Shameema P.M. v. Union of India & Others

## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** # **PRESENT** **THE HONOURABLE MR.JUSTICE C.T.RAVIKUMAR** **&** **THE HONOURABLE MR. JUSTICE K.HARIPAL** **WEDNESDAY, THE 26[TH] DAY OF AUGUST 2020 / 4TH BHADRA, 1942 WP(CRL.) NO. 94 OF 2020** ## **PETITIONER:** **SHAMEEMA P.M., AGED 30 YEARS W/O.AREEKKACHALIL ROSHID (DETENU) R/O KUTTIYULLATHIL,P.O KARAVANNUR, VIA NADUVANNUR, KOZHIKODE-673 525.** **BY ADVS.P.A.AUGUSTIAN SRI.M.S.LALKUMAR** ## **RESPONDENTS:** **1 UNION OF INDIA REPRESENTED BY DIRECTOR GENERAL, CENTRAL ECONOMIC INTELLIGENCE BUREAU, 6TH FLOOR, B WING, JANPATH BHAWAN, JANPATH, NEW DELHI-110001.** **2 JOINT SECRETARY (COFEPOSA) GOVT. OF INDIA, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, 6TH FLOOR, B WING, JANPATH BHAWAN, JANPATH, NEW DELHI-110001.** **3 THE SUPERINTENDENT CENTRAL PRISON, THIRUVANANTHAPURAM.** W.P.(Crl.)No.94 of 2020 2 **4 SENIOR INTELLIGENCE OFFICER DIRECTORATE OF REVENUE INTELLIGENCE, KANNUR REGIONAL UNIT CENTRAL TAX AND CUSTOMS BUILDING, KUZHIKUNNU, KANNUR-670 001.** **BY ADVS.SHRI.P.VIJAYAKUMAR, ASG OF INDIA P.P.SRI.K.A.ANAS SRI.S.MANU, CGC, DIRECTORATE OF REVENUE INTELLIGENCE KERALA REGIONAL UNIT Smt.DAYASINDHU SHREEHARI N.S., CGC** **THIS WRIT PETITION (CRIMINAL) HAVING BEEN FINALLY HEARD ON 26.08.2020, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** W.P.(Crl.)No.94 of 2020 3 ## **JUDGMENT** ## **Ravikumar, J.** The petitioner who is the wife of the detenu Sri.Areekkachalil Roshid filed this habeas corpus writ petition seeking the following prayers:- - “1. That this Hon'ble Court be pleased to issue a writ of Habeas Corpus or any other writ in the nature thereof or order or directions under Article 226 of the Constitution of India calling upon the respondents to forthwith set the detune (sic.,detenu) Shri.Areekkachalil Roshid confined at Central Jail, Trivandrum at liberty; 2. This Hon'ble Court may be pleased to pass an appropriate order or directions, quash and set aside the detention order of detention dated 20[th] May, 2019 bearing F.No.PD-12001/16/2019-COFEPOSA passed under section 3(1) of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act 1974 passed by the Respondent no.2 i.e. Joint Secretary to the Government of India, Ministry of Finance, Department of Revenue, CEIB, New Delhi against the detune (sic.,detenu) Shri.Areekkachalil Roshid;” In respect of the incident vividly mentioned in Ext.P1 order dated 20.5.2019 invoking the power under Section 3(1) of the Conservation of Foreign Exchange & Prevention of Smuggling Activities Act, 1974 (for brevity 'COFEPOSA Act') the said order of detention was passed against W.P.(Crl.)No.94 of 2020 4 the husband of the petitioner. The said order was executed on 19.12.2019. Thereafter the petitioner filed Exts.P3 to P5 representations, all dated 30.12.2019 respectively before the Director General, Central Economic Intelligence Bureau, Government of India, the Joint Secretary, COFEPOSA and the Chairman of the COFEPOSA Advisory Board. Ext.P3 representation before the Government was rejected and the factum of rejection was communicated to the detenu as per Ext.P6 order dated 14.1.2020. Ext.P4 representation was rejected and its rejection was intimated as per Ext.P7. Before the Advisory Board the petitioner was afforded with an opportunity of being heard. As per Ext.P9 the order of detention was confirmed under Section 8(f) of COFEPOSA Act subsequent to the receipt of the opinion from the Advisory Board. It is in the said circumstances that the petitioner filed this writ petition seeking the aforementioned prayers. 2. Heard the learned counsel for the petitioner, the learned Assistant Solicitor General for respondents 1 and 2, the Learned Government Pleader for the 3[rd] respondent and the learned Standing Counsel for the 4[th] respondent. 3. A counter affidavit was jointly filed by respondents 1 and 2 and a separate counter affidavit was filed by the 4[th] respondent. A reply affidavit has been filed by the petitioner and thereafter an W.P.(Crl.)No.94 of 2020 5 additional counter affidavit was filed by respondents 1 and 2 as also by the 4[th] respondent. Later a statement was also filed on behalf of respondents 1 and 2. 4. Various contentions were raised by the petitioner. In support of the contentions and also to establish the entitlement of release relying on the decision of a Division Bench of this Court in **Saeed Zakir Hussain Malik** v. **State of Maharashtra & Others 2012 (3) KLJ 468** it is contended that the livelink between the last prejudicial activity and the order of detention snapped on two grounds firstly, on the ground of delay in passing order of detention and secondly on the ground of delay in execution of Ext.P1 order of detention. In elaboration of the first limb of the said contention it is submitted that the materials on record would reveal that the alleged involvement of the detenu came to the knowledge of the detaining authority on 14.2.2019, but the order of detention was passed only on 20.5.2019. The contention is that there was no explanation for the delay in passing the order of detention. It is contended that even after passing an order of detention on 20.5.2019 it was executed only on 19.12.2019 and therefore, there occurred a delay of about seven months in executing the order of detention. According to the learned counsel appearing for the petitioner in view of the absence of W.P.(Crl.)No.94 of 2020 6 explanation for the delay on the aforesaid grounds the detenu is entitled to be released. The learned Assistant Solicitor General appearing for respondents 1 and 2 objected to the aforesaid contentions and submitted that the contention of snapping of livelink on the aforementioned grounds is absolutely bereft of any basis. It is submitted that a perusal of the counter affidavit and additional counter affidavit filed by respondents 1 and 2 would reveal that the delay allegedly occurred was properly explained and in such circumstances the detenu is not entitled to be released based on the allegation of delay in passing and executing, the order of detention. The counter affidavit filed by respondents 1 and 2 as also by respondent No.4 would reveal that in connection with smuggling of gold from Kannur International Airport two carrier passengers namely, Sri.Nashid Komath Poyil and Sri.Sadath Makkatt were intercepted with gold on 14.2.2019. The petitioner's husband was arrested on 18.4.2019 and he was granted bail on 26.4.2019. Considering his active involvement in the smuggling activities and the propensity to indulge in such similar activities in future proposal for his detention was made on 2.5.2019. The order of detention was passed on 20.5.2019. In paragraph 31 of the counter affidavit filed by respondents 1 and 2 it is stated that though the carrier passengers were arrested on 14.2.2019 with 5.66 W.P.(Crl.)No.94 of 2020 7 Kilograms of gold and there were evidences against his involvement in the matter, the detenu managed to remain outside the purview of the investigation by staying abroad, well for a period of two months after the seizure of the gold until a marriage in the family necessitated his return. It is also stated therein that on the said occasion the officers of DRI searched his residential premises on 18.4.2019 and summoned him to DRI Office, Kannur and from there his voluntary statement under Section 108 of the Customs Act was recorded which lead to his arrest. As noticed hereinbefore, thereafter he was granted a conditional bail only on 26.4.2019. In the aforesaid circumstances, we do not find any reason to uphold the contention of the petitioner that there occurred inordinate delay rather, unexplained delay in the matter of passing of order of detention and thereby the livelink between the last prejudicial activity and the order of detention had snapped. Taking note of the aforesaid circumstances we have no hesitation to hold that there is no proximate nexus between the preventive action and the past activity of the detenu based on which the action was founded. At any rate, it cannot be said that the continuous chain of causation was broken. As regards the contention of the petitioner that owing to the delay in executing Ext.P1 order of detention passed on 20.5.2019 there occurred snapping of the livelink, the learned Assistant Solicitor General W.P.(Crl.)No.94 of 2020 8 took us through the explanation offered through the counter affidavit and the additional affidavit. In this context, it is to be noted that such a contention was raised on the ground that the order dated 20.5.2019 was executed only on 19.12.2019. The Assistant Solicitor General drew our attention to paragraph 32 of the counter affidavit filed by respondents 1 and 2. It is stated therein that the detenu absconded once the order of detention was issued on 20.5.2019. The following recital in the counter affidavit assumes relevance in the context of the contention:- “The Sponsoring authority viz. DRI, Kannur Regional Unit vide their letter dated 29.7.2019 informed that the detenue has been evading arrest and execution of detention order against him. Therefore, as envisaged by the COFEPOSA Act, 1974, the Joint Secretary, Central Economic Intelligence Bureau, New Delhi issued Order dated 14.8.2019 under Section 7(1)(b) of the Act ibid directing the detenue to appear before the Director General of Police, Government of Kerala, Thiruvananthapuram within 7 days of the publication of the said Order in the Official Gazette. The Order was published in the Official Gazette on 14.8.2019. The order of the Detaining Authority was also published in leading dailies of Kerala and more particularly through 'Madhyamam, a Malayalam daily with wide circulation where the detenue resided. However, the detenue remained absconding. Since the detenue was not adhering to the Order dated 14.8.2019, the office of Detaining Authority submitted a Report dated 12.12.2019 under Section 7(1)(a) of the Act ibid before the Hon'ble Judicial First Class Magistrate's Court-II, Perambra, Kozhikode District with a request to initiate further proceedings against Shri Areekkachalil Rodhid, the detenue, under Section 82, 83, 84 and 85 of the Code of Criminal Procedure, 1973. Steps were initiated by the Hon'ble Court to declare the detenue as proclaimed offender. Thus, detenue remained absconding for almost seven months until W.P.(Crl.)No.94 of 2020 9 18-12-2019 when he surfaced and surrendered before the Police on 19-12-2019, under extraneous factors, including the publishing of his absconding in newspapers, the imminent possibility of being declared a proclaimed absconder by a Magistrate court and an enquiry to trace his immovable properties. Further, since the detenue went absconding to evade COFEPOSA detention, the Show Cause Notice dated 12-08-2019 issued by the Joint Director, DRI, Cochin had to be handed over to the petitioner, Smt.Shameema P M, wife of Shri Areekkachalil Roshid at the residence of the detenue, drawn under a Mahazar in the presence of independent witnesses on 13-08-2019.” The learned counsel for the petitioner attempted to canvass the position that after the enlargement on bail of the detenu on 26.4.2019 if he was actually absconding the authorities could have and should have initiated steps for getting his bail cancelled and having chosen not to do so, the respondents cannot be heard to contend that the detenu was absconding since the issuance of order of detention dated 20.5.2019. We do not find any reason to uphold the said contention. When the respondents initiated steps under Section 71(a) of the COFEPOSA Act provided in relation to absconding process actions were taken in tune with the said provision for initiation of further proceedings against the detenu under Sections 82, 83, 84 and 85 of the Code of Criminal Procedure. It is only after initiation of such steps that the detenu had surrendered before the police station on 19.12.2019. In the said circumstances, it is only apposite to refer to a decision of the Hon'ble Apex Court in **Hare Ram Pandey** v. **State of Bihar** reported in **AIR** W.P.(Crl.)No.94 of 2020 10 **2004 SC 738** . The Apex Court held therein that when the plea of delay in execution of the order of detention had been taken up, if it is found that the said person himself was responsible for the delay by adopting various dilatory tactics to avoid execution, it would be no ground to quash the order of detention. The very factum of initiation of steps by the authorities and the fact that the detenu surrendered before the police station only thereafter would tend us to accept the contention of the respondents and we do not find any reason to hold otherwise merely based on the contention of the petitioner that the authorities did not take steps to get the order of bail cancelled. 5. We will now refer to the next contention of the petitioner though not specifically raised in the writ petition. There can be no attribution of delay in the matter of consideration of the representation submitted by the petitioner against the order of detention passed against her husband, the detenu as Ext.P4 representation dated 30.12.2019 which was received on 2.1.2020 was rejected, after consideration and as per Ext.P7 dated 14.1.2020 its outcome viz., rejection was communicated to the detenu as also to the petitioner. The contention of the petitioner is that though under Ext.P7 the rejection of the representation dated 30.12.2019 was intimated the copy of the original order whereby the same was rejected was not W.P.(Crl.)No.94 of 2020 11 served either to the petitioner or to the detenu. In that context, it is further submitted by the learned counsel for the petitioner that the date on which the representation was disposed of was not specifically stated in the counter affidavit filed by respondents 1 and 2. In short, in such circumstances, it is contended relying on a judgment of a Division Bench of this Court in W.P.(Crl.)No.207 of 2019 that the failure on the part of the respondents in communicating the copy of the original order whereby the representation was rejected or to give the details of the said order in the counter affidavit would violate the right under Article 22(5) of the Constitution of India. In the context of the case the pleadings of respondents 1 and 2 raised in the statement filed on their behalf, dated 13.8.2020 also assume relevance. In the said statement the details relating the representation dated 30.12.2019 addressed to the first respondent were given. As per the same, the representation in question was received on 2.1.2020 and it was moved for consideration of CEIB, on receipt of the comments called for, from the sponsoring authority on 13.1.2020. Going by the details, such comments were received from the sponsoring authority on 10.1.2020. The competent authority thereafter took the decision on the representation on 14.1.2020 and Ext.P7 communication was sent to the detenu on the same day itself. To counter the contention of the W.P.(Crl.)No.94 of 2020 12 petitioner made placing reliance on the decision in W.P. (Crl.)No.207/2019 it is contended by the learned Assistant Solicitor General that the factual background under which the said decision was rendered is different from the situation obtained in the case on hand. Furthermore it is submitted that going by the decisions of the Apex Court a detailed, reasoned order is not called for, while rejecting the representation and therefore, there is no violation of any of the rights of the detenu. In paragraph 5 of the statement it is stated thus:- “It is humbly submitted that the representation has been disposed after a detailed examination of it viz a viz (sic., vis-a-vis) the parawise comments given by the Sponsoring Authority and all other relevant materials. There is proper application of mind and there is no delay in the matter.” Considering such contentions in the light of the explanation offered by the respondents we do not think it necessary to delve into the aspects any further. 6. However, we are of the view that a contention raised by the petitioner requires serious consideration. In paragraph 7 of the writ petition it is contended that the allegation levelled against the detenu and the other co-accused Sri.Ummer Koya P.V. is that they were members operating from Doha and while concluding the grounds of preventive detention it is stated that “while Sri.Ummer Koya P.V. and W.P.(Crl.)No.94 of 2020 13 the detenu are the investors based at Qatar.” Based on the same, it is contended thus:- “The petitioner humbly submits that when an allegation was made against Shri.Ummer Koya P.V. Co-accused that he was the kingpins and investor as he had employed the same modus for the last many years and an order of preventive detention was passed against him. In his case, the Central Government was pleased to revoke the said order of detention and released him from preventive detention. Thus Ext.P1 order is unsustainable and liable to be revoked. But the above said facts were not brought to the notice of the Advisoty board while considering the validity of the Ext.P1 detention order against the detenu by Advisory board.” Based on the aforesaid aspect a ground was specifically taken in the writ petition as (P). In Ext.P4 representation dated 30.12.2019 the petitioner has specifically stated that similar allegations were made against one Shri.Ummer Koya P.V. in connection with the very same incident and an order of preventive detention was passed against him as per order F.No.120001/15/2019 (COFEPOSA) and he was detained. Later, as per order dated 5.8.2019 the Central Government revoked the order of detention and released the said Shri.Ummer Koya P.V. and therefore, the order of detention passed against the detenu herein is also liable to be revoked. Taking note of the contentions we have carefully gone through Ext.P2 grounds of detention. Ext.P2 would reveal that the sponsoring authority brought to the attention of the W.P.(Crl.)No.94 of 2020 14 detaining authority as hereunder:- “Specific intelligence was developed by the Officers of Directorate of Revenue Intelligence, Bangalore to the effect that a smuggling syndicate was operating based in Calicut and Doha for smuggling of gold into the country. The syndicate involved two brothers namely Shri.Sajad Sahir (hereinafter referred to as Shri Sajad) and Shri Mohammed Renose (hereinafter referred to Shri Renose), both S/o.Abdussalam, residing at Ali Sameer, Francis Road, Calicut along with you i.e. Shri.Areekkachalil Roshid (hereinafger referred to as you i.e. Shri Roshid), S/o.Pokker Kutty, Kuttiyullathil, P.O.Karuvannur, Kozhikode and Shri Ummer Koya P.V. (hereinafter referred to as Shri Ummer), S/o. Imbichiali Haji, Kappunkara, Vakayad, Naduvannur, Kozhikode who were organising/mastermind the operation, and thereby acting as kingpins to the smuggling racket of Gold into the country. The latter two persons viz., Shri Ummer Koya P.V. and you i.e. Shri Areekkachalil Roshid were operating based at Doha by way of investing in the gold smuggling as well as arranging carrier passengers for the smuggling operation when signaled by the two brothers,.....” The relevant portion of paragraph (xxxiv) of Ext.P2, in this context, reads thus:- “....... while Shri Ummer Koya P.V. and you i.e.. Shri. Areekkachalil Roshid were members operating from Doha …...................” On our careful scanning of Ext.P2 we found substance in the contention that against the detenu and Shri Ummer Koya P.V. similar allegations were raised and at the same time, subsequently the order of detention passed against Shri.Ummer Koya P.V. was revoked. This position is not W.P.(Crl.)No.94 of 2020 15 seriously disputed and in fact, it is indisputable in view of the recitals in Ext.P2. Therefore, the question is whether the indisputable fact of revocation of the detention order passed against the co-detenu and his consequential release was taken into consideration by the Advisory Board and also the detaining authority. Taking note of the aforesaid submissions this Court passed an order on 29.7.2020. For forming an opinion that perusal of the records of the Advisory Board, containing the opinion given by the Advisory Board in respect of the petitioner's husband Shri.Areekkachalil Roshid as also in respect of Shri. Ummer Koya.P.V. is required, we directed the Secretary, COFEPOSA, Advisory Board, to make available the files for perusal. On such perusal, when the files are made available for perusal, we found that this aspect was not specifically brought to the notice of the Advisory Board and the Advisory Board also did not pointedly considered this aspect. Naturally, without taking into account the said fact the order of detention was confirmed. 7. In this contextual situation, it is relevant to refer to the decision of the Hon'ble Apex Court in **Alpesh Navinchandra Shah** v. **State of Maharashtra ((2007) 2 SCC 777),** after referring to the earlier judgment in **Pawan Bhartiya** v. **Union of India ((2003 11 SCC 479).** The Apex Court held thus:- W.P.(Crl.)No.94 of 2020 16 “The above judgment, in our view, squarely applies to the facts and circumstances of the case on hand. In the instant case, the petitioner's brother has already been released on the ground there was no sufficient cause for the detention of the detenu under Section 3(1) of the Act. The Government also accordingly revoked the detention order issued against him and the Government of Maharashtra, after considering the report of the Advisory Board and the material on record and in exercise of the powers conferred by Section 8(f) of the COFEPOSA Act revoked the aforesaid detention order and further directed that Kamlesh Navinchandra Shah be released forthwith on receipt of the said order dated 05.06.2006. In our opinion, the petitioner before us who is also similarly placed and who has also paid the customs duty etc. pursuant to the order of the Settlement Commission and got the unconditional immunity by the Settlement Commission is entitled to the same treatment. At the time of hearing, it is pointed out that the petitioner has ceased his activities in the field of import or export and has already paid the tax with penalty as demanded by the authority and there is nothing on record that the appellant has indulged in any such activity in the recent past. It is settled by law that the purpose of passing the detention order is to prevent the detenu from continuing his prejudicial activity but not to punish him.” (emphasis supplied) It is evident from the afore-extracted portion from the decision in **Alpesh Navinchandra Shah's** case (supra) that virtually, the Apex Court held that non-consideration of an order of revocation of detention of a co-detenu passed after considering the report of the Advisory Board would vitiate the subsequent order confirming the order of detention of a detenu involved in the same transaction. In the context W.P.(Crl.)No.94 of 2020 17 of the aforesaid contention it is also relevant to refer to the decision of the High Court of Uttar Pradesh in **Jagdish Prasad Kasana Alias Jaggi** v. **State of Uttar Pradesh (2001 0 Crl.J 372)** . For the purpose of this case it is suffice to extract paragraph 11 of the said decision. It reads thus:- “It is not disputed that co-accused Arun Kumar Jain was also detained under Section 3 of the Act, but his detention order was revoked by the State Government on the advice of Advisory Board. It is clear from the affidavit of Sri.A.K.Awasthi, District Magistrate, Meerut dated 24-4-2000 that the order of revocation was well within his knowledge, but it was not considered before passing detention order of the petitioners. Sri.Mahendra Pratap, learned A.G.A. Contemplated that the revocation order was confidential document and was not available to the detaining authority and he had no access to it, therefore, it was not taken into consideration. Relying on Full Bench decision of this Court in the case of **Chandresh Paswan** v. **State of U.P. (1999) All LJ 1167)** he contended that if the detaining authority was not possessed of the document, there was no question for consideration by aim and there was sufficient material for forming the subjective satisfaction for passing an order of preventive detention against the petitioner and nonconsideration of the revocation order would not vitiate the order.” In that case, the order of revocation passed in respect of a co-detenu was not considered before passing detention order in respect of the petitioner therein. In that case, one co-accused by name Arun Kumar Jain was also detained in respect of the same transaction, under W.P.(Crl.)No.94 of 2020 18 Section 3 of the National Security Act, 1980. In his case, the order of detention was revoked. A contention was raised that the order of detention of Arun Kumar is a confidential document and therefore, it could not be made available to the detaining authority. The High Court held that the said order could not be said to be a confidential document for the State. It was held that it vitiated the order passed in the case of the petitioner therein. In the case on hand, as noticed hereinbefore, at the time when Ext.P1 detention order was passed Ext.P6 was not in existence. But, at the same time, we are of the view that the ratio of the said decision is applicable in this case. This is because the order of revocation in respect of co-detenu Sri.Ummer Koya.P.V. was passed by the Government. Ext.P2, the grounds of detention issued to the detenu in this case viz., Sri.Areekkachalil Roshid would reveal the fact that Sri.Ummer Koya.P.V. was his co-detenu, in the same transaction is very much known to the Government. The case of Sri.Areekkachalil Roshid came up for consideration of the Government to consider whether Ext.P1 is to be confirmed or not, only after the issuance of Ext.P6 and therefore, was very much available for consideration. In similar situation, a Division Bench of this Court in which one among us (C.T.Ravikumar, J.) was a party in W.P.(Crl.)No.479 of 2018 relying on the aforesaid decisions set aside the detention order in respect of one W.P.(Crl.)No.94 of 2020 19 Shri.Abulais @ Abdul Laise. In the light of the order dated 5.8.2019 of the Central Government it cannot be said that the factum of revocation of the order of detention in respect of the co-detenu Shri.Ummer Koya.P.V. was not known to the Government. It is also to be noted that in the case of the detenu herein Ext.P4 representation came up for consideration of the Government only after the issuance of the said order dated 5.8.2019. However, this aspect was not considered by the Advisory Board and subsequently, by the Government when it rejected Ext.P4 representation. The writ petition is therefore liable to be allowed. In the result, this Writ Petition (Crl.) is disposed of with a direction to the respondents to set Sri.Areekkachalil Roshid at liberty forthwith, in case his custody is not required in connection with any other case. Sd/- **C.T.RAVIKUMAR Judge** Sd/- **K.HARIPAL Judge** TKS W.P.(Crl.)No.94 of 2020 20 ## **APPENDIX OF WP(CRL.) 94/2020** **PETITIONER EXHIBITS** **EXHIBIT P1 TRUE COPY OF ORDER F.NO.PD-12001/16/2019COFEPOSA DATED 20.5.19.** - **EXHIBIT P2 TRUE COPY OF THE GROUNDS OF DETENTION WITH COPY OF THE LIST OF RELIED UPON DOCUMENTS.** - **EXHIBIT P3 TRUE COPY OF THE REPRESENTATION DATED 30.12.19.** - **EXHIBIT P4 TRUE COPY OF THE REPRESENTATION BEFORE THE HON'BLE JOINT SECRETARY (COFEPOSA) DATED 30.12.19.** - **EXHIBIT P5 TRUE COPY OF THE REPRESENTATION DATED 30.12.19 MADE TO THE HON'BLE CHAIRMAN OF COFEPOSA ADVISORY BOARD.** - **EXHIBIT P6 TRUE COPY OF THE ORDER DATED 14.1.2020.** - **EXHIBIT P7 TRUE COPY OF THE ORDER DATED 14.1.2020 ISSUED BY JOINT SECRETARY.** - **EXHIBIT P8 TRUE COPY OF THE LETTER DATED 16.1.2020.** - **EXHIBIT P9 TRUE COPY OF THE ORDER NO.PD-12001/16/2019COFEPOSA DATED 28.2.2020.** TKS