O.P.(KAT) No.51 of 2022

## **`IN THE HIGH COURT OF KERALA AT ERNAKULAM`** ``` PRESENT ``` ``` THE HONOURABLE MR. JUSTICE ALEXANDER THOMAS ``` ``` & ``` ## **`THE HONOURABLE MR.JUSTICE VIJU ABRAHAM`** ``` WEDNESDAY, THE 16[TH] DAY OF MARCH 2022 / 25TH PHALGUNA, 1943 ``` ``` OP(KAT) NO. 51 OF 2022 ``` ``` AGAINST THE ORDER DATED 15.02.2022 IN OA (EKM) NO.1125/2020 OF KERALA ``` ## **`ADMINISTRATIVE TRIBUNAL, ERNAKULAM`** ## **`PETITIONER/APPLICANT IN THE MA/APPLICANT IN THE O.A.:`** ``` DR.N.K.BABU AGED 55 YEARS, S/O. V.RAMANKUTTY NAIR, ASSOCIATE PROFESSOR, GOVT. ARTS AND SCIENCE COLLEGE, PATHIRIPALA, PALAKKAD-678642, RESIDING AT DEVANANDANAM, MELEPATTAMBI P.O., PATTAMBI, PALAKKAD-679306. BY ADVS. P.CHANDRASEKHAR A.RAJASIMHAN VYKHARI.K.U ``` ``` RESPONDENTS/RESPONDENTS IN THE M.A./RESPONDENTS IN THE O.A.: ``` ``` 1STATE OF KERALA REPRESENTED BY THE PRINCIPAL SECRETARY TO GOVERNMENT, HIGHER EDUCATION DEPARTMENT, SECRETARIAT, STATUE P.O., THIRUVANANTHAPURAM-695001. 2DIRECTOR, DIRECTORATE OF COLLEGIATE EDUCATION, VIKAS BHAVAN P.O., THIRUVANANTHAPURAM-695033. 3CHAIRMAN, SELECTION COMMITTEE FOR PRINCIPALS, HIGHER EDUCATION DEPARTMENT, SECRETARIAT, STATUE P.O., THIRUVANANTHAPURAM-695001. 4DR. R.PRAGASH, AGED 51 YEARS, ASSOCIATE PROFESSOR, S/O. LATE P.RAMAIAH, PHYSICS DEPARTMENT, GOVERNMENT COLLEGE, KOTTAYAM, RESIDING AT KALLARKARA, PEERUMEDU, IDUKKI DISTRICT, ERNAKULAM-685531. ``` ``` R1 TO R3 BY SHRI.ASOK M.CHERIAN, ADDL. ADVOCATE GENERAL INSTRUCTED BY SRI.SAIGI JACOB PALATTY, SR.GOVT.PLEADER R4 BY SRI.THOMAS ABRAHAM LEEJOY MATHEW.V. MERCIAMMA MATHEW ASWIN.P.JOHN R.ANANTHAPADMANABAN THAYYIB SHA P.S. ``` ## **`THIS OP KERALA ADMINISTRATIVE TRIBUNAL HAVING COME UP FOR ADMISSION ON`** ``` 16.03.2022, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ``` O.P.(KAT) No.51 of 2022 2 ## **ALEXANDER THOMAS & VIJU ABRAHAM, JJ.** **------------------------------------------------------------------** O.P.(KAT) No.51 of 2022 _[arising out of order dated 15.02.2022 in O.A. (Ekm) No.1125/2020 on the file of the KAT, Ekm Bench]_ **------------------------------------------------------------------** Dated this the 16[th] day of March, 2022 ## **JUDGMENT** ## **Alexander Thomas, J.** Ext.P20 interim order dated 15.02.2020 rendered by the Kerala Administrative Tribunal, Ernakulam Bench on M.A.(Ekm) No.289/2022 in the instant O.A. (Ekm) No.1125/2020, is under challenge in this original petition, filed under Articles 226 & 227 of the Constitution of India. 2. The sole petitioner in the O.P. is the sole applicant in the abovesaid M.A. and O.A. before the Tribunal. The respondents in the O.P. are the respondents in the abovesaid M.A. and O.A. 3. Heard Sri.P.Chandrasekhar, learned counsel appearing for the petitioner in the O.P./applicant in the O.A., Sri.Asok M. Cherian, learned Additional Advocate General, instructed by Sri.Saigi Jacob Palatty, learned Senior Government Pleader, appearing for respondents 1 to 3 in the O.P./respondents in the O.A. and Sri.Thomas O.P.(KAT) No.51 of 2022 3 Abraham, learned counsel appearing for contesting respondent No.4 in the O.P./contesting respondent No.4 in the O.A. 4. The prayers in the instant original application filed before ## the Tribunal are as follows:- _“i) Direct the respondents to convene the Selection Committee for the appointment of Principles in Govt. Arts and Science Colleges in the existing vacancies and to conduct the selection and appointment as per UGC Regulations, 2018 without any further delay and in a time bound manner._ _ii) Issue an order or direction to the respondents which this Hon’ble Tribunal may deem fit and proper in the interest of justice.”_ 5. The interim relief sought for in the O.A. is as follows:- _“i) It is prayed that this Hon’ble Tribunal may be pleased to issue an interim order directing the 3[rd] respondent to convene meeting of the Selection Committee provisionally for the selection of Principals, pending the disposal of the Original Application.”_ 6. The interim prayer made in Ext.P18 M.A.(Ekm) ## No.289/2022, in the instant O.A., is as follows:- _“For the reasons stated above it is most humbly prayed that in the interest of justice this Hon’ble Tribunal may be pleased to stay all further proceedings in Annexure A10 till the disposal of this OA.”_ 7. A brief recital to the factual aspects in this case would be pertinent. By Anx.A1 notification/circular dated 21.04.2020, the Director of Collegiate Education, Government of Kerala, had invited applications for promotion to the posts of Principals of Government colleges from incumbents who are Associate Professors, having 15 years of experience in colleges under the Kerala Government Collegiate Education Department and who have the requisite qualifications, as per the UGC regulations, including Ph.D., 15 years of service, etc. and O.P.(KAT) No.51 of 2022 4 the last date for submission of application was upto 30.04.2020. Anx.A2 dated 13.05.2020 is yet another circular issued by the Director of Kerala Government Collegiate Education Department, whereby it is stated that the requisite qualifications for appointment as Principals, in terms of UGC regulation, should have been obtained by the claimants before 01.05.2020. Anx.A10 is yet another circular dated 28.01.2022, issued by the Director of the Kerala Government Collegiate Education Department, pointing out that the abovesaid 15 years of service should be one acquired by the incumbents in Government Colleges under the Kerala Government Collegiate Education Department, for the purpose of promotion as Principals in Government Colleges, etc. According to the applicant, he is fully qualified and eligible for the abovesaid consideration for promotion as Principal and he had submitted his application in response to Anx.A1 circular dated 21.04.2020 and the receipt of the said application has been referred to as Sl. N0.26 of the list referred to Anx.A6, given on page No.59 of the paper book of this original petition. According to the applicant, the incumbent should be Associate Professor/Professor in the Kerala Government Collegiate Education Department, having Ph.D. Degree and the 15 years of teaching experience could be either in Government Colleges or in Private Aided Colleges, which are approved O.P.(KAT) No.51 of 2022 5 by the Universities. That, the applicant has the requisite minimum 15 years of experience, if his prior Aided College service is counted. That, Anx.A4 is the extract of the relevant portion of the UGC regulations, 2018, as per which, for appointment as Principal of a College, Ph.D. is the minimum academic qualification and Professors/Assistant Professors having total service/experience of atleast 15 years of teaching/research in Universities, Colleges and other institutions of higher education, would be eligible, subject to certain other norms. That, the applicant could reliably learn that, going by some of the subsequent circulars issued, the departmental authorities have taken the stand that the abovesaid 15 years of teaching experience should be one that should be obtained only in Government Colleges and such teaching experience, even in approved Private Aided Colleges, will not be reckoned. On that grievance the petitioner has approached the Tribunal, in which initially an interim order was passed as per Ext.P2 on 20.08.2020, whereby the Tribunal has directed that the promotion to the post of Principal in Government Colleges should be effectuated strictly in accordance with the provisions in the UGC regulations, 2018. The operative portion of Ext.P2 interim order rendered by the Tribunal on 20.08.2022, in the instant O.A., as given on para. No.2 thereof, reads as follows:- O.P.(KAT) No.51 of 2022 6 _“The respondents will ensure that the appointment to the post of Principal is done strictly in accordance with the UGC Scheme and the decision of the Full Bench of the Hon’ble High Court of Kerala in Radhakrishnan Pillai D (Dr) v. Travancore Devaswom Board and others, 2016 (2) KLT 245.”_ 8. That, by virtue of the subsequent circulars, the department processed the claims of only those incumbents, who are Professors/Associate Professors and who have Ph.D. Degree, but the 15 year of teaching experience was counted only in Government Colleges, with the result that it was learnt that the applicant has been excluded from the field of choice. On that aspect, the applicant had moved the abovesaid Ext.P18 M.A. (Ekm) No.289/2022, in the above O.A., with the aforementioned interim prayer. The Tribunal has now rendered the impugned Ext.P20 interim order dated 15.02.2022 in M.A.(Ekm) No.289/2022 in O.A.(Ekm) No.1125/2020, which reads as follows:- _“The applicant seeks stay of all further proceedings pursuant to Annexure A10 circular inviting applications for appointment to the post of Principal in accordance with UGC 2018 Regulations. As per Annexure A10, applications are called for from eligible teachers with not less than 15 years of service in Government Arts and Science Colleges along with Confidential Report for the years 2019, 2020 & 2021. The last date prescribed for submission of application is 15.2.2022 i.e. today._ _2. In so far as the circular calls for application for selection to the post of Principal in accordance with UGC Regulations and the last date prescribed for submission of application is on 15.2.2022, the prayer for an interim stay of Annexure A10 circular is rejected. It is made clear that all further proceedings pursuant to Annexure A10 circular will be subject to further orders in the Original Application.”_ 9. The main contention urged by Sri.P.Chandrasekhar, learned counsel appearing for the petitioner in the O.P./applicant in the O.A., is that the interim order at Ext.P2, rendered by the Tribunal O.P.(KAT) No.51 of 2022 7 on 20.08.2020, in the instant O.A., directing strict enforcement of the conditions in the UGC Scheme as well as the dictum laid down by the Full Bench of this Court in the aforecited decision, has not been challenged by anyone, including the State and the departmental authorities and that the present interim order, rendered by the Tribunal at Ext.P20, permitting the department to go ahead with Anx.A10 circular, whereby the 15 years of teaching service could be counted only in Government Colleges, etc. would militate against Ext.P2 interim order as well as the UGC Scheme. That, going by Ext.P2 interim order as well as the UGC Scheme, the respondent authorities concerned are obliged in law to take into account the teaching service, not only in Government Colleges, but also in University approved Private Aided Colleges and such other institutions, for the purpose of counting the 15 years of teaching service for promotion to the post of Principal and the contrary prescription by the State in Anx.A10 is illegal and ultra-vires and would be in violation of the earlier interim order passed by the Tribunal at Ext.P2. 10. Per contra, Sri.Asok M.Cherian, learned Additional Advocate General, instructed by Sri.Saigi Jacob Palatty, learned Senior Government Pleader appearing for official respondents 1 to 3, would submit on the basis of instructions as well as with support of the O.P.(KAT) No.51 of 2022 8 pleadings in the statement dated 05.03.2022, etc. that the norms followed by the State Government is based on the UGC Regulations and the only modification is that a rigorous provision has been made that the 15 years of teaching experience of the incumbents concerned should be reckoned only in Government college services under the Kerala Government Collegiate Education Department and not in private, aided colleges, etc., as the teaching service in Government colleges is constituted by Special Rules and norms in that regard for the Collegiate Education Department teaching service. That, seniority in the Government college service would be an integral component for promotion as Principals of Government colleges of and to ensure those aspects, the State Government has earlier issued a Government Order as G.O.(P) No.10/2017/H.Edn. dated 19.03.2017, wherein it has been _inter-alia_ ordered in para No.6 thereof, which reads as follows:- - _“Associate Professor/Professor with the following qualifications_ - _are eligible for promotion as Principal:_ - _(I) Educational qualifications in the category of lecturer._ - _(ii) Should possess Ph.D. Degree in concerned/allied/relevant discipline._ - _(iii) Should have a minimum period of 15 years of service in Collegiate Education Department.”_ 11. Further, it is pointed out that the abovesaid G.O.(P) dated 19.03.2017 was issued after the order was passed by the Apex Court in the Special Leave Petition arising out of the Full Bench matter in O.P.(KAT) No.51 of 2022 9 ## _**Radhakrishnan Pillai D (Dr) v. Travancore Devaswom**_ _**Board and others**_ [2016 (2) KLT 245 (FB)], etc. In that regard, it is pointed out that the minimum academic qualification of Ph.D. insisted by the UGC is not, in any manner, diluted and that the feeder category is Associate Professor/Professor as insisted by the UGC and that the minimum teaching experience is also 15 years as insisted by the UGC. But that the norm regarding minimum teaching service of 15 years has been made more rigorous by the State Government, inasmuch as the said teaching service will be counted only in Government college service and not in private aided colleges. That, the UGC regulations are framed in consonance with the primacy of Union legislation, arising out of entry 66 of list 1 of the Constitution of India, relatable to Co-ordination and determination of standards in higher education sector and the minimum standards laid down by such Central regulatory bodies, as per the central laws concerned, are certainly binding on the State authorities. But that, it is well established that the said minimum standards laid down by the Central Regulatory Authorities can be modified by making more rigorous provisions by the State authorities, etc. That, the abovesaid modification, that a minimum of 15 years of service should necessarily be in Government colleges, has been made by the State Government for _bona-fide_ O.P.(KAT) No.51 of 2022 10 reasons, since the teaching service in Government colleges is constituted by a separate service under the Government, etc. and hence the State authorities will have the competence in the matter, not only under the relevant entry in the concurrent list relating to education but also the relevant entry in the State list relating to Public Services, etc. Further that since the appointment is to the post of Principal of Government colleges, the insistence that 15 years of teaching service should necessarily be in the Government college service has reasonable nexus with the objective of selecting most competent experienced hands for manning the responsible position of the Heads of the Government College. That the norm of 15 years teaching service in Government colleges, would ensure respecting the seniority of the claimants in the Government college service, but would also lead to selection of personnel as Principal of Government colleges having more experience and exposure in dealing with various problems in Government colleges. 12. To this, the learned counsel appearing for the petitioner would strongly contend that the abovesaid prescriptions in the aboesaid G.O. would be plainly contradictory to the norms stipulated by the UGC, as per the UGC Regulations, 2018, etc. O.P.(KAT) No.51 of 2022 11 13. Sri.Thomas Abraham, learned counsel appearing for contesting respondent No.4, would broadly adopt the submissions of the learned Additional Advocate General, appearing for official respondents 1 to 3. 14. After hearing both sides, we see that the matter is now pending before the Tribunal. 15. Since the matter is now pending at the interim stage before the Tribunal, it may not be right and proper for us to enter into the merits of the main issue in controversy in this case, as mentioned above. 16. Hence, we would relegate the petitioner and all other parties to raise all their contentions in that regard before the Tribunal in the pending O.A. 17. The main point now raised by both sides has not even been raised before the Tribunal by either of the parties. Hence, we feel that it will not be right and proper for us to enter into the merits of the main controversy. 18. There is yet another aspect of the matter, a third party has sought for impleadment in this case, on the ground that, based on her complaint, memo of charges has been issued by the departmental O.P.(KAT) No.51 of 2022 12 authorities against the applicant on 06.03.2021 and later show cause notice was also issued on 05.01.2022 and that the applicant has challenged the same in an O.A. before the Tribunal, etc. and that, as of now, only the show cause notice dated 05.01.2022 has been stayed by the Tribunal, pending consideration of the interim prayer therein and that the memo of charges dated 06.03.2021 has not been stayed by the Tribunal. Further that, it is contended by Sri.Leejoy Mathew V., learned counsel, who appeared for the said third party that the specific factual aspects relating to the memo of charges dated 06.03.2021 and the show cause notice dated 05.01.2022 has not been disclosed in the present O.P.(KAT), filed before this Court on 17.02.2022. Further that it is elementary that pendency of memo of charges for disciplinary proceedings is highly relevant and germane for deciding claims for promotions of such delinquent officials. 19. To this, Sri.P.Chandrasekhar, learned counsel appearing for the petitioner, would point out that it has been averred in the last portion of para No.9 of the present O.P. that, in the meantime, attempts were made to implicate the petitioner in false cases with a view to illegally deny him promotion to the post of Principal, for which he is eligible, by way of which he had to approach the Tribunal in another set of proceedings, etc. The abovesaid third party has filed a O.P.(KAT) No.51 of 2022 13 separate application as I.A. No.2 of 2022 in the present O.P., seeking for impleadment. We have already closed the said I.A., holding that since the said party is a third party/stranger in the O.A. before the Tribunal, it may not be right and proper for him to seek impleadment directly before this Court in view of the settled legal position in that regard (see _**Rajeev Kumar & Anr.** v._ _**Hemraj Singh Chauhan & Ors.**_ [2010 (4) SCC 554], _**Gireesh Babu M.B. & Ors.** v._ _**Pavithran T.T.V. & Ors.**_ [2013 (3) KLT 453 (DB)] & _**Haris K.M. & Ors.** v_ _**. Jahfer K. & Ors.**_ [2021 (4) KLT 155 (FB)], _**Thiruvalla Government Employees C-operative Bank Ltd.** v._ _**V.K. Devarajan & Ors.**_ [2021 (2) KLT 25 (DB)], etc.). 20. We have already granted liberty to the said third party to approach the Tribunal with any such impleadment application and to present his version in the matter, before the Tribunal. Hence, there is no necessity for us to enter into the merits of any such rival pleas canvassed before us by the said party and the original applicant. 21. The learned Additional Advocate General, appearing for official respondents 1 to 3, submits that the said respondent authorities will file their pleadings in the matter in respect of the matters arising out of G.O.(P) No.10/2017/H.Edn. dated 19.03.2017 and other relevant aspects, without any further delay. O.P.(KAT) No.51 of 2022 14 22. Sri.P.Chandrasekhar, learned counsel appearing for the petitioner, would point out that the petitioner is due to retire from service on 31.05.2022 and that this Court may give necessary directions to ensure the early consideration and final disposal of the main matters before the Tribunal in the above O.A. 23. Taking note of the facts and circumstances of the case, we would respectfully request the Tribunal for early consideration and final disposal of the main matter in the O.A., without much delay and the above said plea made by the petitioner that he is due to retire from service on 31.05.2022 may also be duly taken note of by the Tribunal. We hope and trust that the Tribunal would give early priority for hearing and dispose of the matter within a reasonable time limit that may be fixed by the Tribunal. 24. The upshot of the above discussion is that, there is no necessity for us to interfere with the impugned interim order passed by the Tribunal at Ext.P20. All contentions available to the petitioner and all other parties could be raised by them before the Tribunal and it is for the Tribunal to resolve the said issues without any further delay and also by taking note of the fact that the petitioner is due to retire O.P.(KAT) No.51 of 2022 15 from service on 31.05.2022. No other orders and directions are called for. With these observations and directions, the above original petition will stand disposed of. Sd/- **ALEXANDER THOMAS, JUDGE** Sd/- **VIJU ABRAHAM, JUDGE** Skk//29032022 O.P.(KAT) No.51 of 2022 16 ## **`APPENDIX OF OP(KAT) 51/2022`** ## **`PETITIONER'S EXHIBITS:-`** ``` Exhibit P1TRUE COPY OF OA (EKM) NO.1125/2020 FILED IN THE KERALA ADMINISTRATIVE TRIBUNAL, ERNAKULAM. ``` ``` ANNEXURE A1TRUE COPY OF THE CIRCULAR NO.UGC CELL 2/5754/2020/COLL.EDN. DATED 21.4.2020 ISSUED BY THE 2ND RESPONDENT. ANNEXURE A2TRUE COPY OF THE CIRCULAR NO. UGC CELL (2)/5744/2020/COLL. EDN. DATED 13.5.2020 ISSUED BY THE 2ND RESPONDENT. ANNEXURE A3TRUE COPY OF THE FORWARDING LETTER DATED 22.5.2020 OF THE PRINCIPAL, SREE NEELAKANDA GOVT. SANSKRIT COLLEGE, PATTAMBI. ANNEXURE A4TRUE COPY OF THE REPORT PUBLISHED IN THE MATHRUBHOOMY NEWS PAPER ON 30.6.2020. Exhibit P2TRUE COPY OF THE ORDER DATED 20.8.2020 IN OA (EKM) NO.1125/2020 OF THE KERALA ADMINISTRATIVE TRIBUNAL, ERNAKULAM. Exhibit P3TRUE COPY OF MA (EKM) NO.1657/2020 FILED IN THE KERALA ADMINISTRATIVE TRIBUNAL, ERNAKULAM. ANNEXURE A5TRUE COPY OF G.O.(RT) NO.1121/2020/HEDN. DATED 8.9.2020. Exhibit P4TRUE COPY OF THE REPLY STATEMENT DATED NIL FILED BY THE 1ST RESPONDENT. Exhibit P5TRUE COPY OF THE REJOINDER FILED BY THE PETITIONER ON 13.11.2020. Exhibit P6TRUE COPY OF MA (EKM) NO.1666/2020 FILED IN THE KERALA ADMINISTRATIVE TRIBUNAL, ERNAKULAM. ANNEXURE A6TRUE COPY OF THE REPLY DATED 27.8.2020 GIVEN BY THE UNDER SECRETARY AND STATE PUBLIC INFORMATION OFFICER, THIRUVANANTHAPURAM UNDER THE RIGHT TO INFORMATION ACT, 2005. Exhibit P7TRUE COPY OF THE MA (EKM) NO.1745/2020 FILED IN THE KERALA ADMINISTRATIVE TRIBUNAL, ERNAKULAM BY THE 4TH RESPONDENT ON 3.12.2020. Exhibit P8TRUE COPY OF THE REPLY STATEMENT DATED 9.12.2020 FILED BY THE 2ND RESPONDENT. Exhibit P9TRUE COPY OF THE ADDITIONAL REPLY STATEMENT DATED 14.12.2020 FILED BY THE 1ST RESPONDENT. Exhibit P10TRUE COPY OF THE ADDITIONAL REJOINDER FILED BY THE PETITIONER ON 7.1.2021. ANNEXURE A7TRUE COPY OF THE CERTIFICATE OF SERVICE DATED 19.9.2017 ISSUED BY THE DEPUTY DIRECTOR OF COLLEGIATE EDUCATION, THRISSUR. Exhibit P11TRUE COPY OF THE REPLY STATEMENT DATED 13.1.2021 FILED BY THE 4TH RESPONDENT. ANNEXURE R4(a)TRUE COPY OF THE RELEVANT PAGES OF THE SPECIAL RULES FOR THE KERALA COLLEGIATE EDUCATION SERVICE, 1994. ``` O.P.(KAT) No.51 of 2022 17 - **`ANNEXURE R4(b) TRUE COPY OF THE RELEVANT PAGES OF THE UGC REGULATIONS ON MINIMUM QUALIFICATIONS FOR APPOINTMENT OF TEACHERS AND OTHER ACADEMIC STAFF IN UNIVERSITIES AND COLLEGES AND MEASURES FOR THE MAINTENANCE OF STANDARDS IN HIGHER EDUCATION, 2018.`** ``` Exhibit P12TRUE COPY OF THE OBJECTION FILED BY THE PETITIONER ON 15.1.2021 IN MA (EKM) NO.1745/2020. ``` ``` Exhibit P13TRUE COPY OF MA (EKM) NO.113/2021 FILED BY THE 4TH RESPONDENT ON 22.2.2021. ``` - **`ANNEXURE R4(C) TRUE COPY OF THE ORDER G.O. (MS) NO.5 DATED 11.1.2021 ISSUED BY THE GOVT. OF TAMILNADU.`** - **`ANNEXURE R4(D) TRUE COPY OF THE ORDER DATED 16.3.2019 ISSUED BY THE GOVT. OF KARNATAKA.`** - **`Exhibit P14 TRUE COPY OF MA (EKM) NO.843/2021 FILED BY THE PETITIONER ON 10.6.2021.`** - **`ANNEXURE A8 TRUE COPY OF THE CIRCULAR NO.B3/1039/2021/DCE DATED 8.6.2021 ISSUED BY THE 2ND RESPONDENT.`** - **`ANNEXURE A9 TRUE COPY OF THE ORDER DATED 7.4.2021 IN OA NO.1580/2020.`** - **`Exhibit P15 TRUE COPY OF MA (EKM) NO.844/2021 FILED BY THE PETITIONER ON 10.6.2021.`** - **`Exhibit P16 TRUE COPY OF THE STATEMENT DATED 9.7.2021 FILED BY THE 2ND RESPONDENT.`** - **`Exhibit P17 TRUE COPY OF MA (EKM) NO.288/20122 FILED BY THE PETITIONER ON 14.2.2022.`** - **`ANNEXURE A10 TRUE COPY OF THE CIRCULAR NO.B3/3488/2022/DCE DATED 28.1.2022 ISSUED BY THE 2ND RESPONDENT.`** - **`Exhibit P18 TRUE COPY OF THE MA (EKM) NO.289/2022 FILED BY THE PETITIONER ON 14.2.2022.`** - **`Exhibit P19 TRUE COPY OF THE MA (EKM) NO.290/2022 FILED BY THE PETITIONER ON 14.2.2022.`** - **`Exhibit P20 FREE COPY OF THE ORDER DATED 15.2.2022 IN MA (EKM) NO.289/2022.`** - **`Exhibit P21 TRUE COPY OF THE ORDER NO.UGC CELL 2/14403/20/COLL.EDN. DATED 16.6.2020.`** - **`Exhibit P22 TRUE COPY OF OA(EKM) NO.621/2021 FILED IN THE KERALA ADMINISRATIVE TRIBUNAL, ERNAKULAM`** - **`Exhibit P23 TRUE COPY OF THE REPLY STATEMENT FILED BY THE 2ND RESPONDENT DATED 16/11/2021`** - **`Exhibit P24 TRUE COPY OF MA(EKM) NO.64/2022 FILED IN THE KERALA ADMINISTRATIVE TRIBUNAL, ERNAKULAM ON 11/1/2022`** - **`Exhibit P25 TRUE COPY OF MA(EKM) NO.67/2022 FILED IN THE KERALA ADMINISTRATIVE TRIBUNAL, ERNAKULAM ON 11/1/2022`** - **`Exhibit P26 TRUE COPY OF THE ORDER IN MA(EKM) NO.67/2022 DATED 24/1/2022 OF THE KERALA ADMINISTRATIVE TRIBUNAL`** - **`Exhibit P27 TRUE COPY OF REPLY STATEMENT FILED BY 3RD RESPONDENT DATED 24/2/2022`**