Saji K.S. v. State of Kerala and others (W.P.(C) No. 41759 of 2023)

## **`IN THE HIGH COURT OF KERALA AT ERNAKULAM`** ``` PRESENT ``` ``` THE HONOURABLE MR. JUSTICE ANIL K. NARENDRAN ``` ``` & ``` ``` THE HONOURABLE MR. JUSTICE G. GIRISH ``` ``` WEDNESDAY, THE 28[TH] DAY OF FEBRUARY 2024/9TH PHALGUNA, 1945 ``` ## **`WP(C) NO.41759 OF 2023`** ## **`PETITIONER:`** ``` SAJI K.S, AGED 39 YEARS, S/O SAJAN, KARIKKATTIL, POOVANCHI, KOKKAYAR IDUKKI DISTRICT, PIN – 686 513 ``` ``` BY ADVS. P.DEEPAK RILGIN V.GEORGE ``` ## **`RESPONDENTS:`** ``` 1STATE OF KERALA REPRESENTED BY THE PRINCIPAL SECRETARY TO GOVERNMENT, REVENUE (DEVASWOM) DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN – 695 001 ``` ``` 2THE TRAVANCORE DEVASWOM BOARD, REPRESENTED BY ITS SECRETARY, DEVASWOM HEAD QUARTERS, NANTHANCODE, KAWDIAR POST, THIRUVANANTHAPURAM, PIN – 695 003 ``` ``` 3THE EXECUTIVE OFFICER, SABARIMALA DEVASWOM, PAMBA, PATHANAMTHITTA, PIN – 689 713 ``` ``` 4THE ADMINISTRATIVE OFFICER, SABARIMALA DEVASWOM, NILAKKAL, PATHANAMTHITTA, PIN – 689 662 ``` - **`**5 [CHIEF VIGILANCE OFFICER,`** ``` TRAVANCORE DEVASWOM BOARD, NANTHANCODE, KAWDIAR POST, THIRUVANANTHAPURAM 695 003] **[AS PER ORDER DATED 15.12.2023 IN I.A-2/2023 IN WP(C) NO 41759/2023,R5 IS DELETED FROM THE PARTY ``` 2 W.P.(C)No.41759 of 2023 ## **`ARRAY ], PIN - 695003`** - **`6 THE DISTRICT COLLECTOR COLLECTORATE, PATHANAMTHITTA, KERALA, PIN 689 645`** ## **`7 THE DEPUTY SUPERINTENDENT OF POLICE VIGILANCE AND ANTICORRUPTION BUREAU, PATHANAMTHITTA UNIT, PATHANAMTHITTA DISTRICT, PIN – 689 645`** - **`***8 [CHIEF VIGILANCE AND SECURITY OFFICER], TRAVANCORE DEWASWOM BOARD, THIRUVANANTHAPURAM -695 003] *** [‘VIGILANCE OFFICER’ CORRECTED AS CHIEF VIGILANCE AND SECURITY OFFICER AS PER ORDER DATED 15.12.2023 IN I.A-3/2023 IN WP(C) 41759/2023]`** - **`9 SURESH M.S, S/O SIVARAMAN AYYAPPAN, MECHERIL HOUSE, ARAKKULAM P.O IDUKKI DISTRICT ERNAKULAM, PIN – 685 591`** ## **`*ADDL.R10 DEPUTY DIRECTOR,`** ``` KERALA STATE AUDIT DEPARTMENT, TRAVANCORE DEVASWOM BOARD AUDIT, NANTHANCODE, KAWDIAR POST, THIRUVANANTHAPURAM 695 003 [ADDL.R10 IS IMPLEADED AS PER ORDER 15.12.2023 IN I.A.No.1/2023 IN WP(C) NO.41759/2023] ``` ``` BY ADVS. ``` ``` V KRISHNA MENON ``` ``` J.SURYA(K/1007/2005) SRI. S. RAJMOHAN SR. GP SRI. G. BIJU SC, TDB PRINSUN PHILIP(K/818/2009) ``` ``` THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 28.02.2024, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ``` 3 W.P.(C)No.41759 of 2023 ## **JUDGMENT** ## **Anil K. Narendran, J.** The petitioner, who is a devotee of Lord Ayyappa of Sabarimala Sree Dharmasastha Temple, which is a temple under the management of the Travancore Devaswom Board, has filed this writ petition under Article 226 of the Constitution of India, seeking a writ of mandamus commanding the 2[nd] respondent Travancore Devaswom Board to recover the arrears of bid amount from the defaulted Kuthaka holders, in accordance with law. The petitioner has also sought for a writ of mandamus commanding the 2[nd] respondent Board to furnish the details of the action taken to recover the arrears from the defaulters; a writ of mandamus commanding the 7[th] respondent Deputy Superintendent of Police, Vigilance and Anti-Corruption Bureau, Pathanamthitta and the additional 8[th] respondent Chief Vigilance and Security Officer, Travancore Devaswom Board, to conduct enquiry relating to the grant of Kuthaka rights in Sabarimala Devaswom for the year 2023-24 and find out whether any defaulters obtained contracts for that year. 2. On 15.12.2023, when this writ petition came up for consideration, the learned Senior Government Pleader took notice on admission for respondents 1, 6, 7 and the additional 4 W.P.(C)No.41759 of 2023 10[th] respondent and the learned Standing Counsel for Travancore Devaswom Board for respondents 2, 4 and 8. Urgent notice on admission by special messenger was ordered to the 9[th] respondent, returnable by 19.12.2023. The learned Senior Government Pleader and also the learned Standing Counsel for Travancore Devaswom Board were directed to get instructions. 3. The 9[th] respondent has filed a counter affidavit dated 19.02.2024, producing therewith Exts.R9(a) to R9(h) documents, raising various contentions. In the counter affidavit it is alleged that the petitioner has approached this Court with ulterior motives, at the instance of one Dr.Surendran Tharayil, the person who filed Ext.P1 application before the State Public Information Officer, Travancore Devaswom Board, invoking the provisions under the Right to Information Act, 2005. 4. Heard the learned counsel for the petitioner, the learned Senior Government Pleader for respondents 1, 6, 7 and the additional 10[th] respondent, the learned Standing Counsel for Travancore Devaswom Board for respondents 2, 4 and 8 and also the learned counsel for the 9[th] respondent. 5. During the course of arguments, the learned counsel for the petitioner would point out that the judgment of this Court dated 09.10.2023 in W.P.(C)No.32729 of 2023, which was one 5 W.P.(C)No.41759 of 2023 filed by Swamy Ayyappa Enterprises, in which the 9[th] respondent herein and his father are partners. 6. Though the petitioner and the 9[th] respondent have raised various allegations against each other, we do not propose to consider those allegations in this writ petition, since in an original suit filed by the Travancore Devaswom Board, against the 9[th] respondent, an application for restoration is pending before the Munsiff Court, Ranni. 7. Travancore-Cochin Hindu Religious Institutions Act, 1950 enacted by the State Legislature makes provision for the administration, supervision and control of incorporated and unincorporated Devaswoms and of other Hindu Religious Endowments and Funds. As per sub-section (3) of Section 1 of the Act, substituted by the Kerala Adaptation of Laws Order, 1956, Part I of the Act shall extend to Travancore, Part II of the Act shall extend to Cochin and Part III of the Act shall extend to the whole of the State of Kerala, excluding the Malabar District. 8. Chapter II of the Act deals with the Travancore Devaswom. As per Section 3, the administration of incorporated and unincorporated Devaswoms and of Hindu Religious Endowments and all their properties and funds as well as the fund constituted under the Devaswom Proclamation, 1097 M.E. 6 W.P.(C)No.41759 of 2023 and the surplus fund constituted under the Devaswom (Amendment) Proclamation, 1122 M.E. which were under the management of the Ruler of Travancore prior to the first day of July, 1949, except the Sree Padmanabhaswamy Temple, Sree Pandaravaka properties and all other properties and funds of the said temple, and the management of all institutions which were under the Devaswom Department shall vest in the Travancore Devaswom Board. As per sub-section (2) of Section 4, the Board shall be a body corporate having perpetual succession and a common seal with power to hold and acquire properties for and on behalf of the incorporated and unincorporated Devaswoms and Hindu Religious Institutions and Endowments under the management of the Board. 9. As per sub-section (1) of Section 15, subject to the provisions of Chapter III of Part I, all rights, authority and jurisdiction belonging to or exercised by the Ruler of Travancore prior to the first day of July, 1949, in respect of Devaswoms and Hindu Religious Endowments shall vest in and be exercised by the Board in accordance with the provisions of this Act. As per sub-section (2) of Section 15, the Board shall exercise all powers of direction, control and supervision over the incorporated and unincorporated Devaswoms and Hindu Religious Endowments 7 W.P.(C)No.41759 of 2023 under their jurisdiction. As per Section 15A, it shall be the duty of the Board to perform the following functions, namely, (i) to see that the regular traditional rites and ceremonies according to the practice prevalent in the religious institutions are performed promptly; (ii) to monitor whether the administrative officials and employees and also the employees connected with religious rites are functioning properly; (iii) to ensure proper maintenance and upliftment of the Hindu religious institutions; (iv) to establish and maintain proper facilities in the temples for the devotees. Section 16 of the Act deals with supervision and control by the Board. As per Section 16, the Board shall, subject to the provisions of Part I of the Act, exercise supervision and control over the acts and proceedings of all officers and servants of the Board and of the Devaswom Department. 10. In **A.A. Gopalakrishnan v. Cochin Devaswom Board** **[(2007) 7 SCC 482]** a Three-Judge Bench of the Apex Court held that the properties of deities, temples and Devaswom Boards are required to be protected and safeguarded by their trustees/ archakas/shebaits/employees. Instances are many where persons entrusted with the duty of managing and safeguarding the properties of temples, deities and Devaswom Boards have usurped and misappropriated such properties by setting up false 8 W.P.(C)No.41759 of 2023 claims of ownership or tenancy, or adverse possession. This is possible only with the passive or active collusion of the authorities concerned. Such acts of ‘fence eating the crops’ should be dealt with sternly. The Government, members or trustees of boards/trusts, and devotees should be vigilant to prevent any such usurpation or encroachment. It is also the duty of courts to protect and safeguard the properties of religious and charitable institutions from wrongful claims or misappropriation. 11. In **Travancore Devaswom Board v. Mohanan Nair [(2013) 3 KLT 132]** a Division Bench of this Court noticed that in **A.A. Gopalakrishnan [(2007) 7 SCC 482]** the Apex Court emphasised that it is the duty of the courts to protect and safeguard the interest and properties of the religious and charitable institutions. The relevant principles under the Hindu law will show that the Deity is always treated similar to that of a minor and there are some points of similarity between a minor and a Hindu idol. The High Court therefore is the guardian of the Deity and apart from the jurisdiction under Section 103 of the Land Reforms Act, 1957 viz. the powers of revision, the High Court is having inherent jurisdiction and the doctrine of parents patriae will also apply in exercising the jurisdiction. Therefore, when a complaint has been raised by the Temple Advisory 9 W.P.(C)No.41759 of 2023 Committee, which was formed by the devotees of the Temple, about the loss of properties of the Temple itself, the truth of the same can be gone into by the High Court in these proceedings. 12. In **T. Krishnakumar v. Cochin Devaswom Board** **[2022 SCC OnLine Ker 3700 : 2022 (5) KHC SN 8]** , a Division Bench of this Court, in which both of us were parties, held that in view of the law laid down by this Court in **Abu** **K.S. v. Travancore Devaswom Board [2022 SCC OnLine Ker 1642]** , relying on the decision of the Apex Court in **M.V. Ramasubbiar v. Manicka Narasimachara [(1979) 2 SCC** **65]** , while leasing out the buildings owned by the Devaswoms, the Cochin Devaswom Board and its officials have to ensure that proper income is generated from the said buildings. In such transactions, the Board and its officials have to show reasonable diligence in the manner of an ordinary prudent man of business to conduct his own affairs. The action of the Board as a trustee cannot be equated to that of mere landlord. The best interest of the Devaswoms under the control of the Board would be subserved only if income is generated. 13. In **Sunil Kumar P.G. v. State of Kerala [2022:KER: 71822]** a Division Bench of this Court, in which one among us [Anil K. Narendran, J] was a party, was dealing 10 W.P.(C)No.41759 of 2023 with the auction conducted for the Kuthaka item No.119 (maintenance of Pamba toilet block) in Sabarimala Devaswom for the year 1197 ME (2021-2022). By the judgment dated 13.10.2022, W.P.(C)Nos.29772 of 2021 and 29859 of 2021 were disposed of by directing the Chief Vigilance Officer, Travancore Devaswom Board to conduct a detailed enquiry, with notice to - the writ petitioners and also the party respondents, on the e tender process for Kuthaka items in Sabarimala Devaswom, for the year 1197 ME, with specific reference to item No.119 (maintenance of Pamba toilet block), after the MandalaMakaravilakku Season of 1198 ME is over. The report of the Chief Vigilance Officer was directed to be placed before the Travancore Devaswom Board, by the first week of March, 2023. The decision taken by the Board, based on the enquiry report of the Chief Vigilance Officer, was directed to be placed before this Court, along with the report of the Special Commissioner, Sabarimala. ## 14. In **Sunil Kumar P.G. v. State of Kerala** **[2022:KER: 71822]** a Division Bench of this Court, in which one among us [Anil K. Narendran, J] was a party, was dealing with the auction conducted for the Kuthaka item No.119 (maintenance of Pamba toilet block) in Sabarimala Devaswom 11 W.P.(C)No.41759 of 2023 for the year 1197 ME (2021-2022). By the judgment dated 13.10.2022, W.P.(C)Nos.29772 of 2021 and 29859 of 2021 were disposed of by directing the Chief Vigilance Officer, Travancore Devaswom Board to conduct a detailed enquiry, with notice to - the writ petitioners and also the party respondents, on the e tender process for Kuthaka items in Sabarimala Devaswom, for the year 1197 ME, with specific reference to item No.119 (maintenance of Pamba toilet block), after the MandalaMakaravilakku Season of 1198 ME is over. The report of the Chief Vigilance Officer was directed to be placed before the Travancore Devaswom Board, by the first week of March, 2023. The decision taken by the Board, based on the enquiry report of the Chief Vigilance Officer, was directed to be placed before this Court, along with the report of the Special Commissioner, Sabarimala. ## 15. In **Sunil Kumar P.G. [2022:KER:71822]** this Court ordered that the entire e-tender for Kuthaka items in Sabarimala Devaswom, from Mandala-Makaravilakku festival season of 1199 ME (2023-24) onwards shall be conducted, after publishing an auction notification specifying the highest bid for the previous three years, excluding the period during which there were - restrictions on account of Covid 19 pandemic. After completion 12 W.P.(C)No.41759 of 2023 of the tender process, the details of the successful bidders along with the bid amount, the balance bid amount payable, its due date, etc., shall be exhibited on the official website of the Board. The list of those who have defaulted payment of the balance bid amount shall also be exhibited on the official website. The list of defaulters shall be forwarded to the Devaswom Commissioner for necessary action. A copy of that list shall also be forwarded to the Special Commissioner, Sabarimala. 16. In **Sunil Kumar P.G. [2022:KER:71822]** this Court directed the Travancore Devaswom Board to adopt a similar procedure in respect of all major temples under its management, in which the annual income is above Rs.2 Crore. In respect of such temples, the list of defaulters shall be forwarded to the Devaswom Commissioner for necessary action. The Kuthaka holders, who have defaulted payment of the balance bid amount, shall be proceeded against, in accordance with the tender conditions. In appropriate cases, proceedings shall also be initiated for blacklisting. In the said decision, this Court ordered that the successful bidders and their staff, if any, in respect of Kuthaka items in Sabarimala Devaswom and other Devaswoms under the management of the Travancore Devaswom Board shall be issued with photo identity cards. They shall be required to 13 W.P.(C)No.41759 of 2023 produce police clearance certificate. In respect of Kuthaka items above Rs.5,00,000/-, the Travancore Devaswom Board shall insist on the Income Tax particulars of the bidders. 17. In the matter of **Audit Report of the Travancore Devaswom Board for the year 1967-1968 (Sabarimala Improvement Fund)** reported in **[(1990) 1 KLT 347]** , in the context of Section 32 of the Travancore-Cochin Hindu Religious and Charitable Institutions Act, a Division Bench of this Court reminded the President and Members of the Travancore Devaswom Board about their public accountability. In the said decision, it was made clear that it is for all persons concerned to see that greater vigil is exercised by the President and Members of the Board in the overall administration of the Board and in the collection and disbursement of funds. 18. In **Suo Motu v. State of Kerala and others [2023** **(3) KHC SN 12 : 2023:KER: 21878]** relating to collection of parking fees in the parking grounds at Nilakkal Base Camp for the year 1198 ME (2022-23), a Division Bench of this Court, in which one among us [Anil K. Narendran, J] was a party, noticed that despite the directions contained in the decisions of this Court in **Abu K.S. v. Travancore Devaswom Board [2022:KER: 6409]** , **Suneesh K.S. v. Travancore Devaswom** 14 W.P.(C)No.41759 of 2023 **Board [ILR (2022) 1 Ker 1091]** and **Sunil Kumar P.G. [2022:KER:71822]** the Travancore Devaswom Board and its officials have not shown reasonable diligence in the manner of an ordinary prudent man of business who conduct his own affairs, in matters relating to the auctioning of Kuthaka rights at Sabarimala Devaswom for the year 1198 ME (2022-23). 19. Clause (3) of the general conditions in the general and special conditions which form part of the e-tender notification dated 24.08.2023 issued by the 4[th] respondent Executive Officer, for Kuthaka items in Sabarimala Devaswom, during the MandalaMakaravilakku festival season of 1199 ME (2023-24), for the period from 11.11.2023 till 31.10.2024, provides for the disqualification of defaulters and persons who are blacklisted by the Travancore Devaswom Board. Clause (3) of the general conditions read thus; “(3). ടെൻഡറിൽ പടെെു്കു്ᩐവർ 1500/- രൂപ രജി്ᩗ്രെഷൻ ഫീ ഓൺലൈൻ ആയി അെ്്ക്ᩂതാണ്. െി തുക തിരിടക ൈഭി്കു്ᩐതൈല. അരപകാരം ഹാജരാ്കാ്ᩈവടരയും, നിരത രരവയം , ഹാജരാ്കാ്ᩈവടരയും സാധാരണ വയവ്ഽകൾ അനുസരി്ച് ടെൻഡറിൽ പടെെു്ᩔി്കുവാൻ ്യാഗ്യത ഇൈലാ്ᩈവടരയും ടെൻഡറിൽ ്േരാൻ അനുവരി്കു്ᩐതൈല. ്േൽ്ᩔറ്ഞ ്യാഗ്യതകൾ ഉ്ᩂായിരു്ᩐാൈും ടെൻഡറിൽ ഏടതെിൈും വയ്വിടയ ്േർ്കുക്യാ ്േർ്കാതിരി്കുക്യാ ടേ്ᩞു്ᩐതിന് ടെൻഡർ സവീകരി്കു്ᩐ ഉ്രയാഗ ന് പരിപൂർ്ᩆ അധികാരം . ഉ്ᩂായിരി്കു്ᩐതാണ് ഈ വയവ്ഽകൾ നെ്ᩔ് ്കാൺരൊക്െർ ോർ്കും ബാധകോയിരി്കും. േുൻകുെി്ിക്ാടരയും, ്ാ്ക് ൈി്ഹ് ടേയതവടരയും യാടതാരു കാരണവശാൈും ടെൻഡറിൽ പടെെു്ി്ു്തൈ. ഓ്ᩔൺ ്ൈൈം നെ്കു്ᩐ ്വളയിൽ 15 W.P.(C)No.41759 of 2023 ്ൈൈഹാളിൽ രപ്വശി്ച് ്ൈൈ്ᩈിൽ പടെെു്കു്ᩐതിന് കു്ᩈക ഓ്രാ ്നടര ടഷഡയൂളുകളിൽ ഇന്ങളുടെ ്രഖട്ᩔെു്ᩈിയി്ടു്ᩦ നിരതരരവയ തുകകൾ (അെി്ഽാന്ൈൈ തുകയുടെ പ്ᩈു ശതോനം) ടക്ടിവയ ്ക്ᩂതും, ്ൈൈഹാളിൽ ്ൈൈം ടകാ്ᩦാ്ᩈവരുടെ തുക അ്്ᩐ രിവസട്ᩈ ്ൈൈ നെപെികൾ പൂർ്ᩆോയി കഴിയു്ᩐ േുറയ ് തിരിടക . നൽകു്ᩐതും ആയിരി്കും നൽകു്ᩐതും ആയിരി്കും ്ൈൈ്ᩈിൽ പടെെു്കു്ᩐവർ്ക് ടോലബൽ ്ഫാൺ ഉപ്യാഗ്ി്കാൻ പാെിൈലാ്ᩈതാണ്.” ## 20. In **S. Vijayakumar v. State of Kerala and others** **[2023:KER:60248]** a Division Bench of this Court in which one among us [Anil K. Narendran, J.] noticed that, Kuthaka holders, who defaulted payment of the balance bid amount, are bound to pay the defaulted payment together with penal interest at the rate of 18% per annum from the respective due dates, as per the conditions of the tender/e-tender notifications issued by the Travancore Devaswom Board. A person who is a defaulter in payment of the balance bid amount in respect of Kuthaka items - - - as on the date of a tender/e tender notification or re tender/re e-tender notification is disqualified from submitting tender/etender pursuant to such a notification, on account of the disqualification provided in Clause (3) of the general conditions. 21. The accounts of Sabarimala Devaswom are subject to statutory audit by the additional 10[th] respondent Deputy Director, Kerala State Audit Department, Travancore Devaswom Board Audit. 16 W.P.(C)No.41759 of 2023 22. Having considered the pleadings and materials on record and also the submissions made at the Bar, we deem it appropriate to dispose of this writ petition by directing the additional 10[th] respondent Deputy Director, Kerala State Audit Department, Travancore Devaswom Board Audit, to conduct a thorough enquiry in respect of payment of bid amount by the successful bidders in respect of all Kuthaka items in Sabarimala - Devaswom for Mandala Makaravilakku Festival season of 1199 - ME (2023 24), after verifying the relevant records and also the account statements of the designated Bank account maintained by the 2[nd] respondent Travancore Devaswom Board at the Nanthancode Branch of Dhanlaxmi Bank. Thereafter, the additional 10[th] respondent shall file a detailed report before this Court on the above aspect, which shall be numbered as DBAR and listed before the Devaswom Bench, within a period of two months from the date of receipt of a certified copy of this judgment. 23. The 2[nd] respondent Travancore Devaswom Board is directed to make necessary modifications in the terms and conditions of the e-tender notifications for Kuthaka rights in the Devaswoms under its management, requiring the bidders to furnish the name and address proof of the partners/Directors, in 17 W.P.(C)No.41759 of 2023 case the tenders are submitted by a partnership firm/Company. The details of the partners/Directors shall be entered in the relevant register maintained by the Travancore Devaswom Board, in order to ensure that the partners/Directors of a partnership/Company which is a defaulter of Kuthaka right are not participating in the tender process for the subsequent year, in their individual capacity or vice-versa. With the above directions, this writ petition is disposed of. **Sd/-** **ANIL K. NARENDRAN, JUDGE** **Sd/-** **G. GIRISH, JUDGE** ded 18 W.P.(C)No.41759 of 2023 ## **`APPENDIX OF WP(C) 41759/2023`** ## **`PETITIONER EXHIBITS`** ``` EXHIBIT P1TRUE COPY OF THE APPLICATION UNDER RTI DATED 30.09.2022 ``` ``` EXHIBIT P2TRUE COPY OF THE REPLY TO THE APPLICATION UNDER RTI DATED 19.03.2023 ``` ``` EXHIBIT P3TRUE COPY OF THE JUDGMENT IN O.S 37 OF 2018 DATED 25.01.2022 OF MUNSIFF'S COURT RANNI ``` ## **`RESPONDENT EXHIBITS`** ``` EXHIBIT R9(a)COPY OF THE PARTNERSHIP DEED OF SSA ENTERPRISES DATED 5.11.2013 ``` ``` EXHIBIT R9(b)COPY OF THE PARTNERSHIP DEED DATED 23.1.2016 ``` ``` EXHIBIT R9(c)COPY OF THE PARTNERSHIP DEED OF 24.10.2014 ``` ``` EXHIBIT R9(d)COPY OF THE RECONSTITUTED PARTNERSHIP DEED DATED 11.8.2015 ``` ``` EXHIBIT R9(f)COPY OF THE JUDGMENT IN W.P.(C) NO.23993/2021 DATED 3.11.2021 ``` ``` EXHIBIT R9(g)COPY OF THE BANK CHALLAN DATED 7.10.2023 ``` ``` EXHIBIT R9(h) ``` ``` COPY OF THE LETTER DATED 13.10.2023 ADDRESSED TO THE PRESIDENT/COMMISSIONER OF THE SECOND RESPONDENT ``` ``` EXHIBIT R9(e)COPY OF THE COMPLAINT PETITION DATED 11.8.2021 STATED TO HAVE BEEN SUBMITTED BY SRI. SURENDRAN BEFORE THE COMMISSIONER OF POLICE, KOCHI AND OBTAINED FROM THE WHATSAPP GROUP OF THE SABARIMALA VYAPARYI VYAVASAYIS ```