WP(C) Nos.21246/2020, 22403/2020 & 17173/2022

# **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE MRS. JUSTICE ANU SIVARAMAN** **FRIDAY, THE 12[TH] DAY OF AUGUST 2022 / 21ST SRAVANA, 1944** **WP(C) NO. 21246 OF 2020** ## **- PETITIONERS :** 1 KEXCON EMPLOYEES UNION (INTUC) REG.NO.2/16/2013 REP. BY ITS GENERAL SECRETARY GOPAN KUTTICHIRA, AGED 52 YEARS, S/O.SADASHIVAN UNNITHAN, RESIDING AT RAJANI MANDIRAM, MATHRUKA NAGAR-14, KALLUMTHAZHAM P.O., KOLLAM DISTRICT, PIN-691 004. 2 MURALEEDHARAN.V., AGED 54 YEARS S/O.BALAKRISHNAN.R., THARAVATTIL HOUSE, KADATHOOR P.O., KOLLAM DISTRICT, PIN-690 523. BY ADV B.RENJITHKUMAR **-** 1 STATE OF KERALA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF INDUSTRIES, KERALA GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. 2 THE KERALA FEEDS LIMITED, REPRESENTED BY ITS MANAGING DIRECTOR, KALLETTUMKARA, THIRUSSUR DISTRICT, PIN-680 683. 3 KERALA EX-SERVICEMEN WELFARE AND REHABILITATION CORPORATION, REPRESENTED BY ITS MANAGING DIRECTOR, KEXCON, OPP.AMRITHA HOTEL, THYCAUD, THIRUVANANTHAPURAM-695 001. BY ADVS. JOSEPH M.P. R.S.KALKURA JOSEPH M.P. SMT.K.M.SAROJINI, GP ## **- RESPONDENTS :** THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 12.08.2022, ALONG WITH WP(C).22403/2020 AND 17173/2022, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 2 :- ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE MRS. JUSTICE ANU SIVARAMAN FRIDAY, THE 12[TH] DAY OF AUGUST 2022 / 21ST SRAVANA, 1944 WP(C) NO.22403 OF 2020** ## **- PETITIONER :** M/S.KERALA STATE EX-SERVICEMEN DEVELOPMENT AND REHABILITATION CORORATION, A GOVERNMENT OF KERALA UNDERTAKING, HAVING ITS REGISTERED OFFICE AT T.C.25/838, VIMALA MANDIR, OPPOSITE AMRITHA HOTEL, THYCAUD, THIRUVANANTHAPURAM-695 014, REPRESENTED BY THE ADMINISTRATIVE OFFICER (DEPUTY SECRETARY, GOVERNMENT OF KERALA ON DEPUTATION). BY ADV R.S.KALKURA ## **- RESPONDENTS :** 1 STATE OF KERALA REPRESENTED BY THE SECRETARY, AGRICULTURE DEVELOPMENT AND FARMERS WELFARE (AHF) DEPARTMENT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001. 2 KERALA FEEDS LTD., A GOVERNMENT OF KERALA UNDERTAKING HAVING ITS REGISTERED OFFICE AT FEEDS NAGAR, KALLETUMKARA, THRISSUR-680 683, REPRESENTED BY ITS MANAGING DIRECTOR. SRI.M.RAJEEV, GP SRI.JOSEPH M.P. THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 12.08.2022, ALONG WITH WP(C).21246/2020 AND 17173/2022, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 3 :- ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE MRS. JUSTICE ANU SIVARAMAN FRIDAY, THE 12[TH] DAY OF AUGUST 2022 / 21ST SRAVANA, 1944** **WP(C) NO.17173 OF 2022** ## **- PETITIONERS :** 1 SUDHAKARAN R., AGED 58 YEARS S/O. N. RAJAPPAN NADAR, RESIDING AT SS BHAVAN MELKONAM, PERUMKADAVILA P.O., NEYYATTINKARA, THIRUVANANTHAPURAM DISTRICT-695 124 2 SUNIL KUMAR R.V, AGED 58 YEARS S/O RAGHUNADHAN, RESIDING AT SS NIVAS, VAMANAPURAM, KARIMKUTTYKARA P.O, THIRUVANTHAPURAM-695 606. 3 PREMAKUMARAN NAIR. S, AGED 59 S/O.SUKUMARAN NAIR, RESIDING AT 20/428A, NEDUMAN KALLAYAM P.O, THIRUVANANTHAPURAM-695 043 BY ADVS. T.MADHU C.R.SARADAMANI SHAHID AZEEZ RESHMA SANTHOSH RENJISH S. MENON ## **- RESPONDENTS :** 1 STATE OF KERALA REPRESENTED BY ITS PRINCIPAL SECRETARY, DEPARTMENT OF SPORTS AND YOUTH AFFAIRS KERALA GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. 2 DIRECTOR DIRECTORATE OF SPORTS AND YOUTH AFFAIRS VELLAYAMBALAM, THIRUVANANTHAPURAM-695 033 WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 4 :- 3 THE MANAGING DIRECTOR & CEO SPORTS KERALA FOUNDATION, JIMMY GEORGE INDOOR STADIUM, VELLAYAMBALAM, THIRUVANANTHAPURAM-695 033 4 KERALA EX-SERVICEMEN DEVELOPMENT & REHABILITATION CORPORATION, REPRESENTED BY ITS MANAGING DIRECTOR, KEXCON, OPP. AMRITHA HOTEL, THYCAD, THIRUVANANTHAPURAM-695 001. BY ADVS. P.U.SHAILAJAN R.S.KALKURA SRI.M.RAJEEV, GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 12.08.2022, ALONG WITH WP(C).21246/2020 AND 22403/2020, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 5 :- ## **JUDGMENT** ## **[WP(C) Nos.21246/2020, 22403/2020 & 17173/2022] Dated this the 12th day of August, 2022** These writ petitions are filed with regard to the appointment of security staff in the public sector undertakings which are arrayed as respondents in these writ petitions. 2. In W.P.(C) No.21246/2020, the 1[st] petitioner is a registered trade union of Ex-servicemen and the 2[nd] petitioner is a member thereof. The challenge is against Ext.P4 notification issued by the 2[nd] respondent calling for e-tenders for security services for one year. The 2[nd] respondent is the Kerala Feeds Limited, which is admittedly a Government of Kerala undertaking. 3. W.P.(C) No.22403/2020 has been filed by the Kerala State Ex-servicemen Development and Rehabilitation Corporation seeking directions to respondents 1 and 2 to comply with the directions contained in Exts.P1 to P4. 4. In W.P.(C) No.17173/2022, the petitioners, three in number, are Ex-servicemen registered with the petitioner in W.P. (C) No.22403/2020 and the challenge is against Ext.P9 communication issued by the 3[rd] respondent stating that the said WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 6 :- Foundation does not intend to extend the contract for providing security services with effect from 31.5.2022. 5. Heard the learned counsel for the petitioners, the learned Government Pleader, Adv.R.S. Kalkura, the learned counsel appearing for the KEXCON, Adv.Joseph M.P., the learned counsel appearing for the Kerala Feeds Limited as well as Adv.P.U.Shailajan, the learned counsel appearing for the Sports Kerala Foundation. 6. The learned counsel for the petitioners in these writ petitions would contend that there is a specific Government Policy as evidenced by Exts.P3 and P4 produced along with W.P.(C) No.22403/2020 to the effect that the contracts for security services in respect of Government Departments and Public Sector Undertakings, Local Bodies, Quasi Government Organisations, etc. have to be issued in favour of the Kerala State Ex-servicemen Development and Rehabilitation Corporation. It is submitted that the said Government Policy is specifically made applicable to all Governmental Organisations including Public Sector Undertakings, Local Bodies and other Quasi Government Organisations. It is contended that Ext.P4 would show that there is a specific direction to all such Governmental and Quasi Governmental Organisations to WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 7 :- engage personnel for security services exclusively from KEXCON and not to invite tender/quotation from private agencies for the purpose. It was also instructed to terminate existing contracts with private agencies and enter into contract with KEXCON. 7. Counter affidavits have been placed on record in these writ petitions. 8. The learned counsel appearing for the 2[nd] respondent in W.P.(C) No.22403/2020 would contend that the amount required for entering into security service contract with KEXCON is much more than is required for engaging private security agencies. It is further submitted that there have been several complaints with regard to the security services provided by the personnel engaged by KEXCON and that complaints have been preferred by the 2[nd] respondent before the KEXCON as well. 9. The learned counsel appearing for the 3[rd] respondent in W.P.(C) No.17173/2022 would contend that the 3[rd] respondent is a newly formed Government company and that the Government Circular and orders issued directing the engagement of service personnel exclusively from KEXCON is not applicable to it. It is further submitted that the 3[rd] respondent does not have the financial wherewithal to engage the personnel through KEXCON WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 8 :- since the charges quoted by the KEXCON are considerably higher than that of private security agencies. 10. The learned counsel for the petitioners in W.P.(C) No.22403/2020 places reliance on the judgment of this Court in W.P.(C) No.33329/2018 and connected cases. By judgment dated 16.9.2020, this Court had considered the identical situation and had held that since the Government Order directs all Departments, Public Sector Undertakings, Local Bodies, Quasi Government Organisations and Establishments to engage security personnel sponsored by the Kerala State Ex-servicemen Development and Rehabilitation Corporation exclusively for security related duties, the contention that the respondents are not specifically the Government or Public Sector Undertakings would not stand in the way of implementation of the said directives of the Government since the same is applicable to all departments of the Government, Public Sector Undertakings, Local Bodies, Quasi Government Organisations and Establishments. 11. The learned counsel for the petitioners in W.P.(C) No.17173/2022 also places reliance on an unreported judgment of this Court in W.P.(C) No.4992/2009, where the validity of the Government Order had been considered by this Court on a WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 9 :- challenge raised by the Proprietor of a private security agency. This Court, after considering all the contentions, held that the Government Order which directs Government Departments and Governmental Organisations to engage only the KEXCON and personnel sponsored by it for security duties does not offend any of the provisions of the Constitution and that the said directive is valid and binding on the respondents. 12. The learned counsel for the 3[rd] respondent in W.P.(C) No.17173/2022 placed reliance on the judgments of the Apex Court in **Chief Settlement Commissioner and others, Punjab** v. **Om Parkasha and others** [1969 KHC 649] and **HEC Voluntary Retd. Employees Welfare Society and another** v. **Heavy Engineering Corpn. Ltd. and others** [2006 KHC 471] to contend that directions issued in respect of Government employees would not be automatically applicable to employees of Government Companies. 13. I am of the opinion that the decisions cited by the respondents have no application in the instant case where the Government Orders specifically provide the directions to all Government Departments, Public Sector Undertakings, Governmental and Quasi Governmental Organisations as well as WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 **==> picture [49 x 7] intentionally omitted <==** Local Bodies. The respondents in these writ petitions cannot, by any stretch of imagination, contend that they do not come within the purview of the Government Orders themselves. This Court is not considering any challenge to the Government Order at the instance of the respondents in these writ petitions. The language of the Government Order being clear and unequivocal, the respondents, who are admittedly public sector undertakings, cannot contend that they are not bound by the same. In the above view of the matter, these writ petitions are liable to be allowed. I do so. The impugned notifications and orders are set aside. There will be a direction to the respondents to continue to engage personnel as provided in Ext.P1 Government Order and Ext.P4 circular produced in W.P.(C) No.22403/2020. In case of any complaint with regard to conduct of any specified personnel, the organisations are free to raise such complaints before the KEXCON which shall consider the same. In case there is any complaint with regard to the wages charged by the KEXCON as well, the respondents are free to raise such issues before the Government which shall be duly considered with notice to the KEXCON as well. The amounts due as pay to the petitioners in W.P.(C) No.17173/2022 for the period they have rendered the WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 **==> picture [49 x 7] intentionally omitted <==** services will also be released by the 3[rd] respondent, at the earliest, at any rate, within one month from the date of receipt of a copy of this judgment. **Sd/ANU SIVARAMAN JUDGE** Jvt/20.8.2022 WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 12 :- ## **APPENDIX OF WP(C) 21246/2020** PETITIONER EXHIBITS EXHIBIT P1 TRUE COPY OF THE ORDER NO.GO(MS) NO.179/GAD DATED 04.06.2005. EXHIBIT P2 TRUE COPY OF THE ORDER NO.134/05/GAD DATED 12.12.2005. EXHIBIT P3 TRUE COPY OF THE CIRCULAR DATED 04.11.2019 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P4 TRUE COPY OF THE NOTIFICATION PUBLISHED IN MALAYALAM MANORAMA DATED 02.10.2010. EXHIBIT P5 TRUE COPY OF THE REQUEST DATED 05.10.2020 SUBMITTED BY THE 1ST PETITIONER TO THE RESPONDENTS 2 AND 3. EXHIBIT P6 TRUE COPY OF THE INTERIM ORDER IN WPC NO.2826/2018 DATED 25.01.2018. EXHIBIT P7 TRUE COPY OF THE JUDGMENT IN W.P.(C) NO.21986/ 2020 DATED 24.11.2020 OF THIS HON'BLE COURT. RESPONDENT EXHIBITS EXHIBIT R2(a) TRUE COPY OF THE WOR ORDER NO.CEPP/13/94 3664/13DATED 27.6.2013 ISSUED BY THE 2ND RESPONDENT TO 3RD RESPONDENT EXHIBIT R2(b) TRUE COPY OF THE MINUTES OF THE 102ND BOARD MEETING OF 2ND RESPONDENT. EXHIBIT R2(c) TRUE COPY OF THE AGREEMENT EXECUTED BETWEEN THE COMPANY AND 3RD RESPONDENT FOR THE PERIOD 15.07.2014- 14 07.2015 EXHIBIT R2(d) TRUE COPY OF THE NOTICE ISSUED BY 3RD WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 13 :- ## RESPONDENT OT THEIR EMPLOYEES EXHIBIT R2(e) TRUE COPY OF THE DETAILED E TNEDER NOTICE DATED 30.09.2020 ISSUED BYTHE 2ND RESPONDENT EXHIBIT R2(f) TRUE COPY OF THE LETTER DATED 28-09-2020 ISSUED BY 2ND RESPONDENT TO 3RD RESPONDENT. Exhibit R3(a) TRUE COPY OF GO (MS)179/2005/GAD DATED 4.6.2005 Exhibit R3(b) TRUE COPY OF THE CIRCULAR NO 134/05/GAD DATED 12.12.2005 ISSUED BY THE GOVERNMENT OF KERALA Exhibit R3(c) TRUE COPY OF THE CIRCULAR NO 71307/12/GAD DATED 1.10.2012 ISSUED BY THE 1ST RESPONDENT Exhibit R3(d) TRUE COPY OF THE LETTER NO CFPP/13/94/3664/13 DATED 27.6.2013 Exhibit R3(e) TRUE COPY OF THE AGREEMENT DATED 14.7.2014 ENTERED INTO BETWEEN THE 3RD RESPONDENT AS SECOND PARTY AND THE 2ND RESPONDENT AS FIRST PARTY Exhibit R3(f) TRUE COPY OF THE AGREEMENT DATED 15.8.2018 ENTERED INTO BETWEEN THE THIRD RESPONDENT AND THE 2ND RESPONDENT Exhibit R3(g) TRUE COPY OF THE LETTER DATED 8.7.2019 ISSUED BY THE RESPONDENT TO THE 2ND RESPONDENT Exhibit R3(h) TRUE COPY OF THE LETTER DATED 26.9.2020 ISSUED BY THE 2ND RESPONDENT TO THE 3RD RESPONDENT Exhibit R3(i) TRUE COPY OF THE ADVERTISEMENT DATED 2.10.2020 APPEARING IN MALAYALA MANORAMA DAILY PUBLISHED BY THE SECOND RESPONDENT IN ERNAKULAM EDITION Exhibit R3(j) TRUE COPY OF THE JUDGMENT DATED 16.9.2020 IN WPC NO.33329/2018 Exhibit R3(k) TRUE COPY OF THE LETTER DATED 14.7.2020 ISSUED WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 14 :- BY THE 3RD RESPONDENT TO THE 2ND RESPONDENT Exhibit R3(l) TRUE COPY OF THE COMMUNICATION DATED 24.8.2020 ISSUED BY THE THIRD RESPONDENT TO THE 2ND RESPONDENT - Exhibit R3(m) TRUE COPY OF THE REPRESENTATION DATED 5.10.2020 SUBMITTED BY THE THIRD RESPONDENT BEFORE THE 1ST RESPONDENT Exhibit R3(n) TRUE COPY OF THE LETTER DATED 5.10.2020 ISSUED BY THE 3RD RESPONDENT Exhibit R3(o) TRUE COPY OF THE LETTER DATED 28.9.2020 ISSUED BY THE 2ND RESPONDENT TO THE 3RD RESPONDENT Exhibit R3(p) TRUE COPY OF THE LETTER NO.501/PROJ/AGMT KF/17/KEXCON DATED 13.10.2020 WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 15 :- ## **APPENDIX OF WP(C) 22403/2020** PETITIONER EXHIBITS EXHIBIT P1 TRUE COPY OF G.O.(MS)179/2005/GAD DATED 4.6.2005. EXHIBIT P2 TRUE COPY OF THE OFFICE MEMORANDUM DATED 9.7.2012 ISSUED BY THE GOVERNMENT OF INDIA, MINISTRY OF DEFENCE, DEPARTMENT OF EX-SERVICEMEN WELFARE. EXHIBIT P3 TRUE COPY OF THE CIRCULAR NO.134/05/GAD DATED 12.12.2005 ISSUED BY THE GOVERNMENT OF KERALA. EXHIBIT P4 TRUE COPY OF THE CIRCULAR NO.71307/12/GAD DATED 1.10.2012 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P5 TRUE COPY OF THE AGREEMENT DATED 14.7.2014 ENTERED INTO BETWEEN THE PETITIONER AND THE 2ND RESPONDENT. EXHIBIT P6 TRUE COPY OF THE AGREEMENT DATED 15.8.2018 ENTERED INTO BETWEEN THE PETITIONER AND THE 2ND RESPONDENT. EXHIBIT P7 TRUE COPY OF THE LETTER DATED 8.7.2019 ISSUED BY THE PETITIONER TO THE SECOND RESPONDENT. EXHIBIT P8 TRUE COPY OF THE LETTER DATED 26.9.2020 ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER. EXHIBIT P9 TRUE COPY OF THE ADVERTISEMENT DATED 2.10.2020 APPEARING IN MALAYALA MANORAMA DAILY PUBLISHED BY THE SECOND RESPONDENT IN ERNAKULAM EDITION. EXHIBIT P10 TRUE COPY OF THE JUDGMENT DATED 16.9.2020 IN WP(C) 33329/2020. EXHIBIT P11 TRUE COPY OF THE LETTER DATED 14.7.2020 ISSUED BY THE PETITIONER TO THE 2ND RESPONDENT. WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 16 :- EXHIBIT P12 TRUE COPY OF THE COMMUNICATION DATED 24.8.2020 ISSUED BY THE PETITIONER TO THE 2ND RESPONDENT. EXHIBIT P13 TRUE COPY OF THE REPRESENTATION DATED 5.10.2020 SUBMITTED BY THE PETITIONER BEFORE THE 1ST RESPONDENT. EXHIBIT P14 TRUE COPY OF THE LETTER DATED 5.10.2020. EXHIBIT P15 TRUE COPY OF THE LETTER DATED 28.9.2020 ISSUED BY THE SECOND RESPONDENT TO THE PETITIONER. RESPONDENT EXHIBITS Exhibit R2(a) TRUE COPY OF THE WORK ORDER DATED 27-6-2013 ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER. Exhibit R2(b) TRUE COPY OF THE MINUTES OF THE 102ND BOARD MEETING OF THE 2ND RESPONDENT Exhibit R2(c) TRUE COPY OF THE MINUTES OF THE BOARD MEETING OF THE 2ND RESPONDENT HELD ON 04-11-2019. Exhibit R2(d) TRUE COPY OF THE MINUTES OF THE BOARD MEETING OF THE 2ND RESPONDENT HELD ON 27-02-2020. Exhibit R2(e) TRUE COPY OF THE RELEVANT PAGES OF DETAILED E- TENDER NOTICE DATED 30-09-2020 ISSUED BY THE 2ND RESPONDENT. Exhibit R2(f) TRUE COPY OF THE LETTER No.CEPP/13/94/4009/14, DATED 30-09-2014, ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER. Exhibit R2(g) TRUE COPY OF THE LETTER No.CEPP/13/94/C1418/15, DATED 23-02-2015. Exhibit R2(h) TRUE COPY OF THE NOTICE DATED 12-11-2016 ISSUED BY UNIT HEAD, KERALA FEEDS LTD., KARUNAGAPPALLY UNIT TO THE SECURITY SUPERVISOR WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 17 :- ## WORKING AT KARUNAGAPPALLY UNIT. Exhibit R2(i) TRUE COPY OF THE LETTER KFL/249/98/C-1823/17, DATED 31-03-2017, ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER. Exhibit R2(j) TRUE COPY OF THE EMAIL DATED 22.5.2017 ISSUED BY THE UNIT HEAD, KERALA FEEDS LTD., KARUNAGAPPALLY UNIT TO M/S.KEXCON. Exhibit R2(k) TRUE COPY OF THE NOTE DATED 27-7-2017, ISSUED BY UNIT HEAD, KERALA FEEDS LTD., KARUNAGAPPALLY UNIT TO THE SECURITY SUPERVISOR WORKING AT KARUNAGAPPALLY UNIT. Exhibit R2(l) TRUE COPY OF THE LETTER KFL/KNPY/045/11/ 1693/17, DATED 27-12-2017, ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER. Exhibit R2(m) TRUE COPY OF THE LETTER No.CFPP/13/94/L-4584/ 18, DATED 10-04-2018, ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER. - Exhibit R2(n) TRUE COPY OF THE LETTER DATED 11/09/2020, ISSUED BY THE SECURITY OFFICER TO THE 2ND RESPONDENT. Exhibit R2(o) TRUE COPY OF THE LETTER DATED 7/8/20 ISSUED BY THE SECURITY OFFICER TO THE 2ND RESPONDENT. Exhibit R2(p) TRUE COPY OF THE NOTICE ISSUED BY THE PETITIONER TO ITS STAFF. Exhibit R2(q) TRUE COPY OF THE LETTER DATED 26/08/2020, ISSUED BY THE PETITIONER TO SECURITY OFFICER. WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 18 :- ## **APPENDIX OF WP(C) 17173/2022** PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE IDENTITY CARD ISSUED BY THE SECOND RESPONDENT TO THE FIRST PETITIONER Exhibit P2 TRUE COPY OF THE IDENTITY CARD ISSUED BY THE SECOND RESPONDENT TO THE SECOND PETITIONER Exhibit P3 TRUE COPY OF THE IDENTITY CARD ISSUED BY THE SECOND RESPONDENT TO THE THIRD PETITIONER. Exhibit P4 THE TRUE COPY OF THE GOVERNMENT CIRCULAR NO 71307/12/GAD DATED 1-10-2012 THE GOVERNMENT OF KERALA. Exhibit P5 THE TRUE COPY OF THE GOVERNMENT CIRCULAR NO SW1/126/2019/SAINIK WELFARE DPT DATED 4.11.2019. Exhibit P6 THE TRUE COPY OF LETTER NO 501/PROJ/DSYATA/10.E/06/KEXCON 19.4.2022 SENT BY THE FOURTH RESPONDENT. Exhibit P7 THE TRUE COPY OF LETTER NO M307/22/SKF DATED 9.5.2022 ISSUED BY THE THIRD RESPONDENT. Exhibit P8 THE TRUE COPY OF LETTER NO 501/PROJ/DSYATA/10.E/07/KEXCON DATED 12.5.2022. Exhibit P9 THE TRUE COPY OF THE LETTER NO M307/22/SKF DATED 18.5.2022 ISSUED BY THE THIRD RESPONDENT. Exhibit P10 TRUE COPY OF THE JUDGEMENT IN W.P © 21986/2020. RESPONDENT EXHIBITS Exhibit R3(a) THE TRUE COPY OF THE MEMORANDUM OF ASSOCIATIORI AND ARTICLES OF ASSOCTATION OF SPORTS KERALA FOUNDATION WP(C) Nos.21246 & 22403 OF 2020 and 17173 of 2022 -: 19 :- Exhibit R3(b) TRUE COPY OF THE INCOME AND EXPENDITURE STATEMENT OF SPORTS KERALA FOUNDATION AS ON 27.6,2022 Exhibit R3(c) TRUE COPY OF THE LETTER DATED 9.5.2022,NO:M307/22/SKF ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT Exhibit R3(d) THE TRUE COPY OF THE. QUOTATION NOTICE NO:M305/22/SKF DETED 25.4.2022 Exhibit R4(a) TRUE COPY OF G.O.(MS) 179/2005/GAD DATED 4.6.2005 Exhibit R4(b) TRUE COPY OF THE G.O.(MS) 179/2005/GAD DATED 4.6.2005 ISSUED BY THE GOVERNMENT OF KERALA Exhibit R4(c) TRUE COPY OF THE CIRCULAR NO 134/05/GAD DATED 12.12.2005 Exhibit R4(d) TRUE COPY OF THE CIRCULAR NO 71307/12/GAD DATED 1.10.2012 ISSUED BY THE IST RESPONDENT Exhibit R4(e) TRUE COPY OF THE JUDGMENT DATED 16.9.2020 IN WPC NO 3339/2020