Rajan Antony v. State of Kerala and The Director General of Police

## **IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT** **THE HONOURABLE MR. JUSTICE ALEXANDER THOMAS** **&** **THE HONOURABLE MR.JUSTICE VIJU ABRAHAM FRIDAY, THE 18TH DAY OF FEBRUARY 2022 / 29TH MAGHA, 1943 OP(KAT) NO. 28 OF 2022** **AGAINST THE ORDER DATED 21.10.2021 IN OA NO.812/2019 OF KERALA ADMINISTRATIVE TRIBUNAL, THIRUVANANTHAPURAM PETITIONER/APPLICANT IN O.A.:** **RAJAN ANTONY,AGED 53 YEARS, S/O (LATE) ANTONY, PC.NO.3482, CIVIL POLICE OFFICER, RAILWAY POLICE STATION, KOLLAM,PIN-691 001, RESIDING AT SABIN VILLA. VADAKKUMBHAGOM, CHAVARA SOUTH, KOLLAM, KERALA-691 584.** **BY ADVS.M.V.THAMBAN R.REJI,THARA THAMBAN B.BIPIN,ARUN BOSE SUNEESH KUMAR R.** **RESPONDENTS/RESPONDENTS IN O.A.:** **STATE OF KERALA** **REPRESENTED BY THE ADDITIONAL CHIEF SECRETARY, 1 HOME DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM,PIN- 695 001, KERALA. THE DIRECTOR GENERAL OF POLICE 2 HEAD QUARTERS, THIRUVANANTHAPURAM, PIN- 695 014,KERALA** **BY SRI.B.UNNIKRISHNA KAIMAL, SR.GOVT.PLEADER** **THIS OP KERALA ADMINISTRATIVE TRIBUNAL HAVING COME UP FOR ADMISSION ON 18.02.2022, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** OP(KAT) No.28 of 2022 2 ## **ALEXANDER THOMAS & VIJU ABRAHAM, JJ.** ## **..........................................................................** ## **O.P.(KAT) No.28 of 2022** _[Arising out of the impugned final order dated 21.10.2021 in O.A. No.812 of 2019 on the file of the KAT, TVM]_ **.................................................................** Dated this the 18[th] day of February, 2022 ## **JUDGMENT** ## **Viju Abraham, J.** The above Original Petition is filed by the applicant in O.A.No.812 of 2019 aggrieved by the order dated 21.10.2021 of the Kerala Administrative Tribunal, Thiruvananthapuram Bench. 2. Disciplinary proceedings were initiated against the petitioner/applicant while working as Civil Police Officer at Changaramkulam Police Station, on the allegation of misbehaviour towards a Woman Police Constable. A preliminary inquiry was conducted in the matter and thereafter an oral inquiry was held by the Circle Inspector of Police, Tirur, as inquiry officer. The disciplinary authority disagreeing with the findings of the inquiry officer in the oral inquiry, issued a show-cause notice to the petitioner to submit his objection as to why the tentative decision to impose a punishment of barring of two increments with cumulative effect should not be confirmed. On receipt of his explanation, proceedings were finalized as per Annexure-A1 order affirming the OP(KAT) No.28 of 2022 3 tentative decision and imposed a punishment of withholding of two increments with cumulative effect. The appeal and the review petition preferred against the same were rejected by the Inspector General of Police, Thrissur, and the Director General of Police respectively. Aggrieved by the same, the petitioner moved the 1[st] respondent Government by filing Annexure-A2 review petition dated 06.04.2010 under Rule 36A of the Kerala Police Departmental Inquiry, Punishment and Appeal Rules, 1958. It is contended that while considering the above review petition, the 1[st] respondent arrived at a tentative decision to reduce/modify the punishment to one of “black mark” as provided under Rule 15(1)(f) of the Kerala Police Departmental Inquiry, Punishment and Appeal Rules, 1958 and thereafter consulted the Public Service Commission in the matter. The Public Service Commission disagreed with the tentative decision of the Government to reduce the punishment and advised the Government not to interfere with the punishment imposed by the disciplinary authority. Thereafter, the said review petition was dismissed by the Government as per Annexure-A3 order dated 04.10.2011. Aggrieved by the said order, the petitioner moved the Tribunal filing O.A.No.1584 of 2016 and the said Original Application was disposed of as per Annexure-A4 order dated OP(KAT) No.28 of 2022 4 24.08.2017 whereby Annexure-A3 order passed by the Government was set aside with a direction to pass fresh orders in the matter. It was also directed in Annexure-A4 order that a copy of the letter dated 20.08.2011 issued by the Public Service Commission shall also be made available to the petitioner and he shall be afforded an opportunity to make a representation on the same. Finally, a hearing was conducted in the matter on 22.11.2018. In the said proceedings the petitioner submitted Annexure-A7 representation reiterating his contentions. After considering the objections of the petitioner, the review petition was rejected by the Government as per Annexure-A8 order dated 29.12.2018. It is aggrieved by the same, O.A.No.812 of 2019 was filed before the Tribunal. 3. Exhibit-P2 reply statement was filed on behalf of the 1[st] respondent in the O.A, mainly contending that Annexure-A8 order has been issued after complying with all the procedural formalities and therefore, it is perfectly legal and valid. The petitioner has filed Exhibit-P3 rejoinder dated 15.03.2021 in answer to the various contentions by the Government in their reply statement. 4. The Tribunal after considering the various contentions raised by both sides dismissed the Original Application as per Exhibit P4 order holding that Annexure-A8 order has been issued by OP(KAT) No.28 of 2022 5 the 1[st] respondent on a proper consideration of the various contentions raised and the same is in accordance with the directions issued by the Tribunal in Annexure-A4 order. It is aggrieved by the said order passed by the Tribunal in O.A.No.812 of 2019 that the present Original Petition is filed. 5. The first contention raised by the petitioner is that the disciplinary authority went wrong in issuing Annexure-A1 order imposing punishment despite the fact that in Ext.P5 Punishment Roll there is a clear finding that the act alleged against the petitioner was never intentional and was only accidental. It is specifically contended by the petitioner that before issuing Annexure-A1 order of punishment, no memo of charge or an opportunity of hearing was afforded to the petitioner and that he has received only a notice intimating the decision to impose the punishment and therefore, Annexure-A1 order is issued in violation of the principles of natural justice. A perusal of the reply statement filed by the 1st respondent would show that on initiation of Punishment Roll, a memo of charge detailing the allegations along with supporting documents was served on the petitioner, and on the culmination of the inquiry, a copy of the PR minutes was also served on the petitioner. During the oral inquiry, sufficient opportunity was granted to the petitioner to OP(KAT) No.28 of 2022 6 defend the allegations raised against him. Though the inquiry officer entered a finding that the alleged act of the petitioner does not appear to be intentional, the disciplinary authority did not concur with the said finding of the inquiry officer. It is settled law that the disciplinary authority is not bound to concur with every finding entered into by the inquiry officer and it is well within its powers to take a different view taking into consideration the evidence adduced and the materials on record brought out in the inquiry proceedings. The said action initiated by the disciplinary authority is well within its powers conferred as per Rule 6 of the Kerala Police Departmental Inquiries Punishment and Appeal Rules, 1958 which deals with the procedure for initiating a departmental inquiry. Rule 6(11) of the said Rules relevant for consideration of this case is extracted below: ## “ _**Rule 6. Procedure for Inquiry.-**_ _xxxxx xxxxx xxxxxx (11): The authority competent to dispose of the proceedings shall, on an examination of such proceedings, record his findings on the several charges inquired into and record a further finding in cases where no charges have been made out whether the member of the Service is free from blame.” (underline supplied)_ Going by Rule 6(11), the disciplinary authority is well within its power to accept or not to accept the findings of the inquiry officer. The only mandate is that the disciplinary authority should provisionally decide on the issue of guilt and penalty to be imposed on the public servant and thereafter notice must be issued to the OP(KAT) No.28 of 2022 7 delinquent officer regarding the proposed action. A perusal of Annexure-A1 order imposing penalty makes it clear that a showcause notice was issued to the petitioner informing him about the tentative decision and the proposed penalty of withholding of two increments with cumulative effect and requiring the petitioner to show cause as to why the said decision shall not be confirmed. In fact, a reply to the said show-cause notice was submitted by the petitioner and it is only after considering the reply submitted by the petitioner that the provisional decision to withhold two increments with cumulative effect was confirmed by the disciplinary authority as per Annexure-A1 order. In view of the above, the contention of the petitioner that no memo of charges was issued and he was not heard before imposing the punishment as per Annexure-A1 order is without any basis. 6. A similar issue regarding action initiated under the Kerala Police Departmental Inquiries, Punishment and Appeal Rules, 1958 was considered by this Court in _**Mathew v. State of Kerala, 1989 (1) KLT 88,**_ and held in paragraph 3 of the judgment as follows: _“3. The power of the Government to differ from the report of the enquiry officer cannot now be questioned. The Government are entitled to consider the report and evidence recorded by the enquiry officer. The Government may agree with the report or may differ either wholly or partly in so far as the conclusions arrived at by the enquiry officer is concerned. If_ OP(KAT) No.28 of 2022 8 _the Government disagree with the finding arrived at by the enquiry officer and hold that the charges framed against the delinquent officer are prima facie proved, the Government should provisionally decide as to what punishment should be imposed on the public servant. Then a notice must be issued to the delinquent officer regarding the proposed action. Second notice is to enable the public servant to satisfy the Government that he is innocent of the charges framed against him and that even if the charges are held proved against him the proposed punishment is unduly severe. No decision has laid down the proposition that the findings recorded by the enquiry officer conclude the matter and that the Government which ordered the enquiry is bound by the findings arrived at by the enquiry officer. Nor has it been said that the findings arrived at by the - enquiry officer are final and cannot be re opened by the Government. The object of the enquiry is to enable the Government to hold an investigation into the charges framed against a public servant. So, the Government can consider the evidence adduced and decide whether the said charges are proved or not. In this view, it is difficult to hold that the findings recorded by the enquiry officer binds the Government and that the Government cannot deviate from the conclusions recorded by the enquiry officer in the last paragraph of the report. As stated earlier, the report, Ext.P4, has not exonerated the petitioner from guilt. Conceding for arguments sake that the 2[nd] respondent has exonerated the petitioner from the charges, the Government are legally entitled to differ from the said finding. In the instant case, the Government informed the petitioner by Ext.P3 notice, their conclusions on the enquiry and requested the petitioner to show cause why a punishment of dismissal from service should not be imposed.” (underline supplied)_ The said view taken in **Mathew case** 's case (supra) was reiterated and upheld by Division Bench of this Court in _**State of Kerala v. Venugopal, 2002 (1) KLT 146**_ . The Apex Court in _**Punjab National Bank and Ors. v. Kunj Behari Misra, (1998) 7 SCC 84**_ , while considering the power of the disciplinary authority to impose a punishment disagreeing with the findings of the inquiry officer, has held that the principles of natural justice only require the disciplinary authority to give an opportunity to the officer charged OP(KAT) No.28 of 2022 9 with misconduct to file a representation and represent his case before a final decision is taken by the disciplinary authority to impose a punishment. The relevant portion of the judgment reads as follows: - “ _19. The result of the aforesaid discussion would be that the principles of natural justice have to be read into Regulation 7(2). As a result thereof, whenever the disciplinary authority disagrees with the enquiry authority on any article of charge, then before it records its own findings on such charge, it must record its tentative reasons for such disagreement and give to the delinquent officer an opportunity to represent before it records its findings. The report of the enquiry officer containing its findings will have to be conveyed and the delinquent officer will have an opportunity to persuade the disciplinary authority to accept the favourable conclusion of the enquiry officer. The principles of natural justice, as we have already observed, require the authority which has to take a final decision and can impose a penalty, to give an opportunity to the officer charged of misconduct to file a representation before the disciplinary authority records its findings on the charges framed against the officer.”_ _(underline supplied)_ The Apex Court in _**J.A.Naiksatam v. Prothonotary & Senior Master, High Court of Bombay and Ors., (2004) 8 SCC 653**_ , while considering a similar issue after considering the decisions in _**Punjab National Bank**_ 's case (supra) and _**Yoginath D.Bagde v. State of Maharashtra, (1999) 7 SCC 739**_ , held as follows: - “ _5. The learned counsel for the appellants contended that as per the Bombay High Court (Discipline and Appeal) Rules (for short “the Bombay Rules”), the appellants were entitled to get a copy of the report of the enquiry officer and they should have been heard_ OP(KAT) No.28 of 2022 10 _before the same was accepted or rejected by the disciplinary authority. The contention was that by virtue of Rule 8, according to the appellants' counsel, though the report of the enquiry officer was furnished, the appellants were not given an effective opportunity to place their arguments against this and it was contended that even before the issuance of show-cause notice the disciplinary authority had made up his mind and had already taken a decision disagreeing with the enquiry officer and seeking an explanation from the delinquent officers was only an empty formality and there was thus serious violation of principles of natural justice._ ## _6._ xxxxxx xxxxxx xxxxxx _Relying on these decisions, the counsel for the appellants contended that after the receipt of the report from the enquiry officer, the disciplinary authority should have given notices to the appellants with its tentative conclusion and an opportunity be given to the delinquent before the report of the enquiry officer is reversed by the disciplinary authority. It was also argued that the appellants should have been heard by the disciplinary authority before such a decision was rendered. Even though the rule as such does not contemplate giving an opportunity to the appellant delinquents before the disciplinary authority takes a final decision to disagree with the reasons given by the enquiry officer, such a provision could be read into the rule but even then the appellants cannot be heard to say that there shall be a personal hearing by the disciplinary authority. In the instant case, the appellants were given a copy of the tentative decision of the disciplinary authority and the appellants furnished detailed explanation and we are of the view that the principles of natural justice have been fully complied with and we do not find any infraction of rules or infirmity in the said decision._ 7. _The counsel further contended that from the tentative decision it could be spelt out that the disciplinary authority had already taken a final decision in the matter and the details have been given therein and the opportunity which was given to the appellants was only an exercise in futility. We are not inclined to accept this contention. It is true that the disciplinary authority gave its reasons for disagreement with the report of the enquiry officer and -_ _the appellants had given their full fledged explanation and if at all the disciplinary authority gave detailed tentative decision before seeking explanation from the appellants, it enabled them to give an effective representation and the principles of natural justice were fully complied with and it cannot be said that the appellants were not being heard in the matter.”_ _(underline supplied)_ OP(KAT) No.28 of 2022 11 In view of the above, the contention of the petitioner that in issuing Annexure-A1 order there is a gross violation of the principles of natural justice is without any basis. 8. The next contention raised by the petitioner is that while exercising the power of review under Rule 36A of Kerala Police Departmental Inquiries, Punishment and Appeal Rules, 1958, there is no requirement for the Government to consult with the Public Service Commission and therefore Annexure-A8 order passed by the Government in the review petition is against law in as much as the Government acted on the advice of the Public Service Commission. It is contended by the petitioner that going by Regulation 6(b) of the Kerala Public Service Commission (Consultation) Regulations, 1957, the Commission need not be consulted by the Government before passing final orders and therefore the tentative decision to reduce the punishment as “black mark” ought to have been confirmed. It is also contended that the report of the Public Service Commission is only recommendatory in nature and therefore, the Government should have taken an independent decision, _dehors_ the opinion of the Public Service Commission. In support of the above said contentions, the petitioner relies on the decision in _**Dy. Director General, NCC v. Gopinathan, 2006 (3) KLT 247**_ and also the OP(KAT) No.28 of 2022 12 decision of the Tribunal in _**Manikandakumar V.V. v. State of Kerala, 2016 Part 2 KAT Reporter Vol. V page 264**_ . On the strength of the said decisions cited above, it was contended that since the original order imposing penalty is not by the Government there is no necessity for consulting with the Public Service Commission when the Government considers a review petition against the original order imposing punishment. After having gone through the said judgments relied on by the petitioner, we feel that those judgments are not applicable in the facts of the present case in as much as in _**Gopinathan**_ ’s case (supra) this Court was considering Regulation 6 of the Kerala Public Service Commission (Consultation) Regulations, 1957 and Rule 15(12)(ii)(a) of the Kerala Civil Services (Classification Control and Appeal) Rules, 1960 and held that consultation with the PSC is necessary only when Government proposes to pass an original order imposing penalty and when the penalty is imposed by an authority other than Government it does not make it obligatory on the said disciplinary authority to consult with the Public Service Commission before such penalty is imposed as provided in Rule 15(12)(ii)(a) of the Kerala Civil Services (Classification Control and Appeal) Rules, 1960. In _**Manikandakumar**_ ’s case (supra) the Tribunal only followed the judgment in _**Gopinathan**_ ’s case (supra). OP(KAT) No.28 of 2022 13 9. Inquiries, Punishment and Appeals in relation to police personnel are governed by the Kerala Police Departmental Inquiry, Punishment and Appeal Rules, 1958. Rule 17 of the said Rules deals with the procedure for imposing penalties. In the present case, the punishment imposed is withholding of increment with cumulative effect as provided in the Kerala Police Departmental Inquiry, Punishment and Appeal Rules, 1958. Admittedly, in the case in hand, the original order of punishment was not imposed by the Government and therefore no consultation with the Public Service Commission is required before imposing punishment as per Annexure-A1 order. But Regulation 6(1)(c) of the said Regulations mandates that when the Government proposes to pass any order in any appeal or revision from or review of an order which has imposed any of the penalties referred to in Sub-clause (a) of the said Regulation, then the Government is bound to consult the Public Service Commission. Regulation 6(1)(c) of the Kerala Public Service Commission (Consultation) Regulations, 1957 reads as follows: _“6.(1) It shall not be necessary for the Commission to be consulted on any disciplinary matter affecting a person serving in connection with the affairs of the State, except-_ _xxxxxxxx xxxxxxx xxxxxxxx_ _(c) where in any appeal or revision from or review of an order which has imposed any of the penalties referred to in sub-clause (a) Government proposes to pass any order.”_ _(underline supplied)_ 11. Rule 36A of the Kerala Police Departmental Inquiry, OP(KAT) No.28 of 2022 14 Punishment and Appeal Rules, 1958 deals with the power of the Government to review any order passed by a Subordinate Authority. Going by Rule 36A of the Kerala Police Departmental Inquiry, Punishment and Appeal Rules, 1958, the Government may on its own motion or otherwise review any order passed by the Subordinate Authority after consultation with the Public Service Commission where such consultation is necessary and confirm, modify or set aside the order or impose any penalty or set aside or issue any other orders as provided under Clauses (a) to (d) of Rule 36A of the Kerala Police Departmental Inquiry, Punishment and Appeal Rules, 1958. In the present case, a punishment of barring of two increments with cumulative effect was awarded and the said punishment is one which is provided under Regulation 6(1)(a)(i)(a) of the Kerala Public Service Commission (Consultation) Regulations, 1957. As per Regulation 6(1)(c) of the Kerala Public Service Commission (Consultation) Regulations, 1957, when the Government proposes to pass any order in any appeal or revision from or review of an order which has imposed any of the penalties referred to in Sub-clause (a) of Regulation 6(1), then the Government is bound to consult the Public Service Commission. A combined reading of Regulation 6(1) (c) of the Kerala Public Service Commission (Consultation) OP(KAT) No.28 of 2022 15 Regulations and Rule 36A of the Kerala Police Departmental Inquiry, Punishment and Appeal Rules, 1958 makes it explicitly clear that when the State Government exercises its power to review an order under the Kerala Police Departmental Inquiry, Punishment and Appeal Rules, 1958, consultation with the Public Service Commission is mandatory. A similar issue was considered by a Division Bench of this Court in _**State of Kerala and Others v. Benny E. and Another, 2019 (1) KHC 557 (DB)**_ , and held that when under Rule 17 of the Kerala Police Departmental Inquiry, Punishment and Appeal Rules, 1958 the order imposing penalty could be passed by the Government only after consulting the Public Service Commission, the order of the Government in appeal or review reducing penalty imposed by disciplinary authority could also have been passed by the Government only after consulting the Public Service Commission, in accordance with the stipulation in Rule 36A of the Kerala Police Departmental Inquiry, Punishment and Appeal Rules, 1958 and the fact that the original order was not passed by the Government is of no consequence. It will be pertinent to refer to the decision of the Division Bench of this Court in _**Benny E.**_ 's case supra [ _**2019 (1) KHC 557 (DB)**_ ], Paragraph 15 which reads as follows: _“15. From a reading of Annexure-A9 order it is clear that the initial_ OP(KAT) No.28 of 2022 16 _proposal of the Government was to reduce the punishment imposed by the disciplinary authority. The penalty imposed by the disciplinary authority was removal from service of the State Government, which is a penalty that is described in Clause (l) of R.15(4) of the Kerala Police Departmental Inquiries, Punishment and Appeal Rules, 1958. The procedure for imposing certain penalties is prescribed under R.17. R.17(i)(b) prescribes the procedure to be followed in cases where it is proposed to impose any of the penalties mentioned in clauses (ja), (k), (l) and (m) of sub-R.1 of R.15. Along with other procedure, the Rule also mandates consultation with the Public Service Commission, before imposing penalty, if the competent authority is the Government. In Abdul Khader's case, one of the grounds of challenge placed by the petitioners therein was that the order imposing punishment was passed without consulting the Government. In that case, the order imposing punishment was issued by the Board of Revenue, under R.11 of the Kerala Civil Services (Classification, Control & Appeal) Rules, 1960. Placing reliance on R.15A of the CCA Rules it was contended that the order imposing penalty is bad for nonconsultation with the Public Service Commission. The contention was rejected by the learned Single Judge, after referring to Regulation 6(1) of the Kerala Public Service Commission (Consultation) Regulations, 1957, which mandated consultation before imposing punishment, only in cases where the Government proposes to pass an original order. In Gopinathan's case also, the contention based on R.15 of the CCA Rules was rejected for the reason that it was not the Government that had issued the original order imposing penalty. The case at hand is entirely different. When, under R.17 of the Kerala Police Departmental Inquiries, Punishment & Appeal Rules, the order imposing penalty could be passed by the Government, only after consultation with the Public Service Commission, necessarily, the order reducing penalty could also have been passed only after consulting the Public Service Commission, in accordance with the stipulation in R.36A. In such circumstances the fact that the original order was not passed by the Government is of no consequence. Therefore, the contention based on the decisions in Abdul Khader & Gopinathan, that before passing Annexure-A9 order, the Government should not have consulted the PSC, is legally unsustainable.”_ 12. In view of the above, Annexure-A8 order issued by the 1[st] respondent rejecting the review petition exercising the power under Rule 36A of the Kerala Police Departmental Inquiry, Punishment and Appeal Rules, 1958 is perfectly in accordance with the law. A copy of the report given by the Public Service Commission was served on the petitioner and Annexure-A8 decision was taken by the Government only after considering the objection filed by the OP(KAT) No.28 of 2022 17 petitioner. Further, the Government has also independently considered the issues involved in compliance with the directions in Annexure-A4 order passed by the Tribunal and also took into consideration the gravity of the allegations involving harassment of a woman at the workplace, that too by a member of a disciplined force and found that there is no reason to interfere with the order of punishment of barring of two increments with cumulative effect imposed on the petitioner as per Annexure-A1 order. Tribunal after considering the contentions raised by the petitioner in detail also entered a finding that the decision of the Government evidenced by Annexure A8 order is in accordance with the law. Hence we find no reason to interfere with the decision of the Tribunal in O.A. No. 812 of 2019 and accordingly the Original Petition is dismissed. Sd/- ## **ALEXANDER THOMAS, JUDGE** Sd/- ## **VIJU ABRAHAM, JUDGE** cks OP(KAT) No.28 of 2022 18 ## **APPENDIX OF OP(KAT) 28/2022** ## **PETITIONER EXHIBITS** - **TRUE COPY OF THE ORIGINAL APPLICATION** - **Exhibit P1 IN O.A.NO. 812/2019 TRUE COPY OF THE ORDER NO. H2/PR/** - **Annexure A1 2007/MM DATED 13.06.2008 TRUE COPY OF THE REVIEW PETITION DATED** - **Annexure A2 06.04.2010 SUBMITTED BY THE APPLICANT. TRUE COPY OF THE G.O.(RT) NO.** - **Annexure A3 2959/2011/ HOME DATED 04.10.2011 TRUE COPY OF THE JUDGMENT DATED** - **Annexure A4 24.08.2017 IN OA NO. 1584/2016 TRUE COPY OF THE G.O.(RT) NO.** - **Annexure A5 3283/2018/ HOME DATED 09.11.2018** - **TRUE COPY OF THE INTERIM ORDER OF THE** - **Annexure A6 HON'BLE TRIBUNAL DATED 14.11.2018 IN CP NO. 86/2018 TRUE COPY OF THE REPRESENTATION DATED** - **Annexure A7 25.10.2018 HANDED OVER TO THE HEARING OFFICERON 22.11.2018 TRUE COPY OF THE G.O.(RT)** - **Annexure A8 NO.3825/2018/ HOME DATED 29.12.2018 TRUE COPY OF THE REPLY STATEMENT FILED** - **Exhibit P2** - **TRUE COPY OF THE REPLY STATEMENT FILED BY THE 1ST RESPONDENT.** - **Exhibit P3 Exhibit P4** **TRUE COPY OF THE REJOINDER FILED BY THE PETITIONER IN O.A.NO.812/2019. TRUE COPY OF THE ORDER DATED 21.10.2021 IN O.A.NO.812/2019.**