Sree Narayana Guru Memorial Educational and Cultural Trust v. State of Kerala and Others

## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** ## **THE HONOURABLE MR. JUSTICE ANIL K.NARENDRAN** **TUESDAY, THE 02ND DAY OF MARCH 2021 / 11TH PHALGUNA, 1942** ## **WP(C).No.28062 OF 2020(G)** ## **PETITIONER:** **SREE NARAYANA GURU MEMORIAL EDUCATIONAL AND CULTURAL TRUST THIRUMALABHAGOM.P.O,THURAVOOR, CHERTHALA,ALAPPUZHA DISTRICT-688540,REPRESENTED BY ITS PRESIDENT P.SANKAN,AGED 73 YEARS,S/O.PURUSHOTHAMAN,RESIDING AT CHINGAMTHARAYIL HOUSE,THURAVOOR, ALAPPUZHA DISTRICT-688540.** **BY ADV. SRI.ANOOP.V.NAIR** ## **RESPONDENTS:** |**1**|**THE STATE OF KERALA**| |---|---| ||**REPRESENTED BY SECRETARY,HEALTH AND FAMILY**| ||**WELFARE DEPARTMENT,GOVERNMENT**| ||**SECRETARIAT,THIRUVANANTHAPURAM-695001.**| |**2**|**THE KERALA UNIVERSITY OF HEALTH SCIENCE,**| ||**THRISSUR DISTRICT-680596,**| ||**REPRESENTED BY ITS REGISTRAR.**| |**3**|**THE DIRECTOR OF MEDICAL EDUCATION,**| ||**OFFICE OF THE DIRECTOR OF MEDICAL**| ||**EDUCATION,THIRUVANANTHAPURAM-695011.**| |**4**|**THE REGISTRAR,**| ||**PHARMACY COUNCIL OF INDIA,COMBINED COUNCIL**| ||**BUILDING,KOTLA ROAD,**| ||**NEW DELHI-110002.**| - **5 THE ALL INDIA COUNCIL FOR TECHNICAL EDUCATION, 7TH FLOOR,CHANDER LOK BUILDING, JANPATH,NEW DELHI-110001,REPRESENTED BY ITS CHAIRMAN.** **BY ADV. SHRI.P.VIJAYAKUMAR, ASG OF INDIA BY ADV.M.A.ASIF, SPL. GP** **THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 02.03.2021, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** W.P.(C)No.28062 of 2020 2 ## **JUDGMENT** The petitioner Trust is running Sree Narayana Guru Memorial Pharmacy College at Valamangalam South, Thuravoor, which is a Self-Financing College conducting D.Pharm course, with the approval of the Pharmacy Council of India and the affiliation of the 3[rd] respondent Director of Medical Education, Kerala. The petitioner has filed this writ petition under Article 226 of the Constitution of India, seeking a writ of certiorari to quash Ext.P7 order dated 14.03.2020 of the 1[st] respondent State, whereby Ext.P3 application dated 20.08.2019 made by the petitioner for issuance of noobjection certificate for starting B.Pharm course in that college, during the academic year 2020-21, stands rejected, for the reasons stated therein. The petitioner has also sought for a writ of mandamus commanding the 1[st] respondent State to consider and dispose of Ext.P8 application dated 03.12.2020 made by the petitioner seeking no-objection certificate for starting B.Pharm course in its college, during the academic year 2021-22, within a time limit to be fixed by this Court; and a declaration that the petitioner's college is eligible to get no-objection certificate from the 1[st] respondent State, for starting B.Pharm course, during the W.P.(C)No.28062 of 2020 3 ## academic year 2021-22. 2. On 16.12.2020, when this writ petition came up for admission, the learned Government Pleader sought time to get instructions. 3. A statement dated 15.01.2021 has been filed on behalf of the 1[st] respondent State, opposing the reliefs sought for in this writ petition. The petitioner has filed a reply affidavit dated 20.01.2021. 4. Heard the learned counsel for the petitioner, the learned Special Government Pleader for respondents 1 and 3 and also the learned Assistant Solicitor General of India appearing for the 4[th] respondent. 5. The issue that arises for consideration in this writ petition is as to whether any interference is warranted on Ext.P7 order dated 14.03.2020 of the 1[st] respondent State, whereby Ext.P3 application made by the petitioner for grant of no-objection certificate for starting B.Pharm course in its college, during the academic year 2020-21, stands rejected. 6. Section 12 of the Pharmacy Act, 1948 deals with approved courses of study and examinations. As per sub-section (1) of Section 12, any authority in a State which conducts a course W.P.(C)No.28062 of 2020 4 of study for pharmacists may apply to the Central Council for approval of the course, and the Central Council, if satisfied, after such enquiry as it thinks fit to make, that the said course of study is in conformity with the Education Regulations, shall declare the said course of study to be an approved course of study for the purpose of admission to an approved examination for pharmacists. 7. In exercise of the powers conferred by Sections 10 and 18 of the Pharmacy Act, 1948, the Pharmacy Council of India, with the approval of the Central Government made the Bachelor of Pharmacy (B.Pharm) Course Regulations, 2014. As per Regulation 3, the duration of B.Pharm course shall be four academic years (annual/semester) full time with each academic year spread over a period of not less than two hundred working days for annual pattern and hundred working days for each semester. As per subregulation (1) of Regulation 9, no person, institution, society, trust or university shall start and conduct B.Pharm programme without the prior approval of the Pharmacy Council of India. 8. As per sub-regulation (2) of Regulation 9 of the Course Regulations, 2014, any person or pharmacy college for the purpose of obtaining permission under sub-section (1) of section 12 of the W.P.(C)No.28062 of 2020 5 Pharmacy Act, shall submit a scheme as may be prescribed by the Pharmacy Council of India. As per clause (3) of Regulation 9, the scheme referred to in sub-regulation (2) above, shall be in such form and contain such particulars and be preferred in such manner and be accompanied with such fee as may be prescribed. As per the proviso to Regulation 9, the Pharmacy Council of India shall not approve any institution under these regulations unless it provides adequate arrangements for teaching in regard to building, accommodation, labs, equipment, teaching staff, non-teaching staff, etc., as specified in Appendix A to these regulations. 9. Appendix A of the Course Regulations, 2014 deals with conditions to be fulfilled by the academic training institution. As per para. (1) of Appendix A, any authority or institution in India applying to the Pharmacy Council of India for approval of courses of study for B.Pharm under sub-section (1) of section 12 of the Pharmacy Act shall comply with the infrastructural facilities as prescribed by the Pharmacy Council of India from time to time. As per para. (2), B.Pharm programme shall be conducted only in those institutions which are approved by the Pharmacy Council of India for B.Pharm course, as provided under Section 12 of the Pharmacy W.P.(C)No.28062 of 2020 6 Act. Para. (3) of Appendix A deals with teaching staff requirement; para. (4) deals with non-teaching staff; para. (5) deals with accommodation; and para. (6) deals with equipment and apparatus. 10. The petitioner submitted Ext.P3 application dated 20.08.2019 before the 1[st] respondent State for grant of noobjection certificate for starting B.Pharm course in its college, during the academic year 2020-21. Ext.P3 application stands rejected by Ext.P7 order dated 14.03.2020 of the 1[st] respondent State. Paragraphs 2 and 3 of that order read thus; “2. The present scenario in respect of the B.Pharm courses in the State of Kerala is that there are 48 institutions which are conducting Degree Course in Pharmacy. After an analysis of the situation that prevail in the State with respect to the employment opportunity of Degree Holders in Pharmacy as also the employability of those candidates who pass out B.Pharm from Self Financing Institutions are concerned, it was reported by the Director of Medical Education that there are serious issues with unemployment of Degree Holders in Pharmacy and also by the proliferation of Pharmacy Colleges/Institutions, unhealthy competition exists and the standards of education is depleting and the quality of the students who pass out from such Self Financing Institutions is alarming. Based on the study conducted, the Director of Medical Education had reported to the Government that there W.P.(C)No.28062 of 2020 7 is no need to sanction new Pharmacy institution imparting Bachelor of Pharmacy Course in Self Financing Sector in the State as there is no demand for such qualified hand in the State and that the present sanctioned strength will satisfy the requirement. It could be most inappropriate to start new institutions for imparting Pharmacy Courses without assessing the educational need in the State. 3. Government have examined the matter in detail and in the light of the above facts, the request for NOC for starting the new B.Pharm college in the existing self financing diploma level Sree Narayana Guru Memorial Pharmacy College is hereby rejected.” 11. Though Ext.P7 order of the 1[st] respondent State is one dated 14.03.2020, the petitioner has chosen to file this writ petition only on 15.12.2020, challenging the rejection of Ext.P3 application made for grant of no-objection certificate for starting B.Pharm course in its college, during the academic year 2020-21. In the writ petition, the petitioner has not offered any explanation whatsoever for the delay of nearly nine months in challenging Ext.P7 order of the 1[st] respondent State. 12. Vide letter No.14-56/2019-PCI (Moratorium)/3720-3826 dated 17.07.2019, the Pharmacy Council of India put a moratorium on the opening of new pharmacy colleges for running D.Pharm as well as B.Pharm courses for a period of five years beginning from 8 W.P.(C)No.28062 of 2020 the academic year 2020-21. Such a resolution was taken unanimously, in the 106[th] meeting of the Central Council held on 9[th] & 10[th] April, 2019 taking into consideration the availability of sufficient qualified pharmacist workforce in the country. The moratorium shall not be applicable in the North Eastern region of the country where there is shortage of pharmacy colleges. The Central Council in its 106[th] meeting noted that there are approximately 1,985 D.Pharm and 1,439 B.Pharm institutions in the country. The annual intake of students in these institutions (both D.Pharm and B.Pharm) is 2,19,279. This available workforce is enough to meet the current pharmacists-to-population needs of the country. 13. By Ext.P1 communication dated 09.09.2019 of the Pharmacy Council of India, all State Governments and Union Territories were informed that, in the 107[th] meeting of the Central Council held on 5[th] & 6[th] August, 2019 it was unanimously decided that moratorium on the opening of new pharmacy colleges for running Diploma as well as Degree courses in pharmacy for a period of five years beginning from the academic year 2020-2021 will be subject to the following conditions; W.P.(C)No.28062 of 2020 9 (a) The moratorium will not apply to the Government institutions; (b) The moratorium will not apply to the institutions in North Eastern region; (c) The moratorium will not apply to the States/Union Territories where the number of D.Pharm and B.Pharm institutions (both combined) is less than 50; (d) The institutions which had applied for opening D.Pharm and/or B.Pharm colleges for 2019-20 academic session either to the Pharmacy Council of India or to the All India Council for Technical Education and the proposal was rejected or not inspected due to some reason or the other will he allowed lo apply for 2020-21 academic session and this relaxation is given only for one year, i.e., for 2020-21 academic session only; (e) Existing approved pharmacy institutions will be allowed to apply for increase in intake capacity as per the Pharmacy Council of India norms and/or to start additional pharmacy course(s). ## 14. In **Sayali Charitable Trust's College of Pharmacy v.** ## **Pharmacy Council of India [2020 SCC OnLine Bom. 2564]** one of the contentions raised before a Division Bench of the Bombay High Court was that, the Pharmacy Council of India has taken a policy decision on 19.07.2019, to grant moratorium of five years for opening new pharmacy institutes in the country considering the market forces, the distribution of colleges across W.P.(C)No.28062 of 2020 10 the nation, the requirement of Pharmacy workforce, the availability of qualified teaching faculties, pharmacists, and the population ratio. The data placed on record of state wise distribution of doctors and pharmacists vis-a-vis the Indian Population, which is extracted in paragraph 16 of the said decision is reproduced hereunder; |Sl.<br>No.|State<br>Andhra<br>Pradesh<br>Arunachal<br>pradesh<br>Assam<br>Bihar<br>Chattisgarh<br>Delhi<br>Goa<br>Gujrat<br>Haryana<br>Himachal<br>Pradesh<br>J&K<br>Jharkhand<br>Karnataka<br>Madhya<br>Pradesh<br>Maharashtra<br>MCI<br>Nagaland<br>Odisha<br>Punjab<br>Rajasthan<br>Sikkim<br>Tamil Nadu|Population<br>in Lakhs<br>894<br>16.01<br>344.9<br>1089.2<br>288<br>186<br>15.09<br>671<br>279.6<br>76.28<br>142<br>377<br>671.5<br>788.1<br>1206.8<br>31.2<br>453.4<br>299.2<br>748.8<br>6.43<br>797.8|No. of<br>Doctors<br>registered<br>(2017)<br>86129<br>840<br>22532<br>40043<br>6915<br>16176<br>3367<br>53954<br>5717<br>2849<br>14326<br>5093<br>104794<br>34347<br>153513<br>52666<br>801<br>21681<br>44682<br>40559<br>893<br>126399|Doctor per<br>1000<br>population|No. of<br>pharmacist<br>registered<br>(2017)<br>115754|Pharmacis<br>t per 1000<br>population<br>1.3|No. of<br>pharmacist<br>per doctor<br>1.34| |---|---|---|---|---|---|---|---| |1.||||0.96|||| |2.||||0.525|279|0.17|0.332| ||||||||| |3.||||0.65|3668|0.10|0.162| |4.||||0.36|4163|0.04|0.1039| |5.||||0.24|9713|0.33|1.40| |6.||||0.87|32075|1.72|1.98| |7.||||2.24|566|0.37|0.154| |8.||||0.80|119445|1.78|2.213| |9.||||0.20|31663|1.13|5.53| |10.||||0.38|3852|0.50|1.35| ||||||||| |11.||||1.00|||| |12.||||0.135|2337|0.061|0.45| |13.||||1.56|52162|0.77|0.497| |14.||||0.435|NA||| |||||1.27|203089|1.68|1.32| |15.|||||||| |16.|||||||| |17.||||0.25|1553|0.73|1.938| |18.||||0.48|17665|0.39|0.814| |19.||||1.5|44616|1.49|0.998| |20.||||0.54|38156|0.51|0.94| |21.||||1.48|NA|0.73|0.46| |22.||||1.58|58466||| W.P.(C)No.28062 of 2020 11 |**23.**|**Kerala**<br>Uttar<br>Pradesh<br>Uttrakhand<br>West Bengal<br>Telengana<br>Meghalaya<br>Mizoram<br>Tripura<br>Daman &Diu<br>Puducherry||**369.6**|**55251**<br>71480|**1.50**|**35382**|**0.95**|**0.64**| |---|---|---|---|---|---|---|---|---| |24.|||2192.4||0.33|30276|0.14|0.42| |||||||||| |25.|||103.2|7060<br>66974<br>2354|0.68|2643|0.25|0.375| |26.|||954||0.70|89630|0.93|1.33| |27.|||391.2||0.06|NA|0.40|| |28.|||34.7|||1370||| |29.|||15.1|||1313|0.87|| |30.|||44.2|||4747|1.07|| |31.|||3|||52|0.17|| |32.|||7.45|||2493|3.34|| (Data source list of doctors registered with State MCI's and list of Pharmacists registered with State PCI's page 217 and 225 from National Health Profile 2018 published by MOH&FW, GOI. States where no data is provided in the report have been left blank for uniformity) 15. In Ext.P7 order of the 1[st] respondent State, it is stated that at present there are 48 institutions in the State of Kerala conducting B.Pharm course. After an analysis of the situation that prevails in the State with respect to the employment opportunity of B.Pharm holders as also their employability, the 2[nd] respondent Director of Medical Education reported that there are serious issues with regard to unemployment of B.Pharm holders. There is unhealthy competition and proliferation of pharmacy colleges/institutions. The standards of education is depleting and the quality of the students who pass out from Self-Financing Institutions is alarming. Based on the study conducted, the 2[nd] W.P.(C)No.28062 of 2020 12 respondent reported to the Government that there is no need to sanction new Pharmacy institutions imparting Bachelor of Pharmacy course in Self-Financing Sector in the State as there is no demand for such qualified hands in the State and that, the present sanctioned strength will satisfy the requirement and that, it could be most inappropriate to start new institutions for imparting pharmacy courses without assessing the educational need in the State. 16. As per the list of approved institutions available in the official web site of the Pharmacy Council of India there are 39 institutions in State of Kerala conducting D.Pharm course, out of which 5 institutions were granted approval for starting D.Pharm course during the academic year 2020-21. In the reply affidavit filed by the petitioner it is pointed out that several institutions were granted no-objection certificate by the 1[st] respondent State during the academic year 2019-20 and 2020-21 for starting B.Pharm course. In the statement filed on behalf of the 1[st] respondent State it is pointed out that, as per Ext.P1, the institutions which had applied for opening D.Pharm and/or B.Pharm colleges for the academic session 2019-20 and where the proposal was rejected or W.P.(C)No.28062 of 2020 13 not inspected due to some reasons or the other, they will be allowed to apply for 2020-21 academic session. It is not discernible from the pleadings and materials on record as to whether the institutions which were granted approval for starting B.Pharm course during the academic year 2020-21 falls under that category. 17. The 2[nd] respondent Kerala University of Health Sciences issued Ext.P2 notification dated 27.08.2020 inviting application for starting new colleges/additional courses/enhancement of seats for the academic year 2021-22. As per Ext.P2, applications are invited for starting additional courses/enhancement of seats in UG/PG courses in the existing affiliated pharmacy institutions; and for starting new degree courses in Government institutions/institutions having the approval of Pharmacy Council of India for starting UG courses. Though Ext.P2 notification issued by the 2[nd] respondent University is one dated 27.08.2020, the petitioner has chosen to submit Ext.P8 representation before the 1[st] respondent State, only on 03.12.2020, seeking no-objection certificate for starting B.Pharm course in its college, during the academic year 2021-22. 18. As already noticed, in the 106[th] meeting of the Central Council held on 9[th] & 10[th] April, 2019 a resolution was taken W.P.(C)No.28062 of 2020 14 unanimously to put a moratorium on the opening of new pharmacy colleges for running D.Pharm as well as B.Pharm courses for a period of five years, beginning from the academic year 2020-21, taking into consideration the availability of sufficient qualified pharmacist workforce in the country, which is enough to meet the current pharmacists-to-population needs. Later, by Ext.P1 communication dated 09.09.2019 of the Pharmacy Council of India, which is issued based on the decision taken in the 107[th] meeting of the Central Council held on 5[th] & 6[th] August, 2019, all State Governments and Union Territories were informed that the moratorium for a period of five years beginning from the academic year 2020-2021 will be subject to certain conditions. As per Ext.P1, the moratorium will not apply to the States/Union Territories where the number of D.Pharm and B.Pharm institutions (both combined) is less than 50. The existing approved pharmacy institutions will be allowed to apply for increase in intake capacity as per the Pharmacy Council of India norms and/or to start additional pharmacy course(s). 19. Along with the reply affidavit filed by the petitioner, Exts.P9 and P10 documents, which are relevant extracts of two W.P.(C)No.28062 of 2020 15 articles published in respect of job opportunities for pharmacy students are placed on record, in order to point out that there will be a huge demand for pharmacists even during post COVID period. 20. As already noticed hereinbefore there are 48 institutions in the State of Kerala conducting B.Pharm course with the affiliation of the 2[nd] respondent Kerala University of Health Sciences and there are 39 institutions conducting D.Pharm course with the affiliation of the 3[rd] respondent Director of Medical Education. In view of the Course Regulations of the Pharmacy Council of India, an academic training institution conducting B.Pharm course or D.Pharm course is required to fulfil the conditions regarding the requirement of teaching staff, in addition to the requirement as to infrastructure. Therefore, before granting approval by the Pharmacy Council of India/consent of affiliation by the 2[nd] respondent University or the 3[rd] respondent Director of Medical Education for B.Pharm or D.Pharm course, the availability of qualified faculties, sufficient in number, for imparting education in such institutions will have to be ensured, failing which such institutions will produce half-baked pharmacists, which in turn, would adversely affect the health of the general public. W.P.(C)No.28062 of 2020 16 21. The no-objection certificate/essentiality certificate of the 1[st] respondent State is a mandatory document, which has to be submitted by an institution seeking approval/affiliation for conducting B.Pharm or D.Pharm course. Consideration of the request for no-objection certificate/essentiality certificate by the 1[st] respondent State should be in a fair manner and the procedure that has to be adopted should be one in conformity with the principles of natural justice. The materials or data collected by the 1[st] respondent State, through the 3[rd] respondent Director of Medical Education, should be made available to the applicant, who should be given an opportunity of being heard and the decision taken by the 1[st] respondent State should reflect application of mind to the relevant aspects. 22. As already noticed hereinbefore, though Ext.P7 order of the 1[st] respondent is one dated 14.03.2020, whereby Ext.P3 application made by the petitioner for issuance of no-objection certificate for starting B.Pharm course in its college, during the academic year 2020-21 stands rejected, the petitioner has chosen to file this writ petition challenging the said order only on 15.12.2020. At this distance of time, no interference is warranted W.P.(C)No.28062 of 2020 17 on Ext.P7 order, since Ext.P3 application is for the academic year 2020-21. 23. By Ext.P1 communication dated 09.09.2019, the Pharmacy Council of India has resolved that the moratorium on the opening of new pharmacy colleges for running Diploma as well as Degree courses in pharmacy for a period of 5 years beginning from the academic year 2020-21 will be subject to certain conditions stipulated therein. The 1[st] respondent State has to consider Ext.P8 application made by the petitioner seeking no-objection certificate for starting B.Pharm course, for the academic year 2021-22, by considering the entire issue afresh, taking note of the conditions stipulated in Ext.P1 and also the observations contained in this judgment. Any materials or data collected through the 3[rd] respondent Director of Medical Education on the request made by the petitioner for no-objection certificate shall be made available to the petitioner and the petitioner shall be permitted to submit written submission raising appropriate legal and factual contentions, which shall be adverted to by the 1[st] respondent State while taking a decision on Ext.P8 application. Therefore, this writ petition is disposed of by directing the 1[st] W.P.(C)No.28062 of 2020 18 respondent State to undertake the exercise of consideration of Ext.P8 application made by the petitioner, as directed above, and pass a reasoned order, as expeditiously as possible, at any rate, within a period of three weeks from the date of receipt of a certified copy of this judgment. Sd/- **ANIL K. NARENDRAN JUDGE** **yd** W.P.(C)No.28062 of 2020 19 ## **APPENDIX** ## **PETITIONER'S EXHIBITS:** **EXHIBIT P1 TRUE COPY OF THE ORDER DATED NIL ISSUED BY THE PHARMACY COUNCIL OF INDIA TO ALL THE STATE GOVERNMENTS AND UNION TERRITORIES EXHIBIT P2 TRUE COPY OF THE NOTIFICATION,DATED 27.08.2020 BEARING NO.25494/ACI/GEN A2/2020/KUHS,ISSUED BY THE 2ND RESPONDENT EXHIBIT P3 TRUE COPY OF THE APPLICATION NO.ACAD/02/BP-107/08/19,DATED 20.08.2019 SUBMITTED BY THE PETITIONER TO THE 1ST RESPONDENT FOR GETTING THE NOC FROM THE GOVERNMENT OF KEALA FOR STARTING THE NEW B.PHARM DEGREE COURSE FOR THE ACADEMIC YEAR 2020-2021,IN THE PETITIONER'S COLLEGE EXHIBIT P4 TRUE C0PY OF THE ACKNOWLEDGMENT RECEIPT DATED 25.11.2020 ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER VIA E-MAIL EXHIBIT P5 TRUE COPY OF THE ORDER ISSUED BY THE 4TH RESPONDENT DATED 11.03.2020 EXHIBIT P6 TRUE COPY OF THE JUDGMENT IN WP(C)NO.31050/2018 AND CONNECTED CASES DATED 04.09.2019 EXHIBIT P7 TRUE COPY OF THE ORDER DATED 14.03.2020 ISSUED BY THE 1ST RESPONDENT TO THE PETITIONER BEARING NO.G.O(RT)NO.574/2020/H&FWD EXHIBIT P8 TRUE COPY OF THE APPLICATION SUBMITTED BY THE PETITIONER TO THE 1ST RESPONDENT FOR GETTING NOC FOR STARTING B.PHARM DEGREE COURSE FOR THE ACADEMIC YEAR 2021-2022. EXHIBIT P9 TRUE COPY OF THE RELEVANT PAGES OF AN ARTICLE PUBLISHED IN RESPECT OF JOB OPPORTUNITIES FOR PHARMACY STUDENTS.** W.P.(C)No.28062 of 2020 20 **EXHIBIT P10 TRUE COPY OF RELEVANT PAGE OF AN ARTICLE PUBLISHED BY ONE MIKE HENNESSEY IN RESPECT OF JOB OPPORTUNITIES FOR PHARMACY STUDENTS.** ## **RESPONDENTS' EXHIBITS:NIL** **TRUE COPY** **P.A. TO JUDGE**