Full Judgment
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT THE HONOURABLE MRS. JUSTICE ANU SIVARAMAN MONDAY, THE 21ST DAY OF AUGUST 2023 / 30TH SRAVANA, 1945 WP(C) NO.13048 OF 2022 PETITIONER :- PADMINI K., D/O.PADMAVATHI AMMA, KARUVATHI (H), THRIKANDIYOOR AMSOM, ANNARA DESOM, TIRUR TALUK, TIRUR P.O., PIN - 676 101, MALAPPURAM DISTRICT. BY ADVS.P.CHANDRASEKHAR SATHEESH V.T. K.K.MOHAMED RAVUF MANJARI G.B. RESPONDENTS :-
1 THE STATE OF KERALA REPRESENTED BY PRINCIPAL SECRETARY TO GOVERNMENT OF KERALA, GENERAL EDUCATION DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695 001. 2 THE DIRECTOR OF GENERAL EDUCATION GENERAL EDUCATION DEPARTMENT, JAGATHI, THIRUVANANTHAPURAM - 695 014. 3 THE DEPUTY DIRECTOR OF EDUCATION, MALAPPURAM, KOTTAPADY, DOWN HILL, MALAPPURAM - 676 519. 4 THE ASSISTANT EDUCATIONAL OFFICER, TANUR, MALAPPURAM DISTRICT, PIN - 676 302. 5 SMT.KARUVATHIL VASANTHA W/O.SANKARA NARAYANAN, KRISHNA KRIPA HOUSE, ARIYALLUR P.O., MALAPPURAM DISTRICT - 676 313. 6 SMT.SANOOJA W/O.MURALI K.M., SREELAKSHMI, MANOIT HOUSE, OLAKKARA P.O., PIN - 676 306, TIRURANGADI TALUK, MALAPPURAM DISTRICT. 7 SMT.RESHMI B. W/O.SUJITH S., G-9-32 UNIVERSITY FAMILY QUARTERS, CALICUT UNIVERSITY BUILDING, CHELARI, -: 2 :- MALAPPURAM DISTRICT - 673 635. BY ADVS.R.PRADEEP KUMAR U.BALAGANGADHARAN S.P.ARAVINDAKSHAN PILLAY N.SANTHA V.VARGHESE PETER JOSE CHRISTO S.A.ANAND K.N.REMYA L.ANNAPOORNA VISHNU V.K. ABHIRAMI K.UDAY BY SRI.PREMCHAND R., GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION
ON 21.08.2023 ALONG WITH W.P.(C)Nos.18588 & 21373 OF 2022, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: -: 3 :-
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT THE HONOURABLE MRS. JUSTICE ANU SIVARAMAN MONDAY, THE 21ST DAY OF AUGUST 2023 / 30TH SRAVANA, 1945 WP(C) NO.18588 OF 2022 PETITIONER :_ RESMI B, UPPER PRIMARY SCHOOL TEACHER, S.N.U.P. SCHOOL, NANNAMBRA, MALAPPURAM DISTRICT, PIN-676 320. BY ADVS. S.P.ARAVINDAKSHAN PILLAY N.SANTHA S.P.BALAKRISHNA PILLAY V.VARGHESE PETER JOSE CHRISTO S.A.ANAND K.N.REMYA L.ANNAPOORNA VISHNU V.K. ABHIRAMI K. UDAY RESPONDENTS :-
1 STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, GENERAL EDUCATION DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. 2 THE DIRECTOR OF GENERAL EDUCATION, JAGATHY, THIRUVANANTHAPURAM-695 014. 3 THE DISTRICT EDUCATIONAL OFFICER, THIROORANGADI, MALAPPURAM-673 001. 4 THE ASSISTANT EDUCATIONAL OFFICER, TANUR, MALAPPURAM-673 001. 5 THE MANAGER, S.N.U.P. SCHOOL, NANNAMBRA, MALAPPURAM-676 320. -: 4 :-
6 HEADMASTER, S.N.U.P. SCHOOL, NANNAMBRA, MALAPPURAM-676 320. 7 PADMINI K., KARUVATHIL HOUSE, THRIKKANDIYOOR, TIRUR P.O., MALAPPURAM, PIN-676 101. 8 KARUVATHIL VASANTHA, KRISHNAKRIPA HOUSE, ARIYALLUR P.O., MALAPPURAM, PIN-676 313. ADDL.9 SAKEENA M.K. PAZHUDUKANDI VEEDU, VALLIKUNNU, VALLIKUNNU P.O., MALAPPURAM, PIN - 673 314.
ADDITIONAL 9TH RESPONDENT IS IMPLEADED AS PER ORDER
IN I.A.No.1/2022 DATED 21.8.2023. BY ADVS. P.BABU KUMAR P.CHANDRASEKHAR R.PRADEEP KUMAR K.K.MOHAMED RAVUF SATHEESH V.T. MANJARI G.B. SRI.PREMCHAND R., GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 21.08.2023 ALONG WITH W.P.(C)Nos.13048/2022 & 21373/2022, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: -: 5 :-
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT THE HONOURABLE MRS. JUSTICE ANU SIVARAMAN MONDAY, THE 21ST DAY OF AUGUST 2023 / 30TH SRAVANA, 1945 WP(C) NO.21373 OF 2022 PETITIONER :- SANOOJA, AGED 36 YEARS W/O.MURALI K.M., UPPER PRIMARY SCHOOL TEACHER, S.N.U.P.SCHOOL, NANNAMBARA, MALAPPURAM- 676 320 RESIDING AT SREELAKSHMI MANAT HOUSE, OLAKKARA P.O., THIRURANGADI , MALAPPURAM 676 306. BY ADV U.BALAGANGADHARAN RESPONDENTS :-
1 STATE OF KERALA, REPRESENTED BY SECRETARY, GENERAL EDUCATION DEPARTMENT, GOVERNMENT SECRETARIAT (ANNEX), THIRUVANANTHAPURAM - 695 001. 2 THE DIRECTOR OF GENERAL EDUCATION, JAGATHY, THIRUVANANTHAPURAM - 695 001. 3 THE DISTRICT EDUCATIONAL OFFICER, THIROORANGADI, MALAPPURAM - 673 001. 4 THE ASSISTANT EDUCATIONAL OFFICER, THANOOR, MALAPPURAM - 673 001. 5 THE EX-OFFICIO MANAGER AND ASSISTANT EDUCATIONAL OFFICER, S.N.U.P. SCHOOL, NANNAMBARA, THANOOR, MALAPPURAM - 676 320. 6 THE HEADMASTER-IN-CHARGE, S.N.U.P. SCHOOL, NANNAMBARA, MALAPPURAM - 676 320. ADDL.7 PADMINI.K, D/O.PADMAVATHI AMMA, KARUVATHIL (H), THRIKANDIYOOR AMSOM, ANNARA DESOM, TIRUR TALUK, -: 6 :- TIRUR P.O., PIN - 676 101, MALAPPURAM DISTRICT. [ADDL.R7 IS IMPLEADED AS PER ORDER DATED 29/09/2022 IN I.A NO:1/22 IN WP(C) 21373/2022] ADDL.8 KARUVATHIL VASANTHA, AGED 60 YEARS, D/O.PADMAVATHY AMMA, KRISHNA KRIPA HOUSE, ARIYANOOR P.O., MALAPPURAM DISTRICT - 676 313.
ADDITIONAL 8TH RESPONDENT IS IMPLEADED AS PER ORDER
DATED 21.8.2023 IN I.A.No.2/2022. BY ADVS. SRI.PREMCHAND R., GP P.CHANDRASEKHAR R.PRADEEP KUMAR REGIMOL.M.K ANAND SANKAR THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 21.08.2023 ALONG WITH W.P.(C)Nos.13048/2022 & 18588/2022, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: -: 7 :-
JUDGMENT
[W.P.(C) Nos.13048, 18588 & 21373 of 2022] Dated this the 21st day of August, 2023 W.P.(C) No.13048/2022 is filed by one of the co-owners of
Sree Narayana U.P. School, Nannambra, Tirurangadi Taluk challenging Exts.P6 and P16 orders passed by the Government. While W.P.(C) Nos.18588/2022 and 21373/2022 are filed by the persons who had been appointed by the former approved Manager of the school, who passed away on 1.1.2022, seeking implementation of the self same Government Orders and seeking approval of their appointment with effect from 15.7.2021 with all
consequential benefits. Directions are also sought to re-admit the petitioners to duty and to permit them to draw their salary and all other benefits.
2. Heard the learned counsel for the petitioners in the three writ petitions and the learned Government Pleader as well as the learned counsel appearing for the contesting party respondents.
3. It is submitted by the learned counsel for the petitioners in W.P.(C) Nos.18588/2022 and 21373/2022 that the petitioners had been appointed by the approved Manager against -: 8 :-
two substantive vacancies. It is submitted that there was management dispute between the legal heirs of Smt.Padmavathi Amma, who passed away on 1.1.2022. It is contended that three retirement vacancies arose on 1.6.2020. By Ext.P1, the petitioners in W.P.(C) Nos.18588/ 2022 and 21373/2022 were appointed as against two of such vacancies on 3.6.2020 and 2.6.2020 respectively. On the ground that the schools were not functioning due to Covid during the relevant period, the
appointments were not approved. In the very same vacancies, the approved Manager, Smt.Padmavathi Amma appointed the petitioners again with effect from 15.7.2021. By Ext.P4, approval was rejected on the ground of management dispute. Though by Exts.P6 and P7 the Director as well as the Government directed approval of the petitioners' appointment, the appointment has not been approved on the ground that management dispute was pending and that there were documents created by the co-owners of the property assigning the school and its management to two of Padmavathi Amma's daughters.
4. The learned counsel for the petitioners submits that the approved Manager had continued with due approval from the Department till she passed away on 1.1.2022 and that therefore, -: 9 :- the refusal to approve the appointment of the petitioners with effect from 15.7.2021 in vacancies which arose on 1.6.2020 is completely unjustifiable.
5. The petitioner in W.P.(C) No.13048/2022, who is one of the respondents in the other two writ petitions, contends that a
partition deed had been executed on 28.2.2019 between Padmavathi Amma and her children and that the property in which the school is situated and the right of management of the school stood allotted to Padmini and Vasantha who are two of the children of Padmavathi Amma. It is contended that though a request was made by Padmavathi Amma relinquishing the post of Manager of the school and for prior permission for transfer of management of the school in favour of Padmini and Vasantha, the said application could not be forwarded in due time. It is submitted that Smt.Padmavathi Amma was seriously ill at the time of effecting the appointments of the petitioners in W.P.(C) No.18588/2022 and 21373/2022 and that she could not have issued the appointment letters as sought for. It is further contended that an FIR has been registered against Vasantha and Rugmini in 2022 with regard to fraudulent use of the signature and seal of Padmavathy Amma. It is submitted that though these -: 10 :- aspects have been specifically raised by the petitioner before the Director and the Government, these aspects have not been considered while passing Exts.P6 and P16 orders and that the orders are, therefore, bad in law.
6. The learned counsel appearing for the petitioner in
W.P.(C) No.18588/2022 would contend that Smt.Padmavathi Amma was actually continuing as Manager of the school and the AEO who has refused to issue orders of approval of the petitioner's appointment had specifically addressed Smt.Padmavathi Amma as Manager of the school and had been routinely sending communications to Padmavathi Amma as Manager even after the date of Ext.P3 order of appointment with
effect from 15.7.2021. The documents produced as Exts.P17, P18 and P19 are relied on in support of the said contention. It is submitted that till the death of Padmavathi Amma on 1.1.2022, she was the approved Manager of the school and that there was no occasion for the AEO refusing to approve the appointment made by the approved Manager on 15.7.2021.
7. A counter affidavit has been placed on record by the 8 th respondent in W.P.(C) No.18588/2022 contending that Padmavathi Amma never tendered resignation from the post of -: 11 :- Manager and that the signatures of Vasantha and Padmavathi Amma are forged by the 7th respondent for serving her own
interest. A criminal complaint has been filed before the Magistrate against the said action of the 7th respondent. It is also stated that there is an unholy nexus between the 7th respondent, Padmini and the AEO and the story of resignation of the then Manager has been manipulated with the sole intention to reject the appointment of Resmi and Sanooja, who are the petitioners in W.P.(C) Nos.18588/2022 and 21373/2022.
8. A statement and a counter affidavit have been placed on record by the AEO in W.P.(C) Nos.18588/2022 and counter affidavit as follows :-
“3. It is submitted that Smt.Padmavathi Amma handed over the managership and the school propety to her daughters Smt.Karuvathil Padmini and Smt.Karuvathil Vasantha on 28.2.2019 under the deed No.761 registered in Tanur Sub Registrar Office. In this regards Smt.Karuvathil Padmini filed a
suit as O.S.No.24/2021 in Tanur Sub Court. No final judgment
has been passed on this suit. Smt.Karuvathil Padmavathi Amma resigned the managership of this school on 09/2020 and submitted a proposal to this office, which is entered in the Personal Register of B Section as B/2125/2020 of this office. Sri.Udayakumar, the Former Senior Superintendent of this office took the file from the section and not submitted to the officer, -: 12 :- returned it to Smt.Anusree (the Hindi teacher and daughter of Smt.Karuvathil Vasantha, second owner of the school) on 14.01.2020 along with original documents, stating that the application submitted by the manager was not complete, which is noted in the despatch register of this office. After that the manager has not resubmitted the proposal to this office. Smt.Padmavathi Amma passed away on 01.01.2022. These informations are mentioned in detail in G.O.(Rt)No.2077/2022/ G.Edn. dated 30.03.2022 which is produced as Ext.R4(a).”
It is further submitted that on the directions of the Government, the AEO had taken over charge of Manager provisionally on 31.3.2022 and it was noticed that the appointment of the teachers with effect from 15.7.2021 made by the Manager was not proper and the appointment was again rejected. It is stated that the continuance of the teachers by signing the attendance register would lead to their staking claim for continuance in the school and therefore, the teachers were prevented from signing the attendance register.
9. I have considered the contentions advanced on all sides at considerable length. Chapter III of the KER provides for
management of private schools. Rule 3 provides that management of every aided school is to be vested by the Educational Agency in a person who shall be referred to as the -: 13 :- Manager and who shall be responsible to the department for the management of the institution. Rule 5 provides the change of management and Rule 5A provides the change of management involving change of ownership. Rule 5A specifically provides that no change of Management of any aided school involving change of ownership shall be effected except with the previous permission of the Director.
10. In the instant case, though a contention is raised that a
partition deed was entered into in the year 2019 and that a request was made by the approved Manager before the AEO, there is nothing on record to show that the request was ever forwarded to the Director or that the Director had granted any prior approval for the change of Management involving change of ownership of the school in question. The letter produced as Ext.R7(b) in W.P.(C) No.18588/2022, which is purported to be an undated letter written in September, 2020, states that Padmavathi Amma was unaware of the provision with regard to previous sanction for change of mangement and that therefore, the request is being forwarded for such prior permission for change of management. However, nobody has a case that any prior permission had been granted for change of management -: 14 :- involving change of ownership on any date prior to the death of Smt.Padmavathi Amma.
11. In the above factual situation, I am of the opinion that the stand of the AEO that the appointment of the petitioners in
W.P.(C) No.18588/2022 and 21373/2022 with effect from 15.7.2021 could not be approved even in spite of the directions contained in the orders of the Director and the Government is strange, to say the least. In view of the fact that Smt.Padmavathi Amma continued as the approved Manager of the school till she passed away on 1.1.2022 and in the light of the documents produced, I am of the opinion that the contention raised that the appointment cannot be approved in spite of the orders passed by
the Director cannot be sustained. W.P.(C) No.13048/2022 is, accordingly, dismissed leaving open the contentions of the petitioner with regard to her claim over the property and management to be decided in appropriate civil suits. However, the challenge against the orders of the Director and the Government is repelled.
W.P.(C) Nos.18588/2022 and 21373/2022 are allowed. There will be a direction to the AEO to approve the appointment of the petitioners as UPST with effect from 15.7.2021 subject to -: 15 :- all other necessary verifications. Necessary shall be done within a period of three weeks from the date of receipt of a copy of this judgment. All consequential benefits shall be calculated and disbursed to the petitioners within a period of three months thereafter.
Sd/- ANU SIVARAMAN JUDGE Jvt/25.8.2023 -: 16 :- APPENDIX OF WP(C) 13048/2022 PETITIONER EXHIBITS :- Exhibit P1 TRUE COPY OF THE REGISTERED PARTITION DEED DATED Exhibit P2 TRUE COPY OF THE APPLICATION DATED SEPTEMBER, 2020 SUBMITTED BY THE 6TH RESPONDENT TO THE 2ND RESPONDENT THROUGH THE 4TH RESPONDENT, AEO. Exhibit P3 TRUE COPY OF THE LETTER DATED NIL SEPTEMBER, 2020 OF THE 6TH RESPONDENT TO THE 2ND RESPONDENT. Exhibit P4 TRUE COPY OF THE RATION CARD OF THE PETITIONER. Exhibit P5 TRUE COPY OF THE ORDER DATED 21/10/2021 IN WP(C) NO.22383 OF 2021. Exhibit P6 TRUE COPY ORDER NO.DGE/9851/2021-E4 DATED THE OFFICE OF THE 2ND RESPONDENT. Exhibit P7 TRUE COPY OF THE REVISION PETITION OF THE PETITIONER DATED 09/12/2021 BEFORE THE 1ST RESPONDENT. Exhibit P8 TRUE COPY OF THE ADDITIONAL PETITION DATED RESPONDENT. Exhibit P9 TRUE COPY OF THE POSTAL RECEIPT DATED 18/12/2021 EVIDENCING SENDING OF EXHIBIT P8 TO THE 1ST RESPONDENT. Exhibit P10 TRUE COPY OF THE PETITION FOR STAY DATED 09/12/2021 OF THE PETITIONER BEFORE THE 1ST RESPONDENT. Exhibit P11 TRUE COPY OF THE JUDGMENT DATED 22/12/2021 OF THIS HON'BLE COURT IN WP(C) NO.30132 OF 2021. Exhibit P12 TRUE COPY OF G.O.(RT) NO.565/2022/GEDN DATED Exhibit P13 TRUE COPY OF THE ORDER DATED 23/09/2021 IN WP(C) NO.19808 OF 2021. -: 17 :- Exhibit P14 TRUE COPY OF THE ORDER DATED 23/12/2021 IN I.A.NO.3 OF 2021 IN WPC NO.19808 OF 2021. Exhibit P15 TRUE COPY OF THE HEARING NOTE SUBMITTED BY THE PETITIONER TO THE JOINT SECRETARY, TO THE GOVERNMENT OF KERALA, DEPARTMENT OF GENERAL EDUCATION. Exhibit P16 TRUE COPY OF THE GO(RT) NO.2077/2022/GEDN DATED RESPONDENT EXHIBITS EXHIBIT R4(a) TRUE COPY OF G.O.(Rt.) No.2077/2022/G.Edn. dated 30.03.2022 EXHIBIT R4(b) TRUE COPY OF THE ORDER No. B/003/2022 of the Assistant Educational Officer, Tanur dated 31.03.2022. EXHIBIT R4(c) TRUE COPY OF THE ORDER No. B/23482/2021 DATED 10.05.2022 EXHIBIT R4(d) TRUE COPY OF THE ORDER No. B/23483/2021 DATED 10.05.2022 Exhibit R6(a) A TRUE COPY OF APPOINTMENT ORDER DATED 2.6.2020 ISSUED BY THE MANAGER TO 6TH RESPONDENT. Exhibit R6(b) A TRUE COPY OF LETTER OF THE AEO THANOOR DATED 16.10.2020 RETURNING THE PROPOSAL FOR RESUBMISSION. Exhibit R6(c) A TRUE COPY OF APPOINTMENT ORDER ISSUED TO THE 6TH RESPONDENT DATED 15.7.2021. Exhibit R7(a) TRUE COPY OF THE DEATH CERTIFICATE OF SRI.K.MADHAVAN NAIR. Exhibit R7(b) TRUE COPY OF THE DEATH CERTIFICATE OF SMT.PADMAVATHI AMMA.K. Exhibit R7(c) TRUE COPY OF THE ORDER NO.DA1/2021 DATED 31/03/2021 ISSUED BY K.PADMAVATHI AMMA MANAGER OF THE SCHOOL. Exhibit R7(d) TRUE COPY OF THE ORDER NO.KDISB/732/2021 DATED -: 18 :- Exhibit R7(e) TRUE COPY OF THE LETTER NO.B/1641/2020 DATED SMT.K.PADMAVATHI AMMA. Exhibit R7(f) TRUE COPY OF THE LETTER DATED 04/03/2021 FROM THE MANAGER TO THE 4TH RESPONDENT. Exhibit R7(g) TRUE COPY OF THE FIR NO.552/2022 OF TANUR POLICE STATION. Exhibit R7(h) TRUE COPY OF THE APPOINTMENT ORDER DATED 03/06/2020 OF THE MANAGER TO THE 7TH RESPONDENT. Exhibit R7(i) TRUE COPY OF THE LETTER NO.B 4532/2020 DATED Exhibit R7(j) TRUE COPY OF THE APPOINTMENT ORDER OF THE MANAGER TO THE 7TH RESPONDENT.
Exhibit R7(k) TRUE COPY OF THE ORDER NO.B/13827/2021 DATED Exhibit R7(l) TRUE COPY OF THE ORDER NO.B/23482/2021 DATED Exhibit R7(m) TRUE COPY OF THE LETTER ON 01/06/2022 OF THE
HEADMASTER. Exhibit R7(n) TRUE COPY OF THE JUDGMENT DATED 02/06/2022 IN WPC.NO.8995/2022 OF THIS HON'BLE COURT. -: 19 :- APPENDIX OF WP(C) 18588/2022 PETITIONER EXHIBITS :- Exhibit P1 TRUE COPY OF THE APPOINTMENT ORDER DATED 03.06.2020 ISSUED BY THE 5TH RESPONDENT Exhibit P2 TRUE COPY OF THE LETTER NO.B4-4532/2020 DATED 16.10.2020 OF THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE APPOINTMENT ORDER DATED 15.07.2021 OF THE PETITIONER ISSUED BY THE 5TH RESPONDENT. Exhibit P4 TRUE COPY OF THE ORDER NO.B/13827/2021 DATED 28.07.2021 OF THE 4TH RESPONDENT. Exhibit P5 TRUE COPY OF THE JUDGMENT DATED 01.09.2021 IN WP(C)NO.17590/2021 OF THIS HON'BLE COURT. Exhibit P6 TRUE COPY OF THE ORDER NO.DGE/9851/2021-E4 DATED 06.12.2021 OF THE 2ND RESPONDENT. Exhibit P7 TRUE COPY OF THE G.O.(RT)NO. 2077/2022/G.EDN DATED 30.03.2022. Exhibit P8 TRUE COPY OF THE ORDER NO.B/23482/2021 DATED 10.05.2022 OF THE 4TH RESPONDENT. Exhibit P9 TRUE COPY OF THE FORWARDING LETTER NO.B/003/ 2022 DATED 12.05.2022 TO THE PETITIONER BY THE 4TH RESPONDENT. Exhibit P10 TRUE COPY OF THE ORDER NO.B/003/2022 DATED 31.03.2022 OF THE 4TH RESPONDENT. Exhibit P11 TRUE COPY OF THE LETTER DATED 01.06.2022 OF THE HEADMASTER OF THE SCHOOL TO THE PETITIONER. Exhibit P12 TRUE COPY OF THE COMPLAINT DATED 18.05.2022 FILED BY THE PETITIONER BEFORE THE JOINT SECRETARY, GENERAL EDUCATION DEPARTMENT. Exhibit P13 TRUE COPY OF THE GOVERNMENT LETTER NO.GEDNF2/81/2022-GEDN DATED 19.05.2022 TO THE 4TH RESPONDENT Exhibit P14 TRUE COPY OF THE GOVERNMENT LETTER NO.GEDNF2/81/ -: 20 :- 2022-GEDN DATED 03.06.2022. Exhibit P15 TRUE COPY OF THE DEATH CERTIFICATE OF SMT.PADMAVATHI AMMA K. Exhibit P16 TRUE COPY OF THE ORDER NO.DA1/2021 DATED 31.3.2021 ISSUED BY SMT.K.PADMAVATHI AMMA. Exhibit P17 TRUE COPY OF THE ORDER NO.KDISB/732/2021 DATED 15.4.2021 OF THE 4TH RESPONDENT. Exhibit P18 TRUE COPY OF LETTER NO.B1/1641/2020 DATED 11.2.2021 OF THE 4TH RESPONDENT ADDRESSED TO THE MANAGER OF THE SCHOOL. Exhibit P19 TRUE COPY OF THE LETTER DATED 4.3.2021 OF THE MANAGER SENT TO THE 4TH RESPONDENT. Exhibit P20 TRUE COPY OF THE COVERING LETTER NO.B/003/2002 DATED 16.2.2022 OF THE 4TH RESPONDENT ALONG WITH THE ENCLOSED REPORT. Exhibit P21 TRUE COPY OF THE FIR NO.552/2022 OF TANUR POLICE HAS BEEN REGISTERED AGAINST THE 7TH RESPONDENT. RESPONDENT EXHIBITS :- Exhibit R7(a) A TRUE COPY OF PARTITION DEED DATED 28.02.2019 EXECUTED BETWEEN THE PETITIONER AND OTHER LEGAL HEIRS OF THE PETITIONER. Exhibit R7(b) TRUE COPY OF APPLICATION DATED SEPTEMBER 2020 OF SMT. PADMAVATHI AMMA THROUGH THE ASSISTANT EDUCATION OFFICER, TANUR. Exhibit R7(c) TRUE COPY OF THE LETTER SEPTEMBER 2020 OF SMT. PADMAVATHI AMMA TO AEO, TANUR. Exhibit R7(d) TRUE COPY OF THE RETURN AGREEMENT ENTERED BETWEEN 8TH RESPONDENT, SMT. RAMANI AND SMT. RAMYA. -: 21 :- APPENDIX OF WP(C) 21373/2022 PETITIONER EXHIBITS :- Exhibit P1 A TRUE COPY OF APPOINTMENT ORDER DATED 2.6.2020 ISSUED BY THE 5TH RESPONDENT MANAGER TO THE PETITIONER. Exhibit P2 A TRUE COPY OF LETTER OF THE 4TH RESPONDENT AEO DATED 16.10.2020 . Exhibit P3 A TRUE COPY OF ORDER RE-APPOINTING THE PETITIONER ON 15..7..2021. Exhibit P4 A TRUE COPY OF ORDER OF THE 4TH RESPONDENT DATED 28.7.2021. Exhibit P5 A TRUE COPY OF ORDER OF 4TH RESPONDENT DATED 31.3.2022. Exhibit P6 A TRUE COPY OF THE ORDER ISSUED BY THE 2ND RESPONDENT DATED 6.12.2021 Exhibit P7 A TRUE COPY OF GO(RT) NO. 2077/2022/G.EDN DATED 30.3.2022. Exhibit P8 A TRUE COPY OF ORDER NO. B/23403/2021 ISSUED BY THE 4TH RESPONDENT DATED 10..5..2022. Exhibit P9 A TRUE COPY OF THE ORDER DATED 1.6.2022 ISSUED BY THE 6TH RESPONDENT . Exhibit P10 A TRUE COPY OF INTERIM ORDER PASSED BY THIS HON'BLE COURT IN W.P. [C 1258/2022 DATED 16.6.2022. Exhibit P11 A TRUE COPY OF THE OBJECTIONS IA 2/2021 IN OS 24/2021 DATED 08.04.2021 FILED BY KARUVATHIL PADMAVATHY AMMA BEFORE HON'BLE SUB COURT, TIROOR. RESPONDENT EXHIBITS :- Exhibit R4(a) True copy of G.O(Rt) No. 2077/22/GEDN dated. 30.3.22.