & Others

## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** ## **THE HONOURABLE MR. JUSTICE ANIL K.NARENDRAN** **MONDAY, THE 22ND DAY OF FEBRUARY 2021 / 3RD PHALGUNA, 1942** ## **WP(C).No.1048 OF 2021(E)** ## **PETITIONER:** **O/E/N INDIA LIMITED.,** **REGISTERED OFFICE AT THRIPUNITHURA ROAD, VYTTILA , COCHIN-682 019, REPRESENTED BY ITS CHAIRMAN AND MANAGING DIRECTOR.** **BY ADVS. SMT.LATHA ANAND SRI.S.VISHNU (ARIKKATTIL) SHRI.SIDHARTH P.S. SRI.ROHITH MOHAN SHRI.GAUTHAM DEV C.P. SHRI.RISHI VARMA T.R.** ## **RESPONDENTS:** - **1 DIRECTOR GENERAL OF POLICE AND STATE POLICE CHIEF, STATE POLICE CHIEF, KERALA, POLICE HEADQUARTERS, VAZHUTHACAUD, THIRUVANANTHAPURAM, KERALA-695 010** - **2 DISTRICT COLLECTOR, ERNAKULAM, CIVIL STATION, KAKKANAD, KERALA, PIN-682 030** - **3 DISTRICT POLICE CHIEF, ERNAKULAM RURAL, DISTRICT POLICE OFFICE, SH 16, OPP. POWER HOUSE, ALUVA, KERALA-683 101** - **4 DEPUTY SUPERINTENDENT OF POLICE, MUVATTUPUZHA, VELLOORKUNNAM PART, ERNAKULAM, PIN-686 661** - **5 C.I. OF POLICE, CHOTTANIKKARA, CHOTTANIKKARA VANDIPETTA ROAD, CHOTTANIKKARA, KERALA-682 312** - **6 C.I. OF POLICE, PUTHENCRUZ, CHOONDI, KOCHI- MADURAI-TONDI POINT RD, PUTHENKURISH, KERALA-682 308** WP(C).No.1048 OF 2021(E) 2 - **7 C.I. OF POLICE, PIRAVOM, PUMP-POLICE STATION LINK ROAD, PIRAVOM,KERALA 686 664.** - **8 C.I. OF POLICE, MULANTHURUTHY, KARAVATTA KURIZ, MULANTHURUTHY-ARAKKUNNAM ROAD, KANJIRAMATTOM, MULANTHURUTHY, KERALA-682 314** - **9 O/E/N INDIA EMPLOYEES ASSOCIATION, REPRESENTED BY ITS GENERAL SECRETARY, ELECTROGIRI, VETTIKKAL, MULANTHURUTHY P.O-682 314** - **10 O/E/N INDIA EMPLOYEES UNION, REPRESENTED BY ITS GENERAL SECRETARY, ELECTROGIRI, VETTIKKAL, MULANTHURUTHY, P.O-682 314** - **11 O/E/N INDIA WORKERS UNION , REPRESENTED BY ITS GENERAL SECRETARY, ELECTROGIRI, VETTIKKAL, MULANTHURUTHY P.O-682 314** **12 O/E/N INDIA EXECUTIVE UNION, REPRESENTED BY ITS GENERAL SECRETARY, ELECTROGIRI, VETTIKKAL, MULANTHURUTHY P.O-682 314 R1-8 BY SRI.K.V.SOHAN, STATE ATTORNEY R10 BY ADV. SRI.BIJU .C. ABRAHAM R11 BY ADV. SRI.K.S.ARUN KUMAR R11 BY ADV. SRI.JUSTINE JACOB R11 BY ADV. SMT.BINDU MOHAN R11 BY ADV. SMT.AMRUTHA P S R11 BY ADV. SMT.AMRUTHA K P R11 BY ADV. SHRI.VIJAY SANKAR V.H. R11 BY ADV. SHRI.ARJUN KUMAR K.S. R12 BY ADV. SRI.ASOK M.CHERIAN R12 BY ADV. SRI.N.SATHEESH R1 TO R8 BY SRI K.V.SOHAN- STATE ATTORNEY** **THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 22.02.2021, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** WP(C).No.1048 OF 2021(E) 3 ## **JUDGMENT** The petitioner Company, which is engaged in the manufacture of relays, switches, electro mechanical components and various other electronic systems and sub-systems, has filed this writ petition under Article 226 of the Constitution of India, seeking a writ of mandamus commanding respondents 1 to 8 to give adequate, effective and timely police protection for the petitioner company, its willing workers, executives and managerial personnel from the obstructions caused by the 12[th] respondent, their members, allies and sympathisers and to restrain them from causing any obstructions to the ingress and egress of consignments, staff, workers, vehicles, etc. to the premises of factory. The petitioner has also sought for a writ of mandamus commanding respondents 1 to 8 to give adequate, effective and timely police protection to carry on the business activities without being obstructed by the members of 12[th] respondent union, their members, allies and sympathisers; a writ of mandamus commanding respondents 1 to 8 to shift the panthal erected by the 12[th] respondent to a safe location to prevent any untoward incidents; and a declaration that the executive employees are not WP(C).No.1048 OF 2021(E) 4 workmen under the Industrial Disputes Act,1947 and therefore they have no right to work invoking the provisions of the said Act. 2. On 14.01.2021, when this writ petition came up for admission, the learned Government Pleader took notice on admission for respondents 1 to 8. Urgent notice on admission by special messenger was ordered to respondents 9 to 12, returnable by 15.01.2021. By the order dated 14.01.2021, the 5[th] respondent Station House Officer was directed to ensure that there is no threat to law and order in the locality, at the instance of respondents 9 to 12 and their members. 3. On 15.01.2021, when this writ petition came up for consideration, this Court passed an interim order directing the 8[th] respondent Circle Inspector of Police, Mulanthuruthy Police Station to give adequate police protection to the petitioner company, its willing workers, etc., from the obstructions caused by the 12[th] respondent and its members. Paragraphs 6 to 12 read thus: “6. The learned Senior Counsel for the petitioner would point out that on 10.01.2021, the members of the 12[th] respondent Union raised a 'Panthal' near the main gate of the factory. The members of the said Union, with the support of a gang of persons, forcibly obstructed the non striking workers, executives and managerial personnel, who WP(C).No.1048 OF 2021(E) 5 reported for duty at the commencement of various shifts commencing from 7.00 a.m and 8.30 a.m. They have also threatened that they would not permit the non striking workers, executives and managerial personnel to enter the factory. 7. From the submissions made by the learned Senior Counsel for the petitioner and also the learned counsel for the 12[th] respondent, this Court finds that there is certain disputes between the Management and the employees, who are members of 12[th] respondent Union. The members of the 12[th] respondent Union are staging protest against the Management, in front of the factory. 8. The learned counsel for the 12[th] respondent Union would submit that the members of that Union have absolutely no intention to take law into their hands or cause any obstruction whatsoever to the functioning of the factory and they will only conduct peaceful agitation, within the permissible limits. 9. The learned counsel for the 10[th] respondent Trade Union would submit that the members of that Union are prepared to work, provided there is no threat to their life. 10. The learned Government Pleader, on instructions from the 8[th] respondent Circle Inspector of Police, Mulanthuruthy Police Station, would submit that at present there is no law and order problems in the locality. 11.Having considered the submissions made by the learned counsel on both sides, this Court finds that there are certain disputes between the Management and the members of the 12[th] respondent Union. Now, the members of the 12[th] respondent Union are staging protest against the WP(C).No.1048 OF 2021(E) 6 Management in front of the factory at Mulanthuruthy. They have absolutely no legal right to cause obstruction to the ingress and egress of staff, workers, vehicles, consignments, etc. to the premises of the factory or to threaten the Management or the willing staff and workers or to cause any obstruction to the functioning of the factory. 12. In such circumstances, there will be an interim order directing the 8[th] respondent Circle Inspector of Police, Mulanthuruthy Police Station to give adequate, effective and timely police protection to the petitioner Company, its willing workers, executives and managerial personnel from the obstructions caused by the 12[th] respondent and their members and to restrain them from causing any obstruction to the ingress and egress of staff, workers, vehicles, consignments, etc., to the premises of the factory at Mulanthuruthy.” 4. Thereafter, on 19.01.2021, in I.A.No.1 of 2021, this Court directed respondents 3 to 7, in additional to the 8[th] respondent to extent adequate police protection to the willing workers, executives, etc., of the petitioner company, from the members of the 12[th] respondent union and their allies and sympathisers, at any place within the jurisdiction of respondents 3 to 8. The 3[rd] respondent District Police Chief was directed to take necessary steps to ensure strict compliance of the directions contained in the order dated 15.01.2021 and that contained in this WP(C).No.1048 OF 2021(E) 7 order, by respondents 4 to 8 and their subordinates. Paragraphs 6 to 9 of that order read thus; “6. The learned Senior Counsel for the petitioner would submit that the petitioner has already taken photographs of the obstructions caused by members of the 12[th] respondent Union and their supporters, which shall be placed on record along with an application to accept additional document. 7. The learned counsel for the 12[th] respondent would deny the allegations in the affidavit filed in support of the I.A and seeks time to file counter affidavit. 8. The learned Government Pleader on instructions would submit that at present the 5[th] respondent Circle Inspector of Police, Chottanikkara and the 7[th] respondent Circle Inspector of Police, Piravom are taking earnest efforts along with the 8[th] respondent Circle Inspector of Police to ensure that there is no threat to law and order in the locality or any obstruction to free ingress and egress to the petitioner's factory at Mulanthuruthy. 9. Having considered the submissions made by the learned counsel on both sides, this Court deem it appropriate to direct respondents 3 to 7, in addition to the 8[th] respondent to extend adequate, timely and effective police protection to the willing workers, executives and managerial personnel to enter the company without being obstructed by the members of the 12[th] respondent union their allies and sympathizers WP(C).No.1048 OF 2021(E) 8 at any place within the jurisdiction of respondents 3 to 8. The 3[rd] respondent District Police Chief shall take necessary steps to ensure that the directions contained in the order of this Court dated 15.01.2021 and that contained in this order are complied with in letter and spirit by respondents 4 to 8 and their subordinates.” 5. On 20.01.2021, when the matter was taken up for consideration, it was submitted by the learned Senior Counsel for the petitioner that only 10 office staff could enter the factory premises and plant workers could not enter on account of the obstruction caused by the members of the 12[th] respondent Union. The learned Government Pleader and also the learned counsel for the 12[th] respondent sought time to get instructions. The said order was followed by the order dated 21.01.2021, which reads thus; “Heard the learned Senior Counsel for the petitioner, the learned State Attorney appearing for respondents 1 to 8, the leaned counsel for the 11[th] respondent and also the learned counsel for the 12[th] respondent. 2. The learned Senior Counsel for the petitioner would submit that today certain untoward incidents happened at Vettickal in Mulanthuruthy and also at Mamala, where the vehicles transporting employees to the petitioner comp nay were attacked by the supporters of the 12[th] respondent Union. Around 355 workers could only enter the factory during the morning shift. Even now there is obstruction from certain persons. WP(C).No.1048 OF 2021(E) 9 3. The learned State Attorney, on instructions, would submit that immediately on receipt of complaint from the HR Manager of the petitioner company regarding the incidents at Vettickal and Mamala, the 4[th] respondent and his subordinates have taken immediate action to remove the obstructions. The learned State Attorney, on behalf of the 4[th] respondent Deputy Superintendent of Police, undertakes to comply with the orders of this Court dated 15.01.2021 and 19.01.2021 granting police protection in letter and spirit. The learned State Attorney would submit that jurisdictional Station House Officers and their subordinates shall ensure the functioning of the petitioner's factory without any threat or obstruction from the 12[th] respondent Union, its members and supporters. 4. The above undertaking given by the learned State Attorney, on behalf of the 4[th] respondent, is recorded. 5. The learned State Attorney would point out that the Labour Commissioner, Ernakulam has called for a conciliation meeting on 25.01.2021. 6. The learned Senior Counsel for the petitioner would submit that an authorised representative of the management shall appear before the Labour Commissioner on 25.01.2021, who will submit written submission raising appropriate legal and factual contentions. 7. The learned counsel for the 11[th] respondent would submit that the workers of the 11[th] respondent Union are not being obstructed from entering the factory WP(C).No.1048 OF 2021(E) 10 premises. 8. The learned counsel for the 12[th] respondent would sub it that the members of the 12[th] respondent Union or their supporters are not causing any obstruction whatsoever to the functioning of factory.” 6. Heard the learned counsel for the petitioner, the learned State Attorney for respondents 1 to 8, the learned counsel for the 11[th] respondent and also the learned counsel for the 12[th] respondent. 7. The Kerala Police Act, 2011 is enacted to consolidate and amend the law relating to the establishment, regulation, powers and duties of the Police Force in the State of Kerala and for matters connected therewith and incidental thereto. Chapter II of the Act deals with duties and functions of Police. Section 3 of the Act deals with general duties of Police. As per Section 3, the Police, as a service functioning category among the people as part of the administrative system shall, subject to the Constitution of India and the laws enacted thereunder, strive in accordance with the law, to ensure that all persons enjoy the freedoms and rights available under the law by ensuring peace and order, integrity of the nation, security of the State and protection of human rights. Section 4 of the Act deals with functions of Police. As per Section 4, the Police WP(C).No.1048 OF 2021(E) 11 Officers shall, subject to the provisions of the Act, perform the functions enumerated in clauses (a) to (s) of Section 4. As per clause (a), the Police Officers shall enforce the law impartially; and as per clause (b), the Police Officers shall protect the life, liberty, property, human rights and dignity of all persons in accordance with the law. 8. Lord Denning in 'The Due Process of law' [First Indian Reprint 1993, Page 102] has described the role of the Police thus; "In safeguarding our freedoms, the police play vital role. Society for its defence needs a well-led, well-trained and well-disciplined force or police whom it can trust, and enough of them to be able to prevent crime before it happens, or if it does happen, to detect it and bring the accused to justice. The police, of course, must act properly. They must obey the rules of right conduct. They must not extort confessions by threats or promises. They must not search a man's house without authority. They must not use more force than the occasion warrants." 9. In **Manohar Lal Sharma v. Principal Secretary [(2014) 2 SCC 532]** the Apex Court held that, one of the responsibilities of the police is protection of life, liberty and property of citizens. The investigation of offences is one of the important duties the police has to perform. The aim of investigation WP(C).No.1048 OF 2021(E) 12 is ultimately to search for truth and bring the offender to the book. The Apex Court reiterated the said principle in **Ankush Maruti Shinde v. State of Maharashtra [(2019) 15 SCC 470]** . 10. In **Gujarat Steel Tubes Ltd. Vs. Gujarat Steel Tubes Mazdoor Sabha [(1980) 2 SCC 593]** the Apex Court held that, the right to unionise, the right to strike as part of collective bargaining and subject to the legality and humanity of the situation, the right of the weaker group viz. labour, to pressure the stronger party viz. capital, to negotiate and render justice, are processes recognised by industrial jurisprudence and supported by Social Justice. While society itself, in its basic needs of existence, may not be held to ransom in the name of the right to bargain and strikers must obey civilised norms in the battle and not be vulgar or violent hoodlums industry, represented by intransigent Managements, may well be made to reel into reason by the strike weapon and cannot then sequeal or wail and complain of loss of profits or other ill-effects but must negotiate or get a reference made. The broad basis is that workers are weaker although they are the producers and their struggle to better their lot has the sanction of the rule of law. Unions and strikers are no more WP(C).No.1048 OF 2021(E) 13 conspiracies than professions and political parties, are, and being far weaker, need succour. Part IV of the Constitution, read with Article 19, sows the seed of this burgeoning jurisprudence. The Gandhian quote at the beginning of the judgment [Para.5 @ Page 603 SCC] sets the tone of economic equity in industry. Of course, adventurist, extremist, extraneously inspired and puerile strike, absurdly insane persistence and violent or scorched earth policies boomerang and are anathema for the law. Within these parameters the right to strike is integral to collective bargaining. 11. The learned State Attorney would submit that at present, there is no law and order issues in the locality and respondents 3 to 8 shall take necessary steps to ensure that there is no threat to law and order in the locality in connection with any protest/agitation by the members of the 12[th] respondent union. 12. The learned Senior Counsel for the petitioner would submit that after the interim order of this Court dated 15.01.2021, the police has rendered necessary protection from any threat or obstructions from the side of the members of the 12[th] respondent union and their supporters. In the conciliation proceedings before the Additional Labour Commissioner, Thiruvananthapuram the WP(C).No.1048 OF 2021(E) 14 petitioner has submitted Ext.P23 written submission dated 25.01.2021, raising a specific contention that the members of the 12[th] respondent union will not come under the purview of 'workman', as defined in clause (s) of Section 2 of the Industrial Disputes Act, 1947 and that the dispute raised by the said union will not come within the purview of an 'industrial dispute', as defined in clause (k) of Section 2 of the said Act. The learned Senior Counsel would submit that, as specifically contended in Ext.P23, the Assistant Labour Commissioner has absolutely no authority or jurisdiction to hold conciliation proceedings under the provisions of the said Act. Therefore, the contention raised by the learned counsel for the 11[th] respondent union and also the learned counsel for the 12[th] respondent union that the petitioner management is not cooperating with the conciliation proceedings is absolutely untenable. 13. Having considered the submissions made by the learned counsel on both sides, this writ petition is disposed of with the following directions: - (i) The respondents 3 to 8 shall take necessary steps to ensure that there is no threat to law and order in the locality, in connection with any protest/agitation by the WP(C).No.1048 OF 2021(E) 15 members of the 12[th] respondent union or their supporters. (ii) In case there is any threat to life and property of the petitioner, its staff, employees, workers, etc., from the side of the members of the 12[th] respondent union and their supporters, the petitioner shall move respondents 5 to 8 Station House Officers with a request for Police protection. (iii) In case any such request for Police protection is made by the petitioner, the respondents 5 to 8 shall take necessary action on that request, without any delay, taking note of the statutory provisions referred to hereinbefore and also the law laid down in the decisions referred to supra. (iv) The petitioner management and the 12[th] respondent union shall participate in the conciliation proceedings, which is pending before the Additional Labour Commissioner, Thiruvananthapuram, who shall proceed with the matter further only after considering the specific contention raised by the management as to maintainability of such proceedings, in view of the provisions under the Industrial Disputes Act, 1947. No order as to costs. **Sd/-** ## **ANIL K.NARENDRAN** JV ## **JUDGE** WP(C).No.1048 OF 2021(E) 16 ## **APPENDIX** ## **PETITIONER'S/S EXHIBITS:** **EXHIBIT P1 TRUE SPECIMEN COPY OF TRANSFER ORDER ISSUED TO SIDDHARTHA JYOTHIS. EXHIBIT P2 TRUE SPECIMEN COPY OF TRANSFER ORDER ISSUED TO SIDDARTHA JYOTHIS. EXHIBIT P3 TRUE COPY OF REPRESENTATION DATED 15.12.2020 SUBMITTED BEFORE THE CONCILIATION OFFICER. EXHIBIT P4 PETITION DATED O9.01.2021 FILED BEFORE THE 5TH RESPONDENT CI OF POLICE. EXHIBIT P5 PETITION DATED 11.01.2021 FILED BEFORE THE 5TH RESPONDENT CI OF POLICE. EXHIBIT P6 PETITION DATED 12.01.2021 FILED BEFORE THE 5TH RESPONDENT CI OF POLICE. EXHIBIT P7 TRUE COPY OF LETTER DATED 16.1.2021 GIVEN BY PRINCY TRAVELS. EXHIBIT P8 COPIES OF THE WILLINGNESS OF THE EMPLOYEES. EXHIBIT P9 TRUE COPY OF PHOTOGRAPH SHOWING THE OBSTRUCTION EXHIBIT P10 TRUE COPY OF HTE PHOTOGRAPH SHOWING HTE WILLING EMPLOYEES BEING HELD UP NEAR GLOBAL PUBLIC SCHOOL EXHIBIT P11 TRUE COPY OF HTE PHOTOGRAPH SHOWING OBSTRUCTION CAUSED TO THE BUS ENGAGED BY THE PETITIONER FOR FERRYING THE EMPLOYEES OF THE PETITIONER ON 16.01.2021 EXHIBIT P12 TRUE COPY OF THE PHOTOGRAPH DATED 19.01.2021 OBSTRUCTING WILLING EMPLOYEES AT VETTIKAL JUNCTION EXHIBIT P13 PHOTOGRAPH WHOING SIMILAR OBSTRUCTION NEAR 'APTIVE' COMPANY** WP(C).No.1048 OF 2021(E) 17 **EXHIBIT P14** **PHOTOGRAPH OF THE SIMILAR BLOCKADE WAS DONE BY THE 12TH RESPONDENT NEAR STELLA MARY SCHOOL ON 16.01.2021** **EXHIBIT P15 PHOTOGRAPH OF THE SIMILAR BLOCKADE WAS DONE BY THE 12TH RESPONDENT NEAR STELLA MARY SCHOOL ON 18.01.2021** **EXHIBIT P16 TRUE COPY OF THE COMPLAINT FILD BY THE SMT.NISHA T.P. TO THE MANAGING DIRECTOR DATED 16.01.2021** **EXHIBIT P16(A) SIMILAR COMPLAINTS FILED BY AMRUTHA U TO THE MANAGING DIRECTOR DATED 16.01.2021** - **EXHIBIT P16(B) SIMILAR COMPLAINTS FILED BY GANGA K TO THE MANAGING DIRECTOR DATED 16.01.2021** - **EXHIBIT P16(C) SIMILAR COMPLAINTS FILED BY MANJESH MATHEW TO THE MANAGING DIRECTOR DATED 16.01.2021** - **EXHIBIT P16(D) SIMILAR COMPLAINTS FILED BY ARUN K TO THE MANAGING DIRECTOR DATED 16.01.2021** - **EXHIBIT P16(E) SIMILAR COMPLAINTS FILED BY DIVYA P.MENON TO THE MANAGING DIRECTOR DATED 16.01.2021** - **EXHIBIT P16(F) SIMILAR COMPLAINTS FILED BY DEEPTHI K MATHAI TO THE MANAGING DIRECTOR DATED 16.01.2021** - **EXHIBIT P16(G) SIMILAR COMPLAINTS FILED BY JOJO MATHEW TO THE MANAGING DIRECTOR DATED 16.01.2021** - **EXHIBIT P16(H) SIMILAR COMPLAINTS FILED BY HARISHANKAR R TO THE MANAGING DIRECTOR DATED 16.01.2021** - **EXHIBIT P17 TRUE COPY OF THE COMPLAINT FILED BY MR.MANJESH MATHEW TO THE MANAGING DIRECTOR DATED 18.01.2021** **EXHIBIT P17(A) SIMILAR COMPLAINTS FILED BY DEEPTHI P.N. TO THE MANAGING DIRECTOR DATED 18.01.2021** **EXHIBIT P17(B) SIMILAR COMPLAINTS FILED BY DEEPTHI K MATHAI TO THE MANAGING DIRECTOR DATED 18.01.2021** WP(C).No.1048 OF 2021(E) 18 - **EXHIBIT P17(C) SIMILAR COMPLAINTS FILED BY ARUN K TO THE MANAGING DIRECTOR DATED 18.01.2021** - **EXHIBIT P17(D) SIMILAR COMPLAINTS FILED BY DIVYA P MENON TO THE MANAGING DIRECTOR DATED 18.01.2021** - **EXHIBIT P17(E) SIMILAR COMPLAINTS FILED BY HARISHANKAR R TO THE MANAGING DIRECTOR DATED 18.01.2021** - **EXHIBIT P17(F) SIMILAR COMPLAINTS FILED BY JOJO MATHEW TO THE MANAGING DIRECTOR DATED 18.01.2021** - **EXHIBIT P17(G) SIMILAR COMPLAINTS FILED BY SANDEEP K.M. TO THE MANAGING DIRECTOR DATED 18.01.2021** - **EXHIBIT P18 TRUE COPY OF THE COMPLAINT FILED BY SMT.NISHA T.P. TO THE MANAGING DIRECTOR DATED 19.01.2021** - **EXHIBIT P18(A) SIMILAR COMPLAINTS FILED BY ARUN K TO THE MANAGING DIRECTOR DATED 19.01.2021** - **EXHIBIT P18(B) SIMILAR COMPLAINTS FILED BY SANDEEP K.M. TO THE MANAGING DIRECTOR DATED 19.01.2021** - **EXHIBIT P18(C) SIMILAR COMPLAINTS FILED BY MANJESH MATHEW TO THE MANAGING DIRECTOR DATED 19.01.2021** - **EXHIBIT P18(D) SIMILAR COMPLAINTS FILED BY JUVENA SHAJI TO THE MANAGING DIRECTOR DATED 19.01.2021** - **EXHIBIT P18(E) SIMILAR COMPLAINTS FILED BY SUMA SEELA TO THE MANAGING DIRECTOR DATED 19.01.2021** - **EXHIBIT P18(F) SIMILAR COMPLAINTS FILED BY DIVYA P.MENON TO THE MANAGING DIRECTOR DATED 19.01.2021** - **EXHIBIT P18(G) SIMILAR COMPLAINTS FILED BY BEENA K.MATHEW TO THE MANAGING DIRECTOR DATED 19.01.2021** - **EXHIBIT P19 TRUE COPY OF THE COMPLAINT FILED BY THE DEPUTY GENERAL MANAGER (HR) OF THE PETITIONER COMPANY BEFORE THE CIRCLE INSPECTOR OF POLICE, CHOTTANIKKARA DATED 16.01.2021** **EXHIBIT P20 TRUE COPY OF THE RECEIPT OF THE** WP(C).No.1048 OF 2021(E) 19 **ACKNOWLEDGEMENT RECEIPT OF EXT.P19** **EXHIBIT 21 TRUE COPY OF HTE COMPLAINT FILED BY THE DEPUTY GENERAL MANAGER (HR) OF THE PETITIONER COMPANY BEFORE HTE CIRCLE INSPECTOR OF POLICE, CHOTTANIKKARA DATED 18.01.2021** **EXHIBIT P22 TRUE COPY OF THE RECEIPT OF THE ACKNOWLEDGMENT RECEIPT OF EXT.P21** **EXHIBIT P23 TRUE COPY OF THE SUBMISSION DATED 25.1.2021 MADE BY THE PETITIONER BEFOR EHTE ADDITIONAL LABOUR COMMISSIONER**