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Manager, vs State of Kerala

Manager, vs State of Kerala

Type Court Judgment Court Kerala Decided Feb 16, 2024
~14 min read
https://sooperkanoon.com/case/1288057

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Citation
Court
Kerala High Court
Judge
Decided On
Case Number
WP(C)/2784/2021
Subject
Land Acquisition

Case Summary

AI-generated summary - not the official court judgment text.

Land Acquisition

Key legal issue
Land Acquisition

Parties & Advocates

Appellant / Petitioner

Manager,

Respondent

State of Kerala

Excerpt

.....by dr.sali kurian,jr.consultant,general hospitalmuvattupuzha exhibit p7 true copy of the representation submitted by petitioner before the government dated 27.07.2019 exhibit p8 true copy of the g.o.(rt)no.2509/2020/g.edn.dated exhibit p9 true copy of the representation vide letter dated 04.11.2020 submitted by the petitioner before the deo,kothamangalam exhibit p10 true copy of covering letter no.b4/8677/2018 dated 03.12.2020 of the deo,kothamangalam addressing the manager. exhibit p10(a) true copyf of the enquiry report no.b4/8677/2018 dated 03.12.2020 furnished by the deo, kothamangalam. exhibit p11 true copy of the 2nd show cause notice issued by the manager dated 23.01.2021. exhibit p12 true copy of the agreement betweenpetitioner and manager dated 14.12.2020 on which the mangager has obtained the signature of the petitioner under coercionexhibit p13 true copy of the resignation letter obtained by the manager under coercion from the petitioner dated 18.12.2020. exhibit p14 true copy of the petition submitted by the petitioner before the deo,kothamangalam dated 14.01.2021. appendix of wp(c) 29913/2022 petitioner exhibits :- exhibit p1 true copy of the decision reported in 2017(3) khc 429 (ajith kumar k v v. state ofkerala and others reported in dated 19.06.2017 exhibit p2 true of the order no. b4/2621/2017 dated 05.12.2017 of the deo, kothamangalam exhibit p3 true copy of the disability certificate no. c1-3596/2019 dated 10.07.2019 of the petitioner issued by the general hospital, muvattupuzha exhibit p4 true copy covering letter no. b4/8677/2018 dated 03.12.2020 of the deo, kothamangalam addressing the manager exhibit p4 a true copy of the enquiry report no. b4/8677/2018 dated 03.12.2020 furnished by the deo, kothamangalam exhibit p5 true copy of the show cause notice issued by the manager to the petitioner dated 23.01.2021 exhibit p6 true copy of the order no. b4/8677/2021 dated 15.12.2021 of the deo, kothamangalam exhibit p7 true.....

Full Judgment

IN THE HIGH COURT OF KERALA AT ERNAKULAM

PRESENT THE HONOURABLE MR.JUSTICE MOHAMMED NIAS C.P. FRIDAY, THE 16TH DAY OF FEBRUARY 2024 / 27TH MAGHA, 1945 WP(C) NO. 35070 OF 2023 PETITIONERS :- 1 SAJU KURIAKOSE, MANAGER, AGED 58 YEARS ST.MARY'S HIGH SCHOOL, KRARIYELY, PERUMBAVOOR, ERNAKULAM - 683 544. AGED 58 RESIDING AT ATHIRAMPUZHAYIL HOUSE, PUTHUMANA, KOMBANAD PO, ERNAKULAM, PIN - 683546 2 ALBIN SHAJ, AGED 26 YEARS OFFICE ATTENDANT, ST.MARY'S HIGH SCHOOL, KRARIYELY, PERUMBAVOOR, ERNAKULAM - 683 544 AGED 26,S/O SHAJU KURIAKOSE ARACKAKUDY HOUSE, KOMBANAD, KUNNATHUNAD TALUK, ERNAKULAM, PIN - 683546

BY ADVS. M.A.FAYAZ C.B.ABHINAVA M.VISHNUPRIYA RESPONDENTS :- 1 STATE OF KERALA REP. BY SECRETARY TO THE GOVERNMENT, GENERAL EDUCATION DEPARTMENT, SECRETARIAT, ANNEXURE-II, THIRUVANANTHAPURAM, PIN - 695001 2 THE DIRECTOR OF GENERAL EDUCATION O/O THE DIRECTOR OF GENERAL EDUCATION JAGATHY, THIRUVANANTHAPURAM, PIN - 695014 3 DEPUTY DIRECTOR OF EDUCATION ERNAKULAM O/O DEPUTY DIRECTOR OF EDUCATION, ERNAKULAM CIVIL STATION, KAKKANAD, ERNAKULAM, PIN - 682030 4 DISTRICT EDUCATIONAL OFFICER KOTHAMANGALAM O/O THE DISTRICT EDUCATIONAL OFFICER KOTHAMANGALAM KOTHAMANAGALAM, PIN - 686691

5 BINOY ABRAHAM PADIKUDIZHI HOUSE, KOMBANAD P.O., KUNNATHUNAD, ERNAKULAM, PIN - 683544 BY ADVS. SMT.K.G.SAROJINI, GP V.A MUHAMMED M.SAJJAD(K/335/1997) THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 16.02.2024, ALONG WITH WP(C).2784/2021, DELIVERED THE FOLLOWING:

IN THE HIGH COURT OF KERALA AT ERNAKULAM

PRESENT THE HONOURABLE MR.JUSTICE MOHAMMED NIAS C.P. FRIDAY, THE 16TH DAY OF FEBRUARY 2024 / 27TH MAGHA, 1945 WP(C) NO. 2784 OF 2021 PETITIONER :- MANAGER, ST.MARYS HIGH SCHOOL, KARIYELY, PERUMBAVOOR, ERNAKULAM-683 544. BY ADVS. M.A.FAYAZ SMT.M.VISHNUPRIYA SMT.C.B.ABHINAVA RESPONDENTS :- 1 STATE OF KERALA REP BY SECRETARY TO THE GOVERNMENT, GENERAL EDUCATION DEPARTMENT, SECRETARIAT, ANNEXURE-11, THIRUVANANTHAPURAM-695 001.

2 THE DIRECTOR OF GENERAL EDUCATION, JAGATHY, THIRUVANANTHAPURAM-695 001. 3 DEPUTY DIRECTOR OF EDUCATION, ERNAKULAM, CIVIL STATION, KAKKANAD, ERNAKULAM-682 030. 4 DISTRICT EDUCATIONAL OFFICER, KOTHAMANGALAM, KOTHAMANGALAM-686 691. 5 BINOY ABRAHAM, PADIKUDIZHI HOUSE, KOMBANAD P.O. KUNNATHUNAD, ERNAKULAM-683 544. BY SMT.K.G.SAROJINI, GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 16.02.2024, ALONG WITH WP(C).35070/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

IN THE HIGH COURT OF KERALA AT ERNAKULAM

PRESENT THE HONOURABLE MR.JUSTICE MOHAMMED NIAS C.P. FRIDAY, THE 16TH DAY OF FEBRUARY 2024 / 27TH MAGHA, 1945 WP(C) NO. 3589 OF 2021 PETITIONER :- BINOY ABRAHAM, AGED 27 YEARS SON OF P.O.ABRAHAM,OFFICE ATTENDANT (UNDER SUSPENSION),ST.MARY'S HIGH SCHOOL KRARIYELY,KOMBANAD.P.O, ERNAKULAM DISTRICT-683546,(RESIDING AT PADICKAKUDY HOUSE,KOMBANAD.P.O, KUNNATHUNADU, ERNAKULAM DISTRICT-683546). BY ADVS. M.SAJJAD SMT.P.A.JENZIA RESPONDENTS :- 1 THE STATE OF KERALA REPRESENTED BY ITS SECRETARY TO GOVERNMENT,GENERAL EDUCATION DEPARTMENT,SECRETARIAT ANNEXE-II, THIRUVANANTHAPURAM-695001.

2 THE DIRECTOR OF GENERAL OF EDUCATION, JAGATHY,THIRUVANANTHAPURAM-682030. 3 THE DEPUTY DIRECTOR OF EDUCATION, ERNAKULAM AT KAKKANAD-682030. 4 THE DISTRICT EDUCATIONAL OFFICER, KOTHAMANGALAM,ERNAKULAM DISTRICT-686691. 5 THE HEADMASTER, ST.MARY'S HIGH SCHOOL KRARIYELY, KOMBANAD.P.O, ERNAKULAM DISTRICT-683546. 6 THE MANAGER, ST.MARY'S HIGH SCHOOL KRARIYELY, KOMBANAD.P.O, ERNAKULAM DISTRICT-683546. BY ADVS. SMT.K.G.SAROJINI, GP SRI.M.A.FAYAZ SMT.C.B.ABHINAVA THIS WRIT PETITION (CIVIL) HAVING COME UP FOR

ADMISSION ON 16.02.2024, ALONG WITH WP(C).35070/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

IN THE HIGH COURT OF KERALA AT ERNAKULAM

PRESENT THE HONOURABLE MR.JUSTICE MOHAMMED NIAS C.P. FRIDAY, THE 16TH DAY OF FEBRUARY 2024 / 27TH MAGHA, 1945 WP(C) NO. 29913 OF 2022 PETITIONER :- BINOY ABRAHAM, AGED 27 YEARS SON OF P.O ABRAHAM, OFFICE ATTENDANT (UNDER SUSPENSION), ST. MARY'S HIGH SCHOOL, KRARIYELY, KOMBANAD P.O, ERNAKULAM DISTRICT - 683

546. (RESIDING AT PADICKAKUDY HOUSE, KOMBANAD P.O, KUNNATHUNADU, ERNAKULAM DISTRICT - 683 546) BY ADVS. M.SAJJAD P.A.JENZIA RESPONDENTS :- 1 THE STATE OF KERALA REPRESENTED BY ITS SECRETARY TO GOVERNMENT, GENERAL EDUCATION DEPARTMENT, SECRETARIAT ANNEXE - II, THIRUVANANTHAPURAM - 695 001.

2 THE DIRECTOR OF GENERAL OF EDUCATION, JAGATHY, THIRUVANANTHAPURAM - 695 014. 3 THE DEPUTY DIRECTOR OF EDUCATION, ERNAKULAM AT KAKKANAD - 682 030. 4 THE DISTRICT EDUCATIONAL OFFICER, KOTHAMANGALAM, ERNAKULAM DISTRICT - 686 691. 5 THE HEADMASTER, ST. MARY'S HIGH SCHOOL KRARIYELY, KOMBANAD P.O, ERNAKULAM DISTRICT- 683 546. 6 THE MANAGER, ST. MARY'S HIGH SCHOOL KRARIYELY, KOMBANAD P.O, ERNAKULAM DISTRICT- 683 546. BY SMT.K.G.SAROJINI, GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR

ADMISSION ON 16.02.2024, ALONG WITH WP(C).35070/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

JUDGMENT

[WP(C) Nos.35070/2023, 2784/2021, 3589/2021, 29913/2022] W.P.(C) No.2784 of 2021, filed by the Manager of the School to direct the 4th respondent to approve the resignation tendered by the 5th respondent.

2. W.P.(C) No.3589 of 2021 is filed by the 5th respondent in

W.P.(C) No.2784 of 2021, Binoy Abraham, for a direction to the respondents not to terminate his services as he is not mentally fit and also to accommodate him in a supernumerary post on finding that he is not suitable for the post he is holding under the provisions of the Right of Persons with Disabilities Act, 2016.

3. W.P.(C) No.29913 of 2022 is also filed by Binoy Abraham

challenging Exts.P8 and P9, which found the petitioner guilty of the charges after a disciplinary enquiry and granted prior permission for imposing the penalty of removal from service, as per the order dated 14.09.2022.

4. W.P.(C) No.35070 of 2023 is filed by the Manager of the

School and the person appointed in the place of the petitioner in W.P.(C) Nos.29913 of 2022 & 3589 of 2021. The prayer sought in this writ petitioner is for approving the appointment of the second petitioner as FTM w.e.f 01.01.2021 and also to grant all consequential benefits. The petitioner is that case also challenged against Exts.P15 and P16, which declined to consider the request of approval of the second petitioner on the ground of pendency of the writ petitions filed by Sri.Binoy Abraham.

5. Having heard the learned counsel for both sides and the learned

Government Pleader, It cannot be disputed that the petitioner in W.P.(C) Nos.29913 of 2022 & 3589 of 2021 Sri. Binoy Abraham was removed from service. The petitioner was removed from service following the orders dated 12.09.2022 (Ext.P14) by which the Deputy Director, the third respondent, granted permission for prior sanction for imposing a penalty for Binoy Abraham and consequently, as per Ext.P14(a), the Manager imposed the punishment of removal from service.

6. The learned counsel for the delinquent submits that he filed a

revision against Exts.P14 and P14 (a) before the Director of General Education vide Ext.R5(b). In view of this development, the prayers sought in W.P.(C) Nos.2784 of 2021, 3589 of 2021, and 29913 of 2022 have become infructuous. It will be open to the petitioner (Sri. Binoy Abraham) to challenge the correctness of the order passed removing him from service in the revision preferred before the Director. He is free to raise such contentions as are permissible under law in the revision. As far as the approval of the appointment of the second petitioner in W.P.(C) No.35070 of 2023 is concerned, it has a bearing on the decisions to be taken by the Director as directed above in the revisions. In the light of the above, there will be a direction to the Director General of Education, the second respondent in W.P.(C) No.35070 of 2023, to pass orders with notice to the petitioner, the Manager and other affected parties, if any, on Ext. R 5 (b) revision preferred by the fifth respondent (Binoy Abraham).

7. The orders as directed above shall be passed within a period of

two months from the date of receipt of a copy of this judgment. The approval of the second petitioner in W.P.(C) No.35070 of 2023 will be considered by the fourth respondent after the Director passes the order as directed above. He shall consider and pass appropriate orders within one month from the date of the order to be passed by the Director in Ext R 5 (b) revision. It is made clear that all the contentions of the parties are left open. Though the learned counsel for Benoy Abraham submits that he must be given the right to challenge the orders refusing permission which he sought under the provisions of the Right of Persons with Disabilities Act, this will arise only in case orders are passed in his favour by the Director in Ext R 5(b) revision, and in that event, it will be open for Sri Binoy Abraham to stake such claims. These writ petitions are disposed of as above. Sd/- MOHAMMED NIAS C.P. JUDGE SMA APPENDIX OF WP(C) 2784/2021 PETITIONER EXHIBITS :- EXHIBIT P1 PHOTOCOPY OF THE SUSPENSION ORDER ISSUED TO THE 5TH RESPONDENT DATED 17.12.2018 EXHIBIT P2 PHOTOCOPY OF PROCEEDINGS NO B4/8677/18 DATED 22.12.2018 ISSUED BY THE 4TH RESPONDENT EXHIBIT P3 PHOTOCOPY OF THE PROCEEDINGS NO M- MANAGER EXHIBIT P4 PHOTOCOPY OF THE LETTER NO B4/8677/2018 DATED 22.5.2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P4 (A) PHOTOCOPY OF THE ENQUIRY REPORT NO B4/8677/2018 DATED 22.5.2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P5 PHOTOCOPY OF THE ORDER IN WPC NO 8862/2019 DATED 22.3.2019 EXHIBIT P6 PHOTOCOPY OF MEMO OF CHARGE ISSUED TO THE 5TH RESPONDENT DATED 19.12.2019 EXHIBIT P6 (A) PHOTOCOPY OF THE STATEMENT OF ALLEGATION ISSUED ALONG WITH EXT P6. EXHIBIT P7 PHOTOCOPY OF THE LETTER DATED 5.2.2020 ISSUED BY THE MANAGER EXHIBIT P8 PHOTOCOPY OF THE WRITTEN STATEMENT FILED BY THE PETITIONER BEFORE THE 1ST RESPONDENT DATED 5.12.2019 EXHIBIT P9 PHOTOCOPY OF GO(MS) NO 2509/2020/G.EDN DATED 27.8.2020 EXHIBIT P10 PHOTOCOPY OF THE REMINDER SUBMITTED BY THE MANAGER DATED 22.9.2020 EXHIBIT P11 PHOTOCOPY OF THE HEARING NOTICE ISSUED BY THE 4TH RESPONDENT DATED 30.10.2020 EXHIBIT P12 PHOTOCOPY OF LETTER NO B4/8677/2018 DATED 3.12.2020 ISSUED BY THE 4TH RESPONDENT EXHIBIT P12 (A) PHOTOCOPY OF THE ENQUIRY REPORT NO B4/8677/2018 DATED 3.12.2020 EXHIBIT P13 PHOTOCOPY OF THE RESIGNATION LETTER SUBMITTED BY THE 5TH RESPONDENT DATED 18.12.2020 EXHIBIT P14 PHOTOCOPY OF THE PROCEEDINGS NO M4/2020 DATED 18.12.2020 ISSUED BY THE MANAGER. EXHIBIT P15 PHOTOCOPY OF THE LETTER DATED 22.12.2020 ISSUED BY THE MANAGER EXHIBIT P16 PHOTOCOPY OF THE NEWS ARTICLE APPEARED IN MALAYALA MANORAMA DAILY DATED 1.10.2019 Exhibit P17 PHOTOCOPY OF LETTER NO.VB1/223328/2021/DGE DATED 16-11-2021 ISSUED BY THE 2ND RESPONDENT. Exhibit P18 PHOTOCOPY OF ORDER NO.B4/8677/2021 DATED 15-12-2021 ISSUED BY THE 4TH RESPONDENT. Exhibit P19 PHOTOCOPY OF FIR NO.0096 DATED 14-02-2021 OF KURUPPAMPADY POLICE STATION. Exhibit P20 PHOTOCOPY OF FIR NO.0090 DATED 11-02-2021 OF KURUPPAMPADY POLICE STATION. Exhibit P21 PHOTOCOPY OF ORDER NO.DGE/9501/2019-EC2 DATED 16-01-2022 APPENDIX OF WP(C) 3589/2021 PETITIONER EXHIBITS :- EXHIBIT P1 TRUE COPY OF THE ORDER NO.B4/2621/2017 DTED 05.12.2017 OF THE DEO,KOTHAMANGALAM EXHIBIT P2 TRUE COPY OF THE COVERING LETTER NO.B4/8677/2018 DATED 22.05.2019 OF THE DEO,KOTHAMANGALAM ADDRESSING THE MANAGER EXHIBIT P3 TRUE COPY OF INVESTIGATION REPORT VIDE NO.B4/8677/2018 DATED 22.05.2019 FURNISHED BY THE DEO,KOTHAMANGALAM. EXHIBIT P4 TRUE COPY OF THE SHOW CAUSE NOTICE NO.M21/18-19 DATED 06.06.2019 ISSUED BY THE MANAGER TO THE PETITIONER. EXHIBIT P5 TRUE COPY OF THE EXPLANATION SUBMITTED BY THE PETITIONER BEFORE THE MANAGER DATED 26.06.2019

EXHIBIT P6      TRUE COPY OF THE MEDICAL CERTIFICATE OF
                DISABILITY   VIDE   NO.C1-3596/2019   DATED
                10.07.2019      ISSUED      BY      DR.SALI
                KURIAN,JR.CONSULTANT,GENERAL       HOSPITAL

MUVATTUPUZHA EXHIBIT P7 TRUE COPY OF THE REPRESENTATION SUBMITTED BY PETITIONER BEFORE THE GOVERNMENT DATED 27.07.2019 EXHIBIT P8 TRUE COPY OF THE G.O.(RT)NO.2509/2020/G.EDN.DATED EXHIBIT P9 TRUE COPY OF THE REPRESENTATION VIDE LETTER DATED 04.11.2020 SUBMITTED BY THE PETITIONER BEFORE THE DEO,KOTHAMANGALAM EXHIBIT P10 TRUE COPY OF COVERING LETTER NO.B4/8677/2018 DATED 03.12.2020 OF THE DEO,KOTHAMANGALAM ADDRESSING THE MANAGER. EXHIBIT P10(A) TRUE COPYF OF THE ENQUIRY REPORT NO.B4/8677/2018 DATED 03.12.2020 FURNISHED BY THE DEO, KOTHAMANGALAM. EXHIBIT P11 TRUE COPY OF THE 2ND SHOW CAUSE NOTICE ISSUED BY THE MANAGER DATED 23.01.2021. EXHIBIT P12 TRUE COPY OF THE AGREEMENT BETWEEN

PETITIONER AND MANAGER DATED 14.12.2020 ON WHICH THE MANGAGER HAS OBTAINED THE SIGNATURE OF THE PETITIONER UNDER COERCION

EXHIBIT P13 TRUE COPY OF THE RESIGNATION LETTER OBTAINED BY THE MANAGER UNDER COERCION FROM THE PETITIONER DATED 18.12.2020. EXHIBIT P14 TRUE COPY OF THE PETITION SUBMITTED BY THE PETITIONER BEFORE THE DEO,KOTHAMANGALAM DATED 14.01.2021. APPENDIX OF WP(C) 29913/2022 PETITIONER EXHIBITS :- Exhibit P1 TRUE COPY OF THE DECISION REPORTED IN 2017

(3) KHC 429 (AJITH KUMAR K V V. STATE OF

KERALA AND OTHERS REPORTED IN DATED 19.06.2017 Exhibit P2 TRUE OF THE ORDER NO. B4/2621/2017 DATED 05.12.2017 OF THE DEO, KOTHAMANGALAM Exhibit P3 TRUE COPY OF THE DISABILITY CERTIFICATE NO. C1-3596/2019 DATED 10.07.2019 OF THE PETITIONER ISSUED BY THE GENERAL HOSPITAL, MUVATTUPUZHA Exhibit P4 TRUE COPY COVERING LETTER NO. B4/8677/2018 DATED 03.12.2020 OF THE DEO, KOTHAMANGALAM ADDRESSING THE MANAGER Exhibit P4 A TRUE COPY OF THE ENQUIRY REPORT NO. B4/8677/2018 DATED 03.12.2020 FURNISHED BY THE DEO, KOTHAMANGALAM Exhibit P5 TRUE COPY OF THE SHOW CAUSE NOTICE ISSUED BY THE MANAGER TO THE PETITIONER DATED 23.01.2021 Exhibit P6 TRUE COPY OF THE ORDER NO. B4/8677/2021 DATED 15.12.2021 OF THE DEO, KOTHAMANGALAM Exhibit P7 TRUE COPY OF THE INTERIM ORDER IN W.P.(C) NO. 13387/2022 DATED 24.08.2022 Exhibit P8 TRUE COPY OF THE ORDER NO. G1/5153/2022 DATED 12.09.2022 OF THE DDE, ERNAKULAM Exhibit P9 TRUE COPY OF THE PROCEEDING OF THE MANAGER VIDE ORDER NO. M4/DP/2018 DATED 14.09.2022. Exhibit P10 TRUE COPY OF THE APPEAL MOVED BY THE PETITIONER BEFORE THE DIRECTOR DATED 01.10.2022. APPENDIX OF WP(C) 35070/2023 PETITIONER EXHIBITS :- Exhibit P1 TRUE COPY OF THE APPOINTMENT ORDER ISSUED BY THE 1ST PETITIONER DATED 01.01.2021 Exhibit P2 TRUE COPY OF THE APPOINTMENT ORDER ISSUED BY THE 1ST PETITIONER PROMOTING THE 2ND PETITIONER TO THE POST OF OA DATED 02.05.2023 Exhibit P3 TRUE COPY OF ORDER NO DGE/9501/2019-EC2 DATED 18.01.2022 ISSUED BY THE 2ND RESPONDENT Exhibit P4 TRUE COPY OF THE SUSPENSION ORDER DATED 17.12.2018 Exhibit P5 TRUE COPY OF THE PROCEEDINGS NO.B4/8677/18 DATED 22.12.2018 Exhibit P6 . TRUE COPY OF THE INTERIM ORDER IN W.P(C)NO.8862/2019 DATED 22.03.2019 Exhibit P7 TRUE COPY OF G.O(MS) NO 2509/2020/G.EDN DATED 27.08.2020 ISSUED BY THE 1ST RESPONDENT Exhibit P8 TRUE COPY OF THE COVERING LETTER NO.B4/8677/2018 DATED 03.12.2020 ISSUED BY THE 4TH RESPONDENT. Exhibit P8(a) TRUE COPY OF THE ENQUIRY REPORT DATED 03.12.2020 OF THE 4TH RESPONDENT. Exhibit P9 TRUE COPY OF THE RESIGNATION LETTER DATED 18.12.2020 Exhibit P10 TRUE COPY OF THE PROCEEDINGS NO.M4/2020 DATED 18.12.2020 OF THE 1ST PETITIONER Exhibit P11 TRUE COPY OF ORDER NO B4/8677/2021 DATED 15.12.2021 ISSUED BY THE 4TH RESPONDENT Exhibit P12 TRUE COPY OF THE INTERIM ORDER IN W.P(C)NO 3589/2021 DATED 07.02.2022 Exhibit P13 TRUE COPY OF THE INTERIM ORDER IN W.P(C) NO 13387/2022 DATED 24.08.2022 Exhibit P14 TRUE COPY OF THE ORDER NO G1/5153/2022 DATED 12.09.2022 ISSUED BY THE 3RD RESPONDENT Exhibit P14(a) TRUE COPY OF PROCEEDINGS NO.M4/D.P/2018 DATED 14.09.2022 REMOVED THE 5TH RESPONDENT W.E.F. 17.12.2018 Exhibit P15 TRUE COPY OF ORDER NO B4/34274/2022 DATED 22.07.2022 ISSUED BY THE 4TH RESPONDENT Exhibit P16 TRUE COPY OF ORDER NO B4/217879/2022 DATED 05.06.2023 ISSUED BY THE 3RD RESPONDENT Exhibit P17 TRUE COPY OF FIR NO. 1410 OF 2018 DATED

13.12.2018 REGISTERED BY THE KURUPPAMPADI POLICE STATION AGAINST THE 5TH RESPONDENT UNDER VARIOUS PROVISIONS OF IPC Exhibit P17(a) TRUE COPY OF FIR NO. 0231 OF 2019 DATED 07.03.2019 REGISTERED BY THE KURUPPAMPADI POLICE STATION AGAINST THE 5TH RESPONDENT UNDER VARIOUS PROVISIONS OF IPC Exhibit P17(b) TRUE COPY OF FIR NO. 0090 OF 2021 DATED 11.02.2021 REGISTERED BY THE KURUPPAMPADI POLICE STATION AGAINST THE 5TH RESPONDENT UNDER VARIOUS PROVISIONS OF IPC Exhibit P17(c) TRUE COPY OF FIR NO. 0096 OF 2021 DATED 14.02.2021 REGISTERED BY THE KURUPPAMPADI POLICE STATION AGAINST THE 5TH RESPONDENT UNDER VARIOUS PROVISIONS OF IPC

Exhibit P18 TRUE COPY OF THE ROSTER MADE BY THE 1ST PETITIONER DATED 26.06.2023 Exhibit P18(a) TRUE COPY OF ACKNOWLEDGEMENT ISSUED BY THE SUB REGIONAL EMPLOYMENT OFFICER ERNAKULAM DATED 30.06.2023 Exhibit P19 TRUE COPY OF REQUISITION MADE BY THE 1ST PETITIONER DATED 26.06.2023 RESPONDENT EXHIBITS :- Exhibit R-5 (a) True copy of the Order No. B4/2621/17 dated dated 05.12.2017 of the DEO Exhibit R-5 (b) True copy of the Appeal Memorandum before the Director dated 01.10.2022 Exhibit R-5 (c) True copy of the Judgment in CC No.430/2019 dated 13.01.2023 of the Judicial First Class Magistrate Court III, Perumbavoor Exhibit R-5 (d) True copy of the Judgment in CC No.152/2020 dated 26.05.2023 of the Judicial First Class Magistrate Court III, Perumbavoor

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