Shibin Constructions Components v. The State Police Chief - Kerala High Court, 16 Nov 2022

Judgment

IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MRS. JUSTICE ANU SIVARAMAN WEDNESDAY, THE 16TH DAY OF NOVEMBER 2022 / 25TH KARTHIKA, 1944 WP(C) NO. 35066 OF 2022 PETITIONER:

M/S. THOMSUN SANDS AND METALS THOMSUN ANNEXE, 4 TH FLOOR, ACHUTHA WARRIER LANE, M.G. ROAD, ERNAKULAM, KOCHI 682 035, REPRESENTED BY ITS MANAGING PARTNER, MR. K.V. ABRAHAM, AGED 67, S/O. K.C. VARGHESE, KUTTIPARAMBIL HOUSE, KALATHILPADY, VIJAYAPURAM P.O., KOTTAYAM, PIN: 686 010., PIN - 686010 BY ADVS.

K.R.VINOD M.S.LETHA K.S.SREEREKHA NABIL KHADER CHITHRA C.EDADAN ANUROS MARTIN RESPONDENTS:

1 THE DISTRICT POLICE CHIEF DISTRICT POLICE OFFICE, COLLECTORATE P.O., KOTTAYAM, PIN: 686 002., PIN - 686002 2 THE STATION HOUSE OFFICER, ERUMELY POLICE STATION, ERUMELY, KOTTAYAM DISTRICT, PIN: 686 509., PIN - 686509 3 LORRY OWNERS ASSOCIATION ERUMELY PANCHAYATH COMMITTEE, REPRESENTED BY ITS SECRETARY, SHIJIMON K. THOMAS, AGED ABOUT 40, KATTIPEEDIKAYIL HOUSE, ERUMELY P.O., KOTTAYAM DISTRICT, PIN: 686 509., PIN - 686509

WP(C) NOs.35066 OF 2022 & 35339 of 2022 2 4 SHIJIMON K. THOMAS, AGED ABOUT 40, KATTIPEEDIKAYIL HOUSE, ERUMELY P.O., KOTTAYAM DISTRICT, PIN: 686 509., PIN - 686509 5 CHACKO VARGHESE ALIAS ABY, AGED ABOUT 40, KAVUNKAL HOUSE, MUKOOTTUTHARA P.O., MUKOOTTUTHARA, KOTTAYAM, PIN: 686 510, PIN - 686510 BY ADVS.

P. M RAFEEK (PATTAM) V.A.NAVAS(K/1104/2002) U.NIDHIN(K/689/2006) GIA MATHAI KANDATHIL(K/868/2007) T.K.SHAJAHAN-SR.GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 16.11.2022, ALONG WITH WP(C).35339/2022, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

WP(C) NOs.35066 OF 2022 & 35339 of 2022 3 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MRS. JUSTICE ANU SIVARAMAN WEDNESDAY, THE 16TH DAY OF NOVEMBER 2022 / 25TH KARTHIKA, 1944 WP(C) NO. 35339 OF 2022 PETITIONER:

SHIBIN CONSTRUCTIONS COMPONENTS KOLLAKADAVU INDUSTRIAL ESTATE, KOCHALUMOODU, KALLIMEL P.O., MAVELIKKARA, ALAPPUZHA-690 509, REP. BY ITS MANAGING PARTNER SHIBIN WILLIAM VARGHESE, S/O.LATE N.V.VARGHESE, AGED 39 YEARS, SHIBIN VILLA, VETTICODE P.O., KATTANAM, MAVELIKKARA, ALAPPUZHA- 690 503.

BY ADVS.

B.MOHANLAL P.S.PREETHA ASWIN V. NAIR KARTHIK J SEKHAR ABIJITH M.

RESPONDENTS:

1 THE STATE POLICE CHIEF POLICE HEADQUARTERS, VAZHUTHACAUD, THIRUVANANTHAPURAM - 695 014.

2 THE DISTRICT POLICE CHIEF, DISTRICT POLICE HEADQUARTERS, KOTTAYAM- 686 001 3 THE DISTRICT POLICE CHIEF, DISTRICT POLICE HEADQUARTERS, PATHANAMTHITTA - 689 645 4 THE STATION HOUSE OFFICER, MUNDAKKAYAM POLICE STATION, MUNDAKKAYAM P.O., KOTTAYAM -686 513 5 THE STATION HOUSE OFFICER, PONKUNNAM POLICE STATION, PONKUNNAM P.O.,

WP(C) NOs.35066 OF 2022 & 35339 of 2022 4 KOTTAYAM -686 506 6 THE STATION HOUSE OFFICER, ERUMELY POLICE STATION, ERUMELI P.O., KOTTAYAM -686 509 7 THE STATION HOUSE OFFICER, MANIMALA POLICE STATION, MANIMALA P.O., KOTTAYAM -686 543 8 THE STATION HOUSE OFFICER, RANNI POLICE STATION, RANNI P.O., PATHANAMTHITTA-689 672 9 THE STATION HOUSE OFFICER, ARANMULA POLICE STATION, ARANMULA P.O., PATHANAMTHITTA-689 533 10 THE STATION HOUSE OFFICER, CHENGANNUR POLICE STATION, CHENGANNUR P.O., ALAPPUZHA -689 121 11 THE STATION HOUSE OFFICER, VENMANI POLICE STATION, VENMANI P.O., ALAPPUZHA - 689 509 12 THE STATION HOUSE OFFICER, MAVELIKKARA POLICE STATION, MAVELIKKARA. P.O., ALAPPUZHA - 690 101 13 THE STATION HOUSE OFFICER, KOODAL POLICE STATION, KOODAL P.O., PATHANAMTHITTA-689 693 14 THE STATION HOUSE OFFICER, ADOOR POLICE STATION, ADOOR P.O., PATHANAMTHITTA-691 523 15 THE STATION HOUSE OFFICER, PANDALAM POLICE STATION, PANDALAM P.O., PATHANAMTHITTA-689 501 16 THOMSON SANDS AND METALS, THOMSON ANNEX, 4TH FLOOR, ACHUTHA WARRIAR LANE, M.G.ROAD, ERNAKULAM -682035 REPRESENTED BY MANAGING PARTNER, MR.K.V.ABRAHAM, KATTIPARAMBIL HOUSE, KALATHILPPADY, VIJAYAPURAM P.O., KOTTAYAM - 686 010

WP(C) NOs.35066 OF 2022 & 35339 of 2022 5 17 THE LORRY OWNERS' ASSOCIATION, ERUMELY PANCHAYATH COMMITTEE REPRESENTED BY ITS SECRETARY, SHAJIMON K.THOMAS, KATTIPEEDIKAYIL HOUSE, ERUMELY P.O., KOTTAYAM - 686 509 18 SRI.CHACKO VARGHESE @ ABY, KAVUNKAL HOUSE, MUKKOOTTUTHARA.P.O., MUKKOTTUTHARA, KOTTAYAM - 686 510 SRI.SHIJIMON JOSEPH, MEMBER OF LORRY OWNERS' ASSOCIATION, ERUMELY PANCHAYATH, ERUMELY.P.O., KOTTAYAM - 686 509 (OWNER OF KL-62-E-5545 TORUS HGV VEHICLE) 19 JITHESH, MEMBER OF LORRY OWNERS' ASSOCIATION, ERUMELY PANCHAYATH, ERUMELY P.O., KOTTAYAM - 686 509 (DRIVER KL-34-E-9342 TIPPER) 20 SRI. SHAMEER, MEMBER OF LORRY OWNERS' ASSOCIATION, ERUMELY PANCHAYATH, ERUMELY P.O., KOTTAYAM - 686 509 (DRIVER KL-07-BT-2371 TIPPER) 21 SRI. MANU, MEMBER OF LORRY OWNERS' ASSOCIATION, ERUMELY PANCHAYATH, ERUMELY.P.O., KOTTAYAM - 686 509 22 SRI. AMBADY, MEMBER OF LORRY OWNERS' ASSOCIATION, ERUMELY PANCHAYATH, ERUMELY P.O., KOTTAYAM-686 509 BY ADVS.

K.R.VINOD P. M RAFEEK (PATTAM) V.A.NAVAS(K/1104/2002) U.NIDHIN(K/689/2006) GIA MATHAI KANDATHIL(K/868/2007) M.S.LETHA(K/139/1996) T.K.SHAJAHAN-SR.GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 16.11.2022, ALONG WITH WP(C).35066/2022, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

WP(C) NOs.35066 OF 2022 & 35339 of 2022 6 JUDGMENT Dated this the 16th day of November, 2022 These writ petitions are filed seeking police protection.

WP(c)No.35066/2022 is filed by the registered Partnership firm conducting quarry and crusher unit operations in Erumeli South Village of Kanjirapally Taluk.

WP(c) No.35339/2022 is filed by a transporter, who own several lorries and who seeks protection from respondents 17 to 22 for carrying out the transportation of granite and rubble from the premises of the 16th respondent, who is the petitioner in WP(c)No.35066/2022.

The leaned counsel for the petitioner in WP(c)No.35066/2022 contends that there are complaints with regard to the transportation carried out by the lorry owners and issues with regard to overloading of the lorries and that the petitioner had installed a weigh bridge in his premises to see that overloading is prevented. It is submitted that the lorry owners of the locality are obstructing even the willing lorry owners from carrying out the transportation of materials from the petitioner's

WP(C) NOs.35066 OF 2022 & 35339 of 2022 7 premises.

The petitioner in WP(c) No.35339/2022 would contend that on the ground that the petitioner has being carrying out the transportation of materials from the quarry in question, the petitioner's vehicles had been attacked and FIRs had been launched against the contesting party respondents.

A detailed counter affidavit has been placed on record by the 18th respondent to contend that there is no entity as 17th respondent in WP(c) No.35339/2022 and 3rd respondent in WP(c)No.35066/2022 and that the contentions raised are absolutely incorrect. It is submitted that the allegations that the respondents are overloading the vehicles is perfectly incorrect and that there is no obstruction being offered by the 18th respondent to any transportation work of the quarry owner and that the issues are only with regard to overloading of transport vehicles.

It is submitted that the petitioner in WP(c) No.35339/2022 is also engaging in overloading and that a check report has been generated with regard to overloading by the petitioner as well. It is contended that the complaints are raised

WP(C) NOs.35066 OF 2022 & 35339 of 2022 8 only by the residents of the locality with regard to overloading of vehicles and the consequent problems faced by the residents of the locality.

Having considered the contentions advanced on all sides, I am of the opinion that even if there are complaints with regard to overloading, the same are liable to be brought to the notice of the competent authorities so that action is taken in accordance with law. However, this will not justify any violence or law and order situations being created by any of the parties.

In the above view of the matter, these writ petitions are disposed of, with a direction that in case of any law and order situation, the parties shall approach the police or the competent authorities, who shall look into the complaints and take appropriate action in accordance with law. The Station House Officer shall take appropriate steps to see that law and order is maintained in the locality. All other contentions are left open.

This writ petition is ordered accordingly.

Sd/-

ANU SIVARAMAN ska JUDGE

WP(C) NOs.35066 OF 2022 & 35339 of 2022 9 APPENDIX OF WP(C) 35066/2022 PETITIONER EXHIBITS Exhibit p1 THE COPY OF THE ORDER OF ADDITIONAL DIRECTOR OF MINING AND GEOLOGY, THIRUVANANTHAPURAM DATED 05.10.2018.

Exhibit p2 THE COPY OF THE DEED OF LEASE DATED 20.10.2018 EXECUTED IN FAVOUR OF THE PETITIONER.

Exhibit3 THE COPY OF THE EXPLOSIVE LICENCE ISSUED IN FAVOUR OF THE PETITIONER UNDERSIGNED BY DEPUTY CHIEF CONTROLLER OF EXPLOSIVES, ERNAKULAM.

Exhibit p4 THE COPY OF THE INTEGRATED CONSENT TO OPERATE- RENEWAL ISSUED BY THE KERALA STATE POLLUTION CONTROL BOARD IN FAVOUR OF THE PETITIONER.

Exhibit p5 THE COPY OF THE NO OBJECTION RENEWAL CERTIFICATE ISSUED BY DISTRICT FIRE OFFICER, FIRE AND RESCUE SERVICES, KOTTAYAM DATED 17.09.2022 HAVING VALIDITY TILL 17.09.2023.

Exhibit6 THE COPY OF THE D&O RENEWAL LICENCE ISSUED BY THE SECRETARY, ERUMELY GRAMA PANCHAYATH DATED 07.12.2022.

Exhibit p7 THE COPY OF THE MOVEMENT PERMIT ISSUED BY THE GEOLOGIST, DEPARTMENT OF MINING AND GEOLOGY, KOTTAYAM DATED 14.10.2022.

Exhibit8 THE COPY OF THE RECEIPT ISSUED BY THE OFFICE OF THE 2 ND RESPONDENT ACKNOWLEDGING THE COMPLAINT OF THE PETITIONER.

Exhibit9 THE COPY OF NEWS REPORT PUBLISHED IN MALAYALA MANORAMA DAILY WITH RESPECT TO THE HIGH-HANDED ACTS BEING COMMITTED BY THE 3 RD RESPONDENT AND THEIR UNION MEMBERS.

RESPONDENT EXHIBITS Exhibit R4(a) True copy of the Chelan taken from the website of vehicle department.

PETITIONER EXHIBITS Exhibit P10 THE COPY OF COMPLAINT DATED 28-10-20222 SUBMITTED

WP(C) NOs.35066 OF 2022 & 35339 of 2022 10 BEFORE THE STATION HOUSE OFFICER,ERUMELY POLICE STATION APPENDIX OF WP(C) 35339/2022 PETITIONER EXHIBITS Exhibit P1 THE TRUE COPY OF THE ORDER NO:D1/5234/04 DATED 29/10/2019 ISSUED BY THE GENERAL MANAGER, DISTRICT INDUSTRIES CENTRE, ALAPPUZHA TO THE PETITIONER.

Exhibit P2 THE TRUE COPY OF THE CUMULATIVE LICENSE NO:A4- 2350/2020 DATED 05/05/2020 OBTAINED BY THE PETITIONER FROM THE SECRETARY, THAZHAKKARA GRAMA PANCHAYATH.

Exhibit P3 THE TRUE COPY OF THE D.L. REGISTRATION NO:14/202122/MM/GBS/DOA/528/2021 DATED 25/06/2021 ISSUED BY THE DISTRICT GEOLOGIST, ALAPPUZHA TO THE PETITIONER Exhibit P4 THE TRUE COPY OF THE CONSENT IN FILE NO:PCB/ALP/UCO-609/08 DATED 24/09/2021 ISSUED BY THE ENVIRONMENTAL ENGINEER, POLLUTION CONTROL BOARD, ALAPPUZHA Exhibit P5 THE TRUE COPY OF THE CONSENT IN FILE NO:

PC/ALP/UCO-8129/21 DATED 31/10/2021 ISSUED BY THE ENVIRONMENTAL ENGINEER, POLLUTION CONTROL BOARD, ALAPPUZHA Exhibit P6 THE TRUE COPY OF THE LICENCE NO:D04/CHR/01/641/2018 ISSUED BY THE INSPECTOR OF FACTORIES AND BOILERS, CHENGANNUR DIVISION IN KOLLAM REGION TO THE PETITIONER Exhibit P7 THE TRUE COPY OF THE GST REGISTRATION CERTIFICATE NO:32ADVFS5185LIZ9 DATED 24/06/2020 ISSUED TO THE PETITIONER Exhibit P8 THE TRUE COPY OF THE R.C.PARTICULARS OF THE PETITIONER'S 2018 MODEL BHARATH BENZ GOODS

WP(C) NOs.35066 OF 2022 & 35339 of 2022 11 CARRIER BEARING REG. NO: KL-40-Q-0518 Exhibit P8A THE TRUE COPY OF THE R.C. PARTICULARS OF THE PETITIONER'S 2019 MODEL TATA GOODS CARRIER BEARING REG.NO:KL-31-P-0697 Exhibit P8B THE TRUE COPY OF THE R.C. PARTICULARS OF THE PETITIONER'S 2016 MODEL GOODS CARRIER BEARING REG.NO:KL-31-K-3177 Exhibit P8C THE TRUE COPY OF THE R.C. PARTICULARS OF THE PETITIONER'S 2018 MODEL BHARATH BENZ GOODS CARRIER BEARING REG.NO:KL-40-Q-0520 Exhibit P8D THE TRUE COPY OF THE R.C. PARTICULARS OF THE PETITIONER'S 2019 MODEL ASHOK LEYLAND GOODS CARRIER BEARING REG.NO: KL-31-P-1265 Exhibit P8E THE TRUE COPY OF THE R.C. PARTICULARS OF THE PETITIONER'S 2018 MODEL BHARATH BENZ GOODS CARRIER BEARING REG.NO: KL-31-M-7723 Exhibit P8F THE TRUE COPY OF THE R.C.PARTICULARS OF THE PETITIONER'S 2015 MODEL HGV TIPPER BEARING REG. NO: KL-31-H-3215 Exhibit P8G THE TRUE COPY OF THE R.C. PARTICULARS OF THE PETITIONER'S 2018 MODEL HGV TIPPER BEARING REG. NO: KL-31-L-8541 Exhibit P8H THE TRUE COPY OF THE R.C.PARTICULARS OF THE PETITIONER'S 2018 MODEL BHARATH BENZ GOODS CARRIER BEARING REG.NO: KL-31-M-8582.

Exhibit P8I THE TRUE COPY OF THE R.C. PARTICULARS OF THE PETITIONER'S 2018 MODEL HGV TIPPER BEARING REG.NO: KL-02-BD-7391 Exhibit P8J THE TRUE COPY OF THE BHARATH BENZ GOODS CARRIER BEARING R.C. PARTICULARS OF THE PETITIONER'S 2021 MODEL REG. NO:KL-31Q-1251 Exhibit P8K THE TRUE COPY OF THE R.C.PARTICULARS OF THE

WP(C) NOs.35066 OF 2022 & 35339 of 2022 12 PETITIONER'S 2021 MODEL ASHOK LEYLAND GOODS CARRIER BEARING REG.NO:KL-31-Q-1261 Exhibit P8L THE TRUE COPY OF THE R.C.PARTICULARS OF THE PETITIONER'S 2018 MODEL HGV TIPPER BEARING REG. NO:KL-02-BD-9685 Exhibit P8M THE TRUE COPY OF THE R.C. PARTICULARS OF THE PETITIONER'S 2021 MODEL ASHOK LEYLAND GOODS CARRIER BEARING REG.NO: KL-31-Q-1250 Exhibit P8N THE TRUE COPY OF THE R.C. PARTICULARS OF THE PETITIONER'S 2021 MODEL ASHOK LEYLAND GOODS CARRIER BEARING REG.NO: KL-31-Q-1242 Exhibit P8O THE TRUE COPY OF THE R.C.PARTICULARS OF THE PETITIONER'S 2021 MODEL BHARATH BENZ GOODS CARRIER BEARING REG. NO: KL-31-Q-1423 Exhibit P8P THE TRUE COPY OF THE R.C.PARTICULARS OF THE PETITIONER'S 2019 GOODS CARRIER BEARING REG.

NO:KL-31-P-0679 Exhibit P8Q THE TRUE COPY OF THE R.C. PARTICULARS OF THE PETITIONER'S 2018 MODEL GOODS CARRIER BEARING REG. NO: KL-31-L-6992 Exhibit P8R THE TRUE COPY OF THE R.C.PARTICULARS OF THE PETITIONER'S 2018 MODEL GOODS CARRIER BEARING REG. NO:KL-31-L-5993 Exhibit P8S THE TRUE COPY OF THE R.C. PARTICULARS OF THE PETITIONER'S 2018 MODEL GOODS CARRIER BEARING REG. NO:KL-02-BE-1889.

Exhibit P9 THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:

KL-2021-GP-0324B DATED 06/05/2021 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-40-Q-0518 Exhibit P9A THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:

KL/31/GC/TIPPER/2019/4 DATED 27/11/2019 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S

WP(C) NOs.35066 OF 2022 & 35339 of 2022 13 VEHICLE KL-31-P-0697 Exhibit P9B THE TRUE COPY OF THE CARRIAGE PERMIT NO: KL- 2020-GP-1834A DATED 18/02/2020 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-31-K-3177 Exhibit P9C THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:

KL-2021-GP-0323B DATED 06/05/2021 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-40-Q-0520 Exhibit P9D THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:KL/31/GC/TIPPER/2019/6 DATED 23/12/2019 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-31P-1265 Exhibit P9E THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:KL-2021-GP-6438A DATED 17/03/2021 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-31-M-7723 Exhibit P9F THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:

P.GD. 31/741/2019 DATED 29/07/2019 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-31-H-3215 Exhibit P9G THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:

P.GD. 31/18/2020 DATED 30/01/2020 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-31-L-8541 Exhibit P9H THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:P.GD. 31/19/2020 DATED 30/01/2020 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-31-M-8582 Exhibit P9I THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:P.GD. 31/681/2019 DATED 16/07/2019 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-02-BD-7391 Exhibit P9J THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:

WP(C) NOs.35066 OF 2022 & 35339 of 2022 14 KL2021-NP-0446A DATED 08/03/2021 ISSUED BY THE RTA, ALAPPUZHA TO THE PETITIONER'S VEHICLE KL- 31-Q-1251/2020 Exhibit P9K THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:

KL2021-NP-0447A DATED 08/03/2021 ISSUED BY THE RTA, ALAPPUZHA TO THE PETITIONER'S VEHICLE KL- 31-Q-1261/2021 Exhibit P9L THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:P. GD. 31/687/2019 DATED 03/07/2019 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-02-BD-9685 Exhibit P9M THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:

KL2021-NP-0450A DATED 08/03/2021 ISSUED BY THE RTA, ALAPPUZHA TO THE PETITIONER'S VEHICLE KL- 31-Q-1242/2021 Exhibit P9N THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:

KL2021-NP-0448A DATED 08/03/2021 ISSUED BY THE RTA, ALAPPUZHA TO THE PETITIONER'S VEHICLE KL- 31-Q-1250/2021 Exhibit P9O THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:KL2021-NP-0449A DATED 08/03/2021 ISSUED BY THE RTA, ALAPPUZHA TO THE PETITIONER'S VEHICLE KL-31-Q-1423/2020 Exhibit P9P THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:

KL/31/GC/TIPPER/2019/5 DATED 27/11/2019 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-31P-0679 Exhibit P9Q THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:KL2020-GP-2100A DATED 20/02/2020 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-31-L-6992 Exhibit P9S THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:P.GD.31/692/2019 DATED 05/07/2019 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S

WP(C) NOs.35066 OF 2022 & 35339 of 2022 15 VEHICLE KL-02-BE-2889 RESPONDENT EXHIBITS Exhibit R18(a) True copy of the counter affidavit in W.P.(C) No. 35066/2022 PETITIONER EXHIBITS Exhibit P9R THE TRUE COPY OF THE GOOD CARRIAGE PERMIT NO:KL2020-GP-2099A DATED 20/02/2020 ISSUED BY THE RTA, MAVELIKKARA TO THE PETITIONER'S VEHICLE KL-31-L-6993 Exhibit P10 THE TRUE COPY OF THE TAX INVOICE ISSUED BY THE 16TH RESPONDENT TO THE PETITIONER.

RESPONDENT EXHIBITS Exhibit R18(b) True copy of the Chelan issued in connection with the check report of the vehicle bearing No. KL-31 Q 1242 dated 29/10/2022 issued by Sub regional Transport Office, Kanjirappilly PETITIONER EXHIBITS Exhibit P11 THE TRUE COPY OF THE COMPLAINT DATED 29.10.2022 FILED BY THE PETITIONER BEFORE THE 6TH RESPONDENT AND ITS RECEIPT RESPONDENT EXHIBITS Exhibit R18(c) Chelan copy taken from the website of vehicle department Exhibit R18(d) Chelan copy taken from the website of vehicle department PETITIONER EXHIBITS Exhibit P12 THE TRUE COPY OF THE FIR INC RIME NO.1260/2022

WP(C) NOs.35066 OF 2022 & 35339 of 2022 16 OF ERUMELI POLICE STATION.

RESPONDENT EXHIBITS Exhibit R18(e) Chelan copy taken from the website of vehicle department Exhibit R18(f) Chelan copy taken from the website of vehicle department