W.P.(C) Nos. 18556/2019-T, 18506/2019-K and 18628/2019-C; Vivekananda Educational Trust, Noorul Islam Trust, Westfort Higher Education Trust

W.P(c).No.18556/19-T & c/cases 1 # **IN THE HIGH COURT OF KERALA AT ERNAKULAM** # **PRESENT** **THE HONOURABLE SMT. JUSTICE P.V.ASHA** **FRIDAY, THE 19TH DAY OF JULY 2019 / 28TH ASHADHA, 1941** **WP(C).No.18556 of 2019** **PETITIONER:** **VIVEKANANDA EDUCATIONAL TRUST REP.BY ITS CHAIRMAN, CHENAPPADY P.O., ERUMELY,KOTTAYAM DISTRICT** **BY ADVS.** **SRI.KURIAN GEORGE KANNANTHANAM (SR.) SRI.THOMAS GEORGE SRI.TONY GEORGE KANNANTHANAM** ## **RESPONDENTS:** - **1 STATE OF KERALA REPRESENTED BY THE PRINCIPAL SECRETARY, HIGHER EDUCATION DEPARTMENT, GOVERNMENT SECRETARIAT, TRIVANDRUM-695 001** - **2 THE KERALA UNIVERSITY OF HEALTH SCIENCE, REPRESENTED BY ITS REGISTRAR, MEDICAL COLLEGE P.O., TRICHUR-680 596** ## **STANDING COUNSEL SRI P.SREEKUMAR SPECIAL GOVERNMENT PLEADER SRI M.A.ASIF** **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 19.07.2019, ALONG WITH WP(C).18506/2019, WP(C).18628/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** W.P(c).No.18556/19-T & c/cases 2 # **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE SMT. JUSTICE P.V.ASHA** **FRIDAY, THE 19TH DAY OF JULY 2019 / 28TH ASHADHA, 1941** ## **WP(C).No.18506 of 2019** ## **PETITIONER:** **NOORUL ISLAM TRUST REPRESENTED BY ITS CHAIRMAN, AI-AZAR CAMPUS, PERUMPILLY CHIRA P.O., THODUPUZHA.** **BY ADVS. SRI.KURIAN GEORGE KANNANTHANAM (SR.) SRI.P.M.SANEER SRI.TONY GEORGE KANNANTHANAM** ## **RESPONDENTS:** **1 THE KERALA UNIVERSITY OF HEALTH SCIENCE REPRESENTED BY ITS REGISTRAR, MEDICAL COLLEGE .O., TRICHUR 680 596.** **2 TEH VICE CHANCELLOOR, KERALA UNIVERSITY OF HEALTH SCIENCE, MEDICAL COLLEGE, P.O., TRICHUR 680 596.** ## **STANDING COUNSEL SRI P.SREEKUMAR SPECIAL GOVERNMENT PLEADER SRI M.A.ASIF** **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 19.07.2019, ALONG WITH WP(C).18628/2019, WP(C).18556/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** W.P(c).No.18556/19-T & c/cases 3 ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** ## **THE HONOURABLE SMT. JUSTICE P.V.ASHA** **FRIDAY, THE 19TH DAY OF JULY 2019 / 28TH ASHADHA, 1941** ## **WP(C).No.18628 of 2019** ## **PETITIONER:** **WESTFORT HIGHER EDUCATION TRUST POTTORE, M.G. KAVU P.O, THRISSUR, REPRESENTED BY ITS MANAGING TRUSTEE AND CHAIRMAN, SRI.K.M. MOHANDAS, AGED 67 YEARS, RESIDING AT SREENIDHI, SREENAGAR, WEST FORT, THRISSUR-680004.** **BY ADV. SRI.K.P.DANDAPANI (SR.)** ## **RESPONDENTS:** |**1**|**STATE OF KERALA**| |---|---| ||**REPRESENTED BY ITS SECRETARY,**| ||**HEALTH AND FAMILY WELFARE DEPARTMENT, SECRETARIAT,**| ||**GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695036.**| |**2**|**THE COMMISSIONER OF ENTRANCE EXAMINATION,**| ||**OFFICE OF THE COMMISSIONER OF ENTRANCE EXAMINATION,**| ||**GOVT. OF KERALA, 5TH FLOOR, HOUSING BOARD BUILDING,**| ||**SANTHI NAGAR, THIRUVANANTHAPURAM-695001.**| |**3**|**KERALA UNIVERSITY OF HEALTH SCIENCE,**| ||**MEDICAL COLLEGE P.O, THRISSUR-680596, REPRESENTED**| ||**BY ITS REGISTRAR.**| |**4**|**THE DIRECTOR,**| ||**DIRECTORATE OF MEDICAL EDUCATION,**| ||**MEDICAL COLLEGE P.O, THIRUVANANTHAPURAM-695011.**| ||**SRI.P.SREEKUMAR,SC,**| ||**SRI.M.A.ASIF,SPECIAL GOVERNMENT PLEADER**| **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 19.07.2019, ALONG WITH WP(C).18506/2019, WP(C).18556/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** W.P(c).No.18556/19-T & c/cases 4 ## _**P.V.ASHA, J.**_ **--------------------------** W.P(C) Nos.18556 of 2019-T, 18506 of 2019-K and W.P(c).No.18628 of 2019-C ------------------------------------------ _Dated this the 19[th] day of July, 2019_ ## _**JUDGMENT**_ Petitioners in all these cases are conducting courses in Pharmacy. Their common grievance relates to the denial of extension of affiliation to their colleges. The parties and documents referred to in this common judgment are as described in W.P.(C) No.18556 of 2019. 2. Based on applications submitted for affiliation for the year 2018-19, the petitioners' colleges were granted provisional affiliation for starting B.Pharm course for the academic year 2018-19 as per Ext.P2 order issued on 31.07.2018, based on approval granted by AICTE and Pharmacy Council(PCI) and on the basis of interim order passed in W.P.(C) No.17685 of 2018. The affiliation was granted on 6 conditions including that it has to obtain NOC from Government; the college has to apply for continuation of provisional affiliation for the ensuing years remitting the fee fixed by University along with letters of approval from apex bodies. 3. It is stated that Pharmacy Council had granted approval subject to NOC from State Government and University had incorporated the condition in W.P(c).No.18556/19-T & c/cases 5 Ext.P2. The petitioner filed WP(C).No.17685/18 challenging the condition regarding production of NOC from Government, insisted by PCI as well as the affiliation insisting NOC. In Ext.P4 judgment this Court set aside the B.Pharm Course Regulations 2014, to the extent it insisted NOC from State Government. In the meanwhile, interim orders were passed permitting the petitioners to admit students for the year 2018-19 and thereafter directing the University to register the students so admitted. 4. It is stated that the University invited applications for renewal of affiliation for 2019-20 issuing notification in September, 2018 and the petitioners submitted applications for continuation of affiliation. It is stated that the University thereafter conducted inspection on 5.2.2019. The Principal thereafter requested the Government to include the college in the KEAM prospectus for admission to Kerala Engineering, Architecture and Medical courses. Government as per Ext.P6 letter dated 22.03.2019 informed that it cannot be included since Government has not granted letter of indent or letter of permission. It is stated that the AICTE as per Ext.P7 order granted extension of approval for the year 2019-20, on 25.4.2019. It is submitted that PCI has also granted extension of approval, as seen from their website. The Writ Petition was filed pointing out that the petitioner college is not included in the common allotment process, seeking for directions to the 2[nd] respondent University to issue formal orders granting extension of affiliation to the petitioner's college for 2019-20 and for permitting it to effect admissions to the entire seats sanctioned by AICTE. W.P(c).No.18556/19-T & c/cases 6 5. The University has filed a statement. Eventhough it has stated in paragraph 4 that University is awaiting extension of permission orders from statutory authorities, to issue continuation of affiliation orders to the pharmacy colleges and that once the extended orders are received from the PCI and AICTE appropriate orders would be issued, it has further stated as follows in para 12, 13 and 14 as follows: _“12. xxxx xxxx xxxx The grant of permissions from the statutory authorities and the grant of affiliation are distinct and different. The duties cast upon on the statutory authorities and the university are also distinct and different so the norms adopted in both the process are also different. The affiliation can never be automatic. A perusal of the permissions granted by the AICTE and the PCI shows that they insist that the colleges should obtain affiliation. A close reading of the AICTE permission shows that the permission is only a document intended to enable the colleges to seek affiliation. Going by the scheme the Affiliation is the final step and being the examining and affiliating body the university should have the final say._ _13. It is submitted that earlier when the No Objection Certificate from the Government was obtained the production of essentiality certificate in allied and para medical courses were not insisted. The No Objection Certificate or the Essentiality Certificate from the Government ensures an action from the government in the event of closure of an institution for the want of facilities or any other reason. The government has already conveyed to the university that the government would be having no responsibility over the courses affiliated without the NOC from the government. The matter requires serious consideration as the state has witness even the closure of a medical college during the last academic year and the process of shifting the students to other colleges is yet to be completed and those students have discontinued their studies for the past several months. In the said case, only for the reason that the government has given the essentiality certificate, steps were initiated by the government to protect the interest of the students, who would be nowhere in the absence of such actions on the part of the government. In the above stated circumstances the necessity of the essentiality certificate is to be insisted. The petitioners have not challenged the need for the essentiality certificate as contemplated in the First Statutes and a successful challenge of the PCI scheme cannot take away the necessity of the essentiality certificate. The petitioner college stands on a different footing from the other group of colleges which has produced the NOC from the government at the time of their initial affiliation._ _14. It is also submitted that the establishment of the institutions without any control would be detrimental to the society in different ways. The managements would be able to run the institutions so long as the students pay the fee and students would be able to pay the fee so long as they get educational loans. But after completing the courses the unemployment or the underemployment they face would result in the non repayment of the loans and quite often the government is addressed in this regard. The non repayment of the loans has a wider impact as the same affects the whole society. The wider impact of the situation can be properly assessed by the government machinery and the importance of the essentiality certificate assumes greater significance in this process.”_ W.P(c).No.18556/19-T & c/cases 7 6. I heard the learned Senior Counsel for the petitioners, the learned Standing Counsel for the University and the learned Special Government Pleader. 7. According to Sri. Kurian George Kannanthanam, the learned Senior Counsel, the issue is covered by the judgment in W.A.No.1485/19 that the Govt. or the University cannot have any further say in the matter once the AICTE and PCI, which are the regulatory authorities, have granted approval. It is argued that the University or the Government ought to have raised their objections, if any, before the respective authorities before approval was granted or else they should have challenged the approval granted by it. 8. According to the learned Standing Counsel for the University, affiliation cannot be granted in the absence of essentiality certificate as provided in clause 8 of statute 10 of the Kerala University of Health Sciences First Statutes, 2013 (University Statutes). The learned Special Government Pleader also points out about the requirement of essentiality certificate and that in the absence of the same, Government would not take up the responsibility to protect the students in the event of a casuality where the students are unable to carry on their studies in the college for want of facilities, or on account of financial problems. They relied on the judgment dated 29.10.2018 in the _**Jawaharlal Nehru Technological University Registrar vs. Sangam Laxmi Bai Vidyapeet & Ors in SLP No. 9718 of 2018**_ and argued that mere grant of approval by AICTE or PCI would not be sufficient for granting affiliation. 9. Section 50 Chapter VII of the Kerala University of Health Sciences W.P(c).No.18556/19-T & c/cases 8 Act, 2010 (`University Act' for short) deals with permission, affiliation and recognition of colleges. Section 50 deals with affiliation and recognition. Section 51 deals with procedure for permission. Section 51(4) provides that rules and procedure for affiliation of a college to the University shall be as prescribed by the Statutes. Section 53 provides for continuation of affiliation, which reads as follows: _“53. Continuation of affiliation:-_ _(1) The affiliated college or recognised institution may apply for continuation of affiliation or recognition for the courses of study for which affiliation or recognition was granted ordinarily six months prior to the date of expiry of such affiliation or recognition. The University shall follow the procedure prescribed in Statutes, so far as applicable, for grant of continuation of affiliation._ _(2) The affiliated college or recognised institution may apply for affiliation or recognition for additional courses of study and the same shall be considered by the University following the procedures or rules prescribed in this regard in the Statutes._ _(3) An affiliated college with at least six years standing as an affiliated college may apply for permanent affiliation in the manner as may be prescribed in the Statutes and the University shall consider such applications in such manner as may be prescribed.”_ Chapter XXI of the first statute provides for affiliation of colleges. As per statute 2 under this chapter, applications for affiliation of a college or for affiliation in additional subjects or affiliation for enhancement of seats or for consent of affiliation shall be addressed to the Registrar and shall be forwarded to him on or before the date fixed by the University from time to time. Statute 3 provides for the form of application. Statute 10 deals with grant of affiliation. Clause 8 of Statute 10 reads as follows: _“After considering the commission report and other enquiries, if any, and after obtaining the essentiality certificate from the Central and/or State Councils or authorities in the concerned discipline and after obtaining the essentiality certificate from the Government, the Governing Council shall decide whether the affiliation can be granted or_ W.P(c).No.18556/19-T & c/cases 9 _refused, either in whole or in part.”_ Statute 9, given below statute 10 provides for grant of affiliation, provides for conditional affiliation, which read as follows: _“The affiliation granted may be provisional. If provisional affiliation is granted for a fixed period, the length of the period and the conditions to be fulfilled by the college before the expiry of the period shall be specified in the order of the Governing Council granting the affiliation. If the conditions are not fulfilled by the end of the period fixed, the affiliation shall cease automatically. If the conditions are fulfilled, the Governing Council shall have the power to confirm the affiliation at the end of the period.”_ 10. The petitioner colleges started the course on the basis of the interim orders passed in the earlier Writ Petitions which led to Ext.P4 judgment. Government has not issued essentiality certificates for the colleges. Therefore, it is the contention of the petitioners that once the college has already started the courses in Pharmacy, the University or Government cannot insist that they should obtain an essentiality certificate for continuation of affiliation. It is also their contention that the University or Government did not file any Writ Appeal as against those judgment pointing out that aspect and therefore they cannot be heard to raise any such contention at this stage. 11. According to the learned Standing Counsel for the University, the Pharmacy Council had already insisted for an NOC and the judgment was one relating to the authority of PCI to insist NOC. It is also pointed out that since the admissions were already over and the students had already appeared in the examination on the basis of the interim orders, the matter was not taken up. 12. Having considered the contentions, it is seen that statute 10(8) provides that essentiality certificate of the Government is also one of the pre- W.P(c).No.18556/19-T & c/cases 10 requirements for affiliation, apart from the essentiality certificate from the Central councils. Moreover, Section 53 of the Act provides that the University shall follow the procedure prescribed in statutes so far as applicable for grant of continuation of affiliation. Therefore, I am of the view that the esentiality certificate is necessary for continuation of affiliation, especially when the petitioner colleges do not have essentiality certificates when the provisional affiliation was granted for the year 2018-19. 13. Though the learned Senior Counsel for the petitioners relying on the judgment in W.A.No.1485/2019 argued that the Government cannot have any say in this matter, the statutory provision which provides for the requirement of essentiality certificate for the purpose of affiliation was not an issue considered in that case. The petitioners have not challenged the provisions contained in statute 10(8) which provides for essentiality certificate. 14. It is also relevant to note the contentions raised by the learned Government Pleader as well as the learned Standing Counsel that in the absence of essentiality certificate, there will not be any protection from the Government to the students undergoing courses. Instances, where colleges are being closed when students are in the midst of the course, are increasing day by day, as pointed out by the Standing Counsel and therefore essentiality certificate would only be in the interest of the students. 15. The AICTE or the PCI does not take up any responsibility to protect W.P(c).No.18556/19-T & c/cases 11 the students who are undergoing the courses. In this context the judgment in Jawaharlal Nehru Technological University Registrar's case ( _supra_ ) relied on by the learned Standing Counsel and the learned Special Government Pleader is relevant. The question considered therein was whether the University was bound to give a no objection certificate irrespective of the educational need of the locality under its jurisdiction when the AICTE has issued approval. There the Government had taken a policy decision on the basis of a detailed study of a large number of technical institutions running in Telangana State and it was found that addition of more seats and colleges would adversely affect the quality of education and would make them financially unviable and also it will result in low employability of the students. Section 20 of the State Act 1982 mandated that a survey shall be conducted in order to identify the educational needs of the locality and that educational agencies applying for permission shall satisfy that there is an educational need in that locality. In para.13, the Apex Court held as follows: _“13. The provisions contained in section 20 are wholesome and intend not only to cater to the educational needs of the area but also prevent the mushroom growth of the institutions/courses. In case institutions are permitted to run each and every course that may affect the very standard of education and may ultimately result in substandard education. There is already a paucity of well-qualified teachers in a large number of institutions and the available seats in Pharmacy course in the Hyderabad city are remaining vacant every year in spite of the reduction in a number of seats. It had not been possible to fill up the vacancies due to non-availability of students. Thus, it is apparent that when 30 institutions in Hyderabad city are already running Pharmacy course, the refusal to grant NOC by the University was wholly justified.”_ 16. The University regulations which insisted NOC from the University was also considered therein. As per those regulations, University is to grant permission for starting new programmes as per the priority/policy of the State W.P(c).No.18556/19-T & c/cases 12 Government, if any. Taking note of the judgment in _**Government of Andhra Pradesh v. J.B.Educational Society**_ [(2005) 3 SCC 212], wherein it was held that there was no repugnancy between Section 20 of the State Act 1982 and section 10 of the AICTE Act of 1987, the Apex Court held that the decision taken by the State Government to impose ban based on its survey was perfectly within its powers. Para.26 of the judgment reads as follows: _“Para.26: The provisions contained in Section 20 of the Act of 1982 involved in the instant case are different and its validity vis-a-vis to AICTE Act has already been upheld by this Court. Apart from that, it has not been pointed out that in the exercise of powers under Section 10 of Central Act, norms have been fixed by the AICTE as to how many colleges should function at a particular city/place. Definitely the State Government and the University, in the absence of any such norms/rules having been framed by the AICTE can always have their say as per applicable statutory provisions or policy. In the instant case, Section 20 of Act of 1982, enables Universities to grant no objection certificate after considering the local requirement and as no guidelines in this regard have been framed by the AICTE, it cannot be said to be an exercise of power against the norms fixed by AICTE. Consequently, no repugnancy arises. The mushroom growth of the institutions cannot be permitted, was rightly pointed out in the perspective plan. A large number of institutions have already been permitted to function in the State by the Central Bodies. It is painful to note that at several places mushroom growth of the institutions had been permitted by such bodies in an illegal manner. In case there is no check or balance and the power is exercised in an unbridled reckless manner, the sufferer is going to be the standard of education. At the same time, there is a necessity of good institutions with new technology, but at the same time mushroom growth of the substandard institutions cannot be permitted. There has to be a requirement of educational institutions in the locality and that is one of the main considerations.”_ It is also relevant to point out that the judgment in _**Jaya Gokul Education Trust v.**_ ## _**Commissioner & Secretary to Government of Higher Education Department,**_ _**Thiruvananthapuram, Kerala**_ [(2000) 5 SCC 231], which was relied on by the leaned Senior Counsel for the petitioners was distinguished in the said case. 17. In the above circumstances, I am of the view that no directions can be issued to the 2[nd] respondent University as long as there is no essentiality certificate obtained from the Government as provided in Statue 10(8). W.P(c).No.18556/19-T & c/cases 13 Accordingly, the Writ Petitions are dismissed. _Sd/-_ _**(P.V.ASHA, JUDGE)**_ _rtr/_ W.P(c).No.18556/19-T & c/cases 14 ## **APPENDIX OF WP(C) 18556/2019** ## **PETITIONER'S EXHIBITS:** **EXHIBIT P1 TRUE COPY OF THE ORDER DATED 30.4.2018 ISSUED BY THE ALL INDIA COUNCIL FOR TECHNICAL EDUCATION** **EXHIBIT P2 TRUE COPY OF THE ORDER DATED 31.7.2018 ISSUED BY THE 2ND RESPONDENT** - **EXHIBIT P3 TRUE COPY OF THE ORDER DATED 1.2.2019 IN W.P(C) NO.26571/18 OF THIS HON.COURT** **EXHIBIT P4 TRUE COPY OF THE JUDGMENT DATED 8.2.2019 IN WPC NO.17685/2018 OF THIS HON.COURT** - **EXHIBIT P5 TRUE COPY OF THE APPLICATION FOR CONTRIBUTION OF AFFILIATION 2019-20 BY THE PETITIONER** - **EXHIBIT P6 TRUE COPY OF COMMUNICATION DATED 22.3.2019 ISSUED BY THE GOVERNMENT** **EXHIBIT P7 TRUE COPY OF THE ORDER OF APPROVAL DATED 25.4.2019 BYTE AICTE EXHIBIT P8 TRUE COPY OF THE STATEMENT FILED BY THE STANDING COUNSEL FOR UNIVERSITY IN W.P(C) NO.14721/19 OF THIS HON.COURT** - **EXHIBIT P9 TRUE COPY OF THE LETTER DATED 17.6.2019 ISSUED BY THE DIRECTOR OF MEDICAL EDUCATION** ## **RESPONDENT'S/S EXHIBITS:** **ANNEXURE R3 (a)** A TRUE COPY OF THE MINUTES OF THE MEETING. W.P(c).No.18556/19-T & c/cases 15 ## **APPENDIX OF WP(C) 18506/2019** ## **PETITIONER'S EXHIBITS:** **EXHIBIT P1** **TRUE COPY OF THE LETTER DATED 30.4.2018 ISSUED BY THE ALL INDIA COUNCIL FOR TECHNICAL EDUCATION.** **EXHIBIT P2 TRUE COPY OF THE ORDER DATED 3.7.2018 IN WPC NO. 18063/18 OF THIS HON COURT.** - **EXHIBIT P3 TRUE COPY OF THE ORDER DATED 13.8.2018 ISSUED BY THE 1ST RESPONDENT.** - **EXHIBIT P4 TRUE COPY OF THE JUDGMENT DATED 8.2.2019 IN WPC NO. 27721 /2018 OF THIS HON COURT.** **EXHIBIT P5 TRUE COPY OF THE COVERING LETTER DATED 17.9.2018 TO THE 1ST RESPONDENT.** - **EXHIBIT P6 TRUE COPY OF THE PRINTOUT OF THE APPLICATION FOR EXTENSION OF AFFILIATION SUBMITTED TO THE UNIVERSITY DATED 17.9.2018.** - **EXHIBIT P7 TRUE COPY OF THE RELEVANT PAGES OF THE ANNEXURE-18 OF ITEM NO. 763 OF 106 CENTRAL COUNCIL (APRIL 2019).** **EXHIBIT P8 TRUE COPY OF THE ORDER DATED 18.6.2019 ISSUED BY THE ALL INDIA COUNCIL FOR TECHNICAL EDUCATION.** W.P(c).No.18556/19-T & c/cases 16 ## **APPENDIX OF WP(C) 18628/2019** ## **PETITIONER'S EXHIBITS:** **EXHIBIT P1** **TRUE COPY OF THE EXTENSION OF APPROVAL GRANTED BY AICTE FOR ACADEMIC YEAR 2019-20 DATED 10.04.2019.** **EXHIBIT P2 TRUE COPY OF THE RELEVANT PAGE OF THE ONLINE APPLICATION.** - **EXHIBIT P3 TRUE COPY OF THE DECISION TAKEN BY THE PCI AS AVAILABLE FROM THE WEBSITE OF THE PCI.** - **EXHIBIT P4 TRUE COPY OF THE EMAIL COMMUNICATION OF THE PETITIONER DATED 21.05.2019 TO REGISTRAR OF THE PCI.** - **EXHIBIT P5 TRUE COPY OF THE LETTER OF APPROVAL ISSUED BY THE PCI TO THE PETITIONER DATED 11.06.2019.** - **EXHIBIT P6 TRUE COPY OF THE REPRESENTATION SUBMITTED BY THE PETITIONER BEFORE THE VICE CHANCELLOR, KERALA UNIVERSITY OF HEALTH SCIENCE, THRISSUR BEARING NO.WHET/WCP/KUHS/2019/24 DATED 2.07.2019.** - **EXHIBIT P7 TRUE COPY OF THE RELEVANT PAGES OF THE FINAL PROSPECTUS AND THE LIST OF PRIVATE SELF FINANCED COLLEGES ANNEXED THEREWITH PUBLISHED BY THE 2ND RESPONDENT ON 02.07.2019.** **EXHIBIT P8 TRUE COPY OF THE CLARIFICATION ISSUED BY THE PCI DATED NIL.**