## **IN THE HIGH COURT OF KERALA AT ERNAKULAM**
## **PRESENT**
## **THE HONOURABLE MR. JUSTICE AMIT RAWAL**
**MONDAY, THE 25TH DAY OF JANUARY 2021 / 5TH MAGHA, 1942**
## **WP(C).No.31786 OF 2018(W)**
## **PETITIONER/S:**
- **1 SMITHA C.N., D/O NARAYANAN, CHAKKUMKERI HOUSE, K. R. PURAM P.O, CHERTHALA, ALAPPUZHA DISTRICT- 688556**
- **2 SUNILATHA.R., W/O.SABU.P.G., VELAMKUNNATH HOUSE, PANAVALLY P.O., CHERTHALA, ALAPPUZHA DISTRICT-688 526.**
- **3 BINDU.S. W/O.ASHOK KUMAR.K.R., PANAVILA VADAKKETHIL, MUTHUKATTUKARA, NOORANAD P.O., ALAPPUZHA DISTRICT-690 504.**
- **BY ADVS. SRI.T.R.HARIKUMAR SRI.ARJUN RAGHAVAN SRI.ADITHYA RAJEEV**
## **RESPONDENT/S:**
- **1 THE ALAPPUZHA DISTRICT CO-OPERATIVE BANK LTD. NO.4203, REPRESENTED BY ITS GENERAL MANAGER, HEAD OFFICE, ALAPPUZHA -690001**
- **2 THE PART-TIME ADMINISTRATOR, ALAPPUZHA DISTRICT CO-OPERATIVE BANK LTD.NO.4203, HEAD OFFICE, ALAPPUZHA-690 001, (JOINT REGISTRAR OF CO-OPERATIVE SOCIETIES(GENERAL), ALAPPUZHA).**
- **3 THE KERALA PUBLIC SERVICE COMMISSION, REPRESENTED BY ITS SECRETARY, PATTOM P.O., THIRUVANANTHAPURAM-695 004.**
- **4 THE DISTRICT OFFICER, KERALA PUBLIC SERVICE COMMISSION, DISTRICT OFFICE, ALAPPUZHA-688 001.**
**WP(C).No.31786 OF 2018(W) and conctd. Case**
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- **5 THE JOINT REGISTRAR OF CO-OPERATIVE SOCIETIES(GENERAL), ALAPPUZHA-688 001.**
- **6 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM-695 001.**
- **7 ADDL.R7. THE KERALA CO-OPERATIVE BANK LTD., REPRESENTED BY ITS CEO, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - PIN - 695 033**
**ADDITIONAL R7 IS IMPLEADED AS PER ORDER DATED 27.1.2020 IN I.A.1/2020 IN WP(C).**
**R1-2 BY ADV. SC, ALAPPUZHA DISTRICT CO.OPERATIVE BANK LTD.**
**R3-4 BY ADV. SC, KERALA PUBLIC SERVICE COMMISSION - KPSC R3-4 BY SRI.P.C.SASIDHARAN, SC, KPSC R5-6 BY GOVERNMENT PLEADER SRI. HAREESH KUMAR R7 BY ADV. GILBERT GEORGE CORREYA**
**THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 25.01.2021, ALONG WITH WP(C).29057/2019(F), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:**
**WP(C).No.31786 OF 2018(W) and conctd. Case**
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## **IN THE HIGH COURT OF KERALA AT ERNAKULAM**
## **PRESENT**
**THE HONOURABLE MR. JUSTICE AMIT RAWAL**
**MONDAY, THE 25TH DAY OF JANUARY 2021 / 5TH MAGHA, 1942**
## **WP(C).No.29057 OF 2019(F)**
## **PETITIONER/S:**
|**1**|**BINCY S.**|
|---|---|
||**AGED 36 YEARS**|
||**W/O. SUVARNAKUMAR A.S, RESIDING AT AJAYA NIVAS,**|
||**VARANAD P.O, CHERTHALA 688 539, ALAPPUZHA DISTRICT**|
|**2**|**VINEETHA N.V,**|
||**AGED 32 YEARS**|
||**W/O. SHYMON P.S, RESIDING AT PONNAMTHARA,**|
||**VAYALAR P.O, PIN 688 536**|
|**3**|**REKHA O,**|
||**AGED 39 YEARS**|
||**RESIDING AT MATTATHIL, CHARAMANGALAM, MUHAMMA P.O,**|
||**ALAPPUZHA DISTRICT**|
|**4**|**SABITHA N.B,**|
||**AGED 41 YEARS**|
||**W/O. SAIJU V.G,**|
||**RESIDING AT VAYALVARAM HOUSE, THIRUNALLOOR P.O,**|
||**PIN 688 541**|
|**5**|**BINDU K.T,**|
||**AGED 45 YEARS**|
||**D/O. THANKAPPAN K.K, RESIDING AT KOORAMUTTATHU,**|
||**CHERUVARANAM, VARANAM P.O, ALAPPUZHA DISTRICT**|
|**6**|**ASHAMOL P,**|
||**AGED 41 YEARS**|
||**W/O. LALAN M.V, RESIDING AT MANEEZHATHUVELI,**|
||**NORTH ARYAD P.O, ALAPPUZHA 688 538**|
|**7**|**SANTHOSH KUMAR B,**|
||**AGED 46 YEARS**|
||**S/O. G. BHASKARAN, RESIDING AT INDIRA BHAVANAM,**|
||**KATTACHIRA, PALLICKAL P.O, ALAPPUZHA DISTRICT**|
|**8**|**ASA M,**|
||**AGED 44 YEARS**|
||**RESIDING AT LAKSHMIVILLA , MUTHUKULAM NORTH,**|
||**CHOOLATHERUVU P.O, ALAPPUZHA 690 506**|
**WP(C).No.31786 OF 2018(W) and conctd. Case**
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- **9 REMYA A.K, AGED 34 YEARS**
**W/O. NOBI K.S, RESIDING AT KOLLAMVELI, MUHAMMA P.O, ALAPPUZHA 688 525**
- **10 AJITHAKUMARI K.A, AGED 45 YEARS W/O. GOPINATHAN NAIR, RESIDING AT PALAKKAVIL HOUSE, OLATHALA, PATTANAKKAD P.O, CHERTHALA, ALAPPUZHA**
- **11 BINDU S, AGED 44 YEARS RESIDING AT LEKSHIPURAM, KELAMANGALAM P.O, THAKAZHY, ALAPPUZHA 688 562**
- **12 SUMESH C.B, AGED 51 YEARS S/O. BALASOMAN, RESIDING AT CHIRACKALPARAMBIL, PATTANAKKAD P.O, CHERTHALA, ALAPPUZHA 688 531**
- **13 ASHADEVI R, AGED 45 YEARS W/O. S. CHANDRAN, RESIDING AT KOMALIL KYALVARAM, KANADALLOOR SOUTH P.O, KAYAMKULAM, PIN 690 535**
- **14 MANJUSHA K, AGED 40 YEARS W/O. P.K BABU, RESIDING AT PALATHARA HOUSE, ANJILAKKADU, AROOR P.O, CHERTHALA, ALAPPUZHA 688 534**
- **15 MAYADEVI V, AGED 47 YEARS**
**W/O. N RGGHUNATH, RESIDING AT MADHAVAM, PATTANAKKAD P.O, CHERTHALA, ALAPPUZHA 688 531**
**BY ADVS.**
**SRI.M.R.ANISON SMT.V.BHARGAVI (PANANGAD) SMT.P.A.RINUSA SMT.A.MEENAKSHI**
## **RESPONDENT/S:**
- **1 THE ALAPPUZHA DISTRICT CO-OEPRATIVE BANK LIMITED NO. 4203, REPRESENTED BY ITS PART-TIME ADMINISTRATOR, ALAPPUZHA DISTRICT CO-OEPRATIVE BANK LIMITED NO. 4203, HEAD OFFICE, ALAPPUZHA 691 001**
**WP(C).No.31786 OF 2018(W) and conctd. Case**
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- **2 THE JOINT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL) ALAPPUZHA 688 001**
- **3 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM 695 001**
- **4 THE KERALA PUBLIC SERVICE COMMISSION, REPRESENTED BY ITS SECRETARY, PATTOM, THIRUVNAANTHAPURAM 695 004**
- **5 THE DISTRICT OFFICER,**
- **KERALA PUBLIC SERVICE COMMISSION, DISTRICT OFFICE, ALAPPUZHA 688 001**
- **6 ADDL.R6.KERALA CO-OPERATIVE BANK LIMITED, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, COOPERTIVE TOERS, PALAYAM, THIRUVANANTHAPURAM-695033. ADDL.R6 IS IMPLEADED AS PER ORDER DATED 12.02.2020 IN IA 2/2020**
**R4-5 BY SRI.P.C.SASIDHARAN, SC, KPSC GOVERNMENT PLEADER SRI. HAREESH KUMAR**
**THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 25.01.2021, ALONG WITH WP(C).31786/2018(W), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:**
**WP(C).No.31786 OF 2018(W) and conctd. Case**
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## **JUDGMENT**
## **Dated this the 25[th] day of January 2021**
This order of mine shall dispose of two writ petitions, whereby identical question and prayer has been sought. The facts are being taken from W.P.(C)No.29057 of 2019. Petitioners, are fifteen(15) in number, candidates, were included in the rank list for appointment to the post of Clerk/Cashier under different categories ie., general category, society quota candidates approached this Court seeking the following reliefs:
(a) to issue a writ of mandamus or other appropriate writ order or direction directing the 1 respondent to fill up Clerk/Cashier post by strictly following the ratio stipulated in ExP3 Recruitment Rule and not to fill up any Clerk/Cashier post in excess of the quota set apart in Ext.P3 between direct recruits and promotees,
(b) to issue a writ of mandamus or other appropriate writ order or direction directing 2[nd] and 3[rd] respondents to ensure that 1[st] respondent do not affect any promotion to the post of Clerk/Cashier in violation of the 5:1 ratio and not to fill up the existing vacancies of Clerk/Cashier post in violation of the 5:1 ratio,
(c) to issue a writ of mandamus or other appropriate writ order or direction, directing the respondent to report all Clerk/Cashier vacancies available and arising in the various branches and Head Office of the Branch up to 31.12.2025 to she PSC forthwith, so as to enable the 5[th] respondent to issue advice memo to persons included in Ext. Pl and P2 rank lists,
**WP(C).No.31786 OF 2018(W) and conctd. Case**
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(d) to issue a writ of mandamus or other appropriate writ order or direction directing respondents 1 to 3 to stop the practice of permitting Peons for any other unqualified persons to discharge the duties of Clerk/Cashier in various branches of the Bank after coming into force of Ext. P1 and P2 rank list and to report all such vacancies of Clerk/Cashier to PSC forthwith
(e) to issue a writ of mandamus or other appropriate writ order or direction, directing the 1[st] respondent to report 110 Clerk/Cashier post to the PSC forthwith; so as to enable the PSC to advice candidates from Ext.P1 and Ext.P2 rank list:
2. A ratio of 5:1 between direct recruitees and promotees was fixed in the 'Model Recruitment Rule', framed for the District Co-operative Banks in the State for effecting appointment to the post of Clerk/Cashier.
3. Learned counsel appearing on behalf of the petitioners submits that as on the date of the rank lists, Exts.P1 and P2, large number of Clerk/Cashiers vacancies
were vacant in various branches of the Bank. But ignoring the ratio stipulated in Ext.P3 recruitment Rule, all those vacancies were filled up by promoting persons who are working in the feeder post. Petitioners have demonstrated the number of vacancies and promotions by placing on record chart, Exts.P9 to P11. The first respondent did not report any vacancies to the Public Service Commission only with an intention to fill up all
**WP(C).No.31786 OF 2018(W) and conctd. Case 8**
those vacancies by department itself. The District Cooperative Bank have been adopting the practice of not reporting any vacancies to the PSC and filling up the post in flagrant violation of Ext.P3 Recruitment Rules. Vide circular dated 9.8.2016, Ext.P13 Registrar Co-operative Societies, 3[rd] respondent, directed all the District Cooperative Banks not to fill up the vacancies arising in the Bank otherwise than as provided in the Co-operative Societies Act and Rules, thus, the action of the first respondent is per se illegal and arbitrary. During the pendency of the writ petition an interim application No.1 of 2020 dated 26.1.2020 was filed. It was mentioned that eight (8) vacancy of Clerk/Cashier were filled up by promoting Peons by applying 5:1 ratio between direct recruits and promotees. Four (4) persons were promoted in excess of the promotion quota. Apprehending expiry of ranked list on 22.2.2020, sought the indulgence of this Court for directing the first respondent to report hundred and ten (110) vacancies of Clerk/Cashier to the 5[th] respondent/PSC. This Court vide order dated 19.2.2020, noticing the contention of respondent representing
**WP(C).No.31786 OF 2018(W) and conctd. Case 9**
District Co-operative Banks, Sri.P.C Sasidharan that there were no vacancies existing and pursuant to reclassifications effected since 2006, sanctioned strength in the post of clerk/cashier varied over the years. The aforementioned prayer was not accepted and the said order was assailed before the Division Bench in W.A No.317 of 2020. The Division Bench vide an interim order dated 20.2.2020, directed the respondents 1 to 6 to report thirty nine( 39) vacancies in the post of Cashier/Clerk in Alappuzha District Co-operative Bank to respondent No.4 (Public Service Commission) with copy of Respondent No.5 (District Officer KPSC) with a further direction that no advice shall be effected against the reported vacancies without any order of the court. However vide order dated 3.3.2020, the Division Bench disposed of the writ appeal by observing that the question whether the vacancies directed to be reported are actual vacancies available for effecting appointments and all other issues raised and available for consideration based on the pleadings in the writ petition, were left open. It is contended that even if the District Co-operative Banks
**WP(C).No.31786 OF 2018(W) and conctd. Case 10**
have been amalgamated, the rank list which was already invogue had not lost its validity but the respondent did not report any vacancies to the PSC. In support of the contention relied upon the judgment of this Court in W.P.C No.14915 of 2020 titled as **V. Dineshkumar and Others**
**v. Kerala State Co-operative Bank Ltd** ., whereby the contention of the petitioners (therein) was rejected on the premise that DCBs, on amalgamation, ceased to exist and upheld the action of the respondents in undertaking the task of appointment of vacancies which were in existence before the date of amalgamation in view of saving clause 12 of Section 74H of the Kerala Cooperative Societies Act.
3. Per contra, learned counsel appearing on behalf of the contesting respondents submitted that there are no such vacancies. The prayer in the interim application now filed ie., I.A Nos.4 and 5 of 2020 dated 14[th] December 2020 in respect of fresh process of appointments is not supported by any documents. This Court had already in W.P.(C) No.19568 of 2020 titled as **Jayasree M. and others v. State of Kerala and others** dated
**11**
**WP(C).No.31786 OF 2018(W) and conctd. Case**
12.10.2020, whereby a challenge was laid to the order of transfer and found that since there was amalgamation of DCBs with State Co-operative Banks as per the provisions of Sub Rule 5 of Rule 28A of the Kerala Cooperative Societies Rules, 1969, the Government by notification is required to make changes regarding recruitment, rules, staff regulations, promotions; the process is pending consideration and till such time, there cannot be any reporting of vacancies to the PSC. By taking into consideration the aforementioned fact and the contentions, the transfer orders challenged, were ordered to be kept in abeyance and till such time, no appropriate directions as sought for in the present writ petition may be issued. It was further contended that the ratio culled out in **V.Dineshkumar** (supra) would not be applicable as advice of appointment had been issued prior to amalgamation whereas the facts of the case are entirely different as it is only with regard to reporting of the vacancies and urged this Court for dismissal of the writ petition.
4. I have heard the learned counsel for the parties
**WP(C).No.31786 OF 2018(W) and conctd. Case**
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and appraised the paper book. In the judgment **Jayasree M.** (supra) this Court noticed that the factum of amalgamation and the constitutional validity of Section 14A and 74H was upheld by this and all the DCBs except one were amalgamated with the State Co-operative Bank on account of fulfillment of certain conditions ie, a condition to get the technology in place for smooth transfer of services to clients with carefully configured software. Sub Clause (iv) of clause 6 of the scheme of amalgamation provides that the Government will make a scheme for cadre integration and seniority promotion, transfer, service condition and such other matters related to the employees of the transferor bank and the Transferee Bank. Rule 28A (5) of the Kerala Co-operative Societies Rules empowered the Government to make changes in the recruitment rules, staff regulations, promotion policy and other establishment matters of the Bank. The direction as sought for with regard to the earlier promulgated rank list whose period had already expired, dehore of the fact that the interim directions were issued for reporting it provisionally cannot be
**WP(C).No.31786 OF 2018(W) and conctd. Case 13**
adhered at this stage but this Court cannot lose sight of the fact that there are no such vacancies as the amalgamation scheme had already been notified way back on 29.11.2019. The aforementioned fact was not brought into notice of the Division Bench while passing interim order but was noticed in the order dated 3[rd] of March 2020. For the sake of brevity, paragraph 5 of the said order in W.A No.317 of 2020 is extracted herein below:
The captioned appeal has been preferred against the interim order dated 19.02.2020 in I.A. No. 1/2020 in WP(C) No. 29057/2019. As per the impugned interim order, the learned single Judge had declined to grant the interim relief sought for. As per I.A. No. 1/2020, the petitioner sought for a direction to the first respondent, viz. the Alappuzha District Cooperative Bank Ltd. No. 4203 to report 110 vacancies of Clerk/Cashier to the 5th respondent, viz. the District Officer of Kerala Public Service Commission, pending decision in the writ petition. 2. The learned single Judge has given reasons for declining the interim relief sought for. When the appeal came up for consideration on 20.02.2020, we passed an interim order, whereby we directed respondents 1 to 6 to report 39 vacancies in the post of Cashier/Clerk in Alappuzha District Co-operative Bank to respondent No.4 with copy of W.A.No. 317/2020 5 respondent No.5, appropriately on or before 5 p.m. on 22.02.2020. We passed the said order taking note of various aspects. The list in question where the appellant's figure was to expire on 22.02.2020. A Full Bench of this Court in Vimala Kumari v. State [1994 (2) KLT 47] held that in respect of a ranked list published by the Kerala Public Service Commission, appointments could be effected from the said list, only if vacancies were reported prior to its expiry. 3. We also took note of another aspect. Though one of the contentions raised by the respondents to resist the claims of the appellants/writ petitioners is that in view of the amalgamation of District Co-operative Banks to form the Kerala State Co-operative Bank the District Co-operative Bank in question ceased to
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exist. Obviously, while passing interim order dated 20.02.2020, we put a pointed question to the learned counsel for respondents 1 and 6 as also the learned Government Pleader appearing for respondents 2 and 3 as to whether any appeal was preferred against amalgamation of W.A.No. 317/2020 6 District Cooperative Bank with the Kerala State Co-operative Bank. We got an answer in the affirmation. In other words, against the common order by a learned single Judge in this matter appeals have been preferred and they are pending. We have taken into account all those aspects while passing the interim order. 4. As noticed hereinbefore, as per interim order dated 22.02.2020, we directed the respondents for reporting 39 vacancies in the post of Cashier/Clerk in Alappuzha District Cooperative Bank to respondent No.4 with copy to respondent No. 5. We also ordered that no advice shall be effected against the vacancies so reported, without obtaining further orders from this Court. 5. We are of the considered view that nothing further survives for consideration in this appeal as the very appeal was filed against the interim order dated 19.02.2020 whereby the learned single Judge declined to grant relief sought for in I.A.1/2020. To the extent it is permissible the view of the materials on record we passed the aforesaid interim order. Whether those vacancies directed to be reported provisionally are actual vacancies or not as also the other legal contentions based on the factum of amalgamation of the District Cooperative Bank are matters to be considered in the writ petition. Obviously, the writ petition is still pending. In the said circumstances, the appeal is disposed of making it clear that the question whether the vacancies directed to be reported are actual vacancies available for effecting appointments and all other issues raised and available for consideration based on the pleadings in the writ petition, are left open to be urged in the writ petition.
5. This Court cannot thus ignore the factum of amalgamation as per the notification ibid and accept the prayer of the petitioners by issuing directions to erstwhile DCBs (No longer in existence) now amalgamated with State Co-operative Banks pending promulgation of rules
**WP(C).No.31786 OF 2018(W) and conctd. Case 15**
and regulations as per sub Rule 5 of Rule 28 of the Kerala Co-operative Societies Rule. There is no merit in the writ petition and is accordingly dismissed.
In view of the aforementioned observation, the writ petition No.31786 of 2018 is also dismissed.
## **SD/-**
sab
**AMIT RAWAL JUDGE**
**WP(C).No.31786 OF 2018(W) and conctd. Case**
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## **APPENDIX OF WP(C) 31786/2018**
**PETITIONER'S/S EXHIBITS:**
**EXHIBIT P1**
**A TRUE COPY OF THE NOTIFICATION IN CATEGORY NO.20/2014 DATED 15.03.2014 ISSUED BY THE PUBLIC SERVICE COMMISSION.**
**EXHIBIT P2**
**A TRUE COPY OF THE NOTIFICATION IN CATEGORY NO.21/2014 DATED 15.03.2014 ISSUED BY THE PUBLIC SERVICE COMMISSION.**
**EXHIBIT P3**
**A TRUE COPY OF THE RELEVANT PAGE OF THE RANK LIST FOR THE POST OF CLERK/CASHIER FOR DIRECT RECRUITMENT DATED 23.02.2017.**
**EXHIBIT P4**
**A TRUE COPY OF THE RELEVANT PAGE OF THE RANK LIST FOR THE POST OF CLERK/CASHIER (SOCIETY QUOTA) DATED 23.02.2017.**
**EXHIBIT P5**
**A TRUE COPY OF THE RECRUITMENT(AMENDMENT) RULES FOR DISTRICT CO-OPERATIVE BANKS, 2014 DATED 01.11.2014.**
**EXHIBIT P6 A TRUE COPY OF THE PROCEEDINGS OF THE 2ND RESPONDENT IN PROMOTING THE CLERK TO JUNIOR ASSISTANT DATED NIL**
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## **APPENDIX OF WP(C) 29057/2019**
**PETITIONER'S/S EXHIBITS:**
**EXHIBIT P1**
**TRUE COPY OF THE RELEVANT PAGES OF RANKED LIST FOR THE POST OF CLERK/CASHIER (ALAPPUZHA) WHICH WAS BROUGHT INTO FORCE ON 23-02-2017**
- **EXHIBIT P2 TRUE COPY OF THE RELEVANT PAGES OF RANKED LIST FOR THE POST OF CLERK/CASHIER (PART-II SOCIETY QUOTA-ALAPPUZHA) WHICH WAS BROUGHT INTO FORCE ON 23-02-2017**
- **EXHIBIT P3 TRUE COPY OF THE RECRUITMENT RULE FOR APPOINTMENT TO THE VARIOUS CADRE POSTS IN DISTRICT CO-OPERATIVE BANK**
- **EXHIBIT P4 TRUE COPY OF THE YEARLY BALANCE SHEET OF THE BANK FOR THE YEAR 2016-2017**
- **EXHIBIT P5 TRUE COPY OF THE YEARLY BALANCE SHEET OF THE BANK FOR THE YEAR 2017-2018**
- **EXHIBIT P6 TRUE COPY OF THE YEARLY BALANCE SHEET OF THE BANK FOR THE YEAR 2018-2019**
- **EXHIBIT P7 TRUE COPY OF RELEVANT PAGES OF ANNUAL REPORT OF THE BANK FOR THE YEAR 2016-17**
- **EXHIBIT P8 TRUE COPY OF RECLASSIFICATION ORDERS DATED 08-03-2019**
- **EXHIBIT P9 TRUE COPY OF LIST OF OFFICERS WHO RETIRED DURING THE EXISTENCE OF THE RANK LIST**
- **EXHIBIT P10 TRUE COPY OF THE LIST OF OFFICERS WHO RETIRED IN BETWEEN 22-02-2020 TO 31-12-2020**
- **EXHIBIT P11 TRUE COPY OF THE CHART PREPARED BY THE PETITIONERS SHOWING 39 NAMES OF CLERK/CASHIERS PROMOTED TO THE POST OF JUNIOR ACCOUNTANT**
- **EXHIBIT P12 TRUE COPY OF THE LETTER DATED 19-10-2017 ISSUED BY THE GOVERNMENT**
**EXHIBIT P13 TRUE COPY OF THE CIRCULAR BEARING NO 27/2016 DATED 09-08-2016 EXHIBIT P14 TRUE COPY OF THE CIRCULAR ISSUED BY THE GOVERNMENT DATED 18-01-2019**
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**EXHIBIT P15 TRUE COPY OF CIRCULAR NO. C.3/101/2019/P AND AD DATED 20-09-2019**
**EXHIBIT P16 A TRUE COPY OF THE JUDGMENT DATED 03.03.2020 IN W.A.NO.317/2020.**