JITHU JEEVA v. STATE OF KERALA

THE DISTRICT COLLECTOR, IDUKKI DISRICT, COLLECTORATE, IDUKKI-685 584. THE GEOLOGIST DISTRICT OFFICE OF MINING AND GEOLOGY, MINI CIVIL STATION, THODUPUZHA P.O., IDUKKI DISTRICT, 685 584. THE TAHSILDAR (LR) W.P. (C) 16231 & 16238 of 2021 :4: 5 6 7 8 TALUK OFFICE, PEERUMEDU TALUK, PEERUMEDU P.O.- 685 531. THE VILLAGE OFFICER ELAPPARA VILLAGE, PEERMEDU TALUK, IDUKKI DISTRICT, PIN-685 501. VANDIPERIYAR GRAMA PANCHAYATH PANCHAYATH OFFICE, VANDIPERIYAR P.O.- 685 533, IDUKKI DISTRICT, REPRESENTED BY ITS SECRETARY. ADDL. R7: THE CHIEF SECRETARY GOVERNMENT OF KERALA, SECRETARIAT, THIRUVANANTHAPURAM - 695001 ADDL.R8: SECRETARY, REVENUE DEPARTMENT GOVERNMENT OF KERALA, SECRETARIAT, THIRUVANANTHAPURAM - 695001 ADDL.R7 & R8 ARE IMPLEADED AS PER ORDER DATED 15.09.2021 IN IA NO.1/2021 IN WPC NO. 16238/2021. SRI.JUSTIN JACOB, GOVT. PLEADER THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON

08.04.2024 ALONG WITH WP(C).16231/2021, THE COURT ON 28.05.2024 DELIVERED THE FOLLOWING: W.P. (C) 16231 & 16238 of 2021 :5: JUDGMENT Since common issues arise for consideration in these writ petitions, they are disposed of by this common judgment. The petitioner in W.P. (C) No. 16238 of 2021 is the father of the petitioner in W.P. (C) No. 16231 of 2021. Both had submitted individual application for No Objection Certificate (NOC) for quarrying granite from 9 Hectors of Government land comprised in Sy. No. 184/1 of Elappara Village in Peerumedu Taluk in Idukki District. The issue involved relates to the non consideration of those applications. For the sake of convenience, unless otherwise expressly indicated, the status of the parties and the exhibits referred to hereinbelow shall be as obtaining in W.P. (C) No.16231 of 2021.

W.P. (C) No. 16231 of 2021: The petitioner's father held a quarrying permit in respect of his property having an extent of W.P. (C) 16231 & 16238 of 2021 :6:

17.06 Ares comprised in Sy. No. 184 (1) of Elappara Village in Peerumedu Taluk in Idukki District in the year 2014. He had obtained necessary licenses and permits from all authorities including the Department of Mining and Geology, Pollution Control Board, Deputy Chief Controller of Explosives for commencing the operation of the quarry. However, the various licenses were not simultaneously granted. Though the quarry began functioning in February, 2015, the quarrying permit issued by the Mining and Geology Department expired by the next month. In the meantime, there occurred a change in the Government policy whereby it was decided that quarrying permits cannot be issued in land assigned as patta land. As a part of the said decision, the entire quarrying activity had to be stopped though elaborate infrastructural arrangements were made for commencing the quarrying work. W.P. (C) 16231 & 16238 of 2021 :7:

There is a Government para puramboke lying adjacent to the patta property of the petitioner's father and when there occurred change in Government policy regarding issuance of permits in land assigned as patta land, the petitioner submitted Ext. P1 application dated 18.06.2018 for NOC for quarrying granite from 9 Hectors Government land comprised in Sy. No. 184/1 of Elappara Village. As per Exts. P2 to P4, the Village Officer, the Taluk Surveyor and the Tahsildar (LR) recommended issuance of NOC to the petitioner.

While so, a writ petition, W.P.(C)No.20464 of 2019 was filed before this Court seeking direction to conduct enquiry regarding the genuineness of applications for issuance of NOC for quarrying lease in Survey No.187/1 of Elappara Village in Peerumade Taluk. Though the said writ petition did not relate to the petitioner or his application for NOC, Ext. P1 application for W.P. (C) 16231 & 16238 of 2021 :8: NOC was not further processed in view of the pendency of the said writ petition. The aforesaid writ petition was disposed of by this Court by Ext. P5 judgment dated 24.01.2020 recording the submission of the Government that the Government have already initiated steps to prepare guidelines for grant of NOC for mining of minerals from Government lands and directing the Government to expedite the steps.

Pursuant to Ext. P5 judgment, the process for granting NOC was reopened by the District Collector, who by Ext. P6 communication dated 05.06.2020, sought report from the Geologist as a part of the procedure for grant of NOC for quarrying in the Government land. In response to Ext. P6, the Senior Geologist sent Ext. P7 communication dated 16.06.2020 reporting that the property in question did not fall under the categories classified as one having very high, high or moderate W.P. (C) 16231 & 16238 of 2021 :9: susceptibility to landslides or within ecologically sensitive area and that it was situated more than 13 kms away from a National Park/Wildlife sanctuary and that further steps can be taken as per the procedure for issuance of NOC by the Revenue Department.

The petitioner states that, despite the report of the Geologist, no decision is taken by the District Collector on the petitioner's application for the reason that there is a general order; G.O.(Ms) No.28/2021/RD dated 28.01.2021 (Ext. P8) passed by the Government in respect of mining of minerals from Government lands whereby the NOC's for quarries are to be put up for bidding. According to the petitioner, this would pave way to the quarries in the State being limited to the hands of a few wealthy persons, creating a monopoly and would affect applicants like the petitioner, who seek beneficial enjoyment of adjacent Government puramboke land. The petitioner also states W.P. (C) 16231 & 16238 of 2021 :10: that, after Ext. P5 judgment, NOC was granted by the District Collector in Peerumedu Taluk for another applicant.

The petitioner, therefore, submitted Ext. P9 representation dated 05.07.2021 before all the concerned authorities to consider his case as different from those generally covered by Ext. P8 G.O as the petitioner had undergone the entire process as per the existing policy and also undertaken huge financial commitments to execute the work as per the requirements which existed. The petitioner also pointed out that the inordinate delay in granting final orders on his application does not, in any way, reflect inaction or indifference on his part. The respondents have not responded to Ext. P9. Accordingly, the petitioner has filed this writ petition for direction to quash Ext. P8 to the extent it affects the petitioner in the matter of sanctioning of NOC applied for in Ext. P1 and for direction to W.P. (C) 16231 & 16238 of 2021 :11: the respondents 1, 7 and 8 to modify Ext. P8 G.O to the effect that the same does not affect the petitioner in the matter of sanctioning of NOC considering the exceptional circumstances of his case and not to give retrospective application to Ext. P8 G.O. hampering the issuance of NOC in cases like that of the petitioner where the applications submitted have been acted upon on the basis of the policy which existed prior to the issuance of Ext. P8. A direction is also sought to the 2nd respondent to issue necessary NOC to the petitioner to commence operation of the quarry in 10.9067 hectares of government land in Sy. No.184/1A in Elappara Village taking into account the recommendations reflected in Exts. P2 to P4 and P7.

W.P. (C) No. 16238 of 2021: As stated, the petitioner in this writ petition is the father of the petitioner in W.P. (C) No. W.P. (C) 16231 & 16238 of 2021 :12: 16231 of 2021. He submitted Ext. P6 application for NOC for quarrying granite from 9 Hectors of Government land comprised in Sy. No. 184/1 of Elappara Village in Peerumedu Taluk in Idukki District, in respect of the same land for which NOC is applied for by the petitioner in W.P. (C) No. 16231 of 2021. By Exts. P7 to P9 and P12, the Village Officer, the Taluk Surveyor, the Tahsildar (LR) and Senior Geologist had recommended issuance of NOC to the petitioner. However, no decision is taken by the District Collector on the petitioner's application for the reason that there is a general order; G.O.(Ms) No.28/2021/RD dated 28.01.2021 (Ext. P13) passed by the Government in respect of NOC for mining of minerals from Government lands. Ext. P14 representation filed by the petitioner before all concerned authorities was not responded to. Accordingly, this writ petition is filed. The reliefs sought for, W.P. (C) 16231 & 16238 of 2021 :13: are similar to those in W.P. (C) No. 16231 of 2021.

According to the petitioners, there is inordinate delay in considering their applications for issuance of NOC for quarrying lease. Had the District Collector not kept the petitioners' application pending for a long time, they would have been able to commence the quarrying operation earlier. The applications of the petitioners for NOC for quarrying lease are dated

18.06.2018. The Village Officer, the Taluk Surveyor, the Tahsildar (LR) and the Senior Geologist had recommended issuance of NOC to the petitioners before the issuance of Ext. P8 guidelines. It is contended that Ext. P8 guidelines for grant of NOC for mining of minerals from Government lands issued on

28.01.2021 cannot stand in the way of considering the applications of the petitioners submitted prior to the said guidelines and their applications have to be decided on the basis W.P. (C) 16231 & 16238 of 2021 :14: of the guidelines then existed. It is further contended that Ext. P8 cannot be applied with retrospective effect and change of policy shall not hamper the petitioners' project for quarrying. The petitioners had undergone the entire process as per the policy then prevalent and their applications cannot be revisited in view of Ext. P8.

Separate counter affidavits dated 06.06.2022, identically worded, have been filed by the Secretary to Government, Revenue Department, the 8th respondent in the writ petitions wherein it is stated that as per Rule 27 (2) (d) of the Kerala Minor Mineral Concession Rules, 2015 (hereinafter called the 'Rules', for short) an application for grant of quarrying lease, where minor mineral is to be removed from the Government land, shall be accompanied with an NOC issued by the District Collector concerned, to the effect that they have no W.P. (C) 16231 & 16238 of 2021 :15: objection for the extraction of minor mineral from the said land. For issuance of permit for quarrying, similar provisions and procedure contemplated under Rule 4 of the Rules have to be followed. It is stated that Idukki District consists of very ecological sensitive areas prone to natural calamities including landslides and before issuing NOC, it is inevitable to call for reports from various departments and the delay in considering the applications of the petitioners for NOC is not deliberate.

A reply affidavit is filed by the petitioners denying the averments in the counter affidavits filed by the 8th respondent and stating that during the pendency of their applications, similarly situated persons were granted NOC.

Additional counter affidavit is placed on record by the 8th respondent stating that such persons who have been issued NOC stand on different footing and that no NOC has been granted in Peerumedu Taluk after 16.03.2018. Additional reply affidavit is filed by the petitioners producing Ext. P12 judgment wherein this Court directed the application of the petitioner therein for NOC to be considered in the light of the procedure in force, without reference to Ext. P8 G.O.

Heard Sri. Thomas Abraham, the learned counsel for the petitioners, Sri. Arun Thomas, the learned counsel for the 6 th W.P. (C) 16231 & 16238 of 2021 :18: respondent Panchayat and Sri. S. Kannan, the learned senior Government Pleader.

As per Entry 18 of List II of the Seventh Schedule to the Constitution of India, it is for the State to enact legislation with regard to land, that is to say, right in or over land. Under Article 162 of the Constitution of India, the executive powers of the State Government extend to all matters in respect of which the Legislature of the State has power to make laws. Ext. P8 guidelines for grant of NOC for mining of minerals from Government lands are issued by the Government in terms of the power under Entry 18 of List II of Seventh Schedule to the Constitution of India. The State Government is competent to frame guidelines for grant of NOC for mining of minerals from Government land.

Chapter V of the Rules deals with grant of quarrying W.P. (C) 16231 & 16238 of 2021 :19: leases in respect of lands in which the mineral or mineral rights vests in the Government. Rule 27 deals with application for grant of quarrying lease. Rule 27 (2) (d) provides that an application for grant of quarrying lease shall be accompanied by No Objection Certificate from the District Collector in the case of revenue poramboke lands to the effect that they have no objection for extraction of minor mineral by the applicant subject to the provisions of the Rules. Rule 31 provides that when two or more persons have applied for quarrying lease in respect of the same land, the applicant whose application was received earlier shall have preferential right for grant of lease. Rule 33 deals with disposal of application for quarrying lease after obtaining NOC from the competent authority. Sri. Thomas Abraham would contend that the applications for NOC were submitted before the District Collector on 18.06.2018 and there W.P. (C) 16231 & 16238 of 2021 :20: was inordinate delay in considering the applications.

The next contention of Sri. Thomas Abraham is that since the applications of the petitioners for NOC were submitted prior to Ext. P8 guidelines, their applications are to be decided on the basis of the guidelines that existed prior to Ext. P8. The learned counsel would rely on Ext. P12 judgment wherein this Court directed the application of the petitioner therein for NOC to be considered in the light of the procedure in force on the date of application, without reference to Ext. P8 G.O. The said contention of the petitioners' counsel is opposed by Sri. Kannan relying on the decisions of the Hon'ble Supreme Court in State of Tamil Nadu v. M/s. Hind Stone and Others [(1981) 2 SCC W.P. (C) 16231 & 16238 of 2021 :24: 205: AIR 1981 SC 711) and State of Rajasthan and Others v. Sharwan Kumar Kumawat etc. [AIR 2023 SC 3586: AIR OnLine 2023 584].

To understand the issues and the findings in Ext. P12 judgment, it will be apposite to refer to paragraphs 3, 11 and 12 thereof which read as under:

3. It is submitted by the learned counsel for the petitioner that the petitioner had made an application for NOC for the purpose of obtaining a quarrying permit in Government land on 01.01.2018. It is submitted that the application was sent for enquiry and report and Ext.P2 report was generated on 01.02.2018. When no orders were passed on the request for NOC, the petitioner approached this Court and by Ext.P3 judgment, this Court directed the 2nd respondent to complete the measurement of the property by availing services of the Taluk Surveyor and to submit a report before the 1st st respondent was directed respondent-District Collector. The 1 to process the application forthwith.

xxx xxx xxx “11. Having considered the contentions advanced on either side, I notice that the application for NOC was, admittedly, submitted on 01.01.2018. By Ext.P3 judgment, this Court had specifically directed the consideration of the same after obtaining reports from the Tahsildar and the Taluk Surveyor. W.P. (C) 16231 & 16238 of 2021 :25: The reports were, admittedly, before the respondents in July, 2018. In view of Ext.P3 judgment, there was no justifiable reason for the respondents to have delayed the consideration of the application inordinately. Even if the contention raised by the respondents that the delay occurred due to the floods in 2018 is accepted, in view of Ext.P3 judgment, the 1st respondent was duty bound to take up the application, at least, as soon as the reminder made by the petitioner was submitted. Even as on that date, that is, on 08.06.2020, there was no order revising the procedure.

12. In the above view of the matter, I am of the opinion that the application submitted by the petitioner for NOC is liable to be considered and disposed of in the light of the procedure in force, without reference to the Government Order dated 28.01.2021. Appropriate orders shall be passed in the application submitted by the petitioner for NOC, after considering all relevant aspects of the matter, within a period of six weeks from the date of receipt of a copy of this judgment, without reference to the Government Order dated 28.01.2021.” (underlining supplied by this Court) In Ext. P12 judgment, the petitioner therein had sought for and obtained a direction from this Court for an early consideration of his application for NOC by the District Collector. This Court, in Ext. P12 judgment, therefore, held that in view of the directions W.P. (C) 16231 & 16238 of 2021 :26: in Ext. P3 judgment therein, the District Collector was duty bound to take up the application for NOC submitted by the petitioner and having failed to do so, it was held that the application for NOC is liable to be considered and disposed of in the light of the procedure in force, without reference to the Government Order dated 28.01.2021. In the case at hand, no direction was sought or obtained by the petitioners from this Court for an early consideration of their application for NOC. The petitioners, who had only submitted application for NOC, which was not acted upon before the issuance of Ext. P8 guidelines, cannot seek any direction for consideration of the application for NOC without reference to Ext. P8. Therefore, I am of the view that Ext. P12 judgment of this Court cannot be made applicable in the facts and circumstances of the present case. The pendency of the application for NOC did not create W.P. (C) 16231 & 16238 of 2021 :27: any right in favour of the petitioners. Therefore, the contention of the petitioners that their applications are to be decided on the basis of the guidelines that existed prior to Ext. P8 cannot be accepted.

In Hind Stone (supra), the Hon'ble Supreme Court held that the action of the Government in keeping applications for lease pending for long and later, rejecting them by applying a rule made subsequently, is not open to challenge. The Court observed that no one has a vested right to the grant of lease and none can claim a vested right to have an application for grant of lease to be dealt with in a particular way, by applying particular provisions and that in the absence of any vested right, the application has necessarily to be dealt with according to the rules in force as on the date of disposal of the application despite the fact that there is long delay since the making of the application. W.P. (C) 16231 & 16238 of 2021 :28: Paragraph '13' of the said decision reads as follows: “13. Another submission of the learned counsel in connection with the consideration of applications for renewal was that applications made sixty days or more before the date of G.O. Ms.

Relying on the said decision, the Hon'ble Supreme Court, in Sharwan Kumar (supra), observed as follows:

17. It is far too settled that there is no right vested over an application made which is pending seeking lease of a Government land or over the minerals beneath the soil in any type of land over which the Government has a vested right and regulatory control. In other words, a mere filing of an application ipso facto does not create any right. The power of the Government to amend, being an independent one, pending applications do not come in the way. For a right to be vested there has to be a statutory recognition. Such a right has to accrue and any decision will have to create the resultant injury. When a decision is taken by a competent authority in public interest by evolving a better process such as auction, a right, if any, to an applicant seeking lease over a Government land evaporates on its own. An applicant cannot have an exclusive right in seeking a grant of license of a mineral unless facilitated accordingly by a statute.

In Ajitha Joshy (supra), the appellant therein submitted an application dated 25.01.2019 before the District Collector for issuance of NOC to conduct quarrying operations in the Government puramboke land. On the basis of the communication of the Principal Secretary, Department of W.P. (C) 16231 & 16238 of 2021 :30: Revenue, dated 18.01.2020 (Ext. R8(b) herein), the District Collector, rejected the application stating that grant of NOC for quarrying could be considered only after preparing the guidelines for issuance of NOC. The appellant contended that her application dated 25.01.2019 was rejected on the basis of a Government order issued on 12.12.2019 (Ext. P8 herein) and that the rules applicable at that point of time ought to have been followed in her case. Rejecting the said contention, the Division Bench held as under:

16. Contention of the appellant that the application submitted by her dated 25/01/2019 before the 3rd respondent, being anterior in point of time, ought to have been considered, cannot be countenanced. There cannot be different yardsticks, insofar as applicability of the guidelines, yet to be framed. Merely because the appellant has submitted an application under the KMMC Rules, 2015, she has no absolute right to conduct quarry. Admittedly, mineral is a wealth of the State. Right to permit quarrying mineral, is the prerogative of the State.

W.P. (C) 16231 & 16238 of 2021 :31: Facts in the present cases are similar, and in view of the dictum laid down in Ajitha Joshy (supra), the contention of the petitioners that their applications are to be decided on the basis of the guidelines that existed prior to Ext. P8 is only to be rejected.

Identical question came to be considered by this Court in Sheriff A.H. v. State of Kerala [2024 KHC 1001: 2024 KHC OnLine 1001: 2024 (1) KHC SN 6: 2024 KER 13: 2024 LiveLaw (Ker) 14] wherein this Court held that the application for NOC submitted prior to Ext. P8 guidelines has to be considered only in the light of Ext. P8. Sri. Thomas Abraham has sought to distinguish the said judgment on the ground that unlike in Sheriff (supra), the petitioners have assailed the guidelines and in the case of the petitioners, there was W.P. (C) 16231 & 16238 of 2021 :32: favourable recommendations to grant NOC by the Village Officer, the Taluk Surveyor, the Tahsildar (LR) and the Senior Geologist. The petitioners, who had only submitted application for NOC, which was not acted upon before the issuance of Ext. P8 guidelines cannot seek any direction for the consideration of the NOC without reference to Ext. P8 guidelines. Merely because the petitioners have submitted the application for NOC before the issuance of guidelines, they have no right to seek consideration of the application on the basis of the guideline that existed prior to Ext. P8. I do not find any reason to take a different view.

Sri. Thomas Abraham sought to distinguish the decision in Hind Stone (supra) contending that the Hon'ble Supreme Court in the said decision was considering the case of grant of lease and not NOC. Under Rule 27 (2) (d) of the Rules, every W.P. (C) 16231 & 16238 of 2021 :33: application for grant of quarry lease in a Revenue puramboke land shall be accompanied by NOC from the District Collector. Since NOC from the District Collector is a pre-requisite for considering the application for grant of quarry lease, the application for NOC has necessarily to be dealt with according to the rules in force as on the date of disposal of the application for NOC. Sri. Thomas Abraham also made an attempt to contend that the applications of the petitioners are not under Rule 27 (2) (d), but under Rule 4 (2) (d) of the Rules. I am afraid, the said contention is not in consistent with the pleadings, Ext. P1 application and Ext.

24.1.2020 IN WPC NO.20464 OF 2019. THE TRUE COPY OF THE COMMUNICATION DATED 2.6.2020 SENT BY THE DISTRICT COLLECTOR, IDUKKI TO THE GEOLOGIST, IDUKKI. THE TRUE COPY OF THE LETTER DATED 16.6.2020 ISSUED BY THE SENIOR GEOLOGIST TO THE DISTRICT COLLECTOR, RECOMMENDING ISSUANCE OF NOC. THE TRUE COPY OF THE G.O.(MS)NO.28/2021/RD DATED 28.1.2021 ISSUED BY THE REVENUE DEPARTMENT. THE TRUE COPY OF THE REPRESENTATION DATED 5.7.2021 SUBMITTED BY THE PETITIONER. TRUE COPY OF THE APPLICATION DATED 21/06/2022 SUBMITTED UNDER R.T.I ACT, 2005 TRUE COPY OF THE ANSWERS FURNISHED IN RESPONSE TO EXHIBIT-P15 FROM THE PUBLIC INFORMATION OFFICER ATTACHED TO THE COLLECTORATE IDUKKY AS PER LETTER NO.DCIDK/695/2022-E9 DATED 13/07/2022. THE TRUE COPY OF THE JUDGMENT DATED 22.3.2022 IN W.P.(C) NO.29498 OF 2021. RESPONDENTS’ EXHIBITS EXHIBIT R8(A) EXHIBIT R8(B) A TRUE COPY OF THE LETTER DATED 20.03.2019 ISSUED TO THE DISTRICT COLLECTOR,IDUKKI A TRUE COPY OF LETTER DATED 18.01.2020 ISSUED REVENUE COMMISSIONER,THIRUVANANTHAPURAM LAND THE TO W.P. (C) 16231 & 16238 of 2021 :37: APPENDIX OF WP(C) 16231/2021 PETITIONER EXHIBITS Exhibit P1 Exhibit P2 Exhibit P3 Exhibit P4 Exhibit P5 Exhibit P6 Exhibit P7 Exhibit P8 Exhibit P9 Exhibit P10 THE TRUE COPY OF THE APPLICATION DATED 18.6.2018 SUBMITTED BY THE PETITIONER. THE TRUE COPY OF THE REPORT NUMBERED AS 456/18 DATED 24.7.2018 SUBMITTED BY THE VILLAGE OFFICER. THE TRUE COPY OF THE REPORT DATED 7.8.2018 ALONG WITH ALL THE RELEVANT DOCUMENTS HE RELIED ON FOR PREPARING THE REPORT AS WELL AS THE SURVEY MAP. THE TRUE COPY OF THE COMMUNICATION DATED 30.3.2019 ISSUED BY THE TAHSILDAR (LR) PEERUMEDE TALUK TO THE DISTRICT COLLECTOR RECOMMENDING FURTHER ACTION ON THE APPLICATION SUBMITTED BY THE PETITIONER. THE TRUE COPY OF THE JUDGMENT DATED 24.1.2020 IN WPC NO 20464 OF 2019.

THE TRUE COPY OF THE COMMUNICATION DATED 5.6.2020 SENT BY THE DISTRICT COLLECTOR, IDUKKI TO THE GEOLOGIST, IDUKKI. THE TRUE COPY OF THE LETTER DATED 16.6.2020 ISSUED BY THE SENIOR GEOLOGIST TO THE DISTRICT COLLECTOR, RECOMMENDING ISSUANCE OF NOC. THE TRUE COPY OF THE GO(MS) NO 28/2021/RD DATED 28.1.2021 ISSUED BY THE REVENUE DEPARTMENT THE TRUE COPY OF THE REPRESENTATION DATED 5.9.2021 SUBMITTED BY THE PETITIONER. THE TRUE COPY OF THE APPLICATION DATED 21.6.2022 SUBMITTED UNDER RIGHT TO INFORMATION ACT, 2005. Exhibit P11 THE TRUE COPY OF THE ANSWERS FURNISHED IN W.P. (C) 16231 & 16238 of 2021 :38: RESPONSE TO EXHIBIT P15 FROM THE PUBLIC INFORMATION OFFICER ATTACHED TO THE COLLECTORATE IDUKY AS PER THE LETTER NO.DCIDK/695/2022-E9 DATED 13.7.2022. TRUE COPY OF THE JUDGMENT DATED 22.03.2022 IN W.P.(C)NO.29498 OF 2021. Exhibit P12 RESPONDENTS’ EXHIBITS EXHIBIT R8(A) EXHIBIT R8(B) A TRUE COPY OF THE LETTER DATED 20.03.2019 ISSUED TO THE DISTRICT COLLECTOR,IDUKKI A TRUE COPY OF LETTER DATED 18.01.2020 ISSUED REVENUE LAND COMMISSIONER,THIRUVANANTHAPURAM THE TO