OP(KAT) No.342 of 2020

# **IN THE HIGH COURT OF KERALA AT ERNAKULAM** **PRESENT** **THE HONOURABLE MR. JUSTICE ALEXANDER THOMAS** **&** **THE HONOURABLE MR.JUSTICE K. BABU** **WEDNESDAY, THE 03RD DAY OF MARCH 2021 / 12TH PHALGUNA, 1942** ## **OP(KAT).No.342 OF 2020** **AGAINST THE ORDER IN TA 6902/2012 DATED 26-03-2018 OF KERALA ADMINISTRATIVETRIBUNAL, THIRUVANANTHAPURAM** ## **PETITIONER/RESPONDENT IN T.A:** - **1 THE STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, HEALTH AND FAMILY WELFARE DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN-695001.** - **2 THE DIRECTOR OF HOMEO DIRECTORATE OF HOMEO, THIURVANANTHAPURAM,PIN-695023.** - **3 THE DISTRICT MEDICAL OFFICER(HOMEO) THRISSUR, PIN-680004.** - **4 THE HOMEO MEDICAL OFFICER HOMEO DISPENSARY, ELANAD, THRISSUR, PIN-680586** - **5 THE SECRETARY TO GOVERNMENT FINANCE DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN-695001.** **BY SRI.B.VINOD, SR.GOVERNMENT PLEADER RESPONDENT/APPLICANT IN T.A:** - **R.SUSHAMA, AGED 46 YEARS W/O UNNIKRISHNAN, PART TIME SWEEPER ON FIXED REMUNERATION, GOVERNMENT HOMEO DISPENSARY, ELANAD, THRISSUR, RESIDING AT RARIYAMKUNDATH,ELANAD P O, CHELAKKARA (VIA), THRISSUR, PIN-680586. R1 BY ADV. SRI.M.V.THAMBAN R1 BY ADV. SRI.R.REJI R1 BY ADV. SRI.ARUN BOSE R1 BY ADV. SMT.THARA THAMBAN R1 BY ADV. SRI.B.BIPIN** **THIS OP KERALA ADMINISTRATIVE TRIBUNAL HAVING BEEN FINALLY HEARD ON 03.03.2021, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** O.P (KAT) No.342 of 2020 2 ## **ALEXANDER THOMAS & K.BABU, JJ.** ## **===========================** ## **O.P (KAT) No.342 of 2020** [ _arising out of the impugned final order dated 26.03.2018. in T.A No.6902/2012 on the file of the KAT, Tvm. Bench_ ], **===========================** Dated this the 03[rd] day of March, 2021 ## **JUDGMENT** ## **ALEXANDER THOMAS, J.** The prayers in the aforecaptioned Original Petition (KAT) filed under Articles 226 & 227 of the Constitution of India are as follows (see page No.8 of the paper book of this O.P) : - _“1. To set aside the Annexure A2 Order of the Kerala Administrative Tribunal in O.A.No.6902/2012._ _2. To dismiss the Annexure A1 Original Application No.6902/2012 filed by the Respondent before the Kerala Administrative Tribunal, holding that the said Respondent is not eligible for any of the reliefs claimed in the Exhibit P1 Original Application._ _3. Any other order or direction as this Honourable Tribunal may deem fit and proper in the facts and circumstances of the case.”_ 2. Heard Sri.B.Vinod, learned Senior Government Pleader appearing for the petitioners-State of Kerala and 4 others in the O.P/respondents in the T.A before the Tribunal & Sri.M.V.Thamban, learned counsel appearing for the sole respondent in the O.P/sole O.P (KAT) No.342 of 2020 3 applicant in the T.A before the Tribunal. 3. The prayers in Annexure-A1 Transferred Application, T.A No.6902/2012 filed by the respondent herein are as follows (see page No.20 of this paper book) : - _“i) To sanction a post of Part-time Sweeper is required in respect of the petitioner in the Homeo Dispensary at Elanad where petitioner is working._ - _ii) To regularise the petitioner as Part-time Sweeper and accommodate her in that post to be created._ - _iii) To extend the regular scale of pay as applicable to regular Part-time Sweepers to the petitioner also. Along with consequential arrears from her date of original engagement._ - _iv) To issue such other further reliefs as this Honourable Court may deem fit and proper in the facts and circumstances of this case.”_ 4. The Tribunal after hearing both sides have rendered the impugned Annexure-A2 final order dated 26.03.2018 in T.A No. 6902/2012, wherein it has been held that the 1[st] respondent in the T.A (competent authority of the Government in the Health & Family Welfare Department), should consider the claim of the original applicant for regularization of her service as Part-Time Sweeper in terms of Ext.P-2 G.O (P) No.501/2005/Fin. dated 25.11.2005 in the light of the sweeping area certificate dated 31.12.2014 issued by the Assistant Engineer, PWD, Wadakkancherry and that the 1[st] respondent shall pass orders in that O.P (KAT) No.342 of 2020 4 regard in the matter of regularization of the original applicant, within two months, etc. It is this final order rendered by the Tribunal at Annexure-A2 that is under challenge in this original petition. 5. The Tribunal after hearing both sides based on the pleadings and materials on record, has noted that the original applicant has been working as Part-Time Sweeper in the Government Homeo dispensary, Elanad, Thrissur from September, 1994 onwards on a fixed remuneration. The Government has issued Ext.P-2 G.O(P) No.501/2005 (Fin.) dated 25.11.2005 (see page Nos.24 to 28 of this paper book), whereby it has been ordered that Sweepers like the original applicant, who are working in Government offices prior to the issuance of the said G.O dated 25.11.2005 and where, the sweeping area is 100Sq.M. or above as on the date of issuance of the said G.O, then they are entitled for regularization by creating a post in that regard from the date of appointment of the incumbent as casual sweeper or from 18.06.2001 (three years preceding the date of the judgment of this Court referred to in the said G.O), whichever is later, etc. However, it goes without saying that if the date of appointment of the Sweeper is after the said date, but on any day on or before 25.11.2005 (date of issuance of Ext.P-2 G.O) and so long as the sweeping area is 100 Sq.M or above as O.P (KAT) No.342 of 2020 5 on that date, then the Sweeper is entitled for regularization from that date onwards. 6. In the instant case, though it was earlier found that the sweeping area of the work done by the petitioner was above 100 Sq.M at some point of time, though doubts had arisen in the mind of the authorities concerned, which led to the matter being referred for accurate re-measurement by the Chief Technical Examiner of the Government and it was found that the sweeping area involving the work of the applicant was below 100 Sq.M. At time, it has been found that the sweeping area was 138.68 Sq.M. which was later found to be below that, after such re-measurement process. However, it is common ground that later a fresh certificate dated 31.12.2014 has been issue by the Assistant Engineer of the Public Works Department, wherein it has been clearly certified that the sweeping area of the office of the petitioner has been engaged as Sweeper is 138.68 Sq.M., as can be seen from Ext.P1 certificate dated 31.12.2014 issued by the Assistant Engineer, Public Works Department, Building Section, Wadakkancherry, produced along with the counter affidavit dated 07.02.2021 filed by the respondent herein in this O.P (see page No.10 of the said counter affidavit). O.P (KAT) No.342 of 2020 6 7. The Tribunal found that the original applicant is entitled for regularization at least with effect from 31.12.2014, as it is admitted by the respondents in the T.A that the fresh certificate issued by the Assistant Engineer, Public Works Department, has clearly certified that the sweeping area concerned is 138.68 Sq.M. going by the norms. It is also relevant to note that later, the Government has issued Ext.R2(b) G.O (P) No.61/2010/Fin. dated 09.02.2010, whereby it has been noted in paragraph No.2 thereof (see page Nos.11 to 16 of the counter affidavit of the respondents filed in this O.P), it has been noted that as per conditions stipulated in Ext.P-2 G.O dated 25.11.2005, those who were working on daily wages and those working in offices having sweeping area below 100 Sq.M. were not entitled for regularization and number of such Sweepers, who were not benefited by the decisions taken by the Government, in accordance with the provisions contained in the said G.O dated 25.11.2005, have approached the High Court again, for payment on par with regular Part-Time Sweepers and regularization of service as Part-Time Sweepers, etc. and that this Court has issued directions in those cases as follows (see internal page No.2 of the said G.O dated 09.02.2010) : O.P (KAT) No.342 of 2020 7 _“i) Persons engaged for sweeping on daily wages are also entitled for regularization, since the Government Order read above do not specify that such categories are not entitled to this benefit._ _ii) The Government Order does not differentiate between temporary and permanent establishments._ _iii) The Government Order does not specify that, the Chief Technical Examiner of Finance Department can reassess the sweeping area once assessed by the Public Works Department authorities._ _iv) Sweepers who are in receipt of higher pay by virtue of Court orders are also entitled to the benefit of protection envisaged in clause 11 of the Government Order read above and subsequent revisions, even though the sweeping area is below 100 Sq.Mtrs on reassessment.”_ 8. Accordingly, it has been ordered by the Government in paragraph No.3 (i) of Ext.R1 (b) G.O dated 09.02.2010 that all existing sweepers, other than Casual Sweepers, irrespective of the mode of appointment, shall also be entitled for regularization based on the sweeping area, defined in Ext.P2 G.O dated 25.11.2005, provided their appointments were made on or before the issuance of G.O (P) dated 25.11.2005 and are continuing on such date of this order and the regularization will have effect from the date of this order only. Hence, it can be seen that where the Sweeper concerned has been working prior to the issuance of Ext.P-2 G.O dated 25.11.2005 and the sweeping area had not exceeded the minimum threshold level of 100 Sq.M or above, on or before 25.11.2005 (the date of issuance of Ext.P-2 G.O), but the O.P (KAT) No.342 of 2020 8 sweeping area had exceeded thereafter, but before the issuance of Ext.R1(b) G.O(P) dated 09.02.2010, then such Sweepers will also be entitled for regularization from the date of issuance of Ext.R1(b) G.O dated 09.02.2010, etc. 9. The Division Bench of this Court in various cases including the judgment dated 19.01.2019 in OP(KAT) No.26 of 2019 [arising out of O.A.No.1465 of 2017 on the file of KAT, Thiruvananthapuram] has held as follows in paragraph Nos.5 and 6 thereof as follows: _“5. On the basic fact there is no dispute at all. The fact that but for the break in service occurred on 15.6.2005 the respondent has been in continuous service in the 4th respondent's office, on casual basis from 1.10.2002. Though the sweeping area in the office concerned was less than 100 Sq.m with the renovation of the office in the year 2014, there occurred an increase in the sweeping area and it became 124.164 sq.ms. Taking into account the said circumstances, the 4th respondent forwarded a proposal for creation of posts and also recommended for the regularisation of the respondent in service. It is the delay on the part of the competent authority despite receipt of such proposal to consider the claim of the respondent for regularisation that constrained her to file the above mentioned Original Application, which culminated in the impugned order._ _6. A perusal of the impugned order would reveal that all the relevant aspects were taken into consideration by the Tribunal. The relevant Government Order dated 25.11.2005 carrying the guidelines for sanctioning of posts and also for regularising the casual/daily wage employees engaged in various offices was evidently taken into account by the Tribunal. Therefore, essential question is whether, solely because the sweeping area was below 100 sq.m till 2014, the respondents could hold it out to be a reason to deprive the benefit flowing from the said G.O dated 25.11.2005, to the petitioner. When the admitted position is that subsequent to the renovation of the office in question there occurred an increase in the sweeping area and thereby it became 124.164 Sq.m, cannot be ignored while considering that question. The Tribunal after considering the rival contentions had arrived at the conclusion that it could not be assigned as a reason for granting the benefit to the petitioner. Evidently, it was based on such consideration that the Tribunal found the respondent eligible for regularisation in terms of the said G.O dated 25.11.2005 and also the benefit of the subsequent G.O(P)No.61 of_ O.P (KAT) No.342 of 2020 9 _2010 dated 9.2.2010. It is an interpretation beneficial to the employee and it cannot be taken as a perverse or absurd interpretation considering the object behind issuance of the aforesaid Government Orders. We do not find any reason to hold that the Tribunal had erred in arriving such a conclusion. We also got no hesitation to hold that the said conclusion is nothing but the culmination of the rightful consideration. The directions issued thereafter is a necessary sequel of such conclusion. In the said circumstances, we do not find any reason to interfere with the order passed by the Tribunal in O.A.No.1465 of 2017. As per the impugned order the Tribunal granted two months time from the date of receipt of a copy of the judgment, for complying with the directions thereunder. The said time limit stands extended by two months from the date of receipt of a copy of this judgment. Subject to the above, this Original Petition is dismissed.”_ The abovesaid judgment of the Division Bench of this Court in OP(KAT) No.26 of 2019 has been followed in very number of cases by the Tribunal as well as by this Court. So the legal position is that the case where like this where the sweeper has been engaged prior to the issuance of Ext.P2 G.O. dated 25.11.2005 and where the sweeping area had not exceeded the minimum threshold level of 100 Sq.M. or above either as on the date of issuance of Ext.P2 G.O. dated 25.11.2005 or even subsequently as on the date of issuance of Ext.R1(b) dated 09.02.2010 and where the sweeping area has actually exceeded above the threshold level after the 09.02.2010 and the sweeper has been in service prior to the issuance Ext.P2 G.O. dated 25.11.2005 then, the sweeper is entitled for regularisation at least from the procedure date on which the sweeping area has exceeded the minimum threshold level of 100 Sq.M or above. In the said case considered by the Division Bench in O.P. (KAT) No.26 of 2019, sweeping area had exceeded the minimum O.P (KAT) No.342 of 2020 10 threshold level of 100 Sq.M. or above only in the year 2014 as in this case. This Court held that the direction issued by the Tribunal in that case to grant regularisation to the incumbent therein with effect from the period, during which the sweeping area had definitely exceeded the minimum threshold area of 100 Sq.M or above is legally correct and tenable. 10. The Division Bench of this Court has followed the said dictum laid down by the Division Bench of this Court in O.P.(KAT) No.26 of 2019, in a large number of cases and hence, we find no reasons to be persuaded by the arguments of Sri.B.Vinod, learned Senior Government Pleader appearing for the petitioners to take a contrarian view. The only main submission made by the petitioners is to the effect that there is no provision to that effect taking care of cases as in the instant case, either in Ext.P2 G.O. dated 25.11.2005 or the subsequent Ext.R(1)b dated 09.02.2010, etc. It has to be borne in mind that the above said scheme for regulairsation of part time sweepers has been framed by the Government not voluntarily by issuing G.Os. as in Ext.P2 G.O(P). dated 25.11.2005 and Ext.R(1)b G.O(P). dated 09.02.2010 but only on account of well-considered verdicts rendered by the learned Single Judge of this Court in the case in _**Mercy v. State of Kerala**_ O.P (KAT) No.342 of 2020 11 [2004 (2) KLT 848], which is referred to in Ext.P2 G.O. and which was later substantially affirmed by the Division Bench of this Court in **State of Kerala & Ors. v. M.M.Mercy & Ors. (W.A.No.1863 of 2004 and connected cases).** The State Government had issued GO(P) No.501/2005/Fin dated 25.11.2005, introducing a scheme to govern the cases of regularisation of existing eligible casual sweepers and regarding appointments to future vacancies. Paragraph 8 of the above Government order deals with regularisation of the existing casual sweepers. As per the Government order, the sweeping area has to be calculated in accordance with the guidelines given in the appendix, the measurement being carried out by the PWD officials after notice to the incumbent casual sweeper and in his presence. Wherever the sweeping area exceeds 100 M2 and if there is no post of Part Time Sweeper sanctioned for the office in question, but there is a casual sweeper being engaged, steps are to be taken for creation of a post of part time contingent sweeper. The posts are to be created with effect from the date of appointment of the incumbent as casual sweeper or from 18.6.2001 (i.e., three years preceding the date of the judgment of the learned Single Judge in **Mercy v. State of Kerala** [2004 (2) KLT 848]), whichever is later. O.P (KAT) No.342 of 2020 12 11. The Division Bench of this Court has also held that such norms framed by the Government mainly for the sake of compliance with the directions and orders passed by the constitutional court like this Court, in exercise of the powers of judicial review, should not be lightly tinkered and diluted by the Government from time to time (see para No.2 on page Nos.3 and 4 of the common judgment dated 07.07.2010 rendered by the Division Bench of this Court in W.A.Nos.2199, 8169 and 2218 of 2009). In the light of this wellconsidered legal position, we do to find any valid ground, so as to invoke the public law remedy of judicial review and superintendence conferred under Articles 226 and 227 of the Constitution of India, so as to disturb and interdict the well-considered verdict of the Tribunal in the instant case. However, Sri.M.V.Tamban, learned counsel appearing for the 1st respondent would point out that some of the very relevant pertinent crucial factual aspects in the matter were not in the knowledge of the respondent herein/original applicant as she did not have access to such a vital information inasmuch as it has now been reliably learnt that in fact a post of Part-Time Sweeper was already formally sanctioned by the Government as per G.O.(Ms)No.14/94/H & FWD dated 20.01.1994, where post of Part-Time Sweeper in the office concerned (Govt.Homeo O.P (KAT) No.342 of 2020 13 Dispensary, Elanad, Thrissur District). That this information came to the knowledge of the original applicant recently and to ascertain that she has submitted Ext.R(1)d query letter dated 29.01.2021 by invoking Right to Information Act proceedings before the head of the office concerned to which reply has been given as per Ext.R(1)e dated 03.02.2021, wherein in reply to question Nos.(v) and (vi) of Ext.R(1)d, clear answer has been given as per item Nos.(v) and (vi) of R(1)e that the post of Part-Time Sweeper in the office has been duly sanctioned by the Government as per G.O.(Ms)No.14/94/H&FWD dated 20.01.1994. Further it is also urged by Sri.M.V.Thamban, learned counsel appearing for the original applicant that it has also been ascertained by the Government in Annexure A3 counter affidavit filed on 04.01.2013 filed by the Government in the above T.A, in para No.3 on internal page No.2 of Annexure A3 thereof of the said counter affidavit that the said post of Part-Time Sweeper in the abovesaid office has been later abolished by the Government as per G.O.(Rt) No.2460/2009/H&FWD dated 25.08.2009. It is pointed that the averments in para No.3 on internal page No.2 of Annexure A3 counter affidavit submitted by the Government is in reply to the averments in para No.2 of Annexure A1 petition, wherein it has been stated that the original applicant was not O.P (KAT) No.342 of 2020 14 paid regular scale of pay on the ground that she was not appointed from the Employment Exchange, etc. Hence, it is urged by Sri.M.V.Thamban, learned counsel appearing for the original applicant that since it is clearly admitted by the Government in paragraph No.3 of Annexure A3 counter affidavit that the post in question is subsequently abolished by them as per G.O.(Rt) No.2460/2009/H&FWD dated 25.08.2009 that clearly shows that the abovesaid question was earlier duly sanctioned. On this factual premise learned counsel for the original applicant/respondent herein would also urge that it has been clearly stipulated and mandated by the Government in paragraph No.3 (iv) of Ext.R(1)b G.O.(P) No.61/2010/Fin. dated 09.02.2010 (see page No.13 on internal page No.3 thereof) that in cases, where Sweepers were engaged against existing sanctioned posts for any reason shall also be entitled for regularisation provided the date of appointment was on or before 25.11.2005 etc. On this basis it is argued that by the original applicant that since the post in question has been sanctioned as per G.O(MS) No.14/94/H&FWD dated 20.01.1994 and the petitioner has been appointed as Sweeper in the said office, prior to Ext.P2 G.O. dated 25.11.2005, then she is entitled for regularisation with effect from 25.11.2005, going by the mandate contained in para No.3 (iv) of O.P (KAT) No.342 of 2020 15 Ext.R(1)b G.O dated 09.02.2010, even it is assumed that the sweeping area was below the threshold area of 100 Sq.M and claim for regularisation cannot be denied merely on the ground that incumbent like the petitioner has been appointed not through the regular method of employment exchange posts. 12. After hearing both sides, learned Senior Government Pleader would point out that these pleadings have not been set up in the original petition and that therefore, he is not in a position to defend the respondents in the O.A./petitioners herein in respect of those contentions now raised by the original applicant for the first time. 13. After hearing both sides, we are of the firm view that it may not be proper for us to adjudicate and give a verdict on the issues now newly posed by the original applicant before us and that too for the first time and without raising those factual aspects earlier so that such issues could also have been determined by the Tribunal after hearing both sides. In that view, there is no necessity for us to consider and give a determination on merits on those issues. Sri.M.V.Thamban, learned counsel appearing for the original applicant would point out that liberty may be accorded to the original applicant to file an OP(KAT) before this Court so as to challenge Annexure-A2 final order of the Tribunal of the O.P (KAT) No.342 of 2020 16 Tribunal to the extent the abovesaid aspects are not considered and decided by the Tribunal, etc. so that the petitioner can get regularisation as Part-Time Sweeper with effect from 25.11.2005 and not merely with effect from 31.12.2014 that the date of issuance of Ext.R(1)a certificate, etc. In this regard, it has also been pointed out before us that the previous measurement certified as per Ext.R(1)c dated 07.03.2012 issued by the Assistant Engineer, Public Works Department, Building Section, Wadakkanchery has also certified that even that time the sweeping area of the office concerned, where the original applicant has been working comes to 111.51 Sq.M, etc. We need not get into those issues as none of these aspects now canvassed by the original applicant has been placed for consideration before the Tribunal and as of now the original applicant/respondent herein has not challenge Annexure- A2 final order of the Tribunal in the manner known to law. The challenge has been made solely by the petitioners herein (Government authorities) as against Annexure A2 final order of the Tribunal to the extent it has ordered the regularisation of the original applicant, in the manner indicated hereinabove. We are of the firm view that the petitioners herein have not disclosed any valid grounds, so as to invoke the public law remedy of judicial review. Hence, we are not in a position to O.P (KAT) No.342 of 2020 17 interfere with the verdict of the Tribunal at Annexure A2. We make it clear that we have not decided any of the issues now raised by the original applicant/respondent herein that she is entitled for regularisation with effect from 25.11.2005, on the basis of the abovesaid factual aspects, etc. and those issues are left open, etc., for which liberty is accorded to the applicant to file fresh O.A on those aspects before the Tribunal. However, the petitioners will comply with the directions of the Tribunal at Annexure-A2, within six weeks from the date of receipt of a certified copy of this judgment. With these observations and directions, the above original petition will stand dismissed. ## **Sd/ALEXANDER THOMAS, JUDGE** **Sd/K.BABU, JUDGE** vgd /scs O.P (KAT) No.342 of 2020 18 ## **APPENDIX** ## **PETITIONER'S/S EXHIBITS:** **ANNEXURE A1 TRUE COPY OF THE T A NO.6902/2012 ALONG WITH EXHIBITS. EXHIBIT P1 TRUE COPY OF THE SWEEPING AREA CERTIFICATE DATED 17.03.2006. EXHIBIT P2 TRUE COPY OF THE GO (P) NO.501/2005/FIN DATED 25.11.2005.** **EXHIBIT P3 TRUE COPY OF THE REPRESENTATION DATED 27.02.2008 SUBMITTED BY THE PETIITONER. EXHIBIT P4 TRUE COPY OF THE FORWARDING LETTER DATED 29.02.2008. EXHIBIT P5 TRUE COPY OF THE JUDGMENT DATED 13.01.2009 IN W P (C) NO.30124/-J. EXHIBIT P6 TRUE COPY OF THE G O (RT) 2460/2009/H & FWD DATED 25.08.2009. EXHIBIT P7 TRUE COPY OF THE REPORT DATED 20.04.2006 BY THE MEDICAL OFFICER PAZHANNOOR. EXHIBIT P8 TRUE COPY OF THE LETTER DATED 14.03.2007. ANNEXURE A2 TRUE COPY OF THE ORDER OF THE TRIBUNAL DAT4ED 26.03.2018 IN T A 6902/2012. ANNEXURE A3 TRUE COPY OF THE COUNTER AFFIDAVIT FILED ON BEHALF OF THE FIRST PETITIONER ON 04.01.2013.** O.P (KAT) No.342 of 2020 19 **EXHIBIT R(1) A** **TRUE COPY OF THE SWEEPING AREA CERTIFICATE DATED 31.12.2014 ISSUED BY THE ASSISTANT ENGINEER, PWD BUILDING SECTION, WADAKKANCHERY** **EXHIBIT R(1) B** **TRUE COPY OF THE G.O(P) NO.61/2010/FIN DATED 09.02.2010** **EXHIBIT R1(C)** **TRUE COPY OF THE SWEEPING AREA CERTIFICATE DATED 07.03.2012 ISSUED BY THE ASSISTANT ENGINEER, PWD BUILDING SECTION, WADAKKANCHERRY** **EXHIBIT R1(D)** **TRUE COPY OF THE APPLICATION DATED 29.01.2021 FILED BEFORE THE HOMEO MEDICAL OFFICER, ELANADU** **EXHIBIT R1(E) TRUE COPY OF THE REPLY DATED 03.02.2021 ISSUED BY THE MEDICAL OFFICER, HOMEO DISPENSARY, ELANADU**