Puduppadi Service Co-operative Bank Ltd v. Mathew Joseph

**WP(C) NO. 4144 OF 2022** **1** # **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE MR. JUSTICE RAJA VIJAYARAGHAVAN V FRIDAY, THE 11[TH] DAY OF MARCH 2022 / 20TH PHALGUNA, 1943** **WP(C) NO. 4144 OF 2022** ## **PETITIONER:** PUDUPPADI SERVICE CO-OPERATIVE BANK LTD NO.F 1830, PUDUPPADY P.O., KOZHIKODE - 673 586, REPRESENTED BY ITS SECRETARY. BY ADVS. M.SASINDRAN S.SHYAM KUMAR ## **RESPONDENT:** MATHEW JOSEPH, S/O.JOSEPH, GANAPATHY PLAKKAL HOUSE, KUPPAYAKKODE P.O., KOZHIKODE - 670 580, REPRESENTED BY ITS POWER OF ATTORNEY HOLDER, GEORGE JOSEPH, S/O.JOSEPH, GANAPATHY PLAKKAL HOUSE, KUPPAYAKKODE P.O., KOZHIKODE DISTRICT - 673 580 BY ADVS. GEORGE POONTHOTTAM (SR.) NISHA GEORGE THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 11.03.2022, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: **WP(C) NO. 4144 OF 2022** **2** ## **JUDGMENT** Challenge in this writ petition is mounted against Ext.P11 order passed by the Co-operative Arbitration Court (Northern), Kozhikode, wherein the Arbitration court quashed the disciplinary proceedings initiated against the respondent holding that the charge memo and the charge sheet were issued by the Chairman of the Disciplinary Committee and therefore vitiated as held by this Court in **Kodanchery Service Co-operative Bank Ltd. and Ors. v. Joshy Varghese and Ors.** [2020 (4) KLT 129]. 2. Essentially, the contention advanced by the petitioner to unsettle the order passed by the Co-operative Arbitration court is that the law laid down by this Court in **Kodanchery** (supra) would have only prospective application. The petitioner also raises a contention that the judgment rendered by the Division Bench in **Kodanchery** (supra) is liable to be revisited. 3. The prayer sought for are as under: - (i) Set aside Ext.P11 order dated 16.2.2021 in A.R.C.No.94/2016 before the Co-operative Arbitration Court (Northern) Kozhikode; - (ii) declare that charge memo issued by the disciplinary committee is valid by virtue of Rule 198(2A) of the Kerala Co-operative Societies Rules; **WP(C) NO. 4144 OF 2022** **3** - (iii) in the alternative, to declare that the law laid down by this Hon’ble Court in Kodanchery Service Co-operative Bank Ltd. case (2020 (4) KLT 129] is having only prospective effect from the date of judgment. - (iv) declare that the enquiry proceedings finalized on 11.4.2016 cannot be interfered with based on the law laid down by this Hon’ble court in Kodanchery Service Co-operative Bank Ltd. case; ## (v) award cost to the petitioner. 4. By an interim order dated 8.2.2022, this Court had stayed the proceedings pursuant to Ext.P11 for a period of four weeks. 5. The respondent has entered appearance and has filed a counter affidavit, wherein it is stated that while working as a Secretary in the Society, the respondent had applied for Leave Without Allowance (LWA) from 12.8.2009 to 11.8.2014 for the purpose of travelling abroad and joining his family. He contended that due to illness, he was not able to join duty by 12.8.2014 and a request was made for an extension of leave. On 12.9.2014, show cause notice was issued from the Chairman of the Disciplinary Sub Committee. On 18.10.2014, the respondent was served with a charge memo issued by the Chairman of the Disciplinary Sub Committee. In the meantime, the respondent was demoted to the post of Accountant. A petition was filed before the Joint Registrar on 29.12.2014 challenging the disciplinary action. Later, based on the report submitted by the Joint Registrar, the Registrar, exercising his powers under Rule 176 of the KCS Rules, set aside the order **WP(C) NO. 4144 OF 2022** **4** passed by the bank demoting the respondent to the post of Accountant. Thereafter, on 13.5.2015, a second charge memo was issued by the new Chairman of the Disciplinary Sub Committee and based on the same, an enquiry was conducted and the respondent was dismissed from the service. Challenging the order, ARC No.94/2016 was preferred and by order 16.2.2021, which is impugned in the writ petition, the disciplinary committee was found to be bereft of jurisdiction to issue a charge memo/charge sheet and the dismissal was overturned. 6. The petitioner accepted the order of the Arbitration court and initiated fresh proceedings against the respondent by issuing Ext.R1(a) charge memo on 19.8.2021. Immediately thereafter, an order of suspension was also passed. Responding to the charge memo, the respondent has filed Ext.R1(b) reply. Immediately thereafter, the respondent approached this Court and filed W.P.(C) No.22728/2021 seeking to quash Ext.R1(a) charge memo. By Ext.R1(d) interim order dated 22.12.2021, this Court directed the petitioner to disburse the subsistence allowance to the respondent for the period he was not gainfully employed. The petitioner did not comply with the directions which led the respondent to file COC No. 212/2022 before the learned Single Judge. It was by suppressing all these aspects that the petitioner had approached this Court by merely mentioning the institution of W.P.(C) No. 22728/2021 and had secured the interim order of stay. **WP(C) NO. 4144 OF 2022** **5** 7. It is stated that the intention of the petitioner in filing this writ petition after issuance of fresh charge memo and after suffering an interim order is to buy time till the appointment of a new Secretary and also to deny the respondent the benefits of the interim order granted by this Court in W.P. (C) No.22728/2021. 8. I have considered the submissions and have perused the entire records. 9. I find that the challenge raised by the petitioner is against Ext.P11 order passed by the Co-operative Arbitration Court. It is not in dispute that the charge memo, as well as the charge sheet, had been issued by the Disciplinary Sub Committee. A Division Bench of this Court in **Kodanchery** (supra) has held that no authority has been conferred on the Disciplinary Subcommittee to issue a memo of charges and such an action taken by the Disciplinary Sub Committee would be wholly invalid. It was relying on the said law that the Arbitration Court had allowed the petition filed by the respondent. 10. What is of more relevance is the fact that after the order was set aside by the Arbitration Court, the petitioner has issued a fresh charge memo against the respondent on 19.8.2021. Furthermore, I find that the respondent had filed W.P.(C) No.22728/2021 and a learned Single Judge of this Court had passed a detailed interim order on 22.12.2021 which reads as under: > “Sri.George Poonthottam, has raised a serious objection with regard to **WP(C) NO. 4144 OF 2022** **6** the contents of the letter dated R3(b) dated 29.7.2015 on the ground that as per the contents of the paragraph 3 of the counter affidavit, there has been a specific avernment that respondents had come to know about the e-mail address of the petitioner and the fact that he was in Australia. But the alleged documents of show cause notices and the reply which was purported to be not found satisfactory have not been annexed with this Court. In this view of the matter in order to set the controversy addressed, I direct the respondents to produce all the communication filed pertaining to the suspension and the arbitration proceedings by the next date of hearing. At this stage, Sri. Shyamkumar submitted that as and when the petitioner submits an affidavit of having not gainfully employed, the respondent shall disburse the subsistence allowance for the period he remained not gainfully employed and continue to pay the subsequent subsistence allowance till the expiry of one year of suspension”. 11. As would be evident from the order, the learned counsel for the petitioner had undertaken before this Court that the subsistence allowance due to the petitioner for the period that he remained not gainfully employed would be disbursed. The fact that such an interim order was passed was also not disclosed in the writ petition. The respondent has a case that the said direction was not complied with and they have initiated COC No.212/2022 on 28.1.2022. It was much later that this writ petition was filed on 7.2.2022 and this Court had granted an interim order as prayed for. At the time of admission, the petitioner did not disclose an interim order was passed in W.P.(C) No.22728/2021 filed by the party respondent and a contempt case had been **WP(C) NO. 4144 OF 2022** **7** filed for non-compliance of the interim order. If the said fact was disclosed before this Court at the time of admission, this Court would have thought twice before granting the interim order on 8.2.2022, staying all further proceedings pursuant to Ext.P11 and directions would have been issued to the petitioner to comply with the interim order passed in W.P.(C) No.22728/2021. It is submitted across the bar that the interim order of stay passed in this writ petition was placed before the learned single judge hearing the contempt matter as well. It is well-settled that the jurisdiction exercised by this Court under Article 226 of the Constitution of India is extraordinary, equitable and discretionary and it is imperative that the petitioner approaching the writ court must come with clean hands and put forward all facts before the Court without concealing or suppressing anything. The petitioner is required to disclose all material facts without any reservation even if they are against him. The petitioner must disclose all the facts having a bearing on the relief sought without any qualification. From the sequence of events narrated above, I am firm in my view that the petitioner has not approached this Court with clean hands. 12. In **Kishore Samrite v. State of U.P** ., [(2013) 2 SCC 398] while deprecating the practice of suppression of material facts, the Apex Court had observed thus : 35. With the passage of time, it has been realised that people used to feel **WP(C) NO. 4144 OF 2022** **8** proud to tell the truth in the courts, irrespective of the consequences but that practice no longer proves true, in all cases. The court does not sit simply as an umpire in a contest between two parties and declare at the end of the combat as to who has won and who has lost but it has a legal duty of its own, independent of parties, to take active role in the proceedings and reach at the truth, which is the foundation of administration of justice. Therefore, the truth should become the ideal to inspire the courts to pursue. This can be achieved by statutorily mandating the courts to become active seekers of truth. To enable the courts to ward off unjustified interference in their working, those who indulge in immoral acts like perjury, prevarication and motivated falsehood, must be appropriately dealt with. The parties must state forthwith sufficient factual details to the extent that it reduces the ability to put forward false and exaggerated claims and a litigant must approach the court with clean hands. It is the bounden duty of the court to ensure that dishonesty and any attempt to surpass the legal process must be effectively curbed and the court must ensure that there is no wrongful, unauthorized or unjust gain to anyone as a result of abuse of process of court. One way to curb this tendency is to impose realistic or punitive costs. 36. The party not approaching the court with clean hands would be liable to be non-suited and such party, who has also succeeded in polluting the stream of justice by making patently false statements, cannot claim relief, especially under Article 136 of the Constitution. While approaching the court, a litigant must state correct facts and come with clean hands. Where such statement of facts is based on some information, the source of such information must also be disclosed. Totally misconceived petition amounts to an abuse of process of court and such a litigant is not required to be dealt with lightly, as a petition containing misleading and inaccurate statement, if filed, to achieve an ulterior purpose amounts to an abuse of process of court. A litigant is bound to make “full and true disclosure of facts”. (Refer: **WP(C) NO. 4144 OF 2022** Tilokchand Motichandv. H.B. Munshi[(1969) 1 SCC 110] , A. Shanmugam v. Ariya Kshatriya Rajakula Vamsathu Madalaya Nandhavana Paripalanai Sangam [(2012) 6 SCC 430], Chandra Shashi v. Anil Kumar Verma [(1995) 1 SCC 421] , Abhyudya Sanstha v. Union of India [(2011) 6 SCC 145] , State of M.P. v. Narmada Bachao Andolan [(2011) 7 SCC 639], Kalyaneshwari v. Union of India [(2011) 3 SCC 287]) 37. The person seeking equity must do equity. It is not just the clean hands, but also clean mind, clean heart and clean objective that are the equifundamentals of judicious litigation. The legal maxim jure naturae aequum est neminem cum alterius detrimento et injuria fieri locupletiorem, which means that it is a law of nature that one should not be enriched by the loss or injury to another, is the percept for courts. Wide jurisdiction of the court should not become a source of abuse of process of law by the disgruntled litigant. Careful exercise is also necessary to ensure that the litigation is genuine, not motivated by extraneous considerations and imposes an obligation upon the litigant to disclose the true facts and approach the court with clean hands. 38. No litigant can play “hide and seek” with the courts or adopt “pick and choose”. True facts ought to be disclosed as the court knows law, but not facts. One, who does not come with candid facts and clean breast cannot hold a writ of the court with soiled hands. Suppression or concealment of material facts is impermissible to a litigant or even as a technique of advocacy. In such cases, the court is duty-bound to discharge rule nisi and such applicant is required to be dealt with for contempt of court for abusing the process of court. (K.D. Sharma v. SAIL[(2008) 12 SCC 481] .) 39. Another settled canon of administration of justice is that no litigant should be permitted to misuse the judicial process by filing frivolous petitions. No litigant has a right to unlimited drought upon the court time and public money in order to get his affairs settled in the manner as he **WP(C) NO. 4144 OF 2022** **10** wishes. Easy access to justice should not be used as a licence to file misconceived and frivolous petitions. (Buddhi Kota Subbarao v. K. Parasaran [(1996) 5 SCC 530]) 13. In a recent judgment of the Hon’ble Apex Court in **Shri K. Jayaram and Ors. v. Bangalore Development Authority and Ors.** [Civil Appeal Nos. 7550 and 7553 of 2021], it was held as follows: 12. It is well-settled that the jurisdiction exercised by the High Court under Article 226 of the Constitution of India is extraordinary, equitable and discretionary and it is imperative that the petitioner approaching the writ court must come with clean hands and put forward all facts before the Court without concealing or suppressing anything. A litigant is bound to state all facts which are relevant to the litigation. If he withholds some vital or relevant material in order to gain advantage over the other side then he would be guilty of playing fraud with the court as well as with the opposite parties which cannot be countenanced. 13. This Court in Prestige Lights Ltd. V. State Bank of India [(2007) 8 SCC 449] has held that a prerogative remedy is not available as a matter of course. In exercising extraordinary power, a writ court would indeed bear in mind the conduct of the party which is invoking such jurisdiction. If the applicant does not disclose full facts or suppresses relevant materials or is otherwise guilty of misleading the court, the court may dismiss the action without adjudicating the matter. It was held thus: “33. It is thus clear that though the appellant Company had approached the High Court under Article 226 of the Constitution, it **WP(C) NO. 4144 OF 2022** **11** had not candidly stated all the facts to the Court. The High Court is exercising discretionary and extraordinary jurisdiction under Article 226 of the Constitution. Over and above, a court of law is also a court of equity. It is, therefore, of utmost necessity that when a party approaches a High Court, he must place all the facts before the Court without any reservation. If there is suppression of material facts on the part of the applicant or twisted facts have been placed before the Court, the writ court may refuse to entertain the petition and dismiss it without entering into merits of the matter.” 14. In Udyami Evam Khadi Gramodyog Welfare Sanstha and Another v. State of Uttar Pradesh and Others [(2008) 1 SCC 560], this Court has reiterated that the writ remedy is an equitable one and a person approaching a superior court must come with a pair of clean hands. Such person should not suppress any material fact but also should not take recourse to legal proceedings over and over again which amounts to abuse of the process of law. 15. In K.D. Sharma v. Steel Authority of India Limited and Others [(2008)12 SCC 481], it was held thus: “34. The jurisdiction of the Supreme Court under Article 32 and of the High Court under Article 226 of the Constitution is extraordinary, equitable and discretionary. Prerogative writs mentioned therein are issued for doing substantial justice. It is, therefore, of utmost necessity that the petitioner approaching the writ court must come with clean hands, put forward all the facts before the court without concealing or suppressing anything and seek an appropriate relief. If there is no candid disclosure of **WP(C) NO. 4144 OF 2022** **12** relevant and material facts or the petitioner is guilty of misleading the court, his petition may be dismissed at the threshold without considering the merits of the claim. 35. The underlying object has been succinctly stated by Scrutton, L.J., in the leading case of R. v. Kensington Income Tax Commrs.(1917) 1 KB 486 in the following words: (KB p. 514) “… it has been for many years the rule of the court, and one which it is of the greatest importance to maintain, that when an applicant comes to the court to obtain relief on an ex parte statement he should make a full and fair disclosure of all the material facts—it says facts, not law. He must not misstate the law if he can help it—the court is supposed to know the law. But it knows nothing about the facts, and the applicant must state fully and fairly the facts; and the penalty by which the court enforces that obligation is that if it finds out that the facts have not been fully and fairly stated to it, the court will set aside any action which it has taken on the faith of the imperfect statement.” (emphasis supplied) 36. A prerogative remedy is not a matter of course. While exercising extraordinary power a writ court would certainly bear in mind the conduct of the party who invokes the jurisdiction of the court. If the applicant makes a false statement or suppresses material facts or attempts to mislead the court, the court may dismiss the action on that ground alone and may refuse to enter **WP(C) NO. 4144 OF 2022** **13** into the merits of the case by stating, “We will not listen to your application because of what you have done.” The rule has been evolved in the larger public interest to deter unscrupulous litigants from abusing the process of court by deceiving it. 37. In Kensington Income Tax Commrs.(supra), Viscount Reading, C.J. observed: (KB pp. 495-96) “… Where an ex parte application has been made to this Court for a rule nisi or other process, if the Court comes to the conclusion that the affidavit in support of the application was not candid and did not fairly state the facts, but stated them in such a way as to mislead the Court as to the true facts, the Court ought, for its own protection and to prevent an abuse of its process, to refuse to proceed any further with the examination of the merits. This is a power inherent in the Court, but one which should only be used in cases which bring conviction to the mind of the Court that it has been deceived. Before coming to this conclusion a careful examination will be made of the facts as they are and as they have been stated in the applicant’s affidavit, and everything will be heard that can be urged to influence the view of the Court when it reads the affidavit and knows the true facts. But if the result of this examination and hearing is to leave no doubt that the Court has been deceived, then it will refuse to hear anything further from the applicant in a proceeding which has only been set in motion by means of a misleading affidavit.” (emphasis supplied) 38. The above principles have been accepted in our legal system **WP(C) NO. 4144 OF 2022** **14** also. As per settled law, the party who invokes the extraordinary jurisdiction of this Court under Article 32 or of a High Court under Article 226 of the Constitution is supposed to be truthful, frank and open. He must disclose all material facts without any reservation even if they are against him. He cannot be allowed to play “hide and seek” or to “pick and choose” the facts he likes to disclose and to suppress (keep back) or not to disclose (conceal) other facts. The very basis of the writ jurisdiction rests in disclosure of true and complete (correct) facts. If material facts are suppressed or distorted, the very functioning of writ courts and exercise would become impossible. The petitioner must disclose all the facts having a bearing on the relief sought without any qualification. This is because “the court knows law but not facts”. 39. If the primary object as highlighted in Kensington Income Tax Commrs. (supra) is kept in mind, an applicant who does not come with candid facts and “clean breast” cannot hold a writ of the court with “soiled hands”. Suppression or concealment of material facts is not an advocacy. It is a jugglery, manipulation, manoeuvring or misrepresentation, which has no place in equitable and prerogative jurisdiction. If the applicant does not disclose all the material facts fairly and truly but states them in a distorted manner and misleads the court, the court has inherent power in order to protect itself and to prevent an abuse of its process to discharge the rule nisi and refuse to proceed further with the examination of the case on merits. If the court does not reject the petition on that ground, the court would be failing in its duty. In fact, such an applicant requires to be dealt with for **WP(C) NO. 4144 OF 2022** **15** contempt of court for abusing the process of the court.” 16. It is necessary for us to state here that in order to check multiplicity of proceedings pertaining to the same subject-matter and more importantly to stop the menace of soliciting inconsistent orders through different judicial forums by suppressing material facts either by remaining silent or by making misleading statements in the pleadings in order to escape the liability of making a false statement, we are of the view that the parties have to disclose the details of all legal proceedings and litigations either past or present concerning any part of the subject-matter of dispute which is within their knowledge. In case, according to the parties to the dispute, no legal proceedings or court litigations was or is pending, they have to mandatorily state so in their pleadings in order to resolve the dispute between the parties in accordance with law. 14. In the case on hand, it is obvious that the petitioner has suppressed certain vital facts and has filed this writ petition after the initiation of fresh proceedings against the employee with a dubious motive. A blatant attempt was made to secure orders from this Court without disclosing true, complete and correct facts. A Court of Law is also a Court of Equity. It is, therefore, of utmost necessity that when a party approaches this Court, he must place all the facts without any reservation. While exercising power under Article 226, this Court will indeed bear in mind the conduct of the party who is invoking such jurisdiction. If the applicant does not disclose full facts or suppresses relevant materials or is otherwise guilty of misleading the court, the court will have to dismiss the action without adjudicating the matter. The **WP(C) NO. 4144 OF 2022 16** rule has been evolved in the larger public interest to deter unscrupulous litigants from abusing the process of the court by deceiving it. The very basis of the writ jurisdiction rests in disclosure of true, complete and correct facts. If the material facts are not candidly stated or are suppressed or are distorted, the very functioning of the writ courts would become impossible. For the aforesaid reasons, the petitioner is not entitled to any of the reliefs sought for in this writ petition. This writ petition fails and the same is accordingly dismissed. **Sd/-** **RAJA VIJAYARAGHAVAN V** **JUDGE** ps **WP(C) NO. 4144 OF 2022** **17** ## **APPENDIX OF WP(C) 4144/2022** PETITIONER'S EXHIBITS: Exhibit P1 A TRUE COPY OF THE RESOLUTION SANCTIONING LEAVE TO THE RESPONDENT DATED 21.05.2009. Exhibit P2 A TRUE COPY OF THE SHOW CAUSE NOTICE DATED 12.09.2014 ISSUED BY THE CHAIRMAN, DISCIPLINARY SUB COMMITTEE. Exhibit P3 A TRUE COPY OF THE CHARGE MEMO DATED 18.10.2014 ISSUED BY THE CHAIRMAN, DISCIPLINARY SUB COMMITTEE. Exhibit P3(a) A TRUE COPY OF THE REPLY SUBMITTED BY THE PETITIONER TO THE CHAIRMAN, DISCIPLINARY SUB COMMITTEE DATED 28.10.2014. Exhibit P4 A TRUE COPY OF THE ORDER DATED 04.04.2015 ISSUED BY THE JOINT REGISTRAR OF COOPERATIVE SOCIETIES, KOZHIKODE. Exhibit P5 A TRUE COPY OF THE ORDER DATED 13.04.2015 ISSUED BY THE PRESIDENT OF THE PETITIONER SOCIETY. Exhibit P6 A TRUE COPY OF THE CHARGE MEMO DATED 13.05.2015 ISSUED TO THE 1ST RESPONDENT BY THE DISCIPLINARY COMMITTEE OF THE SOCIETY. Exhibit P6(a) A TRUE COPY OF THE REPLY DATED 20.05.2015 SUBMITTED BY THE 1ST RESPONDENT TO DISCIPLINARY COMMITTEE. Exhibit P7 A TRUE COPY OF THE ORDER OF DISMISSAL DATED 11.04.2016 ISSUED BY THE CHAIRMAN, DISCIPLINARY SUB COMMITTEE. Exhibit P8 A TRUE COPY OF THE APPEAL SUBMITTED BY THE 1ST RESPONDENT TO THE COMMITTEE OF THE SOCIETY Exhibit P8(A) A TRUE COPY OF THE ORDER DATED 13.08.2016 ISSUED BY THE PRESIDENT OF THE PETITIONER SOCIETY. **WP(C) NO. 4144 OF 2022** **18** Exhibit P9 A TRUE COPY OF THE PLAINT IN A.R.C. NO. 94/2016 BEFORE THE CO-OPERATIVE ARBITRATION COURT, KOZHIKODE. Exhibit P10 A TRUE COPY OF THE WRITTEN STATEMENT IN A.R.C. NO.94/2016 BEFORE THE CO-OPERATIVE ARBITRATION COURT, KOZHIKODE DATED 28.04.2017. Exhibit P11 A TRUE COPY OF THE ORDER DATED 16.02.2021 IN A.R.C. NO.94/2016. Exhibit P12 A TRUE COPY OF THE INTERIM ORDER DATED 03.02.2022 IN WP(C) NO.3639 OF 2022. Exhibit P12(IN A TRUE COPY OF THE LETTER DATED 07.02.2022 REPLY AFFIDAVIT) ISSUED BY THE SOCIETY TO THE 1ST RESPODNENT Exhibit P13 A TRUE COPY OF THE LETTER DATED 9.2.2022 SUBMITTED BY THE 1ST RESPONDENT TO THE SOCIETY. Exhibit P14 A TRUE COPY OF THE JUDGMENT DATED 22.2.2022 IN CONTEMPT CASE NO.212/2022 RESPODNENT'S EXHIBITS EXHIBIT R1(a) TRUE COPY OF THE CHARGE MEMO DATED 19.08.2021 ISSUED BY THE BANK TO THE DEPONENT HEREIN EXHIBIT R1(b) TRUE COPY OF THE REPLY TO THE CHARGE MEMO SUBMITTED BY THE DEPONENT HEREIN DATED 07.09.2021 EXHIBIT R1(c) TRUE COPY OF W.P.(C) No.22728 OF 2021 FILED BY THE DEPONENT HEREIN BEFORE THIS HON'BLE COURT, WITHOUT ITS EXHIBITS. EXHIBIT R1(d) TRUE COPY OF THE INTERIM ORDER IN W.P.(C) No.22728 OF 2021 DATED 22.12.2021 PASSED BY THIS HON'BLE COURT. EXHIBIT R1(e) TRUE COPY OF THE CONTEMPT PETITION COC NO.212 OF 2022, WITHOUT ANNEXURES, FILED BY THE DEPONENT HEREIN BEFORE THIS HON'BLE COURT. **WP(C) NO. 4144 OF 2022** **19** EXHIBIT R1(f) TRUE COPY OF THE AFFIDAVIT IN COC NO.212 OF 2022 FILED BY THE RESPONDENT THEREIN, WITHOUT ANNEXURES, BEFORE THIS HON'BLE COURT. EXHIBIT R1(g) TRUE COPY OF THE COMMUNICATION DATED 18.10.2021 ISSUED TO THE PETITIONER BY THE BANK. EXHIBIT R1(h) TRUE COPY OF THE COMMUNICATION DATED 20.10.2021 ISSUED TO THE PETITIONER BY THE CHAIRMAN OF THE DISCIPLINARY COMMITTEE OF THE BANK.