Writ Appeal No.802 of 2021

## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE MR. JUSTICE P.B.SURESH KUMAR** ## **&** **THE HONOURABLE MRS. JUSTICE SOPHY THOMAS** **FRIDAY, THE 26[TH] DAY OF MAY 2023 / 5TH JYAISHTA, 1945 WA NO. 802 OF 2021** **AGAINST THE JUDGMENT IN WP(C) 6700/2020 OF HIGH COURT OF** ## **KERALA** ## **APPELLANTS/RESPONDENTS 1 TO 3 IN W.P.(C):** - **1 THE STATE OF KERALA, REPRESENTED BY THE PRINCIPAL SECRETARY,DEPARTMENT OF HIGHER EDUCATION,GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.** - **2 THE DIRECTOR OF COLLEGIATE EDUCATION, DIRECTORATE OF COLLEGIATE EDUCATION,VIKAS BHAVAN, THIRUVANANTHAPURAM-695004.** - **3 THE DIRECTOR DIRECTOR OF COLLEGIATE EDUCATION, ERNAKULAM-685001.** - **BY ADV A.J.VARGHESE,SR.GOVERNMENT PLEADER** ## **RESPONDENTS/PETITIONER AND 4TH RESPONDENT IN W.P.(C):** - **1 RAJAGIRI COLLEGE OF SOCIAL SCIENCES REPRESENTED BY ITS PRINCIPAL,BINOY JOSEPH,S/O.JOSEPH,AGED 47 YEARS,RAJAGIRI VALLEY.P.O,KAKKANAD,ERNAKULAM-682039.** - **2 MAHATMA GANDHI UNIVERSITY REPRESENTED BY ITS REGISTRAR,PRIYADARSHINI HILLS, ATHIRAMPUZHA.P.O, KOTTAYAM-686650.** - **ADDL.R3 ALL INDIA COUNCIL FOR TECHNICAL EDUCATION (AICTE) REGIONAL OFFICE,REPRESENTED BY ITS DIRECTOR,COLLEGE OF ENGINEERING CAMPUS,THIRUVANANTHAPURAM-695016. (IS IMPLEADED AS ADDL.R3 IN WA 802/2021 AS PER ORDER DATED 6/7/2021 IN IA 1/2021 IN WA 802/2021).** 2 Writ Appeal No.802 of 2021 **ADDL.R4 THE UNIVERSITY GRANTS COMMISSION, BAHADUR SHAH ZAFAR MARG,NEW DELHI110002,REPRESENTED BY ITS SECRETARY (IS SUO MOTU IMPLEADED AS ADDL.R4 IN WA.802/2021 AS PER ORDER DTD 6/7/2021 IN WA.802/2021). BY ADVS. NOUSHAD THOTTATHIL SHRI.SAJITH KUMAR V., SC, ALL INDIA COUNCIL FOR TECHNICAL EDUCATION - AICTE SRI.S.KRISHNAMOORTHY, CGC NOORJI NOUSHAD SURIN GEORGE IYPE, SC** **THIS WRIT APPEAL HAVING COME UP FOR ADMISSION ON 26.05.2023, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** 3 Writ Appeal No.802 of 2021 ## **P.B.SURESH KUMAR & SOPHY THOMAS, JJ.** ## **-----------------------------------------------** **Writ Appeal No.802 of 2021** **----------------------------------------------Dated this the 26[th] day of May, 2023.** ## **JUDGMENT** ## **P.B.Suresh Kumar, J.** This appeal is directed against the judgment dated 15.01.2021 in W.P.(C) No.6700 of 2020. The State and its officials in the Directorate of Collegiate Education who were respondents 1 to 3 in the writ petition, are the appellants in the appeal. Parties and documents are referred to in this judgment for convenience, as they appear in the writ petition. 2. The petitioner is a private college affiliated to the Mahatma Gandhi University and covered by the Direct Payment Scheme of the State Government. Ext.P2 is the direct payment agreement entered into by the College with the State Government on 07.05.1981. In the year 1995, the Government accorded sanction to the College to start a two years Masters Degree Programme in Business Administration with a student 4 Writ Appeal No.802 of 2021 strength of 30. Accordingly, the College was conducting the said Programme with the affiliation of the University. Later, in the year 1999, the College sought permission from the Government to raise the strength of students to be admitted for the Programme from 30 to 60. Ext.P16 is the communication issued by the Government in this regard. As per Ext.P16, the Government permitted the College to raise the strength of students to be admitted for the Programme from 30 to 60 with effect from the academic year 1999-2000 on the condition that there shall not be any financial commitment on the State Government in this regard and that the College shall fulfil the conditions stipulated by the All India Council for Technical Education (AICTE) in the matter of raising the strength of students. In the light of Ext.P16 communication, the College has been conducting the Programme thereafter, with a student strength of 60. 3. It is stated by the petitioner that they have been conducting the Programme with a seven member faculty till 2018 and as they had to relieve two among them from service, one on 26.08.2019 and the other on 29.01.2020, the petitioner made requests before the authorities in the Writ Appeal No.802 of 2021 5 Directorate of Collegiate Education as also the Government, to permit them to conduct selection for appointment of two Assistant Professors in the Department of Business Administration. Similar requests have been made by the petitioner in respect of the vacant posts in other Departments of the College also. The writ petition was filed thereafter seeking directions to the State Government to nominate its representative to constitute the Selection Committee to fill up the vacant posts of teachers including the two posts in the Department of Business Administration, alleging that the requests made by the College in this regard are not being acted upon. The case set out by the petitioner in the writ petition as regards the vacant posts in the Department of Business Administration is that the College is bound to comply with the norms fixed by the AICTE as regards the requirement of faculty, as the Programme is one that is being conducted with the approval of the AICTE in terms of the provisions contained in the AICTE Act; that there shall be one faculty for every 15 students as per the norms fixed by the AICTE; that the student strength of the College for the two year programme being 120, 60 for the first year and 60 for the second year of 6 Writ Appeal No.802 of 2021 the Programme, the College is entitled to have an eight member faculty for the Department of Business Administration and that since they have only five members in the teaching faculty for the said Department, the Government is bound to act upon the requests made by the College in this regard. 4. On 23.06.2020, this Court passed an interim order in the writ petition directing the State Government to constitute a Selection Committee for the selection and appointment of two Assistant Professors in the Department of Business Administration. 5. On 30.10.2020, respondents 1 to 3 filed an interlocutory application seeking orders vacating the interim order dated 23.06.2020 pointing out that since the Government modified the workload criteria of teaching staff in the colleges in the State as per GO(Ms)No.155/2020/H.Edn dated 01.04.2020 in tune with the Regulations issued by the University Grants Commission (UGC) and since the weightage given to postgraduate courses has already been withdrawn, private colleges can have only one teacher for sixteen hours of workload in a week, and that the Government needs to verify the authenticity of the workload of the College, before Writ Appeal No.802 of 2021 7 providing Government representative to the staff selection committee. 6. The petitioner filed a counter affidavit to the said interlocutory application asserting that the norms fixed by the UGC for meeting the faculty requirements of Arts and Science Colleges cannot be applied to the Programme conducted by the College in the Department of Business Administration and that the College is bound to follow the norms fixed by the AICTE for the said purpose, as the Programme is one conducted with the approval of the AICTE in terms of the provisions contained in the AICTE Act. 7. On 18.12.2020, a counter affidavit was filed on behalf of the first respondent in the writ petition contending that the College being only an Arts and Science College, the faculty requirements of the same are to be met based on the workload, in terms of the provisions contained in the Regulations issued by the UGC based on the workload. 8. Although disputes relating to appointment of teaching staff in other departments of the College were also raised in the writ petition, when the writ petition was taken up for final hearing on 15.01.2021, the only dispute that was 8 Writ Appeal No.802 of 2021 subsisting was one relating to the right of the College to appoint two more teaching staff in the Department of Business Administration. The learned Single Judge, in the circumstances, considered the writ petition in the said context. After hearing the parties concerned, the learned Single Judge took the view that inasmuch as affiliation of the AICTE is required for conducting the Programme, the norms to be applied for meeting the faculty requirements of the College are the norms prescribed by the AICTE. Consequently, the writ petition was disposed of, directing the Government to constitute a Selection Committee for the purpose of filling up the two vacancies of Assistant Professor in the Department of Business Administration in the College. As noted, the State and its officials are aggrieved by the decision of the learned Single Judge and hence, this appeal. 9. It is seen that the AICTE and UGC are impleaded in the writ appeal as additional respondents 3 and 4 as per order dated 06.07.2021. 10. The AICTE filed a statement initially and a counter affidavit later in the writ appeal. It is pointed out in their pleadings that the AICTE being a statutory body created 9 Writ Appeal No.802 of 2021 under an Act of the Parliament to lay down norms and standards of technical education throughout the country, the State Government is obliged to follow the norms fixed by the AICTE for ensuring uniform pattern in qualifications and other service conditions of teaching faculty in technical institutions. It is also stated by them in their pleadings that the norms formulated would apply to all programs approved by the AICTE, including the Programme conducted by the College in the Department of Business Administration. It is also stated in their pleadings that the College being an autonomous institution, as per the Approval Process Handbook 2020-21 published by AICTE, the faculty requirement of the Programme is one teaching staff for every 15 students. 11. In an affidavit filed in the course of the proceedings in the appeal, it is stated by respondents 1 to 3, among others, that the workload of the College was assessed by the competent authority as per the norms fixed by the UGC and it was found that the teaching hours of the college per week is only 75 for the Programme conducted by the Department of Business Administration and that the existing teaching staff of the College are therefore, in excess. 10 Writ Appeal No.802 of 2021 12. Heard the learned Senior Government Pleader for respondents 1 to 3, the learned counsel for the petitioner and respective Standing Counsel for the AICTE, the UGC as also the University. 13. The learned Government Pleader persuasively contended that insofar as the College is an Arts and Science College affiliated to the University, the norms to be followed for assessing the faculty requirements of the College are the norms fixed by the UGC for Arts and Science Colleges. It was argued by the learned Government Pleader that the norms fixed by the AICTE under the AICTE Act would apply only to technical institutions which are not affiliated to any University. According to the learned Government Pleader, inasmuch as the workload of such Colleges are assessed based on the norms fixed by the UGC as accepted by the State Government for private colleges covered by the Direct Payment Scheme, the State Government can agree for appointment of faculty in such colleges only in accordance with the norms fixed by the UGC. The learned Government Pleader relied on the decisions of the Apex Court in **Bharathidasan University v. All-India Council for Technical Education** , (2001) 8 SCC 676, 11 Writ Appeal No.802 of 2021 **Parshvanath Charitable Trust v. All India Council for Technical Education** , (2013) 3 SCC 385 and **Assn. of Management of Private Colleges v. All India Council for Technical Education** , (2013) 8 SCC 271, in support of the said contention. The learned Government Pleader has also relied on the decision of the Division Bench of this Court in **Kollengode Educational & Charitable Trust v. All India Council For Technical Education** , 2014 SCC OnLine Ker 28409 for the said purpose. The upshot of the arguments of the learned Government Pleader is that when it comes to the regulation of technical education carried on by institutes/colleges affiliated to a University, the power to regulate is vested with the University and is to be exercised by the University in accordance with the directions and guidelines issued by the UGC. It was pointed out by the learned Government Pleader that the workload of the College in the Department of Business Administration for a week being only 75 hours, the College is entitled to have only four members in their teaching faculty, one each for every 16 hours and the shortfall of 11 hours is to be made up by the College by engaging a guest lecturer. It was stated by the learned Government Pleader that inasmuch as 12 Writ Appeal No.802 of 2021 the College has five members in their faculty for the Department of Business Administration, the Government cannot be found fault with for having not acted upon the request of the College for deputing their nominee for constitution of the Selection Committee, for the purpose of making additional appointments in the said Department. 14. The learned Standing Counsel for the UGC supported the arguments advanced by the learned Government Pleader, pointing out that even assuming that the College is to be regarded as a technical institution, inasmuch as it is affiliated to a University, it can be regulated only by the University and AICTE can function only in an advisory role in the matter of regulation over the field of technical education carried on through affiliated institutes/colleges. 15. Per contra, the learned counsel for the petitioner argued vehemently that the MBA Programme is conducted by the College with the approval of the AICTE and unless the norms prescribed by the AICTE are not followed in the matter of meeting the faculty requirement of the College, the College will lose its approval. It was asserted by the learned counsel that AICTE being a statutory body created under an Act 13 Writ Appeal No.802 of 2021 of the Parliament to lay down the norms and standards of technical education throughout the country, the State Government is obliged to follow the norms fixed by AICTE for ensuring uniform pattern in qualifications and other service conditions of teaching faculty in technical institutions. 16. The stand aforesaid of the learned counsel for the petitioner was ably supported by the learned Standing Counsel for the AICTE. As regards the decisions of the Apex Court relied on by the learned Government Pleader as also the learned Standing Counsel for the UGC to contend that even the power to regulate technical education carried on by institutes/colleges affiliated to a University is vested with the University and is to be exercised in accordance with the directions and guidelines issued by the UGC and that in the context of the said institutions, as the AICTE has only an advisory role, the learned Standing Counsel relied on a few interim orders passed by the Apex Court after the decision in **Assn. of Management of Private Colleges** and it was contended that the said judgment has not been followed by Larger Benches of the Apex Court. It was also argued by the learned Standing Counsel that the Apex Court is now taking a 14 Writ Appeal No.802 of 2021 consistent view that even technical education carried on by institutes/colleges affiliated to a University is to be regulated by the AICTE in accordance with the provisions of the AICTE Act. The essence of the submissions made by the learned Standing Counsel for the AICTE was that the College is required in terms of the provisions of the AICTE Act, to have teaching faculty as fixed by the AICTE. 17. On a query from the Court as to how the College was permitted to have a seven member faculty for the Department of Business Administration, it was clarified by the learned Government Pleader that a seven member faculty was permitted for the College, having regard to the PG weightage given while assessing the workload, by treating one hour of workload as 1.5 hours of workload. It was pointed out that the Government has now withdrawn the PG weightage given while assessing the workload of post graduate courses and it is on that basis that the workload of the College in the Department of Business Administration was re-assessed at 75 hours. 18. Similarly, on a query from the Court, the learned Standing Counsel for the AICTE submitted that in terms of the norms fixed by the AICTE, the College is required to have 15 Writ Appeal No.802 of 2021 one teaching faculty each for every 15 students and the stand taken by the College that they are entitled to have an eight member faculty for the Department of Business Administration, the student strength being 120, 60 for the first year of the programme and 60 for the second year of the programme, is perfectly in order. 19. In the course of the arguments, the learned counsel for the petitioner has handed over a Circular issued by the University on 02.12.1996 informing the College that the Syndicate of the University, in its meeting held on 13.11.1996 had resolved to accept the AICTE norms and staff pattern for fixation of the staff strength for MBA course in affiliated colleges. On a query from the Court, the learned Standing Counsel for the University clarified that the said Syndicate decision stands unaltered even now. 20. We have bestowed our attention to the persuasive arguments made by the learned counsel for the parties. 21. The essence of the decisions of the Apex Court in **Bharathidasan University, Parshvanath Charitable Trust** and **Assn. of Management of Private Colleges** has 16 Writ Appeal No.802 of 2021 been succinctly stated by this Court in paragraph 12 of the judgment in **Kollengode Educational & Charitable Trust.** The said paragraph reads thus: “12. The legal position that emerges, therefore, is that the AICTE is the authority competent to regulate the field of technical education carried on by technical institutes other than those run by the Universities or their component institutes/colleges. When it comes to technical institutes that are affiliated to Universities, the judgment of the Supreme Court in the case of _Association of Management of Private Colleges v. All India Council For Technical Education and Others_ ((2013) 8 SCC 271), clarifies that even such technical institutes can only be regulated by the University in question and the AICTE can only function in an advisory role to the UGC in the matter of regulation over the field of technical education carried on through affiliated institutes/colleges. The upshot of these decisions is that when it comes to the regulation of technical education carried on by institutes/colleges affiliated to a university, the power to regulate is with the University in question and is to be exercised in accordance with the directions and guidelines issued by the UGC.” ## True, after the decision in **Assn. of Management of Private** **Colleges** , the Apex Court has passed a few interim orders in some other matters which are not consistent with the view taken in the said decision. But, we are unable to accept the arguments advanced by the learned Standing Counsel for the AICTE that on account of the said reason, the binding force of the decision of the Apex Court in **Assn. of Management of** 17 Writ Appeal No.802 of 2021 **Private Colleges** is lost. We hold so, as interim orders which do not finally and conclusively decide an issue can never be a precedent [See **State of Assam v. Barak Upatyaka D.U. Karmachari Sanstha** , (2009) 5 SCC 694]. If interim orders cannot be construed as binding precedents, we wonder as to how it could be argued based on the interim orders passed by the Apex Court that the precedential value of the decision in **Assn. of Management of Private Colleges** is lost. 22. Be that as it may, as noticed, the College in the case on hand is a private college affiliated to a University. But for the agreement entered into by the College with the State Government in terms of the scheme formulated by the State Government for direct payment of salary and other allowances to teaching and non teaching staff of private colleges, the College could have taken a decision on their own to have the faculty requirement as fixed by the AICTE. It is since the pay and allowances of teaching and non teaching staff in the College are to be paid by the State Government in terms of the Direct Payment Agreement, that the College has approached the State Government for permission to conduct selection for appointment of teaching staff in terms of the norms fixed by 18 Writ Appeal No.802 of 2021 the AICTE. As noted, Ext.P2 is the Direct Payment Agreement entered into by the College with the State Government. Clause 10 of Ext.P2 agreement provides that the Government shall be liable for direct payment of salary to staff as may be admissible as per the workload and the fixation of staff approved by the University in the case of teaching staff. The said clause reads thus: “10.The Government shall be liable for direct payment of salary only to staff as my be admissible as per the workload and the fixation of staff approved by the University in the case of teaching staff and by the Director of Collegiate Education in the case of non-teaching staff.” In terms of the said provision, the Government is obliged to effect direct payment of salary to teaching staff. As noted, the fact that the Syndicate of the University resolved as early as on 13.11.1996 to accept the AICTE norms and staff pattern for the fixation of staff strength for MBA course in affiliated colleges, is not disputed by the Government. If that be so, according to us, in the light of Clause 10 of Ext.P2 agreement, the State Government is bound to honour the request made by the College to have faculty for the Department of Business Administration fixed in tune with the decision of the University to accept the AICTE norms. Such a view, according to us, will 19 Writ Appeal No.802 of 2021 not go against the decisions of the Apex Court culminated in **Assn. of Management of Private Colleges** , as it has been categorically held in the said decision that even in respect of institutions/colleges affiliated to Universities, as far as technical education is concerned, the norms fixed by the AICTE could be accepted as guidelines. Inasmuch as it is found that the University has decided to accept the norms fixed by the AICTE for fixing the faculty requirement of the College in the Department of Business Administration, according to us, the State Government is obliged to permit the College to have faculty requirement in tune with the said norms. In the said view of the matter, the impugned judgment, to the extent it held that the College is entitled to have faculty in tune with the norms fixed by AICTE, cannot be said to be illegal. The question remaining to be considered is whether the petitioner is entitled to the relief sought for in the writ petition. 23. As noted, when the College sought permission of the Government to raise the strength of the students to be admitted for the Programme from 30 to 60 in the year 1999, the grant of the same by the Government was subject to the conditions that there shall not be any financial commitment on 20 Writ Appeal No.802 of 2021 the State Government in this regard and that the College shall fulfil the conditions stipulated by the AICTE in the matter of raising the strength of the students. Ext.P16, which is the communication issued by the Government in this regard, reads thus: “I am to invite your attention to the references cited and to convey Government concurrence for the increase of student strength of MBA Programme of Rajagiri College of Social Sciences, Kalamassery from 30 to 60 with effect from 19992000 on specific condition that there will not be any financial commitment on the part of the Government and also subject to the condition that the College should fulfil the conditions stipulated by the All India Council for Technical Education.” The effect of the condition in Ext.P16 that there shall not be any financial commitment on the State Government in this regard is that the financial commitment of the State Government under the Direct Payment Agreement will be confined to financial commitment in respect of 30 students. If that be so, even going by the norms fixed by the AICTE for the faculty requirement of the Programme, the strength of the students being only 60, 30 for the first year and 30 for the second year, the teaching staff in the College is in excess, inasmuch as there are already five teachers in the Department. There cannot be any doubt that if the said condition is valid, 21 Writ Appeal No.802 of 2021 the College cannot insist that the Government should permit them to have two more members in the teaching faculty for the Department of the Business Administration. 24. The petitioner has no case that in terms of the provisions contained in the Direct Payment Agreement, the Government is not empowered to impose conditions as indicated in Ext.P16, while permitting a College to raise the strength of the students to be admitted for a Programme. On the other hand, when the learned counsel for the petitioner was required to address the court as to how they could get over the specific condition imposed in Ext.P16 that there will not be any financial commitment on the part of the State Government in the matter of permitting the college to raise the strength of the students to be admitted for the Programme, the stand taken by the learned counsel for the petitioner is that the conditions are imposed without authority of law, as Ext.P16 is only a letter issued by the Principal Secretary to the Government and there was no corresponding Government Order; that the conditions are mutually destructive and that even if the conditions are found to be valid, they can never be a hurdle to fill up two vacant posts of Assistant Professor in the Department, since 22 Writ Appeal No.802 of 2021 the said posts were posts created by the University and admitted by the Government prior to Ext.P16 communication. We are unable to accept the aforesaid arguments. 25. The contention that Ext.P16 is only a letter issued by the Principal Secretary to the Government and that there is no corresponding Government order and hence the same is invalid, is without any substance inasmuch as it is in terms of the very same letter that the petitioner claims that they have admitted 60 students for the Programme from the academic year 1999-2000. The petitioner cannot be heard to contend that the grant in terms of Ext.P16 is valid and the conditions subject to which the grant is made is invalid, as a person drawing benefit from a transaction is not permitted to escape from the disadvantage, if any flowing from it, which is the essence of the principle “approbate and reprobate” [See **Bakshi Ram v. Brij Lal** , 1994 Supp (3) SCC 198]. The contention that the conditions stipulated in Ext.P16 communication are mutually destructive inasmuch as one cannot obey one condition without disobeying the other is also without any substance. If the first condition is accepted as one stipulating that the Government will not undertake in terms of 23 Writ Appeal No.802 of 2021 the provisions of the Direct Payment Agreement the financial commitment arising as a consequence of the enhancement of the students strength, there may not be any difficulty in giving effect to the second condition namely that the College should follow the stipulation made by the AICTE in the matter of raising the strength of the students to be admitted for the Programme. There is nothing on record to indicate on what premise that the University had fixed a seven member teaching faculty for the Department earlier. Be that as it may, inasmuch as it has been found by us that the petitioner is not entitled to the relief sought for in the writ petition, even accepting their case that the norms to be applied for fixing the strength of the faculty are the norms prescribed by the AICTE, according to us, the learned Single Judge was not justified in granting the relief sought for by the petitioner. True, the State Government has not taken a contention to that effect in the writ petition. According to us, merely on account of the said reason, the petitioner cannot be granted the relief sought for in the writ petition when this court finds on facts that they are not entitled to the relief sought for in the writ petition. Needless to say, in the light of the stipulation contained in Ext.P16, the petitioner 24 Writ Appeal No.802 of 2021 is not entitled to have additional members in the faculty for the Department of Business Administration at the expense of the State Government. In the result, the writ appeal is allowed, the impugned judgment is set aside and the writ petition is dismissed. **Sd/-** **P.B.SURESH KUMAR, JUDGE.** **Sd/-** **SOPHY THOMAS, JUDGE.** YKB Writ Appeal No.802 of 2021 25 ## **APPENDIX OF WA 802/2021** ## **PETITIONER'S ANNEXURES** **Annexure A1 PHOTOCOPY OF THE LETTER NO.D4/1397/2020 DATED 24.12.2021 SENT BY THE DIRECTOR OF COLLEGIATE EDUCATION TO THE GOVERNMENT.** - **Annexure A2 PHOTOCOPY OF THE LETTER CUM REPORT NO.FRC/50/22MBA/RCSS DATED 20.06.2022 THE CHAIRMAN, ADMISSION SUPERVISORY COMMITTEE FOR PROFESSIONAL COLLEGE IN KERALA** ## **RESPONDENT ANNEXURES** - **Annexure R3(a) A TRUE COPY OF THE RELEVANT PAGES OF THE AICTE GAZETTE NOTIFICATION DATED 01.03.2019** - **Annexure R3(b) A TRUE COPY OF THE LETTER NO.J2/53/2021/HEDN DATED 24.05.2021 BY THE APPELLANT TO THE 3RD RESPONDENT** - **Annexure R3(c) A TRUE COPY OF THE LETTER NO.F.NO.27/P&AP/PAY/01/2021-22/09 (JULY) DATED 15.07.2021 BY THE 3RD RESPONDENT TO THE APPELLANT** - **Annexure R3(d) A TRUE COPY OF THE FILE NOTE NO.AICTE/ADV/AB/APH/2020-21 DATED 19.02.2020 OF AICTE.** - **Annexure R3(e) A True copy of the relevant pages of the Approval Process Handbook 2022 -23**