Savith Erayi v. State of Kerala and others

# **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE MRS. JUSTICE ANU SIVARAMAN TUESDAY, THE 4[TH] DAY OF JANUARY 2022 / 14TH POUSHA, 1943** ## **WP(C) NO.20583 OF 2021** ## **- PETITIONER :** SAVITH ERAYI, S/O.SURENDRAN ERAYI, KIZHAKKAYIL HOUSE, THOLAMBRA P.O., PERAVOOR VIA, KANNUR-670 673. BY ADVS. V.HARISH RAJAN VISHNURAJ ## **- RESPONDENTS :** |1|STATE OF KERALA,| |---|---| ||REPRESENTED BY ADDITIONAL CHIEF SECRETARY,| ||DEPARTMENT OF INDUSTRIES, SECRETARIAT,| ||THIRUVANANTHAPURAM-695 001.| |2|KERALA STATE ENVIRONMENT IMPACT ASSESSMENT| ||AUTHORITY, K.S.R.T.C. BUS TERMINAL COMPLEX,| ||4TH FLOOR, THAMPANOOR, THIRUVANANTHAPURAM-695 001,| ||REPRESENTED BY CHAIRMAN.| |3|KERALA STATE DISASTER MANAGEMENT AUTHORITY,| ||VIKAS BHAVAN, P.O. OBSERVATORY HILLS,| ||OPPOSITE KANAKAKKUNNU PALACE, NANTHANCODU,| ||THIRUVANANTHAPURAM-695 033,| ||REPRESENTED BY ITS MEMBER SECRETARY.| |4|DIRECTOR OF MINING AND GEOLOGY,| ||DIRECTORATE OF MINING AND GEOLOGY, KESAVADASAPURAM,| ||PATTOM PALACE P.O., THIRUVANANTHAPURAM-695 004.| |5|DISTRICT DISASTER MANAGEMENT AUTHORITY,| ||KANNUR, COLLECTORATE ROAD, THAVAKKARA,| ||KANNUR-670 002, REPRESENTED BY CHAIRMAN.| |6|DISTRICT ENVIRONMENT IMPACT ASSESSMENT AUTHRITY,| ||KANNUR REPRESENTED BY ITS CHAIRMAN,| ||DISTRICT COLLECTOR, COLLECTORATE, KANNUR-670 002.| |7|DISTRICT LEVEL EXPERT APPRAISAL COMMITTEE,| ||KANNUR DISTRICT, REPRESENTED BY ITS| ||MEMBER SECRETARY, DISTRICT GEOLOGIST,| WP(C) NO.20583 OF 2021 -: 2 :- KANNUR-670 002. 8 DISTRICT LEVEL CRISIS MANAGEMENT GROUP, KANNUR, REPRESENTED BY CHAIRMAN, DISTRICT COLLECTOR OFFICE, COLLECTORATE ROAD, THAVAKKARA, KANNUR-670 002. 9 DISTRICT GEOLOGIST, KANNUR DISTRICT, DISTRICT OFFICE MINING AND GEOLOGY, KANNUR-670 002. 10 MALUR GRAMA PANCHAYAT, WARD NO.6, DNO.329, KARETTA KANJILERI MALOOR ROAD, KARETTA, KANNUR-670 702, REPRESENTED BY THE SECRETARY. 11 K.K. SURENDRAN, ASWATHI, VALAYAL, KEEZHALLUR P.O., KANNUR-670 612. 12 MAHESH S., RQP/BNG/338/2014/A, T.C. 31/580, NAVADEEPAM, S.N. NAGAR, HOUSE NO.24, PETTAH POST OFFICE, TRIVANDRUM, KERALA-695 024. 13 REGIONAL CONTROLLER OF MINES, INDIAN BUREAU OF MINES, INDUSTRIAL SUBURB, II STAGE, TUMKUR ROAD, YESHWANTPUR, BANGALORE – 560 022. BY ADVS. SRI.S.KANNAN, SENIOR G.P. SRI.K.P.HARISH SRI.ALEX.M.SCARIA SMT.SARITHA THOMAS SRI.M.P.SREEKRISHNAN, SC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 23.12.2021, THE COURT ON 4.1.2022 DELIVERED THE FOLLOWING: WP(C) NO.20583 OF 2021 -: 3 :- ## **JUDGMENT** ## **Dated this the 4th day of January, 2022** ## 1.This writ petition is filed with the following prayers:- “i) Declare that the 6[th] respondent has no power or authority to issue Exhibit P6 environmental clearance to the 11[th ] respondent after Exhibit P12 judgment. ii)Declare that no mining operations can be undertaken by the 11[th] respondent or his representatives in Re Sy No. 10/114, 10/115 of Tholambra village of Thalaserry Taluk, within 50 meters of river, in violation of the siting criteria laid down in Rules 10(f) and 40(i) of the Kerala Minor Mineral Concession Rules, 2015. iii) Call for the records leading to Exhibit P6 and issue a writ of certiorari or direction or order quashing the same. iv) Call for the records leading to Exhibit P4, P7 and P14 and issue a writ of certiorari or direction or order quashing the same. v) Issue a writ of mandamus or any other appropriate writ directing the respondents No.3 and 5 to ensure that no mining operations is carried out by the 11[th] respondent in Re Sy No. 10/114, 10/115 of Tholambra village of Thalaserry Taluk, without obtaining prior approval from the 8[th] respondent. vi) Issue a writ of mandamus or any other appropriate writ directing the Respondents No.4 and 13 to take appropriate steps/ action against the 12[th] respondent by cancelling his certificate of recognition as a Recognized Qualified Person for preparing Mining Plan. Vii) Issue a writ of mandamus or any other appropriate writ directing the respondents No. 1 to 9 to consider and pass appropriate orders on Exhibit P16 after affording an opportunity of being heard to the petitioner.” 2.Heard Sri.Harish Vasudevan, the learned counsel for the petitioner, Sri.M.P.Sreekrishnan, the learned standing WP(C) NO.20583 OF 2021 -: 4 :- counsel for the 2[nd] respondent, Sri.Alex M Scaria, the learned counsel appearing for the 11[th] respondent and Sri.S.Kannan, the learned Senior Government Pleader. 3.It is submitted by the learned counsel for the petitioner that the petitioner, a resident of Tholambra Village of Thalassery Taluk in Kannur District, is deeply aggrieved by the Environmental Clearance and the consequent permissions granted to the 11[th] respondent for carrying out mining operations in an area which has been demarcated as a moderate landslide hazard zone and is hardly 150 metres away from the high hazard zone. It is submitted that the mining operations are sought to be carried out in a biodiversity rich area, namely Poovatharkundu where a first order river originates from the nearby hill called Puralimala. It is stated that the Poovatharkundu river is the main source of drinking water for the residents of the locality and that several species of flora and fauna are endangered by the mining activity in the area. It is submitted that clearance had been secured by the 11[th] respondent from the 6[th] respondent, which did not have the power or expertise to consider the relevant issues for WP(C) NO.20583 OF 2021 -: 5 :- grant of an Environmental Clearance. It is further submitted that the petitioner, who is a resident of the locality, was made aware of the issuance of the Environment Clearance only when steps were taken to start quarrying in the premises and that the environmental clearance granted is totally without jurisdiction and is liable to be set aside. 4.It is further submitted that Section 16 of the National Green Tribunal Act provides for a challenge to an environmental clearance granted within 30 days with power to condone delay for a further period of 60 days. Relying on the decision of the National Green Tribunal in Appeal No.1 of 2013 (Ms.Medha Patkar and others v. Ministry of Environment and Forests and others), it is contended that the Tribunal has no jurisdiction to condone the delay in filing of an appeal beyond the period of 90 days in terms of the proviso to Section 16 of the National Green Tribunal Act, 2010 (NGT Act for short). It was held that a communication of the grant of the environmental clearance would mean a publication of the same as contemplated in the EIA Notification, 2006. It is stated that in view of the fact that there was no publication of WP(C) NO.20583 OF 2021 -: 6 :- the grant of the environmental clearance either on the website of the project proponent or in newspapers informing the residents of the locality about the grant of the environmental clearance, the petitioner was unable to get the required information within the time specified and was therefore unable to approach the NGT. 5.It is further submitted that Exhibit P6 environmental clearance was issued on 7.11.2018, which is after Exhibit P12 judgment of the NGT holding that the procedure for grant of environmental clearance by the District Environment Impact Assessment Authority (DEIAA for short) is not consistent with the directions of the Apex Court in **Deepak Kumar v. State of Haryana** [(2012) 4 SCC 629] and that therefore, environmental clearance was to be obtained from the State Environment Impact Assessment Authority. It is submitted that thereafter, Exhibit P14 mining permit has also been granted without reference to the fact that the environmental clearance itself is non est and unworkable. It is further submitted that there are two other quarry units within 500 metres of the quarry of the 11[th] respondent and that there is a WP(C) NO.20583 OF 2021 -: 7 :- cluster situation available and that the question with regard to the existence of a first order river has not been considered by the competent authorities while granting the environmental clearance. The learned counsel would also place reliance on the definition of a river as per the Regulation 2(29) of the Metalliferous Mines Regulations, 1961 which includes any stream or current of water, whether seasonal or perennial and includes its banks, extending up to the highest known flood level. It is contended that if the said definition of river is applied to the water course admittedly existing in the subject area, the environmental clearance could not have been granted to the 11[th] respondent. It is submitted that cluster situation, the existence of a first order river and the proximity to a high landslide hazard zone have not been considered while granting the environmental clearance and since the petitioner could not challenge the environmental clearance before the NGT due to lack of proper publication, the petitioner is well within his rights in seeking to challenge the same in these proceedings. 6.A detailed counter affidavit has been placed on record by the WP(C) NO.20583 OF 2021 -: 8 :- learned Government Pleader on behalf of the 9[th] respondent. It is contended that the petitioner's remedy as against an environmental clearance was to file an appeal before the NGT, which has not been done by the petitioner. It is stated that no exceptional circumstances had been pleaded for not approaching the NGT in time and that as such, the challenge is not maintainable before this Court. It is further submitted that the challenge in the writ petition being specifically against Exhibits P4, P6, P7 and P14 and since those Exhibits have worked themselves out, the challenge itself has become infructuous. Without prejudice to the above contentions, it is contended that what is present in the site was only a 'nalla', or a seasonal flow of rain water and that there is absolutely no river present in the subject area and that the definition of river in Exhibit P17 is by no means applicable to the grant of environmental clearance and the said argument is completely misconceived. It is further stated that Exhibit P12 and P13 judgments specifically did not set aside the environmental clearances granted by the 6[th] respondent, DEIAA. It is submitted that Exhibit P8 would show that the environmental clearance had been initially granted on 19.5.2018 and that it WP(C) NO.20583 OF 2021 -: 9 :- was only re-issued after corrections on 7.11.2018. It is stated that the area in question does not form a part of landslide prone area and there is no substance in the allegation that any illegal mining is carried out by the 11[th] respondent. It is further contended that even if all the allegations of the petitioner are accepted, there is no “cluster” in existence and that there is absolutely no necessity for a Common Environment Impact Assessment or an Environment Management Plan, since admittedly, the total area of the three quarries is much less than 5 hectares. - 7.The 3[rd] respondent has placed a counter statement on record. It is stated therein as follows:- “5. The 3[rd] respondent has published Handbook on Disaster Management -Volume I - Hazard Susceptible Areas of Kerala, 2014 (hereinafter referred as HSAK, for short and convenience). Ext. P9 produced along with the Writ Petition (Civil) is from the HSAK 2014 and Ext. P9/3, in page number 101 of the paper book is the Multi Hazard Zonation Map, pertaining to the Kannur district. 6. The Government of Kerala by GO dated 09/09/2016 has approved the State Disaster Management Plan, 2016 as contemplated under Section 23 (1) (2) and (3) of the Disaster Management Act of 2005. As per Section 3.21.1 of the State Disaster Management Plan, 2016, in moderate hazard zones as WP(C) NO.20583 OF 2021 -: 10 :- given in HSAK 2014, quarrying shall be permitted only after getting the approval of the District Level Crisis Management Committee for mining, as constituted as per GO dated 26/05/2014. 7. It is respectfully submitted that Ext. P9 (a) is a copy of superimposed image, which is not owned by the 3[rd] respondent and therefore the 3[rd] respondent cannot confirm the authenticity of Ext. P9 (a) document. Furthermore, it should be verified by using the coordinates of the quarry boundaries, as to whether the said land falls within Hazard Zones. Petitioner has not produced co-ordinates of the quarry involved in the ibid lis.” 8. The 11[th] respondent has placed a detailed counter affidavit on record, inter alia, contending that the 11[th] respondent has all statutory clearances and permissions required and that there is absolutely no cluster situation available, since admittedly the combined area of the three quarries is much less than 5 hectares. It is contended that there was due and proper publication of the grant of the environmental clearance and that there is absolutely no justification in challenging the environmental clearance before this Court without pointing out any reason for not challenging the same before the NGT within the time provided. The contentions of the petitioner with regard to the nature of the quarry site, biodiversity, the cluster situation and the water course in the area are all WP(C) NO.20583 OF 2021 -: 11 :- sought to be disputed with supporting documents. It is further contended that the petitioner is an accused in three crimes and he has also filed O.S.No.329/21 before the Munsiff's Court, Kuthuparamba for identical reliefs, but no orders have been obtained thereon. It is submitted that after the grant of the environmental clearance and taking all necessary steps for preparation of the site for the mining activity, the petitioner is only employing pressure tactics to defeat the rights of the 11[th] respondent and that the same is liable to be interdicted by imposing costs. - 9.Detailed reply affidavits have also been placed on record and it is contended that there was absolute non application of mind in the appraisal conducted by the DEAC and the DEIAA for the purpose of grant of Environmental Clearance. - 10.I have considered the contentions advanced. The petitioner has submitted Ext.P16 representation before the Government with a copy addressed to the 2[nd] respondent pointing out the alleged illegalities in the grant of the Environmental Clearance by the DEIAA. The alleged omissions in the appraisal WP(C) NO.20583 OF 2021 -: 12 :- conducted by the DEAC have also been raised in the said representation. - 11.The contentions raised by the petitioner are essentially factual in nature and this Court would not be justified in considering the contentions on their merits. The Apex Court in **Municipal Corporation of Greater Mumbai v. Ankita Sinha and others** [2021(5)KLT 626 SC] has clearly held that the NGT has wide adjudicatory and suo motu powers and that the constitutional courts may not be justified in carrying out the functions which the NGT is required and equipped to perform. 12. In view of the specific provisions of Clause 8 (vi) of the Environment Impact Assessment Notification of 2006 and in view of the allegations raised by the petitioner in Exhibit P16, I am of the opinion that it is for the SEIAA, which is admittedly empowered to conduct all required assessments, to consider the compliant of the petitioner with regard to the irregularities, if any, in the issuance of the environmental clearance in favour of the 11[th] respondent. Sub-clause (vi) of WP(C) NO.20583 OF 2021 -: 13 :- Clause 8 of the 2006 EIA notification specifically empowers the regulatory authority, after giving a personal hearing and following the principles of natural justice, to consider any issue of deliberate concealment and /or submission of false or misleading information or data which is material to screening or scoping or appraisal or decision on an application for environmental clearance and the rejection of application for and cancellation of prior environmental clearance granted on that basis. In the light of the said provision, the 2[nd] respondent is specifically empowered to consider the complaints of the petitioner with regard to the prior environmental clearance granted to the 11[th] respondent after hearing the 11[th] respondent and considering the rival contentions on merits. - 13.In the above view of the matter, I am of the opinion that it may not be necessary for this Court to go into the merits of any of the contentions raised in this writ petition. Suffice it to say that it is for the SEIAA to take an appropriate decision in the matter. In the result, there will be a direction to the 2[nd] respondent to take up Exhibit P16 and consider all relevant WP(C) NO.20583 OF 2021 -: 14 :- aspects, after hearing the petitioner as well as the 11[th] respondent and take an appropriate decision in accordance with law. In view of the contention that the mining activity has not started in the 11[th] respondent’s premises, the 2[nd] respondent will consider the complaints raised by the petitioner and pass orders with regard to the starting of the mining activity also, taking note of the merits of the contentions raised, on facts. Appropriate interim orders shall be rendered by the 2[nd] respondent on a preliminary examination of the issues involved, within a period of three weeks from its reconstitution. Final orders on Exhibit P16 representation shall also be passed after considering the contentions of all the parties and all relevant aspects within a period of six weeks thereafter. All other issues raised are left open. This writ petition is ordered accordingly. **Sd/Anu Sivaraman, Judge** sj WP(C) NO.20583 OF 2021 -: 15 :- ## **APPENDIX OF WP(C) 20583/2021** PETITIONER EXHIBITS Exhibit P1 A TRUE PHOTOCOPY OF THE NOTIFICATION NO. S.O. 141(E) DATED 15/01/2016 ISSUED BY THE MINISTRY OF ENVIRONMENT, FOREST AND CLIMATE CHANGE. Exhibit P1(a) A TRUE PHOTOCOPY OF THE SO NO.2269(E) DATED 01/07/2016 ISSUED BY THE MINISTRY OF ENVIRONMENT, FOREST AND CLIMATE CHANGE. Exhibit P2 A TRUE PHOTOCOPY OF THE FORM 1M APPLICATION PREFERRED BY THE 11TH RESPONDENT BEFORE THE 6TH RESPONDENT. Exhibit P3 A TRUE PHOTOCOPY OF THE RELEVANT PAGES OF THE PREE-FEASIBILITY REPORT SUBMITTED BY THE 11TH RESPONDENT. Exhibit P4 A TRUE PHOTOCOPY OF THE RELEVANT PAGES OF THE APPROVED MINING PLAN SUBMITTED BY THE 11TH RESPONDENT. Exhibit P5 A TRUE PHOTOCOPY OF THE CLUSTER CERTIFICATE DATED 13/04/2018 ISSUED BY THE 9TH RESPONDENT TO THE 11TH RESPONDENT. Exhibit P5(a) A TRUE PHOTOCOPY OF THE RELEVANT PAGES OF ENVIRONMENTAL CLEARANCE NO. 148/KNR/2017/DEIAA DATED 05/01/2018 ISSUED BY THE 6TH RESPONDENT. Exhibit P6 A TRUE PHOTOCOPY OF THE RELEVANT PAGES OF ENVIRONMENTAL CLEARANCE NO. 152/ECA/KNR/2018/DEIAA DATED 07/11/2018. Exhibit P7 A TRUE PHOTOCOPY OF THE LETTER OF INTENT NO. DOC/M-1004/2018 DATED 07/04/2018 ISSUED TO THE 11TH RESPONDENT BY THE 9TH RESPONDENT. Exhibit P8 A TRUE PHOTOCOPY OF THE SURVEY MAP NO. C43D9 PREPARED BY THE SURVEY OF INDIA. Exhibit P8(a) TRUE COLOR COPY OF THE PHOTOGRAPHS OF THE WP(C) NO.20583 OF 2021 -: 16 :- ||RIVER ADJACENT TO THE 11TH RESPONDENT'S| |---|---| ||QUARRY.| |Exhibit P9|A TRUE PHOTOCOPY OF THE RELEVANT PAGES OF THE| ||HANDBOOK ON DISASTER MANAGEMENT VOLUME -1,| ||HAZARD SUSCEPTIBLE AREAS OF KERALA 2014.| |Exhibit P9 (a)|A TRUE PHOTOCOPY OF THE SATELLITE IMAGES OF| ||THE AREA WHERE THE 11TH RESPONDENT IS| ||CONDUCTING MINING OPERATIONS SUPERIMPOSED WITH| ||THE LANDSLIDE HAZARD MAO OF THE SAID AREA.| |Exhibit P10|A TRUE PHOTOCOPY OF THE G.O.(RT) NO.| ||3667/2016/DMD DATED 09.09.2016 ALONG WITH| ||RELEVANT PAGES OF THE KERALA STATE DISASTER| ||MANAGEMENT PLAN 2016.| |Exhibit P11|A TRUE PHOTOCOPY OF THE GOVERNMENT ORDER G.O.| ||(RT) NO. 542/14/ID DATED 26.05.2014.| |Exhibit P12|A TRUE PHOTOCOPY OF THE JUDGMENT BY THE HONBLE| ||NATIONAL GREEN TRIBUNAL IN SATENDRA PANDERY| ||VS. MOEF AND ORS IN O.A. NO. 186 OF 2016.| |Exhibit P13|A TRUE PHOTOCOPY OF THE ORDER DATED 11.12.2018| ||BY THE HONBLE NATIONAL GREEN TRIBUNAL IN| ||EXECUTIVE APPLICATION NO. 55 OF 2018 IN OA.| ||NO. 520 OF 2016.| |Exhibit P14|A TRUE PHOTOCOPY OF THE MINING PERMIT NO.| ||08/2021-22 /MM/GS/OS/DOC/M-1287/2201 DATED| ||06.07.2021 ISEUD BY THE 9TH RESPONDENT TO THE| ||11TH RESPONDENT.| |Exhibit P15|A TRUE PHOTOCOPY OF THE STUDY REPORT PREPARED| ||BY SEEK IN POOVATHARKUNDU AREA.| |Exhibit P16|A TRUE PHOTOCOPY OF THE REPRESENTATION DATED| ||01.09.2021 PREFERRED BY THE PETITIONER BEFORE| ||THE RESPONDENTS NO. 1 TO 9.| |Exhibit P17|A TRUE PHOTOCOPY OF THE RELEVANT PAGES OF THE| ||METALLIFEROUS MINES REGULATIONS, 1961 CITING| ||REGULATIONS 2 (29).| WP(C) NO.20583 OF 2021 -: 17 :- - Exhibit P18 TRUE COPY OF THE RELEVANT PAGES OF THE MINING PLAN i.e., CHAPTER 2 WHICH DEALS WITH THE LOCATION AND ACCESSIBILITY - Exhibit P19 A TRUE PHOTOCOPY OF THE RELEVANT PAGES OF THE STATE DISASTER MANAGEMENT PLAN - Exhibit P20 A TRUE PHOTOCOPY OF THE NEWS ITEM APPEARED IN MALAYALA MANORAMA DAILY DATED 8.11.2021 - Exhibit P21 A TRUE COPY OF THE SALE DEED DATED 8.6.2000 - Exhibit P21(a) A TRUE PHOTOCOPY OF THE SALE DEED DATED 8.6.2000 - Exhibit P21(b) A TRUE PHOTOCOPY OF THE REGISTERED SALE DEED DATED 28.5.2011 BEARING NO 1793/211 IN FAVOR OF SOBHA - Exhibit P22 A TRUE PHOTOCOPY OF THE REPORT NO 63/2021 OF THE THOLAMBARA VILLAGE OFFICER - Exhibit P23 THE TRUE PHOTOCOPY OF THE RELEVANT PAGES OF WATERSHED CONVERSATION MASTER PLAN OF MALOOR GRAMA PANCHAYATH - Exhibit P24 A TRUE PHOTOCOPY OF THE RELEVANT PAGES OF THE MINUTES OF THE 16TH MEETING OF THE 7TH RESPONDENT - Exhibit P25 A TRUE PHOTOCOPY OF THE RELEVANT PAGES OF THE 115TH MEETING HELD ON 3.5.2020 PF SEAC ## **' - RESPONDENTS EXHIBITS :** Exhibit R11(a) TRUE COPY OF THE EC DATED 19/05/2018 TO ME IN RESPECT OF THE QUARRY AREA COVERED BY EXHIBIT P6. Exhibit R11(b) TRUE COPY OF THE STAY ORDER DATED 31/01/2020 PASSED BY THE HONOURABLE APEX COURT WP(C) NO.20583 OF 2021 -: 18 :- - Exhibit R11(c) TRUE COPY OF THE REPORT DATED 13/02/2019. Exhibit R11(d) TRUE PRINT OUT OF THE RELEVANT PAGES OF LIST OF LANDSLIDE PRONE AREAS IN RESPECT OF THE KANNUR DISTRICT AS PER THE MULTIPLE HAZARD ZONATION MAP. - Exhibit R11(e) TRUE COPY OF THE INTERIM ORDER DATED 10/09/2021. - Exhibit R11(f) TRUE PRINT OUT OF THE NEWS ITEM CIRCULATED BY THE LOCAL CABLE TV NEWS CHANNEL NAMED MALAYORASHABDAM. - Exhibit R11(g) TRUE COPY OF THE FIR IN CRIME No.258/2021 DATED 23/09/2021 OF MALUR POLICE STATION. - Exhibit R11(h) TRUE COPY OF THE FIR IN CRIME No.245/2021 DATED 06/09/2021 OF MALUR POLICE STATION. - Exhibit R11(i) TRUE COPY OF THE FIR IN CRIME No.246/2021 DATED 07/09/2021 OF MALUR POLICE STATION. - Exhibit R11(j) TRUE COPY OF THE PRE-FEASIBILITY REPORT PREPARED FOR CONSIDERATION OF THE DEAC AND DEIAA IN CONNECTION WITH THE PROCEEDINGS. - Exhibit R11(k) TRUE COPY OF THE QUARRY PERMIT - Exhibit R11(l) TRUE COPY OF THE APPLICATION DATED UNDER R.T ACT DATED 13/10/2021 - Exhibit R11(m) TRUE COPY OF THE INFORMATION SUPPLIED AS PER COMMUNICATION DATED 26/10/2021 - Exhibit R11(n) TRUE COPY OF THAT REPORT IN JANAYUGAM DAILY DATED 19/01/2019, ALONG WITH ENLARGED COPY OF THE RELEVANT PORTION THEREOF.