WPC 443/23 & connected cases

1 WPC 443/23 & cnnctd cases ## **`IN THE HIGH COURT OF KERALA AT ERNAKULAM`** ## **`PRESENT`** ## **`THE HONOURABLE MR.JUSTICE BASANT BALAJI`** ``` WEDNESDAY, THE 21[ST] DAY OF FEBRUARY 2024 / 2ND PHALGUNA, 1945 ``` ## **`WP(C) NO. 443 OF 2023`** ## **`PETITIONER/S:`** ``` SUDHEESH M., AGED 34 YEARS ALINKAL HOUSE, DAILY WAGE WORKER, FL-01-9022 CHERUPULASSERY, PALAKKAD, PIN - 679503 ``` ``` BY ADVS. DEEPU THANKAN UMMUL FIDA LAKSHMI SREEDHAR LEKSHMI P. NAIR NAMITHA K.M. ``` ## **`RESPONDENT/S:`** ``` 1KERALA STATE BEVERAGES (M & M) CORPORATION LTD., BEVCO TOWER, VIKASBHAVAN, PALAYAM, THIRUVANANTHAPURAM - 695 033 REP. BY ITS MANAGING DIRECTOR., PIN - 695033 ``` ``` 2KERALA ABKARI WORKERS WELFARE FUND BOARD THIRUVANANTHAPURAM - REP. BY ITS CHIEF WELFARE FUND INSPECTOR., PIN - 695001 BY ADVS. SRI.NAVEEN.T., SC, KERALA STATE BEV.CO. M. AND M. SRI.S.KRISHNA MOORTHY, SC, KAWWFB ``` ``` THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 21.02.2024, ALONG WITH WP(C).1096/2023, 638/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ``` 2 WPC 443/23 & cnnctd cases ``` IN THE HIGH COURT OF KERALA AT ERNAKULAM ``` ## **`PRESENT`** ``` THE HONOURABLE MR.JUSTICE BASANT BALAJI WEDNESDAY, THE 21[ST] DAY OF FEBRUARY 2024 / 2ND PHALGUNA, 1945 WP(C) NO. 1096OF 2023 ``` ## **`PETITIONER/S:`** ``` SMITHA P.P. AGED 46 YEARS DAILY WAGE ABKARI WORKER, FL-01 11019 PERAMBRA, KERALA STATE BEVERAGES (M & M) CORPORATION LTD. KOZHIKODE, RESIDING AT PULIYULLAPARAMBIL VEEDU NOCHADU P.O., NADUVANNUUR, KOZHIKODE, PIN - 673016 BY ADVS. DEEPU THANKAN UMMUL FIDA LAKSHMI SREEDHAR LEKSHMI P. NAIR NAMITHA K.M. ``` ## **`RESPONDENT/S:`** ``` 1KERALA STATE BEVERAGES (M & M) CORPORATION LTD. BEVCO TOWER, VIKASBHAVAN, PALAYAM, THIRUVANANTHAPURAM - REP. BY ITS MANAGING DIRECTOR, PIN - 695033 2KERALA ABKARI WORKERS WELFARE FUND BOARD KERALA ABKARI WORKERS WELFARE FUND BOARD THIRUVANANTHAPURAM - 695 001 REP. BY ITS CHIEF WELFARE FUND INSPECTOR, PIN - 695001 BY ADVS. NAVEEN.T NAVEEN T ``` ``` THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 21.02.2024, ALONG WITH WP(C).443/2023 AND CONNECTED CASES AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ``` 3 WPC 443/23 & cnnctd cases ``` IN THE HIGH COURT OF KERALA AT ERNAKULAM ``` ``` PRESENT ``` ``` THE HONOURABLE MR.JUSTICE BASANT BALAJI ``` ``` WEDNESDAY, THE 21[ST] DAY OF FEBRUARY 2024 / 2ND PHALGUNA, 1945 ``` ``` WP(C) NO.638OF 2023 ``` ## **`PETITIONER/S:`** ``` SARATH K. AGED 35 YEARS DAILY WAGE ABKARI WORKER, FL-01-14010 VELLARIKUNDU, KERALA STATE BEVERAGES (M & M) CORPORATION LTD., KASARAGOD DISTRICT -671533., PIN - 671533 BY ADVS. DEEPU THANKAN UMMUL FIDA LAKSHMI SREEDHAR LEKSHMI P. NAIR NAMITHA K.M. ``` ## **`RESPONDENT/S:`** ``` 1KERALA STATE BEVERAGES (M & M) CORPORATION LTD. BEVCO TOWER, VIKASBHAVAN, PALAYAM, THIRUVANANTHAPURAM - 695 033 REP. BY ITS MANAGING DIRECTOR., PIN - 695033 2KERALA ABKARI WORKERS WELFARE FUND BOARD THIRUVANANTHAPURAM - 695 001 REP. BY ITS CHIEF WELFARE FUND INSPECTOR., PIN - 695001 BY ADVS. NAVEEN.T S.KRISHNAMOORTHY NAVEEN T ``` ``` THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 21.02.2024, ALONG WITH WP(C).443/2023 AND CONNECTED CASES AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ``` 4 WPC 443/23 & cnnctd cases ``` IN THE HIGH COURT OF KERALA AT ERNAKULAM ``` ## **`PRESENT`** ``` THE HONOURABLE MR.JUSTICE BASANT BALAJI ``` ``` WEDNESDAY, THE 21[ST] DAY OF FEBRUARY 2024 / 2ND PHALGUNA, 1945 ``` **==> picture [167 x 10] intentionally omitted <==** ## **`PETITIONER/S:`** ``` SRIBILESH.B AGED 33 YEARS DAILY WAGES WORKER FL-01- 9031 MENONPARA, PALAKKAD, PIN - 678721 ``` ``` BY ADVS. DEEPU THANKAN UMMUL FIDA LAKSHMI SREEDHAR LEKSHMI P. NAIR NAMITHA K.M. ``` ## **`RESPONDENT/S:`** ``` 1KERALA STATE BEVERAGES (M & M) CORPORATION LTD 1. KERALA STATE BEVERAGES (M & M) CORPORATION LTD., BEVCO TOWER, VIKASBHAVAN, PALAYAM, THIRUVANANTHAPURAM REP. BY ITS MANAGING DIRECTOR, PIN - 695033 ``` ``` 2KERALA ABKARI WORKERS WELFARE FUND BOARD THIRUVANANTHAPURAM REP. BY ITS CHIEF WELFARE FUND INSPECTOR, PIN - 695001 BY ADV SRI.NAVEEN.T., SC, KERALA STATE BEV.CO. M. AND M. ``` ``` THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 21.02.2024, ALONG WITH WP(C).443/2023 AND CONNECTED CASES AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ``` 5 WPC 443/23 & cnnctd cases ``` IN THE HIGH COURT OF KERALA AT ERNAKULAM ``` ## **`PRESENT`** ## **`THE HONOURABLE MR.JUSTICE BASANT BALAJI`** ``` WEDNESDAY, THE 21[ST] DAY OF FEBRUARY 2024 / 2ND PHALGUNA, 1945 ``` ``` WP(C) NO.555OF 2023 ``` ## **`PETITIONER/S:`** ``` PRASEEN P. AGED 32 YEARS DAILY WAGE WORKER, FL-01- 9031 MENONPARA, PALAKKAD - 678721, PIN - 678721 ``` ``` BY ADVS. DEEPU THANKAN LEKSHMI P. NAIR NAMITHA K.M. UMMUL FIDA LAKSHMI SREEDHAR ``` ## **`RESPONDENT/S:`** ``` 1KERALA STATE BEVERAGES (M & M) CORPORATION LTD. BEVCO TOWER, VIKASBHAVAN, PALAYAM, THIRUVANANTHAPURAM - 695 033 REP. BY ITS MANAGING DIRECTOR, PIN - 695033 ``` ``` 2KERALA ABKARI WORKERS WELFARE FUND BOARD THIRUVANANTHAPURAM - 695 001 REP. BY ITS CHIEF WELFARE FUND INSPECTOR, PIN - 695001 ``` ``` BY ADVS. NAVEEN.T S.KRISHNAMOORTHY NAVEEN T ``` ``` THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 21.02.2024, ALONG WITH WP(C).443/2023 AND CONNECTED CASES AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ``` 6 WPC 443/23 & cnnctd cases ``` IN THE HIGH COURT OF KERALA AT ERNAKULAM ``` ``` PRESENT ``` ``` THE HONOURABLE MR.JUSTICE BASANT BALAJI ``` ``` WEDNESDAY, THE 21[ST] DAY OF FEBRUARY 2024 / 2ND PHALGUNA, 1945 ``` ``` WP(C) NO.375OF 2023 ``` ## **`PETITIONER/S:`** ``` RANJITH V.R., AGED 28 YEARS DAILY WAGE WORKER, FL- 01-9028 THENKURISSI, PALAKKAD -678671, PIN - 678671 ``` ``` BY ADVS. DEEPU THANKAN UMMUL FIDA LAKSHMI SREEDHAR LEKSHMI P. NAIR NAMITHA K.M. ``` ## **`RESPONDENT/S:`** ``` 1KERALA STATE BEVERAGES (M & M) CORPORATION LTD., 1. BEVCO TOWER, VIKASBHAVAN, PALAYAM, THIRUVANANTHAPURAM - 695 033 REP. BY ITS MANAGING DIRECTOR, PIN - 695033 ``` ``` 2KERALA ABKARI WORKERS WELFARE FUND BOARD 2. THIRUVANANTHAPURAM - 695 001 REP. BY ITS CHIEF WELFARE FUND INSPECTOR., PIN - 695001 BY ADVS. SRI.NAVEEN.T., SC, KERALA STATE BEV.CO. M. AND M. SRI.S.KRISHNA MOORTHY, SC, KAWWFB ``` ``` THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 21.02.2024, ALONG WITH WP(C).443/2023 AND CONNECTED CASES AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ``` 7 WPC 443/23 & cnnctd cases ## **JUDGMENT** (Dated this the 21[st] day of February 2024) [WP(C) Nos.443/2023, 1096/2023, 638/2023, 22488/2023, 555/2023 and 375/2023] The common question arises in all these Writ Petitions is as to whether the petitioners are entitled to the same scale of pay as granted to all the employees working in the same category under the 1[st] respondent Corporation. Therefore, all these Writ Petitions are heard together and a common judgment is passed. 2. The petitioners are working as daily wage abkari workers under the 1[st] respondent Corporation. They joined in service as per orders of the Government under the rehabilitation of the perished abkari workers. The petitioners have joined the Kerala Abkari Workers Welfare Fund Scheme and they have been issued with membership also. According to the petitioners, they are treated differently by the 1[st] respondent, 8 WPC 443/23 & cnnctd cases and they are given wages not on par with the workers who are working there. There are 3 categories of abkari workers in the corporation, namely (i) the employees whoever are working in the retail shop at the time of taking over of sale of foreign liquor by the 2nd respondent corporation, (ii) dependent sons of arrack workers who committed suicide on losing employment due to ban of arrack and (iii) abkari workers who are directly appointed by the Kerala State Beverages Corporation (Corporation). 3. The grievance of the petitioners is that all the above 3 categories of persons are given a scale of pay, but as far as the petitioners are concerned, it is denied that they are given a daily wage rate of Rs.675/- per day only. The duties discharged by the petitioners and other abkari workers are one and the same and therefore, they are entitled to equal pay for equal work. As per Ext.P4 order dated 24.2.2011, persons who were appointed 9 WPC 443/23 & cnnctd cases as per 2[nd] and 3[rd] methods above were granted a scale of pay on par with those who were appointed as per the 1[st] method. Thus, all the persons who have been absorbed in service by the above 3 methods have been granted the same scale of pay. But the petitioners alone are discriminated. 4. The Corporation has tried to categorise the petitioners in all these Writ Petitions in a different category i.e., persons who were minors at the time of the death of the abkari worker in their family and who could not apply before their attaining the age of 18 years. It is seen that all these petitioners, after attaining the age of majority, have applied within a reasonable time, and they were given appointments pursuant to the orders passed by the Government and accepted by the Corporation. 5. A counter affidavit is filed W.P.(C) Nos.638, 555, 375 and 1096 of 2023 and an adoption memo is filed in W.P.(C) Nos.638, 555 and 375 of 2023. The case raised by the 10 WPC 443/23 & cnnctd cases respondents is that the Government has issued orders making daily wage appointment of dependent sons of arrack workers as a one time measure. This court has disposed the Writ Petitions filed by abkari workers, who died prior to 7.8.2004 and who were minors at the time when the applications were invited. It is pursuant to the directions, that the Government considered the issue and directed to provide daily wages to the petitioners and fixed at Rs.675/- per day. The Government had ordered a grant of scale of pay and another service benefit to the 3 categories of Abkari workers. The petitioners were appointed as daily wage employees pursuant to the Government order. Since they were given appointments on daily wage, they cannot now claim the other service benefits. Though they are doing the same work they are treated as separate classes and appointed on daily wages alone. Therefore, they cannot seek parity in the scheme with the other regular workers. They are not recognized by any other Government 11 WPC 443/23 & cnnctd cases Order, and therefore, they are not entitled to any relief from this court. 6. The first respondent has accepted them as abkari workers and allowed to join as abkari workers in the Welfare Fund Scheme. The respondents cannot deny the equal pay which was granted to the other 3 categories of abkari workers. The apex court in **State of Punjab v. Jagjit Singh [2017 (1) SCC 148** ], held as follows: “Having traversed the legal parameters with reference to the application of the principle of 'equal pay for equal work'. in relation to temporary employees (daily-wage employees and the like), the sole factor that requires our determination is, whether the concerned employees (before this Court), were rendering similar duties and responsibilities, as were being discharged by regular employees, holding the same/corresponding posts. This exercise would require the application of the parameters of the principle of 'equal pay for equal work' summarized by us. However, insofar as the instant aspect of the matter is concerned, it is not difficult for us to record the factual position. We say so, because it was fairly acknowledged by the learned counsel representing the State of Punjab, that all the temporary employees in the present bunch of appeals, were appointed against posts which were also available in the regular cadre/establishment. It was 12 WPC 443/23 & cnnctd cases also accepted, that during the course of their employment, the concerned temporary employees were being randomly deputed to discharge duties and responsibilities, which at some point in time, were assigned to regular employees. Likewise, regular employees holding substantive posts, were also posted to discharge the same work, which was assigned to temporary employees, from time to time. There is, therefore, no room for any doubt, that the duties and responsibilities discharged by the temporary employees in the present set of appeals, were the same as were being discharged by regular employees. It is not the case of the appellants, that the respondent-employees did not possess the qualifications prescribed for appointment on regular basis. Furthermore, it is not the case of the State, that any of the temporary employees would not be entitled to pay parity, on any of the principles summarized by us. There can be no doubt, that the principle of 'equal pay for equal work' would be applicable to all the concerned temporary employees, so as to vest in them the right to claim wages, at par with the minimum of the pay-scale of regularly engaged Government employees, holding the same post." 7. It is a fact that the petitioners are all members of the Abkari Workers Welfare Fund Board and they will fall into the definition of “Abkari Worker” as defined under Section 2(a) of the Abkari Workers Welfare Fund Act, 1989. Therefore, they fall into one homogenous group. In such scenarios, there 13 WPC 443/23 & cnnctd cases cannot be any difference in pay in respect of members of one group. 8. In the light of above judgment of the apex court, there cannot be any distinction between the petitioners and abkari workers, who were given appointments in the 3 other categories mentioned above. Therefore, the petitioners are entitled to the same scale of pay as applicable to the other categories of workers referred to in Ext.P4. It is made clear that they will be entitled to the benefit only with effect from the date of enrolment in Abkari Workers Welfare Fund Board. The Writ Petitions are disposed of. Sd/- ## **BASANT BALAJI, JUDGE** dl/ 14 WPC 443/23 & cnnctd cases ## **`APPENDIX OF WP(C) 1096/2023`** ``` PETITIONER EXHIBITS ``` ``` Exhibit P-1A TRUE COPY OF THE ORDER OF THE GOVERNMENT DATED 20/11/2021 ``` ``` Exhibit P-2A TRUE COPY OF THE PROCEEDINGS OF THE MANAGING DIRECTOR OF THE FIRST RESPONDENT CORPORATION DATED 25/11/2021 ``` ``` Exhibit P-3A TRUE COPY OF THE IDENTITY CARD ISSUED BY THE SECOND RESPONDENT ``` ``` Exhibit P-4A TRUE COPY OF THE GOVERNMENT ORDER DATED 24/2/2011 ``` ``` Exhibit P-5A TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT DATED 08/02/2017 IN W.P.(C) NO. 38766/2016 ``` ``` Exhibit P-6A TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT IN W.A.NO. 1922 OF 2017 DATED 10/11/2017 Exhibit P-7A TRUE COPY OF THE ORDER DATED 04/04/2019 ``` ``` Exhibit P-8A TRUE COPY OF THE ORDER OF THE FIRST RESPONDENT DATED 17/11/2022 ``` 15 WPC 443/23 & cnnctd cases ## **`APPENDIX OF WP(C) 638/2023`** ``` PETITIONER EXHIBITS ``` ``` Exhibit P-1. A TRUE COPY OF THE ORDER OF THE GOVERNMENT DATED 13/11/2021 IS PRODUCED HEREWITH AND MARKED AS EXHIBIT P-1. ``` ``` Exhibit P-2A TRUE COPY OF THE PROCEEDINGS OF THE MANAGING DIRECTOR OF THE FIRST RESPONDENT CORPORATION DATED 24/11/2021 ``` ``` Exhibit P-3A TRUE COPY OF THE IDENTITY CARD ISSUED BY THE SECOND RESPONDENT ``` ``` Exhibit P-4A TRUE COPY OF THE GOVERNMENT ORDER DATED 24/2/2011 ``` ``` Exhibit P-5A TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT DATED 08/02/2017 IN W.P.(C) NO. 38766/2016 ``` ``` Exhibit P-6A TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT IN W.A. NO. 1922 OF 2017 DATED 10/11/2017 Exhibit P-7A TRUE COPY OF THE ORDER DATED 04/04/2019 ISSUED BY THE FIRST RESPONDENT Exhibit P-8A TRUE COPY OF THE ORDER OF THE FIRST RESPONDENT DATED 17/11/2022 ``` 16 WPC 443/23 & cnnctd cases ## **`APPENDIX OF WP(C) 22488/2023`** ``` PETITIONER EXHIBITS ``` ``` Exhibit P-1A TRUE COPY OF THE GOVERNMENT ORDER DATED 09/06/2022 ``` ``` Exhibit P-2A TRUE COPY OF THE PROCEEDINGS OF THE MANAGING DIRECTOR OF THE FIRST RESPONDENT CORPORATION DATED 17/06/2022 ``` - `Exhibit P- 3 A TRUE COPY OF THE IDENTITY CARD ISSUED BY THE SECOND RESPONDENT DATED NIL` ``` Exhibit P-4A TRUE COPY OF THE GOVERNMENT ORDER DATED 24/02/2011 ``` - `Exhibit P-5 A TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT IN W.P. (C) NO. 38766/2016 DATED 08/02/2017` - `Exhibit P-6 A TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT IN W.A.NO. 1922/2017 DATED 10/11/2017` - `Exhibit P-7 A TRUE COPY OF THE ORDER DATED 04/04/2019 ISSUED BY THE FIRST RESPONDENT` ``` Exhibit P-8A TRUE COPY OF THE REPRESENTATION DATED 20/03/2023 ``` 17 WPC 443/23 & cnnctd cases ## **`APPENDIX OF WP(C) 555/2023`** ``` PETITIONER EXHIBITS ``` ``` Exhibit P-1A TRUE COPY OF THE GOVERNMENT ORDER DATED 24/03/2021 ``` ``` Exhibit P-2A TRUE COPY OF THE PROCEEDINGS OF THE MANAGING DIRECTOR OF THE FIRST RESPONDENT CORPORATION DATED 04/05/2021 ``` ``` Exhibit P-3A TRUE COPY OF THE IDENTITY CARD ISSUED BY THE SECOND RESPONDENT ``` ``` Exhibit P-4A TRUE COPY OF THE GOVERNMENT ORDER DATED 24/2/2011 ``` ``` Exhibit P-5A TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT DATED 08/02/2017 IN W.P.(C) NO. 38766/2016 ``` ``` Exhibit P-6A TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT IN W.A.NO. 1922/2017 DATED 10/11/2017 Exhibit P-7A TRUE COPY OF THE ORDER DATED 04/04/2019 ISSUED BY THE FIRST RESPONDENT ``` ``` Exhibit P-8A TRUE COPY OF THE ORDER OF THE FIRST RESPONDENT DATED 17/11/2022 ``` 18 WPC 443/23 & cnnctd cases ## **`APPENDIX OF WP(C) 375/2023`** ``` PETITIONER EXHIBITS ``` ``` Exhibit P-1A TRUE COPY OF THE GOVERNMENT ORDER DATED 24/03/2021 ``` ``` Exhibit P-2A TRUE COPY OF THE PROCEEDINGS OF THE MANAGING DIRECTOR OF THE FIRST RESPONDENT CORPORATION DATED 04/05/2021 ``` ``` Exhibit P-3A TRUE COPY OF THE IDENTITY CARD ISSUED BY THE SECOND RESPONDENT ``` ``` Exhibit4A TRUE COPY OF THE GOVERNMENT ORDER DATED 24/2/2011 ``` ``` Exhibit P-5A TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT DATED 08/02/2017 IN W.P.(C) NO. 38766/ 2016 ``` ``` Exhibit6A TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT IN W.A.NO. 1922 OF 2017 DATED 10/11/2017 ``` ``` Exhibit P-7A TRUE COPY OF THE ORDER DATED 04/04/2019 ISSUED BY THE FIRST RESPONDENT Exhibit P-8A TRUE COPY OF THE ORDER OF THE FIRST RESPONDENT DATED 17/11/2022 ``` 19 WPC 443/23 & cnnctd cases ## **`APPENDIX OF WP(C) 443/2023`** ``` PETITIONER EXHIBITS ``` ``` Exhibit P-1A TRUE COPY OF THE ORDER OF THE GOVERNMENT DATED 24/03/2021 ``` ``` Exhibit P-2A TRUE COPY OF THE PROCEEDINGS OF THE MANAGING DIRECTOR OF THE FIRST RESPONDENT CORPORATION DATED 04/05/2021 ``` ``` Exhibit P-3A TRUE COPY OF THE IDENTITY CARD ISSUED BY THE SECOND RESPONDENT ``` ``` Exhibit P-4A TRUE COPY OF THE GOVERNMENT ORDER DATED 24/2/2011 ``` - `Exhibit P-5 A TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT DATED 08/02/2017 IN W.P.(C) NO. 38766/ 2016` - `Exhibit P-6 A TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT IN W.A.NO. 1922 OF 2017 DATED 10/11/2017` - `Exhibit P-7 A TRUE COPY OF THE ORDER DATED 04/04/2019 ISSUED BY THE FIRST RESPONDENT` ``` Exhibit P-8A TRUE COPY OF THE REPRESENTATION DATED 08/11/2022 ``` ``` Exhibit P-9A TRUE COPY OF THE ORDER OF THE FIRST RESPONDENT DATED 17/11/2022 ```