BY AD v. P.SATHISAN

BY ADVS.MANU S., DSG OF INDIA SHRI.SHEEJO CHACKO, SC, CHALAKUDY MUNICIPALITY P.R.AJITH KUMAR SMT K R DEEPA SPL GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON

14.02.2024, ALONG WITH WP(C).13782/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -5- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 14TH DAY OF FEBRUARY 2024 / 25TH MAGHA, 1945 WP(C) NO. 5482 OF 2022 PETITIONER/S: ATC TELECOM INFRASTRUCTURE PVT LTD (FORMERLY KNOWN AS WIRELESS TT INFO SERVICE LTD., ESSAR TELECOM INFRASTRUCTURE PVT LD AND VIOM NETWORKS LTD), ATC HOUSE, 65/1826-28, CHERAMANGALAMTH, SHENOY ROAD, KALOOR, ERNAKULAM , KOCHI-17, REP BY HEAD LEGAL BABU PATTATHANAM, AGED 40 YEARS, S/O. CHANDRAN, RESIDING AT DEVARAGAM, RAMANATTUKARA P.O., PIN-673 633. BY ADVS. P.SATHISAN DONA AUGUSTINE RESPONDENT/S: 1 2 3 UNION OF INDIA DEPARTMENT OF INFORMATION AND TECHNOLOGY, SOUTH DELHI P.O. NEW DELHI-110 003, REPRESENTED BY ITS SECRETARY STATE OF KERALA, REPRESENTED BY CHIEF SECRETARY, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM P.O., PIN-695 001 SECRETARY, LOCAL ADMINISTRATION DEPARTMENT, SECRETARIAT, THIRUVANANTHAPURAM P.O., PIN-695 001 W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -6- 4 5 6 DIRECTOR OF MUNICIPALITIES, SWARAJ BUILDING, NANDANKODE, KAWADIAR P.O., THIRUVANANTHAPURAM-695 003 ERATTUPETTA MUNICIPALITY, NADACKAL, ERATTUPETTA P.O., KOTTAYAM-686 121, REPRESENTED BY ITS SECRETARY THE SECRETARY, ERATTUPETTA MUNICIPALITY, NADACKAL, ERATTUPETTA P.O., KOTTAYAM-686 121 BY ADVS. N.J.ASHWIN SUNIL V.MOHAMMED SMT K R DEEPA SPL GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON

14.02.2024, ALONG WITH WP(C).13782/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -7- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 14TH DAY OF FEBRUARY 2024 / 25TH MAGHA, 1945 WP(C) NO. 13780 OF 2022 PETITIONER/S: ATC TELECOM INFRASTRUCTURE PVT.LTD., (FORMERLY KNOWN AS ATC TELECOM TOWER CORPORATION AND ESSAR TELECOM INFRASTRUCTURE PVT. LTD., VIOM NETWORKS LTD AND WIRELESS TT INFO SERVICES LTD.), ATC HOUSE, 65/1826- 28, CHERAMNAGALATH, SHENOY ROAD, KALOOR, KOCHI-17 REP.BY HEAD - LEGAL, BABUPATTATHANAM, AGED 40 YEARS, S/O CHANDRAN, RESIDING AT DEVARAGAM, MANALUDI, RAMANATTUKARA P.O. PIN-673633. BY ADVS. P.SATHISAN DONA AUGUSTINE RESPONDENT/S: 1 2 3 UNION OF INDIA, DEPARTMENT OF INFORMATION AND TECHNOLOGY, SOUTH DELHI P.O., NEW DELHI-110003, REPRESENTED BY ASSISTANT SOLICITOR GENERAL. STATE OF KERALA REPRESENTED BY THE CHIEF SECRETARY, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM P.O., PIN - 695001. THE SECRETARY, LOCAL ADMINISTRATION DEPARTMENT, GOVT. SECRETARIAT, THIRUVANANTHAPURAM P.O., PIN-695001. W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -8- 4 5 6 DIRECTOR OF MINCIPALITIES, SWARAJ BUILDING, NANDANKODE, KAWADIAR POST, THIRUVANANTHAPURAM - 695003. THIRUVANANTHAPURAM MUNICIPAL CORPORATION, VIKAS BHAVAN P.O., THIRUVANANTHAPURAM - 695 033. REP. BY ITS SECRETARY THE SECRETARY, THIRUVANANTHAPURAM MUNICIPAL CORPORATION, VIKAS BHAVAN P.O., THIRUVANANTHAPURAM - 695 033. BY ADVS. N.NANDAKUMARA MENON (SR.) SHRI.P.K.MANOJKUMAR,SC,TVPM CORPORATION SUMAN CHAKRAVARTHY SMT K R DEEPA SPL G P THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON

14.02.2024, ALONG WITH WP(C).13782/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -9- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 14TH DAY OF FEBRUARY 2024 / 25TH MAGHA, 1945 WP(C) NO. 14015 OF 2022 PETITIONER/S: ATC TELECOM INFRASTRUCTURE PVT.LTD, (FORMERLY KNOWN AS ATC TELECOM TOWER COPORATION AND ESSAR TELECOM INFRASTRUCTURE PVT. LTD., VIOM NETWORKS LTD. AND WIRELESS TT INFO SERVICES LTD.), ATC HOUSE, 65/1826- 28, CHERAMNAGALATH, SHENOY ROAD, KALOOR, KOCHI-17, REP. BY HEAD-LEGAL, BABU PATTATHANAM, AGED 40 YEARS, S/O.CHANDRAN, RESIDING AT DEVARAGAM, MANALUDI, RAMANATTUKARA P.O., PIN-673633. BY ADVS. P.SATHISAN DONA AUGUSTINE RESPONDENT/S: 1 2 3 UNION OF INDIA, DEPARTMENT OF INFORMATION AND TECHNOLOGY, SOUTH DELHI P.O., NEW DELHI-110003, REPRESENTED BY ASSISTANT SOLICITOR GENERAL. STATE OF KERALA, REPRESENTED BY THE CHIEF SECRETARY, GOVERNMENT SECRETARIAT, THIRUVANANTHAPRUAM P.O., PIN-695001. SECRETARY, LOCAL ADMINISTRATION DEPARTMENT, SECRETARIAT, THIRUVANANTHAPURAM P.O., PIN-695001. W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -10- 4 5 6 DIRECTOR OF PANCHAYATS, PUBLIC OFFICE BUILDING, MUSEUM P.O., THIRUVANANTHAPURAM- 695033. KUMBLA GRAMA PANCHAYATH, KUMBLA-BADAIKA ROAD, KUMBLA P.O., KASARAGOD -671321, REP. BY ITS SECRETARY. THE SECRETARY, KUMBLA GRAMA PANCHAYATH, KUMBLA-BADAIKA ROAD, KUMBLA P.O., KASARAGOD -671321. BY ADV P.K.MOHAMMED SMT K R DEEPA SPL G P THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON

14.02.2024, ALONG WITH WP(C).13782/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -11- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 14TH DAY OF FEBRUARY 2024 / 25TH MAGHA, 1945 WP(C) NO. 14044 OF 2022 PETITIONER/S: ATC TELECOM INFRASTRUCTURE PVT LTD., (FORMERLY KNOW AS ATC TELECOM, TOWER CORPORATION AND ESSAR TELECOM INFRASTRUCTURE PVT. LTD.), VIOM, NET WORKS LTD AND WIRELESS TT INFO SERVICES LTD), ATC HOUSE, 65/1826- 28, CHERAMNAGALATH, SHENOY, ROAD, KALOOR, KOCHI 17, REP. BY HEAD- LEGAL, BABU PATTATHANAM, GED 40 YEARS, S/O. CHANDRAN, RESIDING AT DEVARAGAM, MANALUDI, RAMANATTUKARA P.O., 673 633. BY ADV P.SATHISAN RESPONDENT/S: 1 2 3 4 UNION OF INDIA, DEPARTMENT OF INFORMATION AND TECHNOLOGY, SOUTH DELHI P.O., NEW DELHI 11003, REPRESENTED BY ITS SECRETARY. STATE OF KERALA, REPRESENTED BY CHIEF SECRETARY, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM P.O., 695 001. SECRETARY, LOCAL ADMINISTRATION DEPARTMENT, SECRETARIAT, THIRUVANANTHAPURAM P.O., 695 001. DIRECTOR OF PANCHAYATHS, PUBLIC OFFICE BUILDING, MUSEUM W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -12- P.O., THIRUVANANTHAPURAM 695 033. 5 6 RANNI PAZHAVANGADI GRAMA PANCHAYAT, PAZHAVANGADI P.O, RANNI, PATHANAMTHITTA 689 873, REP. BY ITS SECRETARY. THE SECRETARY, RANNI PAZHAVANGADI GRAMA PANCHAYAT, PAZHANGADI P.O, RANNI, PATHANAMTHITTA 689 873. BY ADV SHRI.C.DINESH, CGC SMT DEEPA K R SPL G P THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON

14.02.2024, ALONG WITH WP(C).13782/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -13- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 14TH DAY OF FEBRUARY 2024 / 25TH MAGHA, 1945 WP(C) NO. 18412 OF 2022 PETITIONER/S: ATC TELECOM INFRASTRUCTURE PVT LTD., (FORMERLY KNOWN AS ATC TELECOM TOWER CORPORATION AND ESSAR TELECOM INFRASTRUCTURE PVT. LTD., VIOM NETWORKS LTD AND WIRELESS TT INFO SERVICES LTD.), ATC HOUSE, 65/18 26 , 28, CHERAMNAGALATH, SHENOY ROAD, KALOOR, KOCHI - 17 REP. BY HEAD - LEGAL, BABU PATTATHANAM, AGED 40 YEARS, S/O CHANDRAN, RESIDING AT DEVARAGAM, MANALUDI, RAMANATTUKARA P.O. PIN-673633.. BY ADVS. P.SATHISAN DONA AUGUSTINE RESPONDENT/S: 1 2 3 UNION OF INDIA, DEPARTMENT OF INFORMATION AND TECHNOLOGY, SOUTH DELHI P.O., NEW DELHI-110003, REPRESENTED BY ASSISTANT SOLICITOR GENERAL. STATE OF KERALA REPRESENTED BY THE CHIEF SECRETARY, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM P.O., PIN - 695001. THE SECRETARY, LOCAL ADMINISTRATION DEPARTMENT, GOVT. SECRETARIAT, THIRUVANANTHAPURAM P.O. 695 001. W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -14- 4 5 6 DIRECTOR OF MUNICIPALITES, SWARAJ BUILDINGS, NANDANKODE, KAWADIAR POST, THIRUVANANTHAPURAM 695 003. TANUR MUNICIPALITY, REP. BY ITS SECRETARY, TANUR P.O., MALAPPURAM 676 302. THE SECRETARY, TANUR MUNICIPALITY, TANUR P.O., MALAPPURAM 676 302. SMT DEEPA K R SPL G P THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON

14.02.2024, ALONG WITH WP(C).13782/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -15- J U D G M E N T [WP(C) Nos.13782/2022, 1496/2022, 5482/2022, 13780/2022, 14015/2022, 14044/2022, 18412/2022] All these writ petitions have common questions of law and fact. Therefore, these petitions have been taken together for hearing and are disposed of by this common judgment.

2. The petitioners in all these writ petitions are one and the same, i.e., M/s ATC Telecom Infrastructure Pvt Ltd. The petitioner renders services of providing passive telecom infrastructure for telecom service providers. For the purpose of establishing the passive telecom infrastructure, mobile telecom towers are to be constructed after obtaining due permission from the respective local authorities in the State of Kerala under the provisions of the Kerala Panchayath Raj Act 1994, the Kerala Municipality Act 1994, the Kerala W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -16- Municipality Building Rules 1999 and the Kerala Panchayath Building Rules 2011,

2.1 The mobile towers were not subjected to property tax previously. However, for the first time, mobile towers were brought within the property tax bracket in 2009. It is only in the year 2011 that the State of Kerala issued notifications bearing numbers 17/2011 and 19/2011 fixing upper limits and lower limits for imposing property taxes by Panchayaths and Municipalities on properties situated within their respective jurisdictional limits.

3. The petitioner has filed the present writ petitions impugning the demand notices for property tax issued to the petitioner. Learned Counsel for the petitioner submits that no assessment and demand can be made of the property tax in case of escaped assessment for a period of four years prior to the date of issuance of the notice as per the provisions of W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -17- Section 282 of the Kerala Municipality Act 1994 and Kerala Panchayath Raj Act 1994.

3.1 It is also submitted that no recovery of property tax can be effected from a person three years after the tax is assessed in view of Section 539 of the Kerala Municipality Act.

4. Ms K R Deepa, Learned Special Government Pleader (LSGD) does not dispute the legal position that if a tax is assessed then the recovery can be effected within the period of three years from the date of assessment order and if it is the case of escaped assessment, no tax can be assessed and demanded for a period earlier than four years from the date of notice of demand.

5. Sections 282 and 539, which are relevant for the purposes of these writ petitions are extracted hereunder: “282. POWER TO ASSESS IN CASE OF ESCAPE FROM ASSESSMENT.— Notwithstanding anything to the contrary W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -18- contained in this Act or the rules made thereunder, where for any reason a person liable to pay any tax or fees leviable under this Chapter has escaped assessment in any half- year, the Secretary may at any time within four years from the date on which such person should have been assessed, serve on him a notice assessing to the tax or fee due and demanding payment thereof within fifteen days from the date of such service and thereupon the provisions of this Act and the rules made thereunder shall, so far as may be, apply as if the assessment was made in the half-year to which the tax or fee relates.

539. LIMITATION FOR RECOVERY OF DUES.— (1) No distraint shall be made, no suit shall be instituted and no prosecution shall be commenced in respect of any sum due to a Municipality under this Act after the expiration of a period of three years from the date on which distraint might first have been made, suit might first have been instituted, or prosecution might first have been commenced, as the case may be, in respect of such sum: Provided that in the case of assessments made under section 282 the said period of three years shall be computed from the date on which distraint might have been made, suit instituted, or prosecution commenced, after the assessment under the said section shall have been made. W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -19- (2) Where any amount due to the Municipality has been barred by limitation under subsection (1) due to the default of not taking steps at the appropriate time, and it is found in a lawful enquiry that it was lost due to the default of any officer or officers, the amount so lost to the Municipality shall be realised with twelve per cent interest thereon from such officer or officers.”

6. The language of the aforesaid two sections is plain and explicit. Admittedly, no assessment order was passed before the demand of the property tax in respect of the mobile towers erected by the petitioner. These notices have been issued demanding tax not only for the last four years from the date of the notice but earlier to that.

6.1 In view thereof, the demand notices are unsustainable and the same are set aside. The matter is remitted to the respective Municipality/Panchayat, as the case may be, to issue fresh notice in respect of the property tax for W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -20- the last four years from the date of the impugned notices. Thereafter finalize the assessment orders in accordance with the law, after giving an opportunity of hearing to the petitioner. With the aforesaid directions, the present writ petitions stand allowed in part. Sd/- DINESH KUMAR SINGH JUDGE W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -21- APPENDIX OF WP(C) 1496/2022 PETITIONER EXHIBITS Exhibit P1 Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF THE CERTIFICATE OF REGISTRATION OF THE PETITIONER COMPANY. TRUE COPY OF PRINT OUT OF NOTIFICATION DATED 14.01.2011., Exhibit P2 (A) TRUE ENGLISH TRANSLATION OF EXHIBIT P1 NOTIFICATION. Exhibit P3 Exhibit P4 Exhibit P5 Exhibit P6 Exhibit P7 Exhibit P8 TRUE COPY OF THE INTERIM ORDER PASSED BY THE HONBLE HIGH COURT OF KERALA IN WPC NO. 22723/2011 DATED 20.08.2011. TRUE COPY OF DEMAND NOTICE NO. R2-3428/14 ISSUED BY CHALAKUDY MUNICIPALITY (BUILDING NO. XXIV/157 (DI-UA). TRUE COPY OF OBJECTION SUBMITTED BY THE PETITIONER BEFORE THE 5TH RESPONDENT DATED 15.12.2021 (BUILDING NO. 157 (DI-UA). TRUE COPY OF INTERIM ORDER PASSED BY THE HONBLE HIGH COURT OF KERALA IN WPC NO. 12762/2018 DATED 11.04.2018. TRUE COPY OF INTERIM ORDER PASSED BY THE HONBLE HIGH COURT OF KERALA IN WPC NO. 12729/2018 DATED 10.04.2018. TRUE COPY OF INTERIM ORDER PASSED BY THE HONBLE HIGH COURT OF KERALA IN WPC NO. 35145/2019 DATED 19.12.2019. W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -22- Exhibit P9 Exhibit P10 TRUE COPY OF INTERIM ORDER PASSED BY THE HONBLE HIGH COURT OF KERALA IN WPC NO. 28114 OF 2020 DATED 16.12.2020. TRUE COPY OF INTERIM ORDER PASSED BY THE HONBLE HIGH COURT OF KERALA IN WPC NO. 28401 OF 2021 DATED 10.12.2021. W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -23- APPENDIX OF WP(C) 5482/2022 PETITIONER EXHIBITS Exhibit P1 Exhibit P2 Exhibit P2A Exhibit P3 Exhibit P4 Exhibit P5 Exhibit P6 Exhibit P7 Exhibit P8 TRUE COPY OF RELEVANT EXTRACT OF THE CERTIFICATE OF REGISTRATION OF THE PETITIONER COMPANY TRUE COPY OF PRINTOUT OF NOTIFICATION DATED 14.01.2011 TRUE ENGLISH TRANSLATION OF EXHIBIT P1 NOTIFICATION TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WPC NO.22723/2011 DATED 20.08.2011 TRUE COPY OF DEMAND NOTICE NO.R1-2266/17 ISSUED BY ERATTUPETTA MUNICIPALITY DATED 31.01.2022 TRUE COPY OF THE OBJECTION SUBMITTED BY THE PETITIONER BEFORE THE 5TH RESPONDENT DATED 10.02.2022 ALONG WITH ITS POSTAL RECEIPT TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WPC NO.12762/2018 DATED 11.04.2018 TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WPC NO.12729/2018 DATED 10.04.2018 TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WPC NO.35145 OF 2019 DATED 19.12.2019 W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -24- Exhibit P9 Exhibit P10 TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WPC NO.28114 OF 2020 DATED 16.12.2020 TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WPC NO.28401 OF 2021 DATED 10.12.2021 W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -25- APPENDIX OF WP(C) 13780/2022 PETITIONER EXHIBITS Exhibit P1 Exhibit P2 Exhibit P2A Exhibit P3 Exhibit P4 Exhibit P5 Exhibit P6 Exhibit P7 Exhibit P8 TRUE COPY OF THE CERTIFICATE OF INCORPORATION OF THE PETITIONER COMPANY. TRUE COPY OF PRINT OUT OF NOTIFICATION DATED 14.01.2011. TRUE ENGLISH TRANSLATION OF EXT:P2 NOTIFICATION. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN W.P.(C) NO.22723/2011 DATED 20.08.2011. TRUE COPY OF DEMAND NOTICE OF CORPORATION OF THIRUVANANTHAPURAM FOR BUILDING NO:81/315 (25/2386/1) DATED 23-03-2022 TRUE COPY OF THE OBJECTION SUBMITTED BY THE PETITIONER PERTAINING TO DOOR NO. 81/315 (25/2386/1) BEFORE THE 5TH RESPONDENT DATED 04- 04-2022 TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN W.P(C).NO.12762/2018 DATED 11.04.2018. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN W.P.(C) NO.12729/2018 DATED 10.04.2018. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN W.P.(C) NO.35145 OF 2019 DATED 19.12.2019 W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -26- Exhibit P9 Exhibit P10 TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN W.P.(C) NO.28114 OF 2020 DATED 16.12.2020, TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN W.P.(C) NO.28401 OF 2021 DATED 10.12.2021. W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -27- APPENDIX OF WP(C) 14015/2022 PETITIONER EXHIBITS Exhibit P1 Exhibit P2 Exhibit P2(A) Exhibit P3 Exhibit P4 Exhibit P5 Exhibit P6 Exhibit P7 Exhibit P8 TRUE COPY OF THE CERTIFICATE OF INCORPORATION OF THE PETITIONER COMPANY. TRUE COPY OF PRINT OUT OF NOTIFICATION DATED 14.1.2011. TRUE ENGLISH TRANSLATION OF EXT.P2 NOTIFICATION. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WP(C) NO.22723/2011 DATED 20.8.2011. TRUE COPY OF DEMAND NOTICE OF KUMBLA GRAMA PANCHAYATH FOR BUILDING NO.1/426 DATED 15.3.2022. TRUE COPY OF THE OBJECTION SUBMITTED BY THE PETITIONER PERTAINING TO DOOR NO.1/426 BEFORE THE 5TH RESPONDENT DATED 4.4.2022. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WP(C) NO.12762/2018 DATED 11.4.2018. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WP(C)NO.12729/2018 DATED 10.4.2018. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WP(C) NO.35145 OF 2019 DATED 19.12.2019. W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -28- Exhibit P9 Exhibit P10 TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WP(C) NO.28114 OF 2020 DATED 16.12.2020. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WP(C) NO.28401 OF 2021 DATED 10.12.2021. W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -29- APPENDIX OF WP(C) 14044/2022 PETITIONER EXHIBITS Exhibit P1 Exhibit P2 Exhibit P2(A) Exhibit P3 Exhibit P4 Exhibit P5 Exhibit P6 Exhibit P7 Exhibit P8 TRUE COPY OF THE CERTIFICATE OF INCORPORATION OF THE PETITIONER COMPANY. TRUE COPY OF PRINT OUT OF NOTIFICATION DATED 14.01.2011. TRUE ENGLISH TRANSLATION OF EXT. P2 NOTIFICATION. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WPC NO. 22723/2022 DATED 20.08.2011. TRUE COPY OF DEMAND NOTICE OF RANNI PAZHAVANGADI GRAMA PANCHAYATH FOR BUILDING NO. 14/812 DATED 22.03.2022. TRUE COPY OF THE OBJECTION SUBMITTED BY THE PETITIONER PERTAINING TO DOOR NO. 14/812 DATED BEFORE THE 5TH RESPONDENT DATED 25.03.2022. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WPC NO. 12762/2018 DATED 11.04.2018. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WPC NO. 12729/2018 DATED 10.04.2018. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA, IN WPC NO. 35145 OF 2019 DATED 19.12.2019. W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -30- Exhibit P9 Exhibit P10 TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE COURT OF KERALA IN WPC NO. 28114 OF 2020 DATED 16.12.2020. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN WPC NO. 28401 OF 2021 DATED 10.12.2021. W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -31- APPENDIX OF WP(C) 18412/2022 PETITIONER EXHIBITS Exhibit P1 Exhibit P2 Exhibit P2 A Exhibit P3 Exhibit P4 Exhibit P5 Exhibit P6 Exhibit P7 Exhibit P8 TRUE COPY OF THE CERTIFICATE OF INCORPORATION OF THE PETITIONER COMPANY. TRUE COPY OF PRINT OUT OF NOTIFICATION DATED 14.01.2011. TRUE ENGLISH TRANSLATION OF EXT:P2 NOTIFICATION. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON‘BLE HIGH COURT OF KERALA IN W.P.(C) NO.22723/2011 DATED 20.08.2011. TRUE COPY OF DEMAND NOTICE OF TANUR MUNICIPALITY FOR BUILDING NO: 474A DATED 21.01.2022. TRUE COPY OF THE OBJECTION SUBMITTED BY THE PETITIONER PERTAINING TO BUILDING NO. 474 A BEFORE THE 5TH RESPONDENT DATED 04.04.2022. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN W.P(C).NO. 12762/2018 DATED 11.04.2018. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN W.P.(C) NO. 12729/2018 DATED 10.04.2018. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN W.P.(C) NO.35145 OF 2019 DATED 19.12.2019. W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -32- Exhibit P9 Exhibit P10 TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN W.P.(C) NO.28114 OF 2020 DATED 16.12.2020. TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN W.P.(C) NO.28401 OF 2021 DATED 10,12.2021 W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -33- APPENDIX OF WP(C) 13782/2022 PETITIONER EXHIBITS Exhibit P1 Exhibit P2 Exhibit P2A Exhibit P3 Exhibit P4 Exhibit P4(a) Exhibit P5 Exhibit P5A Exhibit P6 Exhibit P7 TRUE COPY OF RELEVANT EXTRACT OF THE CERTIFICATE OF REGISTRATION OF THE PETITIONER COMPANY. TRUE COPY OF PRINT OUT OF NOTIFICATION DATED 14.01.2011. TRUE COPY OF THE ENGLISH TRANSLATION OF EXHIBIT:P2 NOTIFICATION DATED 14.01.2011 TRUE COPY OF THE INTERIM ORDER PASSED BY THE HON’BLE HIGH COURT OF KERALA IN W.P. (C) NO.22723/2011 DATED 20.08.2011. TRUE COPY OF PROPERTY TAX DEMAND DETAILS OF DOOR NO.392/A1 DATED 06.01.2022 TRUE COPY OF PROPERTY TAX DEMAND DETAILS OF DOOR NO.594/A2 DATED 06.01.2022 TRUE COPY OF THE OBJECTION FILED TO DEMAND NOTICE DATED 15.12.2021 PERTAINING TO DOOR NO. 392(A1). TRUE COPY OF THE OBJECTION FILED TO DEMAND NOTICE DATED 15.12.2021 PERTAINING TO DOOR NO. 594(A2). TRUE COPY OF THE INTERIM ORDER OF HONORABLE HIGH COURT IN W.P(C).NO. 12762/2018 DATED 11.04.2018. TRUE COPY OF THE INTERIM ORDER OF HONORABLE HIGH COURT IN W.P.(C)NO. 12729/2018 DATED W.P.(C) Nos.13782, 1496, 5482, 13780, 14015, 14044 & 18412/2022 -34-

10.04.2018. Exhibit P8 Exhibit P9 TRUE COPY OF THE INTERIM ORDER OF HONOURABLE HIGH COURT IN W.P(C).NO.35145/2019 DATED 19.12.2019. TRUE COPY THE OF INTERIM ORDER OF HONOURABLE HIGH COURT IN W.P(C).NO.28401/2021 DATED 10.12.2021.