S. Surekha v Union of India & Others

## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE MR.JUSTICE MURALI PURUSHOTHAMAN FRIDAY, THE 30[TH] DAY OF JUNE 2023 / 9TH ASHADHA, 1945** ## **WP(C) NO. 18300 OF 2021** ## **PETITIONER:** S.SUREKHA., AGED 53 YEARS WIFE OF R. PRASEED, SUDARSHANA, CHOMBALA P.O. VATAKARA, KOZHIKODE 673 308. BY ADVS. K.RAMAKUMAR (SR.) T.RAMPRASAD UNNI S.M.PRASANTH G.RENJITH R.S.ASWINI SANKAR T.H.ARAVIND ## **RESPONDENTS:** - 1 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF ROAD TRANSPORT AND HIGHWAYS, PARIVAHAN BHAVAN I, PARLIAMENT STREET, NEW DELHI 110 001. - 2 THE NATIONAL HIGHWAYS AUTHORITY OF INDIA, PROJECT IMPLEMENTATION UNIT, HOUSE NO. 2/2175-B, KRISHNA KRIPA, AISWARYA ROD, KOZHIKODE 673 020, REPRESENTED BY ITS PROJECT DIRECTOR. - 3 STATE OF KERALA, REPRESENTED BY THE PRINCIPAL SECRETARY TO GOVERNMENT, PUBLIC WORKS (D) DEPARTMENT, GOVERNMENT OF KERALA, SECRETARIAT, THIRUVANANTHAPURAM 695 001. - 4 THE DISTRICT COLLECTOR, COLLECTORATE, CIVIL STATION, KOZHIKODE 673 020. - 5 THE SPECIAL DEPUTY COLLECTOR (LA), NATIONAL HIGHWAY 17, COLLECTORATE, KOZHIKODE 673 020. BY ADVS. S.GOPINATHAN (SR.GP) J.RAMKUMAR-R1 K.P.SATHEESAN (SR.)-R2 W.P.(c).No.18300 of 2021 2 P.MOHANDAS (ERNAKULAM) K.SUDHINKUMAR S.K.ADHITHYAN SABU PULLAN GOKUL D. SUDHAKARAN N.J.ASHWIN, CGC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 30.06.2023, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P.(c).No.18300 of 2021 3 ## **JUDGMENT** The petitioner states that she is the owner in possession of 19.7 Ares of lands comprised in Sy. No.98/42 of Azhiyur Village in Vatakara Taluk, Kozhikode District. The petitioner has produced Ext. P1 Basic Tax Receipt dated 28.05.2020 to show that her property is comprised in Sy. No.98/42. The petitioner received Ext.P2 notice dated 10.05.2021 under Section 3E(1) of the National Highways Act, 1956 (in short 'the N H Act') from the Special Deputy Collector Land Acquisition (NHAI), Kozhikode (Competent Authority) directing her to vacate from the land in Sy.No. 98/5A included in Section 3D(1) notification published under the N H Act and vested in the Central Government under Section 3D(2), within sixty days from the date of receipt of the said notice or else steps to enforce surrender will be taken through orders of the District Collector. The petitioner submitted Ext.P3 reply stating that her property is not included in Section 3D notification and to exempt her from acquisition. The petitioner has produced Exts. P5 and P6 notifications issued under Section 3D (1) to contend that the name of the petitioner is not shown anywhere and the survey number of the property differs from W.P.(c).No.18300 of 2021 4 that of her. 2. The petitioner was later served with Exts. P7 and P8 proceedings of the Competent Authority intimating her that since she has not produced documents to prove right over the property pursuant to publication of notice under Section 3G (3) for determination of amount payable as compensation, the land under the proposed acquisition will be treated as deferred case and the property will be taken possession of by the Competent Authority and will be handed over to the National Highway Authority of India (NHAI). 3. The petitioner states that she along with certain others had earlier approached this Court by filing W.P (C) No. 29956 of 2012 seeking an enquiry by the CBI with regard to change of alignment of the Highway and the same was dismissed by Ext. P9 judgment. Later, she along with some other persons filed W.P. (C) No. 29333 of 2012 alleging attempt to change the alignment arbitrarily. The said writ petition was disposed of by Ext. P10 judgment with a direction to the Competent Authority to consider and dispose of the representation to be filed in that regard. The order of the Competent Authority W.P.(c).No.18300 of 2021 5 dated 09.03.2016 issued in compliance with the above direction was challenged by the petitioner in W.P. (C) No. 23742 of 2016, which was also dismissed by this Court by Ext. P11 judgment dated 15.11.2017. 4. The petitioner contends that the attempt to acquire her property as indicated in Ext.P2 is in flagrant violation of the mandatory procedural requirements of the N H Act. It is contended that Exts. P5 and P6 notifications under Section 3D neither show the name of the petitioner nor the survey number of her property and, without including the name of the petitioner and the survey number of her property in the 3D notification, her property cannot be acquired and the action of the respondents is in violation of the fundamental rights guaranteed to her under Articles 14, 19 and 21 and Constitutional right under Article 300A of the Constitution of India. Accordingly, petitioner has filed this writ petition for direction to quash Exts. P2, P6 and P7 to the extent they attempt to acquire her property in Sy.No.98/42 of Azhiyur Village. 5. A counter affidavit has been filed by the National Highways Authority of India through its Project Director and the relevant portion thereof is extracted hereunder: W.P.(c).No.18300 of 2021 6 “5. The Notification under section 3A of National Highway Act 1956 for an extent of 0.0850 hectare of land R.S. No. 98/5A in Chombala Desom in Azhiyur Village was published as per Notification No. SO 2759 (E) dated 08.12.2011 Substance of Notification under section 3A in respect of SO No. 2759 (E) was published in Malayala Manorama and Mathrubhumi dailies on 31.12.2011 and 02.01.2012 respectively. After the above 3 A Notification it is found that the above 0.0850 hectare of land was not sufficient for the alignment. Accordingly an additional extent of 0.0336 hectare of land in R.S. No. 98/5A in Chombala desom in Azhiyur Village also has been published as SO 1113(E) dated 2.5.2013. Substance of the above notification was published in Malayala Manorama and Mathrubhumi dailies on 25.06 2013. 6. Consequent on the publication of Above 3A Notifications, detailed survey work has been conducted. Superintendent of Survey and land records approved Sub division Record. On preparing sub division record prepared in accordance with the alignment, it is found that Actual Extent required from the survey number 98/5A is 0.1156 Hectare (newly sub divided as 98/10). Meanwhile the notification u/s 3(C) of NH Act also has been published as laid down in National act 1956. All the objections received have been examined and disposed of as provided under National Highways Act 1956. 7. In continuance to the 0.0850 hectare of land notified as per SO 2759 (E) u/s 3A, corresponding Notification U/S 3D of National Highways Act for an extent of 0.0850 hectare of land in Chombala Village in Azhiyur Desom was published in Central Government gazette S O No. 2855 (E) dated 7.12.2012. Similarly in continuance to the 0.0336 hectare of land notified as per SO 1113(E) was 3A, corresponding Notification U/S 3D of National Highways Act for an extent of 0.0306 hectare of land in R.S. No. 98/5A Chombala Desom in Azhiyur Village was published in Central Govt. gazette S O NO. 3684 (E) in dated 17.12.2013 8. By virtue of the publication of the above Notification s u/s 3D of National Highway Act, the land included in the above notifications have been vested with the Central Govt. free from all encumbrances for the purpose of widening of National Highway 66 as shown below: W.P.(c).No.18300 of 2021 7 |Desom|R.S.N<br>o.|New LA<br>Subdivision|Exten<br>t|Notification by<br>which land vested<br>with the Central<br>Govt.| |---|---|---|---|---| |Chombala|98/5A|98/10|0.085<br>0|S O 2855 (E) dt.<br>07.12.2012| |Chombala|98/5A|98/10|0.030<br>6|S O 3684 (E) dt.<br>17.12.2013| 9. In continuance to these notifications, required notifications under section 3G(3) of National Highway Act were also published in Malayala Manorama and Mathrubhoomi on 6.4.2013 and 27.4.2014 for substantiating all the claim on the land under acquisition. The petitioner along with others did not produce any documents to prove her right over the properties. Instead the petitioner filed W.P.(C) No. 29956/2012 before this Hon'ble Court seeking CBI investigation alleging that acquisition originally stipulated is changed with a different alignment and has caused to be changed at the instance of somebody behind the curtain, causing much loss and hardships to the petitioners. The petitioners apprehends some foul play with regard to the change in alignment and request for the CBI enquiry. The petitioner herein is the 3[rd] petitioner in the said Writ petition and the same is dismissed by this Hon'ble Court as per Ext.P9 judgment. 10. On the basis of available informations, claims and inspection of land, 0.850 hectare of land vested with the Govt. as per 3D Notification No.2855 (E) dated 07.12.2012 has been apportioned as shown below. |Village<br>Desom|R.S.No.<br>Existing|LA<br>Subdivision<br>No.|Extent|Name of<br>land owner| |---|---|---|---|---| |Chombala|98/5A|98/10|0.0029|Road| ||98/5A|98/10|0.0336|Surekha| ## W.P.(c).No.18300 of 2021 8 |||||and Others| |---|---|---|---|---| ||98/5A|98/10|0.0045|Road| ||98/5A|98/10|0.0066|Subair| ||98/5A|98/10|0.0198|Jayan| ||98/5A|98/10|0.0136|Kelappan| ||98/5A|98/10|0.0040|Road| ||**Total**||0.0850 Ha|| similarly 0.0306 hectare of land vested with Govt. free from all encumbrances as per Notification No. SO 3684 (E) dated 17.12.2013 has been apportioned as shown below as per the available records and inspection of land. |Chombal<br>a|98/5A|98/10|0.0145|Surekha and others| |---|---|---|---|---| |Chombal<br>a|98/5A|98/10|0.0109|Jayachandran| |Chombal<br>a|98/5A|98/10|0.0052|Vasantha| ||**Total**||0.0306 Ha|| 11. Hence it can be seen that a total extent of 0.0481 hectare of land in R.S. No. 98/5A (New 98/10) is vested with the Govt. from the possession of Surekha & others (Legal heirs of late Dr Sahadevan) as per the 3D Notification No. SO 2855 (E) dated 07.12.2012 and SO 3684 (E) dated 17.12.2013. On the basis of the above apportionment Detailed Valuation Statement has been prepared and compensation amount has been determined as provided in 3G(1) of National Highway Act. Now the National Highway Authority has provided required fund at W.P.(c).No.18300 of 2021 9 ## the disposal CALA. 12. Even though the notification under section 3G(3) of National Notification was published as laid down in National Highways Act 1956, Petitioner refused to produce documents. Hence after the receipt of required fund from National Highway Authority of India, In addition to the statutory notification, a further notice also has been issued. Required statutory notice under section 3E of National Highway Act for the dispossession of land also has been issued and sent to the land owner by the registered post. Petitioner has acknowledged the same. Further the above notices have been pasted in front of her house in the presence of two witnesses. 13. The statutory Notification under section 3G (3) of National Highway Act 1956 were published in the Malayala Manorama and Mathrubhoomi dailies on 06.04.2013. In these notifications it is specified that the interested parties to produce the documents to prove their right over the property. The Petitioner did not produce any documents. Therefore, another notice was also issued to the petitioner. Even thereafter the petitioner did not produce any documents. Hence competitive authority is not in a position to disburse the compensation of 0.0481 hactor of land in RS No 98/5A (new 98/10) in possession of petitioners and the land has already been vested with National Highways Authority of India by virtue of Section 3D notification 14. As per Section 3E of National Highways Act 1956 the Competent Authority is bound to hand over the property which has already been vested with Central Govt. free from all encumbrances to the National Highway Authority of India and National Highways Authority have deposited required fund in the account of CALA as provided in 3H of National Highways Act 1956. 15. As the land owner is not ready and willing to produce the documents the compensation amount could not be disbursed to the petitioner and the CALA could not hand over the documents to National Highways Authority of India. Under these circumstances it has been decided as per the Office proceedings No. A12569/2021 (1) dated 19.07.2021 and A112569/2021 (3) dated 19.07.2021 to take over all the remaining land by deferred payment of compensations Including 0.0481 hectors (0.0336 + 0.0145) in possession of petitioner In R.S. No. 98/5A (New 98/10) which has been notified as per section 3D and vested with the Government. 16. Since the petitioner refused to accept the order of this office W.P.(c).No.18300 of 2021 10 proceeding No. A1 2565/2021 (I) dated 19.07.2021 and A1 2565/2021 (3) dated 19.07.2021, they have been pasted in front of petitioner's house on 07.08.2021 Further, the above orders have been sent to the petitioner by registered post. Petitioner has acknowledged the receipt of the order of deferred payment of compensation in this Writ Petition. 17. As ordered above Special Revenue Inspector has taken possession an extent of 0.7057 hectare of land with improvements on 24.08.2021 including 0.0481 hectare of petitioners land in R.S No. 98/5A (New 98/10) in Chombala desom_ in Azhiyur village stage. It ts pertinent to note that the petitioner along with others have filed W.P.(C)No. 29333/2012 before this Hon’ble Court which was dismissed by Ext. P10 Judgment. In the said Writ Petition the petitioner herein is the 10[th] petitioner. The property owned by her is mentioned in the Judgment as 10% item ie. the properties in re-survey No. 98/5A. Thus the petitioner was, fully aware of the proceedings as early as in 2012 itself. 18. The compensation amount for (0.0481 Ha of) land vested with the Government and has already been deposited in the account of CALA by National Highway Authority of India as provided in 3H of National Highway Act 1956. The same will be disbursed to the land owner as and when the land owner produces the documents to prove the right over the 0.0481 hectares (0.0336+.0145) of land. Now the petitioner again approached this Hon'ble Court by filing this Writ Petition making the very same allegations. As the land has already been vested with National Highways Authority by the publication of 3D Notifications dated 07.12.2012 and 17.12.2013 and taken possession and handed over to the National Highway Authority of India on 24.08.2021 for the construction work of National Highway development project, this Writ Petition is liable to be dismissed.” 6. A reply affidavit is filed by the petitioner to the counter affidavit filed by NHAI and reiterating the contention in the writ petition that the survey number of her property does not appear in the notifications issued under the N H Act. W.P.(c).No.18300 of 2021 11 7. A counter affidavit is filed by the 5[th] respondent, the Competent Authority under the N H Act, almost in similar lines with the counter affidavit filed by the NHAI and specifically answering the averment of the writ petitioner with regard to the difference in the survey number in the N H Act notifications and the Basic Tax Register. Paragraph 19 thereof reads as follows: “19. It is submitted that notifications which were published in the year 2011, 2012 and 2013 for the land in R.S No. 98/5A (New 98/10) in Chombala desom of Azhiyur Village. In Azhiyur Village resurvey of land has not been done so far. As a result in each subdivision number there are so many holdings having same sub division numbers. Hence in 2017 Govt. introduced Revenue Land Information System (RELIS) by computerization of land records, to collect land tax system by online, **in which land owners have been given separate Thandaper numbers and RELIS sub division numbers on the basis of Computerization of land records. As result the petitioner who is holding land in 98/5A in Chombala desom in Azhiyur village also has been given a RELIS sub division number as 98/42 for her land in 98//5A. Hence it is clear that 98/42 came from 98/5A and 98/42 is the 'RELIS subdivision' Number allotted to petitioner's land in RS No. 98/5A as** W.P.(c).No.18300 of 2021 12 ## **there are so many holdings in 98/5A and it is not the survey** **based sub division number.** It is submitted that ther **e** is no provision for the publication of name of land owners in the 3A notification as pointed out by the petitioner. Section 3A provides for the publication of "description of the land ". In 3A and 3D notification, description of land ie Village Desom Survey number New LA subdivision number and extent has been correctly published. Land owners may change due to the transfer of land. National Highway Act provides for the publication of 3G (3) notification for submitting claim only after the publication of 3D of Notification. Accordingly statutory Notice for producing claims have been published after the 3D notification. 3G (3) notification date in this case is 06.04.2013 and 27.04.2014. The notification is in 2011, 2012, and 2013. RELIS Subdivision number on the basics of computerization of the land records was given only in 2017. Petitioner is well aware of the facts that her land in front of her house is coming within the alignment. That is why petitioner had filed three writ petitions before the Honorable High Court.” W.P(C).No.29956 of 2012 is filed by the petitioner and others seeking an enquiry by the CBI with regard to change of alignment of the Highway. The pleadings in the said writ petition, as evident from W.P.(c).No.18300 of 2021 13 Ext. P9 judgment, would show that the petitioner has stated that a notification has been issued in the dailies dated 31. 12. 2011, specifying the survey numbers of the properties to be acquired, which includes the petitioners' properties as well. The pleadings in W.P.(C). No.29333/2012, as discernible from Ext. P10 judgment, would show that the petitioner has stated therein that her properties in Sy. No. 98/5A were included in Section 3A notification, but her name is not shown as the owner of the property. The petitioner was thus aware, as early as in 2011, that her properties were included in the Section 3A notification. Her attempt to challenge the acquisition on the ground of change of alignment whereby her property came to be included, was dismissed by this Court finding that the acquisition is as per the original alignment itself. Long thereafter, when Ext. P2 notice was issued under Section 3E to take possession of the property, the petitioner has approached this Court with new plea that Section 3D notification does not show her name or the survey number of her property and therefore her property cannot be acquired. It is to be noted that the petitioner has not taken this plea in the earlier rounds of litigation and she cannot be permitted to take this plea in this writ petition, at this belated stage. W.P.(c).No.18300 of 2021 14 8. The challenge against the acquisition is made pointing out the difference in the survey number of the property of the petitioner shown in the notifications issued under the N H Act and in Ext. P1 Basic Tax Receipt dated 28.05.2020. The 5[th] respondent, in their counter affidavit, has explained this aspect stating that the Government have in the year 2017 introduced Revenue Land Information System (RELIS) by computerization of land records to collect land tax by online, in which land owners have been given separate Thandaper numbers and RELIS sub division numbers and the petitioner, who is holding land in Sy.No.98/5A in Chombala desom in Azhiyur village has also been given a RELIS sub division number as 98/42 for her land in 98/5A. It is based on the RELIS sub division number shown in Ext. P1 Basic Tax Receipt dated 28.05.2020, the petitioner contends that the survey number of her property shown in Ext. P1 Basic Tax Receipt and that in Exts. P5 and P6 notifications under Section 3D differs. The notifications issued under the N H Act takes in the property of the petitioner in R.S. No. 98/5A of which the corresponding RELIS sub division number is 98/42. The contention of the petitioner that her property is not included in the 3D notification cannot be sustained. W.P.(c).No.18300 of 2021 15 9. The counter affidavit filed by the NHAI and the Competent Authority would show that the acquisition of the property of the petitioner is in accordance with the provisions of the N H Act and in compliance with the due process of law. The petitioner has not made out any case inviting interference of this Court with the acquisition proceedings. The acquisition is done for the purpose of widening of . In National Highway 66 (old 17) **Project Director, Project** _**v**_ **Implementation Unit . P. V. Krishnamoorthy, [2021 (3) SCC 572],** the Hon'ble Supreme Court made the following observations regarding the requirement of National Highway in the neighbourhood, the State and the Country as a whole: “38. ….The requirement of a national highway within the country as a whole and State - wise, in particular, is to alleviate evolving socio - economic dynamics, for which such a wide power has been bestowed upon the Central Government. The Central Government is obliged to do so to facilitate it to discharge its obligations under Part IV of the Constitution. There is nothing in the Constitution of India or for that matter, the 1956 Act to limit that power of the Central Government only in respect of existing roads / highways within the State. To say so would be counter - productive and would entail in a piquant W.P.(c).No.18300 of 2021 16 situation that the Central Government cannot effectively discharge its obligations under Part IV of the Constitution unto the remote inaccessible parts of the country until the concerned State Government constructs a road / highway within the State. On the other hand, if the concerned State, due to reasons beyond its control or otherwise, is unable / flounder to provision a road / highway in a given segment of the State; despite being imperative to do so to assuage the perennial difficulties faced by the locals in that belt due to lack of access, the Central Government may come forward and step in to construct a national highway and connect the area with the other parts of the country. By its very nomenclature, a national highway is to link the entire country and provide access to all in every remote corner of the country for interaction and to promote commerce and trade, employment and education including health related services. This approach would enhance and further the federal structure. This is because, the existence of a national highway in the neighbourhood paves way for the fulfilment of aspirations of the locals and their empowerment. It not only brings with it opportunity to travel across, but also propels the economy of that region and the country as a whole. It gives impetus to myriads of social, commerce and more importantly, access to other activities / facilities essential for W.P.(c).No.18300 of 2021 17 the health, education and general well - being of the locals, in particular.” Any interference with the acquisition proceedings for the reasons stated in the writ petition would stall the project and would be against public interest. The writ petition is without merit and is, accordingly, dismissed. However, the dismissal of this writ petition will not stand in the way of the petitioner in approaching the authorities for disbursement of the compensation amount deposited, in accordance with law. Sd/- rps **MURALI PURUSHOTHAMAN,** **JUDGE** W.P.(c).No.18300 of 2021 18 ## **APPENDIX OF WP(C) 18300/2021** PETITIONER EXHIBITS - Exhibit P1 - TRUE COPY OF RECEIPT NO. KL11030102331/2020 DATED 28.05.2020 ISSUED BY THE VILLAGE OFFICER AZHIYUR. - Exhibit P2 - TRUE COPY OF NOTICE NO. L/A/C NO. 121/(1)/(II) CHOMBAL DATED 10.05.2201 ISSUED BY THE 5TH RESPONDENT. - Exhibit P3 TRUE COPY OF REPLY DATED 18.07.2021 SUBMITTED BY THE PETITIONER BEFORE THE SPECIAL DEPUTY COLLECTOR (LA, NHAI), KOZHIKODE. - Exhibit P4 TRUE COPY OF REPLY NO C. 1118/21 DATED 04.08.2021 ISSUED FROM THE OFFICE OF THE 5TH RESPONDENT UNDER THE RTI ACT TO THE PETITIONER. - Exhibit P5 TRUE COPY OF S.O. 2855 (E) DATED 07.12.2021 THE NOTIFICATION ISSUED UNDER SECTION 3D OF THE NATIONAL HIGHWAYS ACT BY THE MINISTRY OF ROAD TRANSPORT AND HIGHWAYS, GOVERNMENT OF INDIA, NEW DELHI. - Exhibit P6 TRUE COPY OF S.O. 3684 (E) DATED 17.12.2013 THE NOTIFICATION ISSUED BY THE MINISTRY OF ROAD TRANSPORT AND HIGHWAYS, GOVERNMENT OF INDIA, NEW DELHI. - Exhibit P7 TRUE COPY OF PROCEEDINGS NO. AI.2565/21 (1) OF THE COMPETENT AND SPECIAL DEPUTY COLLECTOR, LAND AQUISITION (NHAI) KOZHIKODE DATED 19.07.2021. - Exhibit P8 TRUE COPY OF PROCEEDINGS NO. A1 2565/21(3) OF THE COMPETENT AND SPECIAL DEPUTY COLLECTOR LAND ACQUISITION (NHAI) KOZHIKODE DATED 19.07.2021. - Exhibit P9 TRUE COPY OF JUDGMENT DATED 31.12.2012 IN WPC NO. 29956 OF 2012. - Exhibit P10 TRUE COPY OF JUDGMENT DATED 17.11.2015 IN 2PC NO. 29333 OF 2012. W.P.(c).No.18300 of 2021 19 - Exhibit P11 - TRUE COPY OF JUDGMENT DATED 15.11.2017 IN WP NO. 23742 OF 2016. - Exhibit P12 TRUE COPY OF RELEVANT PORTION OF SECTION 3G NOTIFICATION PUBLISHED IN THE MATHRUBHOOMI DAILY DATED 06/04/2013. - Exhibit P13 TRUE COPY OF RELEVANT PORTION OF SECTION 3G NOTIFICATION PUBLISHED IN THE MATHRUBHOOMI DAILY DATED 27/04/2014. - Exhibit P14 TRUE COPY OF LETTER BEARING NOS.A1/2232/22(1) DATED 20/07/2022 BY THE COMPETENT AUTHORITY AND SPECIAL DEPUTY COLLECTOR, LAND ACQUISITION (NHAI), KOZHIKODE. - Exhibit P15 TRUE COPY OF LETTER BEARING NOS.A1/2232/22(2) DATED 20/07/2022 BY THE COMPETENT AUTHORITY AND SPECIAL DEPUTY COLLECTOR, LAND ACQUISITION (NHAI), KOZHIKODE. - Exhibit P16 TRUE COPY OF NOTICE NO.RDOVDK/806/2023-J1 DATED 05..05..2023 SENT BY THE REVENUE DIVISIONAL OFFICER, VATAKARA TO THE PETITIONER - Exhibit P17 TRUE COPY OF ORDER NO. A1-4463/21(LANH) DATED 25..04..2023 - Exhibit P18 TRUE COPY OF WRITTEN SUBMISSION DATED 11..05..2023 SUBMITTED BY THE PETITIONER BEFORE THE REVENUE DIVISIONAL OFFICER, VATAKARA - Exhibit P19 TRUE COPY OF INFORMATION BEARING NO. 11117/NHAI/PIU-KOZHIKODE/RTI/2023/751 DATED18..04..2023 ISSUED BY THE DGM(T) & PROJECT DIRECTOR, NATIONAL HIGHWAYS AUTHORITY OF INDIA, KOZHIKODE - Exhibit P20 TRUE COPY OF QUERY DATED 24..12..2021 BY SHRI RENESSH KUMAR T.P. - Exhibit P21 TRUE COPY OF TAX PAID RECEIPT NO. KL11030105841/2021 DATED 09..08..2021 ISSUED BY THE VILLAGE OFFICER, AZHIYUR - Exhibit P22 TRUE COPY OF OBJECTIONS DATED 15..06..2023 W.P.(c).No.18300 of 2021 20 SUBMITTED BY THE PETITIONER BEFORE THE RDO, VADAKARA Exhibit P23 TRUE COPY OF ORDER NO. RDOVDK/806/2023-J1 DATED 15..06..2023 ISSUED BY THE RDO, VADAKARA