Rejimon Joseph v. State of Kerala and Others

## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE MR. JUSTICE K.HARIPAL** **TUESDAY, THE 8[TH] DAY OF FEBRUARY 2022 / 19TH MAGHA, 1943** ## **CRL.MC NO. 5726 OF 2017** **FIR NO. 1279/2015 OF KATTAPPANA POLICE STATION** ## **PETITIONER/ACCUSED:** **REJIMON JOSEPH S/O. SEBASTIAN JOSEPH, NJALLANIYIL HOUSE, PARAKADAVU, KATTAPANA P.O, IDUKKI DISTRICT, PIN - 685 508.** **BY ADVS.SRI.P.K.IBRAHIM SMT.K.P.AMBIKA** ## **RESPONDENTS/COMPLAINANTS:** |**1**|**STATE OF KERALA**| |---|---| ||**REPRESENTED BY PUBLIC PROSECUTOR,**| ||**HIGH COURT OF KERALA,**| ||**ERNAKULAM,**| ||**KOCHI - 682 031.**| |**2**|**THE SUB INSPECTOR OF POLICE**| ||**KATTAPPANA.**| |**3**|**THE DEPUTY SUPERINTEDENT OF POLICE**| ||**KATTAPPANA,**| ||**IDUKKI.**| |**4**|**ROY V.C**| ||**VELLAPPALLIL HOUSE,**| ||**KATTAPPANA,**| ||**IDUKKI DISTRICT, PIN - 685 508.**| |**5**|**SABU JOSEPH**| ||**PLATHOTTANICKAL HOUSE,**| ||**KUNTHALAMPARA,**| ||**KATTAPPANA P.O,**| ||**IDUKKI DISTRICT, PIN - 685 508.**| |**6**|**DAVIS T.J**| ||**THALIYAN,**| ||**I.T.I PADY,**| ||**KATTAPPANA P.O,**| ||**IDUKKI DISTRICT, PIN - 685 508.**| Crl.M.C.No.5726 OF 2017 2 - **7 JOSEPH P.J PATHINANJU PARAMBU, KOCHUTHOVALA, KATTAPPANA P.O,IDUKKI DISTRICT, PIN - 685 508.** - **8 THOMAS E.D ELANTHOOR, KUNTHALAMPARA, KATTAPPANA P.O, IDUKKI DISTRICT, PIN - 685 515.** - **9 SEBASTIAN VARGHESE NAMBURACKAL HOUSE, KATTAPPANA TOWN, KATTAPPANA P.O, IDUKKI DISTRICT, PIN - 685 508.** - **10 JOSE VARGHESE MANAKATTU VILA, KUNTHALAMPARA, KATTAPPANA P.O, IDUKKI DISTRICT, PIN - 685 515.** - **11 JACOB MATHEW CHERUKUNNEL, KATTAPPANA TOWN, KATTAPPANA P.O, IDUKKI DISTRICT, PIN - 685 508.** - **12 MOLY GEORGE MAMBALAM, KOCHUTHOVALA,KATTAPPANA P.O, IDUKKI DISTRICT, PIN - 685 508.** - **13 JOSEPH MANGATTUPOYIKAYIL, PARAKKADAVU, PULIYANMALA, KATTAPPANA P.O, IDUKKI DISTRICT, PIN - 685 508.** **R1 TO R3 BY SMT. PUSHPALATHA M.K.,SENIOR PUBLIC PROSECUTOR** **R4 TO R8, R10 TO R13 BY ADV.SRI.LIJI.J.VADAKEDOM** **THIS CRIMINAL MISC. CASE HAVING BEEN FINALLY HEARD ON** **09.12.2022, THE COURT ON 08.02.2022 PASSED THE FOLLOWING:** Crl.M.C.No.5726 OF 2017 3 ## **ORDER** Njallani Sebastian Joseph was a celebrated cardamom planter in Kattappana. He reached Kattappana, a hill station by migrating from the Central Travancore in his early years and started cultivation of various hill produces on experimental basis. The early days of his cultivation in Kattappana was very adventurous, but gradually he started inventing new and new varieties of cardamom plants and ultimately, he became a successful cardamom planter. There are two cardamom plants in his name; 'Njallani' which is the name of his family and ‘Green Gold’, both are said to be very productive cardamom plants which have become very popular among cardamom growers in the high ranges. But his death on 14.02.2011 has created some controversy. 2. Petitioner is the third son of Sebastian Joseph. According to him, it was himself and his father together who Crl.M.C.No.5726 OF 2017 4 made various innovative cultivations in cardamom planting, they together had invented two cardamom plants, Njallani and Green Gold, for which they were granted awards by the Planning Commission of India and also the Innovation Foundation under the National Council for Scientific and Industrial Research. However, the petitioner claims that his father was not in good terms with other children and it was he who accompanied the father during his last days. Father was a heart patient. On 13.02.2011, he was given an award of Rs.8 lakhs in fixed deposit by the Spices Board which was meant for his future well-being. Interest derived from the fixed deposit could be benefited as pension, that the said prize was given to him on 13.02.2011 at the Spices Park. On the following day, father was found dead in his house. According to the petitioner, it was a natural death, he had died of heart attack, his body was buried in their home parish cemetery, in the presence of large gathering. The body was buried in the family vault in the parish cemetery. The petitioner also claims that he has large number of enemies. For various reasons his younger brother Crl.M.C.No.5726 OF 2017 5 Roymon Sebastian is on inimical terms with him. Petitioner is a dissident in the church. The Vicar and the Assistant Vicar of the church are also on inimical terms with him. On account of an incident in the Sunday School in which his 13 year old daughter was publically humiliated in the presence of about thousand students, he had made a hue and cry and had made complaints against the Parish Vicar and the Mother Superior. Out of that reason, they are on inimical terms with him. He is also maintaining modern ideas on the affairs of the church. He is against the luxurious life of the clergy and also luxurious construction of churches, parish halls, commercial buildings, etc. Once he was asked to make a contribution of Rs.1,00,000/- for such a construction, which he refused and on that account also the clergy and some parishioners are against him. He is an organizer of the priests, ex-priests and ex-nuns of the church and has always raised voice for their cause. He is conducting a crusade against illegal activities of the church and for that reason the church is against him. His younger brother Roymon Joseph had a civil case with the father; he also had Crl.M.C.No.5726 OF 2017 6 caused his mother to initiate proceedings against the father under the Domestic Violence Act and at last, the father was compelled to yield and settle the suit filed by Roymon on account of the proceedings initiated under the Domestic Violence Act. On all these reasons, the father was very much depressed during his last days. For the prize giving ceremony on 13.02.2011 also, he had accompanied the father and later it was he who had dropped the father in his house and on the following day, when he had gone there with breakfast for the father, who was living alone, he was found lying motionless; immediately few neighbours were called and later the body was buried in the family vault in the presence of all concerned. But later, on account of the enmity of the younger brother, some of them have raised baseless allegations against him that the death of the father was not a natural death, the father was killed by him, that he had allegedly told the mother that he had ‘sent the father to the other world’, that the father was afraid of him and that father had related to many persons that the petitioner is waiting for an opportunity to get rid of him, that Crl.M.C.No.5726 OF 2017 7 immediately after the death of the father, posters were seen in and around the place of the petitioner and others at Parakkadavu that it was a case of murder, there are mysterious circumstances leading to the death and therefore, the matter requires investigation by the police after registering a crime. On the basis of such a complaint given to the Inspector General of police, the police registered Annexure - A14 Crime, No.1279 of 2015 of Kattappana police station under Section 174 of the Cr.P.C. Now it is understood that a special investigation team has been constituted and the target of attack is the petitioner. It is stated that it was he who committed murder of the father, but it is totally a false allegation. Such allegations have been spread at the instance of his younger brother and some other members of the parish and the clergy, who are inimically disposed against him. There is no material evidence to register such a crime and commence investigation. The body of the father was buried on 15.02.2011 and thereafter, when the mother died, her body was also buried on 15.06.2012 in the very same vault and any attempt to exhume the body would Crl.M.C.No.5726 OF 2017 8 amount to disturb the peace of the departed souls which is an act of vengeance to tackle the petitioner. Therefore, the petitioner seeks to quash Annexure -A14 FIR No.1279 of 2015 of Kattappana police station and all further proceedings taken pursuant thereto. 3. I heard the learned counsel for the petitioner and also perused Annexures-A1 to A22 documents relied on by him. I also heard the learned Senior Public Prosecutor who opposed granting any relief to the petitioner. 4. According to the petitioner, the very registration of the crime after 4 years and 10 months itself is mischievous. There is absolutely no basis in registering the crime after long lapse of time, that too under Section 174 of the Cr.P.C. Relying on the decisions reported in **Manoj Kumar Sharma and Others v. State of Chhattisgarh** [ **AIR 2016 SC 3930]** , which has been followed in **Rhea Chakraborty v. State of Bihar and others [AIR 2020 SC 3826],** the learned counsel pointed out that so long as the body was buried long before in 2011, there is no justification in initiating proceedings under Section Crl.M.C.No.5726 OF 2017 9 174 of the Cr.P.C. According to him, the object of Section 174 of the Cr.P.C. is merely to ascertain whether a person had died under suspicious circumstances or was an unnatural death and if so, what was the apparent cause of the death. The question regarding the details as to how the deceased had lost his life and the circumstances he was assaulted and allegedly killed etc. are foreign to the ambit and scope of proceedings under Section 174 of the Cr.P.C. Therefore, according to him, such a proceeding initiated under Section 174 of the Cr.P.C.is idle and faulty. 5. He also highlighted that absolutely no reason has been stated for initiating such a proceeding after nearly five years, so far, no effective investigation has been done on the crime. Relying on the decision reported in **State of Haryana and Others v. Bhajan Lal and Others [AIR 1992 SC 604]** , he said that as the criminal proceedings are manifestly attended with malafide and was instituted maliciously, this Court invoking the jurisdiction under Section 482 of the Cr.P.C. can quash the proceedings. Referring to Annexures - A3/A15 Crl.M.C.No.5726 OF 2017 10 complaint or mass petition which led to the registration of Annexure - A14 crime, he said that such a mass petition lacks even a date; after going through the said mass petition, it can be said that it is highly mischievous and it would be foolish to conduct any investigation basing on the same. Therefore, he strongly advocated for quashing the proceedings. 6. On the other hand, the learned Senior Public Prosecutor opposed the prayers of the petitioner. According to her, the petitioner has no locus standi to stall an investigation that may unravel any mystery in which the said Njallani Sebastian Joseph had died. If the hands of the petitioner are clean, according to the learned Public Prosecutor, there is no reason for him to be worried about. The said Sebastian Joseph has four sons and two daughters and except the petitioner, none has any objection in conducting an investigation that might unravel the mystery behind the death of the father. Therefore, since the petitioner is very much worried, according to the learned Public Prosecutor, it is a matter of adverse inference and therefore, the investigation should be allowed to be Crl.M.C.No.5726 OF 2017 11 conducted and the Crl.M.C. is sought to be dismissed. 7. The petitioner claims that he is also a celebrated cardamom planter, he along with the father made innovative researches in the matter of bringing out new varieties of cardamom saplings, which have made vast changes in cardamom growing, which ensured a decent return to the cardamom planters. The varieties 'Njallani' and 'Green Gold' are the products of his innovation as well, for which he also had received award from the National Innovative Foundation, besides a cardamom researcher, he is a social activist and has formed a trust by name Aroma Trust which is providing shelter homes to homeless persons, study materials etc., he has made innovative developments in cardamom planting and also he is a speck in the eye of the clergy, as he had opposed all the lavish and wayward life of the clergy; he is an organiser of an association of former priests and former nuns and therefore, the clergy and other parishioners are opposed to him. He also wanted to say that, he is an advocate of the Church Act. His association had also put up candidates in four assembly Crl.M.C.No.5726 OF 2017 12 constituencies and therefore, some of the persons at the helm of affairs especially, the clergy are totally opposed to him. So, such persons, at the instance of his younger brother Roymon Joseph are behind Annexures - A13/A15 mass representation. His father was a heart patient, that it was only he who had associated with father. It was he who had taken the father to the Spices Park on 13.02.2011 for receiving the award, a gift cheque of Rs. 8,00,000/-. According to him, the other children and others were under the impression that he was given a cash of Rs. 8,00,000/-. In fact, it was a fixed deposit. If at all there was any foul play that might have been done by somebody who might have eye on the assets of the father. 8. After considering the rival contentions and evidence, for numerous reasons, I am of the definite view that it would be a futile exercise to rake up an issue and cause investigation in a death that had happened as early as on 14.02.2011. I am of the view that it is futile to raise contentions based on the provision of law relied on by the prosecution. When such a complaint was received and after Crl.M.C.No.5726 OF 2017 13 making some preliminary enquiry the Inspector General of police sent the communication to the Deputy Superintendent of Police and that was how Annexure - A14 FIR was registered and investigation had commenced. The documents produced by the petitioner indicate that later a special investigation team was constituted and the petitioner was also given notice to appear before the Investigating Officer and to give evidence. Later, Annexure - A21 notice was issued stating that the body is going to be exhumed and then he moved this Court again stating that the allegations are frivolous, belated and contrived and by order dated 26.03.2019, a learned Judge of this Court directed to keep the Annexure - A21 notice in abeyance for two weeks. Thereafter, the said interim order continues in operation. Now the point for consideration is whether there is any meaning in conducting investigation in such a case in respect of a cause of action, which had allegedly arisen as early as on 14.02.2011. 9. As rightly pointed out by the learned counsel for the petitioner, the first and foremost reason impelling this Court to Crl.M.C.No.5726 OF 2017 14 think in favour of the contentions raised by the petitioner is the long lapse of time. As noticed earlier, the father had died on 14.02.2011. According to the petitioner, he had dropped the father in the house in the night of 13.02.2011, where he was living alone. After the ceremony in the Spices Park on 13.02.2011, he had dropped the father in the night in the said house and on 14.02.2011, morning, when he had reached there, father was found lying motionless in the house. He immediately alerted some of the neighbours and thus they found that the father was no more. According to him, at that time there was absolutely no doubt about the cause of the death. It was a death due to cardiac arrest and in the presence of a large crowd the body was buried in the parish cemetery in the family vault on 15.02.2011. It was only long after, on the basis of Annexures - A13/A15, that the crime was registered, which is frivolous and malafide. 10. The alleged death had taken place on 14.02.2011 and the crime under Section 174 of the Cr.P.C. was registered on the basis of Annexures - A13/A15 on 08.10.2015 after four Crl.M.C.No.5726 OF 2017 15 years and ten months. It is peremptory that information about the commission of a cognizable offence should be given at the earliest and investigation should commence. Any delay in alerting the police and commencement of investigation is liable to be explained by the prosecution. If there is undue delay, it is for the prosecution to examine the reason for the delay. Delay in lodging FIR, it is a matter of common knowledge, would lead to embarrassment, exaggeration, embellishment and concoction. Therefore, if somebody says that the criminal proceedings were initiated by the police as an after thought, he cannot be blamed. 11. Secondly, the reasons stated in Annexures - A13/A15 are also thought provoking. Numerous reasons are stated which can be enumerated thus:- 12. Firstly, Sebastian Joseph Njallani had constant threat from his children and he had preferred complaint before police and the police had summoned his children and had admonished them. Here, the allegation is very vague and sweeping. It is not known as to whether the petitioner against Crl.M.C.No.5726 OF 2017 16 whom now the point of accusation goes was also summoned by the police. From this representation, it cannot be inferred that the petitioner was also summoned by the police. 13. Secondly, one of the daughters of Sebastian Joseph had eloped with a person of a different caste and the son born in that relationship was given a property in Kattappana Town by the father. On account of that the petitioner was in constant fight with the father and that he had sleepless nights. Such a contention also is lacking in particulars and vague. 14. Thirdly, the third son of Sebastian Joseph, that is the petitioner used to manhandle the father in the presence of all other siblings, he had also manhandled his elder brother Johny and his wife for which cases are pending before Kattappana police station and court. Here also it is not known whether the father or other children had preferred any complaint alleging that the petitioner had manhandled the father. Such an allegation also is far-fetched and lacking in particulars. Details of cases pending in police station and court are also not furnished. Crl.M.C.No.5726 OF 2017 17 15. Fourthly, the petitioner wanted to create documents for snatching the patent right of 'Njallani' cardamom which was the right of the father and that he had approached various lawyers for getting the patent right excluding others for which also there is evidence. Here also particulars are wanting. 16. Fifthly, the father used to tell in hotels and in other surroundings in the town that the petitioner would kill him. Next is that an altercation that had taken place in hotel Rajadhani where he was given the award in the previous night and that Rejimon wanted to snatch away the prize money and also had allegedly spoken to the father that he would not allow to take the dividend of the gift. Here also the allegations are two wild. 17. Seventhly, it was stated that after taking the award on 13.02.2011, the petitioner had dropped the father at the house where he was living alone; after dropping the father at the residence, no one had seen him alive. On the following day morning, neighbours, Narikuzhi Wilson and Cherukunnel Sathyan had seen Sebastian Joseph lying on the floor on his Crl.M.C.No.5726 OF 2017 18 chest with tongue bitten. There was no one else in the house. Here also, no other details are given. It is also stated in the said complaint that the petitioner had allegedly told his mother that he ‘had sent her husband to the other world’. It is stated that the mother had related this incident to Roy and others. As indicated earlier, mother had died on 15.06.2012. This mass petition signed by ten persons had come to the light only in 2015 and it is not known whether anyone had raised any complaint on this to the police or had sought any investigation in the matter, during the life time of the mother. The mother had died only after about one year and four months of the death of the father. If the petitioner had made such an offensive statement to the mother, necessarily the said statement should have been raised during her life time itself. Long after the death of the mother, it is beyond comprehension as to how far such a statement allegedly made by the petitioner could be used against him. 18. On the date of death of the father, it is stated, he had told the neighbours that entire matters have been settled by the police. Here also there is no materials forthcoming on this Crl.M.C.No.5726 OF 2017 19 statement. Similarly, it is stated that some posters had appeared in the neighbourhood, demanding investigation into the mysterious death of this Sebastian Joseph; here also there is no evidence and according to the petitioner, the statements of the members of family also do suggest that the death was natural death. 19. It is stated that on the basis of such a complaint some enquiry was conducted by the Inspector General of Police and since, some foul play was suspected and the crime was registered. All the signatories in Annexures - A13/A15 are respondents in this case. This court had issued notice to them through the Circle Inspector of Police, Kattappana. Notices were duly served on them, but none of them has come forward and raised any contention supporting the allegations or advocating an investigation into the cause of death after long lapse of time. 20. Sebastian Joseph has died on 14.02.2011 and the funeral was on 15.02.2011. If there was anything suspicious about the death, there was enough time for raising the same Crl.M.C.No.5726 OF 2017 20 before the authorities and seeking post mortem examination. None has raised any doubt till allegations through AnnexuresA13/A15. If the party respondents had any courage of conviction, on being alerted from this Court, they would have turned up and pursued the contentions. Their not responding to the notice is a matter of adverse inference. 21. Now turning to the exhumation of the body after eleven years, I have no doubt that it would be a futile exercise. Not that the death had taken place more than eleven years back, it has come out that the body of the mother was buried in the very same family vault on 15.06.2012. In other words, both the parents were buried about a decade back. In all probability, the body of the mother must have placed above the body of the father in the vault. If the exhumation of the body of the father would become necessary, that could be possible only after exhuming and removing the remnants of the body of the mother. No doubt by long lapse of time, more than a decade, body of both the persons must have decomposed and it would have perished and mixed up. It would not be logical or Crl.M.C.No.5726 OF 2017 21 reasonable to exhume the body and to conduct any investigation after long lapses of time. 22. It was submitted by the learned Public Prosecutor that the petitioner also has contributed for the long delay. An argument was also raised that his objection should be taken to draw adverse inference against him. But basing on AnnexureA21, the proceedings were kept in abeyance only by order dated 26.03.2019. That means, till an interim order was passed by this Court, about eight years had passed after the death of the father. In such a circumstance, it would be a futile exercise to exhume the body and rake up the issue again. 23. The long lapse alone is sufficient to say that it is a futile exercise to rake up the matter. In the circumstances, I am of the view that entire proceedings initiated in Annexure - A14 crime and investigation thereafter, are not going to produce any positive result. Manifestly, it is a futile exercise and therefore, it is not in the interest of all to conduct investigation in such a case. Resultantly, entire proceedings pursuant to the Crl.M.C.No.5726 OF 2017 22 registration of Annexure- A14 FIR of Kattappana police station are quashed. Crl. M. C. is allowed as above. **SD/K.HARIPAL JUDGE** **OKB/DCS/05.02.2022** Crl.M.C.No.5726 OF 2017 23 ## **APPENDIX** ## **PETITIONER'S ANNEXURE** |**ANNEXURE A1**|**TRUE COPY OF THE CERTIFICATE OF AWARD**| |---|---| ||**CONFERRED BY THE NATIONAL INNOVATION**| ||**FOUNDATION.**| |**ANNEXURE A2**|**TRUE COPY OF THE REPORT APPEARED IN**| ||**MALAYALA MANORAMA DAILY DATED 30.11.2001.**| |**ANNEXURE A3**|**TRUE COPY OF AN ARTICLE APPEARED IN SUNDAY**| ||**SHALOM MAGAZINE OF 9.12.2007.**| |**ANNEXURE A4**|**TRUE COPY OF THE NEWS ITEM APPEARED ABOUT**| ||**HIS INNOVATIVE CARDAMOM PLANTING METHOD**| ||**'KUZHIYILA" IN THE NEW INDIAN EXPRESS DAILY**| ||**DATED 12.8.2010.**| |**ANNEXURE A5**|**TRUE COPY OF THE CERTIFICATE FOR BEST**| ||**PRESENTATION AWARD IN THE SECOND INDIAN**| ||**BIODIVERSITY CONGRESS HELD IN DECEMBER 2012**| ||**AT BENGALURU.**| |**ANNEXURE A6**|**TRUE COPY OF THE CERTIFICATE DATED**| ||**14.2.2014 ISSUED BY BAPOOJI KRISHI VIGYAN**| ||**KENDRA, A FARM SCIENCE CENTRE, SPONSORED BY**| ||**ICAR, GOVT OF INDIA.**| |**ANNEXURE A7**|**TRUE COPIES OF THE ARTICLES THAT EARNED**| ||**WRATH OF THE CHURCH "RAKTHASHUDDHIVATHAM**| ||**VIVADATHILEKKU' PUBLISHED IN SATYAJWALA**| ||**DATED APRIL, 2015, NEWS ITEM "CATHOLICA**| ||**SABHAKKU IRATTATHAPPENDDU NAVEEKARANA**| ||**PRASTHANAM" APPERARED IN KERALA KOUMUDI**| ||**DATED 23.11.2016 AND THE NOTICE DATED**| ||**21.9.2015 ISSUED IN RESPECT OF PROTECT**| ||**RALLY AND DHARNA.**| |**ANNEXURE A8**|**TRUE COPY OF THE BANK RECEIPT ISSUED IN**| ||**EVIDENCE OF DEPOSITING BLAKS IN THE ACCOUNT**| ||**OF MRS & MR SEBASTIAN JOSEPH IN THE UNION**| ||**BANK, PUTTADY BRANCH.**| |**ANNEXURE A9**|**TRUE COPY OF THE NEWS ITEM APPEARED ON THE**| ||**DEATH OF PETITIONER'S FATHER SEBASTIAN**| ||**JOSEPH IN THE MALAYALA MANORAMA DAILY DATED**| ||**15.2.2011.**| Crl.M.C.No.5726 OF 2017 24 |**ANNEXURE A10**|**TRUE COPY OF THE PETITION DATED 12.8.2010**| |---|---| ||**FILED BEFORE THE JUDICIAL FIRST CLASS**| ||**MAGISTRATE COURT, KATTAPPANA.**| |**ANNEXURE A11**|**TRUE COPY OF THE COMPLAINT DATED 13.9.2012**| ||**ADDRESSED TO THE SUB INSPECTOR OF POLICE,**| ||**KATTAPANA.**| |**ANNEXURE A12**|**TRUE COPY OF THE ACKNOWLEDGMENT ISSUED IN**| ||**RECEIPT OF PETITION DATED 15.7.2013.**| |**ANNEXURE A13**|**TRUE COPY OF THE COMPLAINT DATED NIL WHICH**| ||**IS NOT EVEN ADDRESSED TO ANY OFFICER.**| |**ANNEXURE A14**|**TRUE COPY OF THE FIR DATED 8.10.2015, THE**| ||**FORWARDING NOTE OF THE INSPECTOR GENERAL OF**| ||**POLICE, KOCHI RANGE OBTAINED UNDER RTI ACT.**| |**ANNEXURE A15**|**TRUE COPY OF THE ALLEGED MASS COMPLAINT**| ||**LEADING TO REGISTRATION OF ANNEX A14 FIR.**| |**ANNEXURE A16(a)**|**TRUE COPY OF THE REPRESENTATION DTD**| ||**12/10/15 SUBMITTED BEFORE THE HON'BLE**| ||**MINISTER FOR HOME AFFAIRS.**| |**ANNEXURE A16(b)**|**TRUE COPY OF THE REPRESENTATION DTD**| ||**12/10/15 SUBMITTED BEFORE THE DIRECTOR**| ||**GENERAL OF POLICE.**| |**ANNEXURE A17**|**TRUE COPY OF THE RECEIPT OF THE**| ||**REPRESENTATION SUBMITTED RECEIVED FROM THE**| ||**OFFICE OF THE HON'BLE MINISTER OF HOME**| ||**AFFAIRS.**| |**ANNEXURE A18**|**TRUE COPY OF THE NOTICE RECEIVED BY HIM**| ||**FROM THE DEPUTY SUPERINTENDENT OF POLICE,**| ||**KOTTAYAM CRIME BRANCH DATED 28.11.2016.**| |**ANNEXURE A19**|**TRUE COPY OF THE NEWS ITEM APPEARED IN**| ||**MALAYALA MANORAMA DAILY ON 14.10.2015.**| |**ANNEXURE A20**|**TRUE COPY OF THE SAID NEWS ITEM APPEARED IN**| ||**MANGALAM DAILY DATED 17.07.2017.**| |**ANNEXURE A21**|**TRUE COPY OF THE NOTICE SERVED ON THE**| ||**PETITIONER ON 23.03.2019 EVENING AT ABOUT**| ||**5.00 P.M.**| Crl.M.C.No.5726 OF 2017 25 **ANNEXURE A22 TRUE COPY OF THE NEWS ITEM APPEARED IN TIMES OF INDIA DATED 17.03.2019 PUBLISHING SUCH A SERVICE RENDERED BY THE ORGANISATION OF THE PETITIONER ANNEXURE A23 TRUE COPY OF THE NEWS ITEM APPEARED IN INDIAN EXPRESS DATED 13.03.2019**