Judgements/High Court of Kerala/O.V. Appachan and others v. The Diary Extension Officer, Department of Diary Panamaram Village, Wayanad; The Assistant Director, Diary Development (C) Block, Civil Station, Wayanad; The Deputy Director, Diary Development (C) Block, Civil Station, Wayanad; Diary Extension Officer, Sulthan Bathery; Pallikkunnu Ksheerolpadaka Sahakarana Sangham Ltd (represented by Secretary); The Kerala Bank, Wayanad; Circle Co-operative Union, Vy-thiri; The State Co-operative Election Commission

High Court of KeralaSingle Judge2021-12-14Writ petitions dismissed; the order superseding...

O.V. Appachan and others v. The Diary Extension Officer, Department of Diary Panamaram Village, Wayanad; The Assistant Director, Diary Development (C) Block, Civil Station, Wayanad; The Deputy Director, Diary Development (C) Block, Civil Station, Wayanad; Diary Extension Officer, Sulthan Bathery; Pallikkunnu Ksheerolpadaka Sahakarana Sangham Ltd (represented by Secretary); The Kerala Bank, Wayanad; Circle Co-operative Union, Vy-thiri; The State Co-operative Election Commission

Case / Petition Number:WP(C) No. 6836 of 2021; WP(C) No. 7440 of 2021

Case Details & Bench

Court: High Court of Kerala
Hon'ble Judges: Sathish Ninan
Judgment Date: 2021-12-14
Court Decision / Holding: Writ petitions dismissed; Ext.P20 order superseding the existing Managing Committee stands, and the subsequent election notification is not interfered with. The elected committee has already assumed office.
Final Disposition: Writ petitions dismissed; the order superseding the present Managing Committee is upheld and the election notification stands; the elected committee has already assumed office.

Parties to the Case

Appellants / Petitioners

O.V. Appachan
P.M. Joseph
K.V. Varkey
Sreeja Sreekumar
Mary Benny
K. Chandu

Respondents

The Diary Extension Officer, Department of Diary, Panamaram Village, Wayanad
The Assistant Director, Diary Development (C) Block, Civil Station, Wayanad, Kalppatta North, Wayanad
The Deputy Director, Diary Development (C) Block, Civil Station, Wayanad, Kalppatta North, Wayanad
Diary Extension Officer, Sulthan Bathery, Sulthan Bathery, Part Time Administrator, Pallikkunnu Ksheerolpadaka Sahakarana Sangham Ltd.
The Pallikkunnu Ksheerolpadaka Sahakarana Sangham Ltd., represented by Secretary
The Kerala Bank, Wayanad, represented by its Deputy General Manager
Circle Co-operative Union, Vy-thiri, Wayanad, represented by its Secretary
The State Co-operative Election Commission, Thiruvananthapuram

Legal Representation & Advocates

Counsels for Petitioners

• P.P. Jacob
• Smt. Mariyam Jacob

Counsels for Respondents

• Smt. Sheeja C.S.
• Sri. M. Sasindran
• Sri. Athul Shaji
• Sri. R. Lakshmi Narayan

Case Synopsis & Summary

These writ petitions are by members of the Pallikkunnu Ksheerolpadaka Sahakarana Sangham Ltd., challenging Ext.P20 order of supersession and, in WP(C) No.7440 of 2021, the election notification for the Managing Committee. The court notes that Ext.P20 records mismanagement allegations arising from acts during the tenure of the previous Managing Committee, including irregularities in the bio-village project, land and building transactions, installation of solar panels, and leasing out plant and machinery. It is highlighted that the earlier acts performed by the former committee led to financial losses and that vouchers were manipulated with amounts remaining unrecovered, all of which were acknowledged in audit reports and in the 65 inquiry. Petitioners argue that past misdeeds cannot be a ground to suspend the present Committee, and that the State’s or Election Commission’s involvement cannot sustain displacement of an elected body. Respondents contend that the findings in Ext.P20 show the Committee’s acts prejudicial to the Society, warranting supersession. The court, after considering the material and authorities, holds that the Ext.P20 findings justify supersession and declines to interfere with the subsequent election notification, noting that the elected Committee has already assumed office. The petitions are dismissed.

Provisions of Law Cited

Section 65 of the Cooperative Societies ActRule 47(d) of the Co-operative Societies RulesRule 29 of the Co-operative Societies RulesSection 68 of the Cooperative Societies Act

Legal Doctrines & Maxims

Electoral/Committee displacement should be exercised sparingly; an elected Committee should seldom be displaced from office unless there are persistent acts of violations or omissions.

Submissions & Arguments

Contentions of Appellants / Petitioners

The petitioners contend Ext.P20 supersession order is a misapplication of Section 65 and the Rules, premised on earlier acts of mismanagement by the preceding Managing Committee. They argue that past irregularities, though serious, cannot automatically oust an elected committee, particularly where the alleged causes relate to prior tenure. They challenge the breadth of findings (i–iv) and insist there is no cogent basis to hold the present committee responsible, especially since the leasing, construction, and purchase dealings were concluded before the petitioners assumed office. They rely on principles in Thrikkadavoor Service Co-operative Society Ltd. v. Sivasankara Pillai (1990) 2 KLT 594 and Rajeev Koshy v. State of Kerala (ILR 2018 Ker. 999) to argue for limited interference with elected bodies unless persistent violations occur. They also contend that any financial irregularities should have been pursued under proper recovery mechanisms and not via supersession. They urge restraint, pointing to the electors already having matured into office and seek a stay on Ext.P20.

Contentions of Respondents

Respondents maintain that the findings in Ext.P20 reveal mismanagement prejudicial to the Society, including non-recovery of dues, manipulation of vouchers, and systematic accounting irregularities. They submit that the 65 inquiry and audit reports demonstrate acts prejudicial to the Society’s interests and that the act of leasing plant and machinery to third parties exceeded the bye-laws and harmed members. They rely on Rule 47(d) to emphasize accountability, and argue that supersession is warranted to protect the Society’s finances. They contend that the election notification is lawful and that the elected committee has already assumed office, which should not be disturbed. They cite precedents including State of M.P. v. Sanjay Nagayach and James v. Joint Registrar to show that elected bodies can be displaced for persistent mismanagement, though leave room for judicial scrutiny when appropriate.

Cited Precedents (4)

Case Name	Citation	Treatment	Explanation
Thrikkadavoor Service Co-operative Society Ltd. v. Sivasankara Pillai	1990 (2) KLT 594	Positive	Cited to support the duty of committees to act in the Society's interest and to reject acts of possible mismanagement under Rule 47(d).
Rajeev Koshy @ Reji K. Koshy v. State of Kerala and Ors.	ILR 2018 (2) Ker. 999	Positive	Cited alongside Thrikkadavoor to justify accountability and the consequences for mismanagement under the cooperative rules.
State of M.P. v. Sanjay Nagayach	(2013) 7 SCC 25	Mentioned Only	Cited by counsel to argue that elected committees should seldom be displaced; court ultimately rejects this approach in favor of Ext.P20 findings.
James v. Joint Registrar	(1997) 2 KLT	Mentioned Only	Cited by counsel; used to illustrate the principle regarding displacement of elected committees but not adopted by the Court.

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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 SATHISH NINAN TUESDAY, THE 14[TH] DAY OF DECEMBER 2021 / 23RD AGRAHAYANA, 1943 WP(C) NO. 6836 OF 2021** ## **PETITIONERS:** 1 O.V.APPACHAN THE BOARD OF DIRECTORS OF THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD NO.D 1940,APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT,PIN-673 122 2 P.M.JOSEPH, MEMBER, THE BOARD OF DIRECTORS OF THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD NO.D 1940,APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT,PIN-673 122 3 K.V.VARKEY MEMBER, THE BOARD OF DIRECTORS OF THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD NO.D 1940,APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT,PIN-673 122 4 SREEJA SREEKUMAR, MEMBER, THE BOARD OF DIRECTORS OF THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD NO.D 1940,APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT,PIN-673 122 5 MARY BENNY, MEMBER, THE BOARD OF DIRECTORS OF THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD NO.D 1940,APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT,PIN-673 122 6 K.CHANDU MEMBER, THE BOARD OF DIRECTORS OF THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD NO.D 1940,APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT,PIN-673 122 BY ADVS. P.P.JACOB SMT.MARIYAM JACOB **WP(C) NO. 6836 OF 2021 -2-** ## **RESPONDENTS:** 1 THE DIARY EXTENSION OFFICER DEPARTMENT OF DIARY, PANAMARAM VILLAGE, WAYANAD-670 721 2 THE ASSISTANT DIRECTOR, DIARY DEVELOPMENT (C) BLOCK, CIVIL STATION, WAYANAD, KALPPATTA NORTH, WAYANAD-673 121 3 THE DEPUTY DIRECTOR, DIARY DEVELOPMENT (C) BLOCK, CIVIL STATION, WAYANAD, KALPPATTA NORTH, WAYANAD-673 121 4 DIARY EXTENSION OFFICER, SULTHAN BATHERY, SULTHAN BATHERY, PART TIME ADMINISTRATOR, THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD NO.D 1940,APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT,PIN-673 122 5 THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD NO.D 1940 APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT,PIN-673 122, REPRESENTED BY SECRETARY 6 THE KERALA BANK, WAYANAD-673 121, REPRESENTED BY ITS DEPUTY GENERAL MANAGER 7 CIRCLE CO-OPERATIVE UNION, VYTHIRI, WAYANAD-673 576, REPRESENTED BY ITS SECRETARY 8 THE STATE CO-OPERATIVE ELECTION COMMISSION, 3RD FLOOR, CO-OPERATIVE BANK TOWER, VIKAS BHAVAN P.O., THIRUVANANTHAPURAM-695 033 BY ADVS. BY SMT.SHEEJA C.S., SR. GOVT. PLEADER M.SASINDRAN ATHUL SHAJI THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 14.12.2021, ALONG WITH WP(C).7440/2021, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** ## **THE HONOURABLE MR. JUSTICE SATHISH NINAN** **TUESDAY, THE 14[TH] DAY OF DECEMBER 2021 / 23RD AGRAHAYANA, 1943** **WP(C) NO. 7440 OF 2021** ## **PETITIONERS:** 1 O.V.APPACHEN AGED 70 YEARS PRESIDENT, THE BOARD OF DIRECTORS OF THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD.NO.D 1940, APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT, PIN-673 122. 2 P.M.JOSEPH, MEMBER, THE BOARD OF DIRECTORS OF THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD.NO.D 1940, APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT, PIN-673 122. 3 K.V.VARKEY, MEMBER, THE BOARD OF DIRECTORS OF THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD.NO.D 1940, APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT, PIN-673 122. 4 SREEJA SREEKUMAR, MEMBER, THE BOARD OF DIRECTORS OF THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD.NO.D 1940, APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT, PIN-673 122. 5 MARY BENNY, MEMBER, THE BOARD OF DIRECTORS OF THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD.NO.D 1940, APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT, PIN-673 122. 6 K.CHANDU, MEMBER, THE BOARD OF DIRECTORS OF THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD.NO.D 1940, APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT, PIN-673 122. BY ADVS. P.P.JACOB SMT.MARIYAM JACOB **WP(C) NO.7440/2021 -2-** ## **RESPONDENTS:** 1 THE DIARY EXTENSION OFFICER DEPARTMENT OF DAIRY, PANAMARAM VILLAGE, WAYANAD-670 721. 2 THE DEPUTY DIRECTOR OF DAIRY DEVELOPMENT (C) BLOCK, CIVIL STATION, WAYANAD, KALPPATTA NORTH, WAYANAD-673 121. 3 DAIRY EXTENSION OFFICER, SULTHAN BATHERY, SULTHAN BATHERY, PART TIME ADMINISTRATOR., THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD.NO.D 1940, APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT, PIN-673 122. 4 THE PALLIKKUNNU KSHEEROLPADAKA SAHAKARANA SANGHAM LTD.NO.D 1940, APCOS, PALLIKKUNNU P.O., WAYANAD DISTRICT, PIN-673 122, REPRESENTED BY SECRETARY. 5 THE STATE CO-OPERATIVE ELECTION COMMISSION, 3RD FLOOR, CO-OPERATIVE BANK TOWER, VIKAS BHAVAN, THIRUVANANTHAPURAM-695 033. BY SMT.SHEEJA C.S., SR. GOVT. PLEADER THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 14.12.2021, ALONG WITH WP(C).6836/2021, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ## **SATHISH NINAN, J.** **= = = = = = = = = = = = = = = = = = W.P.(C) Nos.6836 & 7440 of 2021 = = = = = = = = = = = = = = = = = = Dated this the 14[th] day of December, 2021** ## **J U D G M E N T** These writ petitions are by the members of the Board of Directors of the Pallikkunnu Ksheerolpadaka Sahakarana Sangham Ltd. In W.P.(C) No.6836/2021 they challenge Ext.P20 order of supersession and in W.P(C) No.7440/2021, election notification to the Managing Committee is under challenge. The order of supersession was preceded by an inquiry under Section 65 of the Cooperative Societies Act (hereinafter referred to as “the Act”). 2. Heard Sri.P.P.Jacob, learned counsel for the petitioners, Smt.Sheeja C.S., the learned Senior Government Pleader, Sri.M.Sasindran, learned counsel for the 5[th] respondent and Sri.Athul Shaji, learned counsel for the 6[th] respondent and Sri.R.Lakshmi Narayan, learned counsel for the Election Commission. **W.P.(C) Nos.6836 & 7440 of 2021** -: 2 :- 3. The third respondent, in Ext.P20 order of supersession entered into the following findings:- (i) Irregularities/misappropriation in the biovillage project causing huge financial loss to the Society. (ii) Irregularities/misappropriation in the purchase and construction of land and building. (iii) Illegalities in the installation of solar panels resulting in financial loss to the Society. (iv) Leasing out the plant and machinery of the Society to third party, thus acting to the detriment of the Society and its members. 4. Admittedly, the setting up of bio-village, the acquisition of land and putting up of building, and installation of solar panels, were carried on during the tenure of the previous Managing Committee. The same is heavily relied upon by the learned counsel for the petitioners to contend that, the said findings cannot entail an order of supersession against the present **W.P.(C) Nos.6836 & 7440 of 2021** -: 3 :- committee. 5. It is rightly contended that the earlier acts of mismanagement cannot be a ground to unseat the present Committee, but it is to be noted that the findings in the order does not end as above. It refers to the acts/omissions of the petitioners which are prejudicial to the interests of the Society. Ext.P20 order indicates that, though the acts and the loss caused under points (i) to (iii) noted above were specified in the audit reports and Section 65 report, the petitioners did not take any step to recompense the same. Vouchers were found replaced and accounts manipulated. Amounts due to contractors were not paid though vouchers were obtained and amounts withdrawn. Though the above were pointed out in the audit report as well as in the report of inquiry under Section 65, no steps were taken for recovery of the amounts. When the 65 inquiry revealed the inaction on the part of the Committee for recovery of the amounts due to the Society, the said amounts were included in **W.P.(C) Nos.6836 & 7440 of 2021** -: 4 :- the suspense accounts and maintained like that without initiating proceedings for recovery. Ext.P11 is the objections submitted by the petitioners to the report on inquiry under Section 65. Therein, the incidents of irregularities and misappropriation noted above are practically admitted. The explanation is that, the Secretary was the person who committed the mischief and that action will be taken against him. The Committee cannot shirk of its responsibility in the light of Rule 47(d) of the Co-operative Societies Rules _**[Thrikkadavoor Service Co-operative Society Ltd. v. Sivasankara Pillai 1990 (2) KLT 594, Rajeev Koshy @ Reji K. Koshy v. State of Kerala and Ors. ILR 2018 (2) Ker. 999]**_ . It was also found that the books and other registers to be maintained in terms of Rule 29 of the Rules have not been maintained. 6. The leasing out of the plant and machinery was done by the present Committee. Admittedly such an act is beyond the bye-laws of the Society. Grant of lease of the plant and machinery installed for the members of the ## **W.P.(C) Nos.6836 & 7440 of 2021** -: 5 :- Society is not an act in the interests of the Society. Though on the directions of the Joint Registrar the lease was sought to be terminated, the lessee filed a suit and obtained an order of injunction which is still in force. The above are sufficient enough to find that the conduct of the Committee is prejudicial to the interests of the Society. 7. Relying on the judgment of the Apex Court in _**State of M.P. v. Sanjay Nagayach (2013) 7 SCC 25**_ and of this Court in _**James v. Joint Registrar 1997 (2) KLT**_ **,** Sri.P.PJacob would vehemently contend that, an elected Committee should seldom be displaced from office unless there are persistent acts of violations or omissions. In my opinion, the acts and omissions found in Ext.P20 order satisfies the requirements to attract an order of supersession. 8. Though with reference to the accounts relating to construction of building, the learned counsel for the petitioner attempted to impress upon the Court that the ## **W.P.(C) Nos.6836 & 7440 of 2021** -: 6 :- calculation given in Ext.P20 order is not correct, the difference in the amount if at all any, by itself, is not a ground to absolve the petitioners. The proceeding is not one under Section 68 of the Act for Surcharge. 9. To sum up, the findings on facts in Ext.P20 order have been arrived at on materials. The same does not call for interference by this Court in exercise of its jurisdiction under Article 226 of the Constitution. 10. On the conclusion as above, the challenge against the subsequent election notification is bound to fail. It is reported that the elected committee has already assumed office. In the result, writ petitions fail and are accordingly dismissed. Sd/- **SATHISH NINAN JUDGE** kns/- //True Copy// P.S. to Judge ## **APPENDIX OF WP(C) 7440/2021** PETITIONER EXHIBITS |EXHIBIT P1|TRUE PHOTOCOPY OF THE REPRESENTATION| |---|---| ||SUBMITTED BY THE FIRST PETITIONER BEFORE THE| ||SECOND RESPONDENT DATED 04.01.2021.| |EXHIBIT P2|TRUE PHOTOCOPY THE ELECTION NOTIFICATION| ||ISSUED BY THE FIFTH RESPONDENT DATED| ||11.01.2021.| |EXHIBIT P3|TRUE PHOTOCOPY OF THE JUDGMENT IN WP(C)| ||M1444/21 DATED 10.02.2021.| |EXHIBIT P4|TRUE PHOTOCOPY OF THE JUDGMENT IN WA 349/21| ||DATED 10.02.2021.| |EXHIBIT P5|TRUE PHOTOCOPY OF THE RELEVANT PORTION OF THE| ||ORDER ISSUED BY THE DEPUTY DIRECTOR, PAGES 1| ||AND 16 TO 18.| |EXHIBIT P6|TRUE PHOTOCOPY OF THE ORDER DATED 20.02.21| ||ISSUED BY THE FIFTH RESPONDENT.| ||-----| ## **APPENDIX OF WP(C) 6836/2021** |PETITIONER EXHIBITS|| |---|---| |EXHIBIT P1|TRUE PHOTOCOPY OF THE RESOLUTION NO.1 DATED| ||25.5.2019| |EXHIBIT P2|TRUE PHOTOCOPY OF THE RESOLUTION ADOPTED BY| ||THE PETITIONER SOCIETY DATED 27.12.2019| |EXHIBIT P3|TRUE PHOTOCOPY OF THE AGREEMENT EXECUTED BY| ||THE SOCIETY WITH ONE MR.PRASOON DATED| ||16.6.2020| |EXHIBIT P4|TRUE PHOTOCOPY OF THE NOTICE ISSUED BY THE| ||THIRD RESPONDENT DATED 6.8.2020| |EXHIBIT P5|TRUE PHOTOCOPY OF THE EXPLANATION FILED BY| ||THE PETITIONER DATED 18.8.2020| |EXHIBIT P6|TRUE PHOTOCOPY OF THE STOP MEMO ISSUED BY THE| ||THIRD RESPONDENT DATED 24.9.2020| |EXHIBIT P7|TRUE PHOTOCOPY OF THE LETTER ISSUED BY THE| ||SECRETARY OF THE SOCIETY DATED 14.10.2020| |EXHIBIT P8|TRUE PHOTOCOPY OF THE JUDGMENT IN WPC| ||21188/2020 DATED 23.2.2021| |EXHIBIT P9|TRUE PHOTOCOPY OF THE ORDER ISSUED BY THE| ||THIRD RESPONDENT DATED 24.1.2020| |EXHIBIT P10|TRUE PHOTOCOPY OF THE LETTER DATED 25.08.20| ||OF THE 3RD RESPONDENT ALONG WITH RELEVANT| ||PORTION OF ENQUIRY REPORT (PAGES 1 T 7 AND 23| ||TO 29)| |EXHIBIT P11|TRUE PHOTOCOPY OF THE REPLY DATED 9.9.2020| ||SUBMITTED TO THE THIRD RESPONDENT BY THE| ||PETITIONER| |EXHIBIT P12|TRUE PHOTOCOPY OF THE RELEVANT PORTION OF THE| ||NOTICE DATED 8.10.2020, PAGES 10 TO 8 AND 35| ||TO 36.| ## **APPENDIX-WP(C) 6836/2021 -2-** |EXHIBIT P13|TRUE PHOTOCOPY OF THE JUDGMENT IN WPC| |---|---| ||NO.22692/2020 DATED 23.10.2020| |EXHIBIT P14|TRUE PHOTOCOPY OF THE REPRESENTATION| ||SUBMITTED BY THE PETITIONERS BEFORE THE THIRD| ||RESPONDENT DATED 30.10.2020| |EXHIBIT P15|TRUE PHOTOCOPY OF THE LETTER ISSUED BY THE| ||THIRD RESPONDENT TO THE PETITIONER DATED| ||2.11.2020| |EXHIBIT P16|TRUE PHOTOCOPY OF THE ORDER ISSUED BY THE| ||THIRD RESPONDENT DATED 27.11.2020| |EXHIBIT P17|TRUE PHOTOCOPY OF LETTER ISSUED BY THE| ||AUDITOR WITH DEFECTS NOTED DATED NIL| |EXHIBIT P18|TRUE PHOTOCOPY OF THE REPORT FILED BY THE| ||SECRETARY DATED NIL| |EXHIBIT P19|TRUE PHOTOCOPY OF THE JUDGMENT IN WA| ||NO.349/2021 DATED 18.2.2021| |EXHIBIT P20|TRUE PHOTOCOPY OF THE ORDER NO.B3305/2018| ||ISSUED BY THE THIRD RESPONDENT DATED 3.3.2021| -----