WP(Crl.) No. 98 of 2022; WP(Crl.) No. 426 of 2021 This judgment disposes of two connected writ petitions challenging the legality of a further investigation under section 173(8) Cr.P.C in Crime No. 727/2004 (Kollam East P.S.), renumbered as Crime No.119/CB/KLM & PTA/2018 (Crime Branch). The private complaint, filed by Surendra Babu, led to investigation into alleged misappropriation of funds raised for the Golden Jubilee Celebration of the Sree Narayana Trust and its SN College, Kollam. The accused, Vellappally Natesan, served as secretary of the SN Trust and was implicated along with others in misappropriating substantial sums between 1997 and 1999. Initial investigations by Kollam East Police were found wanting, prompting a private writ petition and the formation of a Special Investigation Team. The final report implicating the accused was filed and cognizance taken, but a subsequent request for further investigation—based on Ext.P6 (a letter by a retired Deputy Superintendent of Police) and a public article alleging profits from the exhibition—led to Ext.P9 (order for further investigation) and Ext.P10 (permission). The court, applying a cautious standard (Neeharika) and various precedents, held that the grounds for further inquiry were not legally sustainable, and thus quashed Ext.P9 and set aside Ext.P10. The CJM is directed to proceed with trial based on the final report. The WP involving the accused (426/2021) is dismissed, with remarks limiting observations to the question of further investigation and preserving merits for trial.
This Regular Second Appeal arises from a suit filed under Section 6 of the Specific Relief Act for possession of 70 sq.meters of plaint schedule property at Changanacherry. Priya, the plaintiff, claimed dispossession on 31.01.2012 after the defendant allegedly trespassed and forcibly took possession. The Munsiff's Court held that while the plaintiff failed to establish trespass, she had title and proceeded to decide the matter under Section 5, ultimately granting title-based relief and directing eviction within 30 days. The first appellate court confirmed this. On appeal, the Kerala High Court held that Section 6 suits are summary and confined to possession within six months; they cannot adjudicate title. The lower courts erred by treating the suit as one for title (Section 5) and granting eviction based on title. Relying on several precedents, including Abdul Rahiman v. Nalakath Muhammed Haji, Rosily v. Annam, Adapa Tatarao v. Chamantula Mahalakshmi, and Ponnappan v. Parukutty, the court emphasized that the question of title is immaterial in Section 6 suits and that relief cannot extend beyond possession. It also noted that remedies for improper results include a regular suit on title or revision under Section 115 CPC. The High Court ultimately allowed the appeal and set aside the decrees, indicating the need to pursue proper remedies.
The appellant Omanakkuttan was convicted under Section 8(2) of the Abkari Act for possession of 4 litres of arrack found at Elukadavu, Thannithodu, Pathanamthitta on 30.12.2004. The trial court sentenced him to one year of rigorous imprisonment and a fine of Rs. 1 lakh. On appeal, the defense challenged the link between the seizure and the Chemical Examiner’s report, arguing that the prosecution failed to establish that the contraband substance reached the laboratory and that essential documentary particulars were missing. Specifically, the seizure mahazar (Ext. P1) did not describe the seal and there was no specimen of the seal produced in court. The arrest memo (Ext. P2) bore a crime number, which the defense argued casts doubt on the genesis of the case, especially if the arrest predates registration of the first information report. The defense relied on precedents, including Santhosh v. State of Kerala and other Kerala cases, to contend that such anomalies undermine the link between seizure, arrest, and lab analysis. The prosecution’s failure to demonstrate a tamper-proof chain of custody and the lack of corroborative link evidence between the sample and the tested material led the court to doubt the prosecution’s case. Ultimately, the court acquitted the appellant and allowed the criminal appeal, directing deposit refunds as per law.
This Regular Second Appeal arises from a suit for declaration and permanent prohibitory injunction regarding a plaint B schedule pathway. The appellants (plaintiffs) claim easement by prescription over the B schedule pathway that allegedly existed and was used by their family for access to their A schedule property. The history includes Ext.A1 (1979) documenting a 10 cent property transfer and Ext.A2 (1982) detailing settlement of 15 cents to the first defendant and 7 cents to the first plaintiff, with another pathway provided to access the plaintiff’s land. The defendants deny the existence of the B schedule pathway and maintain that, at best, a northern path existed for the 10 cents property and a southern path for access to the 7 cents, both of which were earlier provided. The trial court dismissed the suit, and the first appellate court affirmed. The High Court, upon review, held that the plaintiffs did not prove a long, continuous, open, and uninterrupted use of the B schedule pathway as of right for the prescribed twenty years under Section 15 of the Indian Easements Act, noting that evidence suggested the relevant use began only around 1995–1996. The appeal was thus dismissed, denying declaration of easement by prescription and upholding the lower courts’ findings.
This is a Criminal Miscellaneous Case under Section 482 CrPC before the Kerala High Court, seeking to quash proceedings in C.C. No. 437/2014, arising from Nedumangad Police Station Crime No. 104/2014. The petitioners, accused Nos. 1 to 4 (Nidhinraj, Arunsivan, Sai Anand, Saransivan), faced charges under Sections 341, 323 and 324 r/w 34 IPC for allegedly restraining a party and causing injuries. The prosecution contends the respondents sustained injuries during the incident, but the parties have now settled their dispute and do not wish to continue the prosecution. The petition relies on affidavits filed by the respondents; the Public Prosecutor, while hesitant, concedes there are no other crimes against the petitioners. The High Court places reliance on established law from State of MP v. Laxmi Narayan and the line of decisions in Gian Singh v. State of Punjab and Narinder Singh v. State of Punjab, laying down the parameters for invoking the inherent power under Section 482 CrPC to quash non-compoundable offences when the dispute is civil/private in character and settled amicably. The court analyzes the prima facie gravity of the offences, the antecedents, and the absence of public interest adversely affected by quashing, concluding that continuing the prosecution serves no useful purpose. Consequently, the petition is allowed and the proceedings are quashed.
This writ appeal concerns the question whether workers employed by a hardware business for loading and unloading of goods constitute ‘head load workers’ under the Head Load Workers Act, 1978. The appellants challenge a registration requirement, arguing that loading and unloading is only incidental to the principal activity of selling hardware, and therefore the workers should not be treated as headload workers subject to registration. The Full Bench in Raghavan v. Superintendent of Police (1998) (2) KLT 732) laid down that if loading and unloading is performed regularly within the establishment, such workers come within the Act, while if they are principally employed for other tasks and only occasionally perform loading/unloading, they may fall outside the headload worker definition; the outcome is fact-specific. The Larger Bench in Theresa Jose v. Sub Inspector of Police, Thoppumpady & Ors. (2015) (1) KLT 485) approved the Full Bench’s approach, particularly paragraphs 23 and 30, reinforcing the principle that whether a worker is a headload worker depends on the predominance of loading/unloading in the establishment. Obrin v. Sub Inspector of Police (2005) (3) KLT 861) is cited to illustrate the incidental-loading scenario. The Kerala High Court ultimately held that incidentally/occasionally engaged loading/unloading workers would not be headload workers and need not be registered under the Act. The appeal was disposed of, with a direction to the SHO to provide police protection when disturbances arise, and a general caveat that police protection may be directed as needed. The decision harmonizes statutory definitions with practical workplace realities.
This appeal by the complainant A.V. John challenges a trial court judgment dated 15.09.2000 under Section 138 of the Negotiable Instruments Act (NI Act) that acquitted the accused George Joseph. The underlying dispute arises from a loan of Rs. 35,000, evidenced when the accused issued a cheque dated 20.05.1996 to settle the debt. The cheque was dishonoured on 21.05.1996 for funds insufficiency, prompting a statutory notice dated 01.06.1996 (Exhibit P3) and related postal documents (Exhibits P4–P5). The trial court found no proof of summons of ledger extracts to establish the exact date of dishonour and the date of presentation, leading to acquittal under Section 255(1) Cr.P.C. At the Kerala High Court, the appellant’s counsel urged that the cheque and dishonour memo establish timely presentation and that the statutory notice was issued within the statutory period. He invoked Section 146 NI Act and cited Manoharan v. Selvini Shabu and P Soman v. Thomas Paul to support the sufficiency of a dishonour memo. The respondent argued for ledger extracts and contends the notice is vague for including interest. The High Court held that the period for issuing notice under Section 138 is counted from receipt of information by the payee about the cheque’s return unpaid, not from the dishonour date, and that the notice’s inclusion of interest is severable. The appeal is allowed; the trial court’s acquittal is set aside, and the accused is convicted under Section 138 NI Act with Rs.70,000 compensation and a four-month simple imprisonment, with payment within three months and a date to appear for sentencing.
This Kerala High Court writ petition concerns the registration of a sale certificate in a mortgaged property in favour of the auction purchaser, challenged by the State Bank of India (SBI). SBI had mortgaged about 0.66 acres at Kozhencherry; after default, the bank initiated SARFAESI proceedings and the property was auctioned. The bank contends that the sale certificate cannot be registered because the sale is impeded by an alleged attachment order under the CrPC, issued by the Judicial First Class Magistrate, Peermade. The petitioner argues that there was no valid attachment order under Sections 82 and 83 Cr.P.C.; what existed was only a proclamation under Section 82, and subsequent steps by village officers mistakenly treated this as an attachment under Section 83. The respondents contended that steps under Sections 82 and 83, including proclamation and attachment, were in motion, supported by forest case records and village officer certificates. The court scrutinizes order sheets and exhibits spanning 2016–2023, and ultimately relies on decisions in Molly v. State of Kerala, Nithya Shambhavananda v. State of Karnataka, and MD. Nazrul Islam v. State of Assam to emphasize that Sections 82 and 83 Cr.P.C. are distinct and require explicit attachment orders. Finding no valid attachment under Section 83, the court allows SBI’s writ petition and directs registration of the sale certificate, while directing the expunction of attachments from the record.”
This is a suo motu matter initiated in the High Court of Kerala, Ernakulam, by the Travancore Devaswom Board (TDB) concerning the annual festival at Thuravoor Mahakshethram (Thiruvulsavam) and the conduct/auction of stalls in front of the temple. The petition, registered as DBP No. 62 of 2022 on 11 October 2022, arises from a devotee’s complaint alleging irregularities and obstructions during the auction process initiated by the Deputy Devaswom Commissioner, Vaikom. The court summoned and impleaded several parties, including the State of Kerala, the TDB, the Administrative Officer, the Temple Advisory Committee, the local Police, and newly impleaded respondents such as Sree Narasimha Seva Samithi and others, to ensure a fair and lawful auction process and the safety of devotees and pedestrians. The orders of 13–14 October 2022 laid down the framework: auctions must follow the approved layout, avoid obstructing traffic on Chavadi-Thuravoor Road and the NH-66 service road, and rely on prior judgments (Satheesh v. Travancore Devaswom Board) and related precedents (Abu K.S., M.V. Ramasubbiar) to ensure prudent, revenue-generating conduct. By 2023, the court directed removal of obstructions, the use of a vacant 3-acre land behind the temple for stalls, and a revised layout to be prepared by the District Collector with a two-month deadline for approval, culminating in disposal of the DBP with directions.
This is a Kerala High Court second appeal by the plaintiff, P. Hydrose, challenging a decree in a land dispute. The plaintiff claimed title to plaint A and B schedule lands under documents 1555/85 and 2736/85 of SRO, Ernakulam, and sought a declaration that plaint C schedule land, re-surveyed and classified as Kayal Puramboke, is part of his registered holding and that its classification and any attempted assignment under the Kerala Land Assignment Act are illegal. The re-survey, based on de facto possession with boundaries, allocated portions to different Re-Survey numbers and labeled a substantial area as Puzha Puramboke, i.e., government land. The defendants argued that plaint C schedule land is indeed Kayal Puramboke (Puzha Puramboke) and not part of the plaintiff’s holdings; the record showed encroachment by the plaintiff’s power of attorney holder on Puramboke land and reliance on resurvey entries. The trial court dismissed the suit for lack of cogent evidence to prove title and possession in plaint C schedule. The first appellate court affirmed, and the High Court, under Section 100 CPC, dismissed the second appeal, holding that the plaintiff failed to prove his title, the land is government puramboke, and the prior High Court decision in O.P.No.16077/1996 has settled the issue. Water-bodies doctrine is cited to support non-alienation of puramboke land.
Bail Appl. No. 8893 of 2023 This is a Kerala High Court anticipatory bail petition (Bail Appl. No. 8893/2023) filed by Ashik in Crime No. 562/2023 of Pazhayannur Police Station, Thrissur district, alleging offences under IPC sections 376(2)(i), 354, 354A(1)(i), 354B and under the Protection of Children from Sexual Offences Act (POCSO) sections 4(2), 3(b), 6 and 5(l). The accusation is that the petitioner sexually abused and raped the minor sister of his wife on multiple occasions starting January 2021. The petitioner asserts matrimonial discord between his wife and his son led to a string of FIRs and that the earlier bail granted to the petitioner’s father in Crime No.561/2023 indicates the allegations may be manufactured to retaliate within family disputes. He contends there is no prior allegation in Crime No.540/2023 that the petitioner abused his wife’s younger sister and thus that the case is fabricated. The court places weight on peculiar factual matrix: the elder sister of the victim is married to the petitioner’s son, and the sequence of FIRs does not show direct abuse of the minor sister. Relying on Bhadresh Bipinbhai Sheth and Siddharam Satlingappa, and noting the principle from Sushila Agarwal that anticipatory bailes remain within custody-like safeguards, the court grants anticipatory bail subject to conditions. The order emphasizes the liberty to cancel bail for misuse and the need to balance investigation with protection against harassment, while keeping the accused under supervision until trial.
Crl Appeal No.1099 of 2009 Vijayakumar, the appellant, challenges a conviction under Section 58 of the Abkari Act by the Fast Track-II Sessions Court, Thiruvananthapuram. On 08.08.1997 at 2:00 p.m., the accused was found in possession of 5 litres of arrack at Udayankulangara, violating the Abkari Act. After investigation, a final report was filed under Section 55(a) of the Abkari Act and the case was committed to the Sessions Court from the Magistrate. The trial court convicted him after trial and his statement under Section 313 Cr.P.C. The defense contends that the prosecution failed to prove that the contraband reached the Chemical Examiner’s Laboratory and highlights defects: Ext.P1 seizure mahazar does not describe the seal; the specimen of the seal was not produced; the forwarding note was not marked; key transit officials were not examined. The prosecution relies on Ext.P3, the Chemical Analysis Certificate, but the defense and several referenced precedents underscore that lack of proper chain of custody undermines the reliability of laboratory analysis. The Kerala High Court cites Bhaskaran v. State of Kerala, Rajamma v. State of Kerala, Ramachandran v. State of Kerala, Daulat Ram, and Vijay Pandey to emphasize chain-of-custody requirements and corroboration between seized samples and lab reports. Ultimately, the court finds the evidence insufficient to sustain the conviction and allows the appeal, acquitting the appellant and directing release and restitution of deposits as per law.
This writ petition challenges the disciplinary actions and retirement benefits withheld by SupplyCo and the Kerala Civil Supplies Corporation against S. Rajasekharan Nair, a retired assistant sales manager who retired on 31 May 2018. The petitioner contends that the charge memo (Exhibit P1), several notices (Exhibits P6–P9), the disciplinary order (Exhibit P13) and a demand notice (Exhibit P22) were issued/arose without a proper inquiry, rendering them arbitrary, illegal and violative of due process. He seeks quashing of these records and mandamus to disburse retirement benefits, including gratuity, with 12% interest from the retirement date, and compensation for alleged negligence. The respondents counter that allegations of financial irregularities warranted inquiry and that actions were taken under appropriate rules; however, the court notes no proper enquiry was conducted and no penalty imposed in accordance with law, and that several liabilities were pursued only after retirement. The court cites University of Kerala v. Dr. Sobha (2020 KHC 184) and Tewari D.D. (D) v. Uttar Haryana Bijli Vitran Nigam Ltd. (2014 KHC 4492) to support entitlement to gratuity and due-process considerations. Ultimately, the judge holds that gratuity was improperly withheld and directs payment of statutory interest, along with release of other retirement benefits with 6% interest, and sets aside the challenged records; the petition is disposed of accordingly in part.
The petitioner, Jeny Thankachan, a sleeping partner in the 3rd respondent LLP, seeks to declare that the Insolvency and Bankruptcy Code, 2016 (IBC 2016) shall have overriding effect over the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (SARFAESI Act) in light of Ext. P3 Government Order dated 15.11.2019, which purportedly brought into force Sections 78, 79 and 94–187 of the IBC 2016 for individuals and partnership firms. The petitioner asserts a 20% share in the LLP under Section 23(4) of the LLP Act, 2008, and has initiated insolvency proceedings under Section 94 of the IBC 2016 before the NCLT, Kochi Bench (Diary No. 1386/2023). Meanwhile, the 5th respondent-bank invoked SARFAESI proceedings in Misc. Case No. 372/2023, and an Advocate Commissioner was appointed via Ext. P6 to take possession of the property. The petitioner contends that initiation of insolvency resolution should stay any securitisation actions under Sections 96 and 101 of the IBC 2016, especially given the joint-family nature of the property. The bank counters that the Supreme Court in State Bank of India v. B. Ramakrishnan held that moratorium under the IBC does not extend to personal guarantors of corporate debtors, and that the NCLT has not admitted Ext. P4, with no regular case number, thus no deemed moratorium. The court ultimately holds that IBC 2016 does not fully override SARFAESI 2002 and that the petition lacks merit, dismissing the writ petition.
This Division Bench of the High Court of Kerala deals with a suo motu petition concerning the Ernakulathappan Ground, a Devaswom land attached to Ernakulam Siva Temple. The petition, initiated on the court’s own motion after a submission by a former judge, concerns the ground’s pathetically poor state of maintenance and cleanliness. An Advocate Commissioner was appointed to inspect and report, with subsequent directions for explanations from the Cochin Devaswom Board’s officials and for removal of waste material connected to temple activities such as Flower-show and Grihapakarana Mela. Over successive hearings (27.10.2022; 01.11.2022; 08.11.2022; 21.11.2022), the court recorded photographs, directed maintenance orders, and later suo motu impleaded the Ernakulam Kshethra Kshema Samithi as the 4th respondent. By December 2022 and into 2023, the Court reiterated the ground must be kept clean, without permanent construction, and that the Board’s administration must act with fiduciary diligence. On 12.04.2023 and 22.12.2022 directions were issued to ensure periodic removal of waste and to involve the Temple Advisory Committee for cooperation. The matter culminates in a disposition directing ongoing maintenance obligations and conditioned permissions for fairs to include waste-removal provisions and deposit refunds upon cleanup, safeguarding Devaswom property.
The petitioner, Anil G.L., challenges a Family Court Nedumangad order in MC 496/2015 directing him to pay maintenance to his wife, Jisha Devidson, and their minor child, Adish J. Anil, under Section 125 CrPC. The respondents had approached the Family Court seeking monthly maintenance on the ground of desertion since 2014 and lack of means, while the petitioner disputed their marriage's validity, having filed OP 275/2015 seeking a declaration of nullity. The respondents testified, and evidence included Exts P1–P3; the petitioner claimed the first respondent’s marriage was subsisting on the alleged date of ceremony. He admitted paternity of the second respondent and argued that the first respondent had means to support herself. The Family Court partly allowed the application, fixing maintenance at Rs. 9,000 for the wife and Rs. 4,000 for the child from 17.12.2015. The High Court noted authorities to the effect that maintenance is a social-justice remedy under the law and that the validity of marriage cannot be adjudicated in a Section 125 proceeding, citing Pyla Mutyalamma and Sivadasan PK, and Rajnesh, Captain Kaushal, and Bhuwan Mohan Singh. It held that there is a presumption of marriage in the absence of contrary evidence but found no illegality in the impugned order; the revision petition was dismissed, though liberty was granted to pursue a separate declaratory suit on marital status. The court left the maintenance order intact and allowed adjustment of any deposited interim amount against arrears.
CRP 518 of 2018; CRP 696 of 2019 This combined High Court judgment from Kerala deals with two Civil Revision Petitions challenging an order of the Additional District Judge, North Paravur, in O.P. (Electricity) No. 90 of 2011, awarding compensation for trees cut and for diminution in land value caused by the construction of 400 kV transmission lines by Power Grid Corporation of India Ltd. The claimant, Sreenivasan M.G, owned land in Pattimattom Village, where vast numbers of trees (coconut, areca palm, nutmeg, pepper) were felled to facilitate the transmission project, rendering parts of the land less valuable. The lower court computed losses by valuing yields from the felled trees year by year, applying prices per nut, dried produce weights, and an appropriate multiplier to estimate net income loss. For land diminution, the court relied on Ext.A2 sale deed and commission reports (Exts.C1, C1(j), C1(k)) and fixed the land value at Rs. 1,20,000 per cent, awarding 50% of the land value for the affected 10.12 ares (25 cents). Interest was fixed at 8% per annum. The court relied on the Supreme Court’s approach in KSEB v. Livisha (2007) 6 SCC 792 to justify the diminution-in-value assessment and held that government guidelines are not binding on fixation of compensation. The High Court dismissed both revisions, directing payment of enhanced compensation within three months, and maintained the lower court’s approach.
This Regular First Appeal (RFA No. 559/2017) before the Kerala High Court concerns a dispute over specific performance of a sale of land in Adinadu Village, Karunagappally Taluk. Defendants Arifa Beevi and Shamna owned 3.5 acres comprising re-survey Nos. 177/23/2/1 and 177/23/2/2, and had an earlier ex parte decree in favor of Rahim, who claimed rights under a sale agreement. The plaintiff, Nizarudeen, alleges that on 17/11/2012 he entered into an agreement with the defendants to purchase the property for Rs 55,84,000 and paid Rs 10 lakhs as advance. Defendants contend no sale agreement exists; they allege the plaintiff is a real estate broker and that a blank stamp paper was signed to settle a monetary claim rather than to effect a sale. The trial court found the agreement was executed by the defendants and a decree of specific performance was issued. On appeal, the High Court scrutinized the discretionary nature of specific performance (Section 20(2) of the Specific Relief Act, 1963) and examined the totality of circumstances, including the plaintiff’s conduct and the defendants’ financial motivations. It observed a pattern of dubious real estate dealings involving vulnerable women and concluded the plaintiff failed to explain the surrounding circumstances adequately. Consequently, the appeal was allowed; the impugned judgment and decree were set aside, and the court ordered refund of Rs.10,00,000 with interest (6% p.a.) within two months, along with costs. The decision underscores the court’s discretion to deny specific relief where circumstances render it inequitable or potentially exploitative.
Joy Kutty K.K. and Kunjamma K.K filed this writ petition (criminal) in the Kerala High Court seeking transfer of investigation in Crime No.1798/2020 of the Adoor Police Station to the Central Bureau of Investigation (CBI) regarding the death of their son, Joel M.J., following an incident on 1 January 2020. The petition asserts that the Circle Inspector and police personnel assaulted the victim while he was detained after a road traffic collision, and that witnesses and a hospital doctor were allegedly silenced to conceal the alleged torture. A prior petition, W.P.(C) No.11907/2020, directed consideration of a representation to the State Police Chief, and the petitioners were heard in January 2023. The respondents produced an action taken report and a postmortem-based analysis by experts, indicating the death was due to occlusive coronary artery disease, with a history of cardiac arrest and Hepatitis A, and asserting no evidence of police brutality. The court relied on Vishal Tiwari v. Union of India and Others, holding that transfer of investigations should be exercised sparingly and only in extraordinary circumstances, requiring cogent evidence of inadequacy or bias. Finding no such circumstances, the court dismissed the petition, underscoring deference to the investigating agency unless justice demands otherwise.
CRL.A Nos. 2337 and 2338 of 2006 These are two connected criminal appeals under section 374(2) Cr.P.C. arising from the conviction of three accused for an NDPS offence (Section 20(b)(i) of the NDPS Act) following a police seizure of ganja from a jeep in Kasaragod on 25 April 2000. The investigating team, including PW2 (detecting officer), PW1, and PW5, intercepted the vehicle KL-02D/9034 near the Taluk Headquarters Hospital, recovered ganja from a hidden secret cell, and arrested the accused at the place of occurrence. A crime no. 195/2000 was registered, and Exts. P1–P5, along with MO1–MO5, comprised the documentary chain. The trial court convicted all three, sentencing them to three years’ rigorous imprisonment with a fine of ₹25,000 and a default term. On appeal, the prosecution relied on PW1–PW5, but the defense highlighted the absence of independent witnesses, and raised serious concerns about the arrest/memo sequence—specifically the presence of the crime number in arrest memos prepared at the scene, and entry of the number in the FIR later at the station. The High Court found the prosecution’s case doubtful regarding the manner of arrest and seizure and, exercising the benefit of doubt, allowed the appeals and acquitted the accused, setting aside the trial court’s judgment and orders.
