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1 IN THE SUPREME COURT OF CIVIL ORIGINAL JURISDICTION M.A. No. 2219 OF 2018 IN Writ Petition (Civil) No. 878 of 2017 In the Matter of: Russel Joy :: Petitioner Versus Union of India & Ors., :: Respondent

COUNTER AFFIDAVIT ON BEHALF OF STATE OF TAMIL NADU TO THE APPLICATION & SUBMISSIONS FILED ON 16.08.2018 & 17.08.2018 BY PETITIONER

I, M. Selvaraju, Son of S.C. Muthusamy aged 61 years, having my

office at Water Resources Department, Government of Tamil

Nadu, No. 406, Pantheon Road, Egmore, Chennai – 600 008,

Tamil Nadu, presently having come down to New Delhi, do

hereby solemnly and sincerely affirm and state as under:

1. I am the Member, Cauvery Technical Cell cum Inter

State Waters Wing, Water Resources Department,

Chennai, Tamil Nadu and as such I am conversant

with the facts of the case and authorized to file the

present affidavit placing on record the events after the

inspection of Mulla on 04.08.2018 by the

Supervisory Committee constituted pursuant to the

Judgment of this Hon’ble Court (2014) 12 SCC 696.

2. At the outset, all the averments made in the

Application filed on 16.08.2018 and submissions filed Bar & Bench (www.barandbench.com)

2 on 17.08.2018 are denied except those that are

specifically admitted herein.

3. I submit that the State of Tamil Nadu is fully

committed and concerned with the safety of the people

living in the downstream of the Mullai Periyar Dam.

The officials of the two States were exchanging

information and all possible steps are being taken to

safeguard the interest of both the States. Further, the

officials of are also available in the Dam

premises who are observing the hydrological data of the

Dam.

4. Before I proceed to make my reply to the averments it

is relevant to place on record the following: -

5. I state that the Mullai Periyar Dam was constructed,

operated and being maintained by Tamil Nadu under the

Agreement of 1886 and the supplemental Agreement of

1970. The FRL of the Dam was 152 ft. The water is being

diverted through a tunnel to meet the irrigation and

drinking water needs of drought prone areas in the five

districts in Tamil Nadu,viz. Theni, Madurai,

Ramanathapuram, Sivagangai, and Dindukkal. The

operation of the Dam and the storage structures falls

exclusively within the control of State of Tamil Nadu. Bar & Bench (www.barandbench.com)

3 6. I state that in the Periyar basin of Kerala, there are

three reservoirs and one barrage maintained by Kerala

in addition to the above Mullai Periyar Dam.

7. I state that Idukki Dam located about 40 KM

downstream of Mullai Periyar Dam has an independent

catchment area of 649 sq. km. which is a hilly terrain.

It received heavy rainfall during July and August, 2018

and the inflow into Idukki dam was heavy, in the range

of 84.28 Mcm (126.42 MU), and Kerala released water

from Idukki Dam from 10.08.2018 onwards. Similarly,

other major in the State of Kerala received heavy

to very heavy rainfall during the current monsoon

season, beginning from June, 2018 resulting in heavy

overflows in many Dams of Kerala. The quantity of

water spilled by 10 Hydropower dams of Kerala from 1st

to 19th August, 2018 was very high. Idukki reservoir

alone spilled 39.10 TMC in 12 days from 10.08.2018

till 21.08.2018. The details of excess water spilled from

the Dams in the Periyar River basin in Kerala is

annexed herewith and marked as ANNEXURE: I (Page

No. 23)

8. I state that the Chief Engineer of CWC, Dam Safety

Organisation, who is the Chairman of the Supervisory Bar & Bench (www.barandbench.com)

4 Committee along with the Members of the two States

inspected the Mullai Periyar Dam on 04.08.2018. The

overall condition of the Dam and its appurtenant

structures was found to be satisfactory by the

Committee members, vide, Minutes of the meeting. A

copy of the Minutes of the 11th Supervisory Committee

meeting held on 04.08.2018 is annexed as

ANNEXURE: II (Page Nos. 24 to 31). The Executive

Engineer, CWC, who is the Chairman of the Sub

Committee under the Supervisory Committee also

inspected the dam on 15.08.2018 and found everything

in order. The submission made by the Applicant that

the Chairman of the Supervisory Committee directed

the State of Tamil Nadu not to allow the dam height to

cross 139 ft., is totally incorrect and contrary to facts.

9. I state that the water level in the Idukki Dam on

14.08.2018 was 731.08 m (2399 ft.) against the

FRL 732.43 m (2403 ft.) and the quantity spilled was

46.26 Mm3 (1.634 TMC). But on 15.08.2018 the level

was 731.868 m (2401 ft.) and the quantity spilled was

390.51 Mm3 (13.791 TMC), which is evident from data

available in the website of KSEB. Thus it can be seen

that State of Kerala suddenly increased the releases Bar & Bench (www.barandbench.com)

5 from 46.26 Mm3 on 14.08.2018 to 390.51 Mm3 on

15.08.2018. Similarly, the release of water from

Idamalaiyar dam, which flows into the lower part of

Periyar river was 117.72 Mm3 on 16.08.2018 while the

release from the dam was Nil on 14.08.2018 and

15.08.2018, and thus, the release was sudden.

10. The storage level in the Mullai Periyar Dam as on

01.06.2018 was 115.70 ft. and on 14.08.2018 at 8.00

A.M was only 136.1 ft. against the permitted storage

level of 142 ft. The inflow was only 4419 cusecs with a

diversion of 2200 cusecs through the tunnel to Tamil

Nadu. On 15.08.2018, when the water level reached

140 ft., spilling of water to downstream of the dam

commenced and the initial release was 4489 cusecs.

This was gradually stepped up in the course of the day

to 8905 cusecs and the average spilling was 14429

cusecs. On 15th morning the level rose to 140.7 ft. and

the inflow was 16629 cusecs and the quantity spilled

to Idukki Dam was only 14429 cusecs (1.247 TMC),

whereas the outflow from Idukki Dam on the same day

was 390.51 Mm3 or 13.79 TMC. On 16.8.2018, inflow

into Mullai Periyar Dam was 25,730 cusecs and the

quantity spilled to Idukki Dam was 23,397 cusecs i.e., Bar & Bench (www.barandbench.com)

6 2.022 TMC and the outflow from Idukki Dam was

126.63 Mm3 (4.472 TMC). Similarly on 17th, 18th & 19th,

Idukki Dam surplused 114.84 Mm3, 70.52 Mm3 & 59.4

Mm3 respectively. Thus, the total quantity spilled from

Idukki Dam from 14th to 19th August 2018 is 808.16

Mm3 (28.54 TMC), and from Idamalaiyar dam in the

corresponding period is 219 Mm3 (7.74 TMC) totaling to

1027.16 Mm3 (36.28 TMC), whereas the quantity

released from Mullai Periyar Dam to Idukki Dam

during the corresponding period is far less than the

quantity surplused from Idukki and Idamalaiyar dams.

Thus, it is seen that that flood surplus from the Idukki

dam is mainly due to the flows generated from its own

independent catchment due to unprecedented heavy

rainfall while the contribution from Mullai Periyar Dam

was significantly less.

10. The lower Periyar basin, apart from receiving the

surplus waters from Idukki dam, receives surplus from

Idamalayar Reservoir, Bhuthathankettu Reservoir etc.,

in Kerala, which also contributed to the flooding of

lower Periyar area. Thus the spillage from Mullai

Periyar Dam is far less when compared to the total

surplus flow from the Idukki, Idamalayar and other Bar & Bench (www.barandbench.com)

7 tributaries of Periyar basin. Further, even this small

surplus from Mullai Periyar Dam could have been

reduced to a major extent, if the State of Kerala had

not obstructed to complete the balance strengthening

works to enable Tamil Nadu to restore water the level

upto 152 ft.

11. I state that the designed Maximum Water Level (MWL)

of Mullai Periyar Dam is 155 ft. for which the safety

was examined and found to be safe by this Hon’ble

Court, vide, (2014) 12 SCC 696 CB (Para: 201). Thus

the Flood cushion available is 13 ft. (155 ft. – 142 ft.)

which could not be utilized by Tamil Nadu due to non-

cooperation of State of Kerala, in order to help the

encroachers, who have illegally occupied the water

spread area between 142 ft. and 155 ft. leased to State

of Tamil Nadu. The State of Tamil Nadu has filed an

Original Suit, O.S. No. 4 of 2014, before this Hon’ble

Court which is pending.

12. It is stated that Kumuli to Vandiperiyar road got

damaged due to flood flow and the road was flooded

although there was no spill from Mulla Periyar dam,

and traffic was disrupted, vide media report dated.

16.07.2018. A translated version of the news item Bar & Bench (www.barandbench.com)

8 dated 16.07.2018 of Dinamalar Daily is enclosed as

ANNEXURE: III (Page No. 32). However, the Petitioner

being aware of the ground realities filed the present

application on 16.08.2018 and mentioned the matter

as though the entire problem arose only after the water

spilled from the Mullai Periyar Dam on 15.08.2018 and

attributing failure of the party States in monitoring the

safety of the inhabitants in the downstream of the dam.

Keeping in view the rains in the catchment area of

Mullai Periyar Dam, the flood warning for every raise of

water level of 1 ft. was issued to the concerned officials

in the State of Kerala. When the water level in the

Mullai Periyar Dam reached 140 ft., water was allowed

to spill through the spillway of the Dam after giving

sufficient flood warning and was made in the presence

of the Engineers of Kerala.

Reply to Submission made on 17.08.2018 – Preliminary Submission

13. I submit that the Sub-Committee of the National

Executive Committee (NEC) constituted under the

Disaster Management Act, 2005 (Act, 2005) held its

1st meeting on 04.06.2018 at New Delhi. Thereafter,

pursuant to the orders of this Hon’ble Court, a meeting

was held through video conferencing under the Bar & Bench (www.barandbench.com)

9 Chairmanship of the Secretary (WR, RD & GR), in

which the officials of CWC and the officials of the two

States participated. The representative of Tamil Nadu

explained the position and stated that the storage level

could be retained at 142 ft. and pointed out that any

reduction in permitted water storage level would mean

extra release of water from the Dam, which could

aggravate the existing flood situation in Kerala. Tamil

Nadu reiterated that it was permitted a storage level of

142 ft. by the Constitution Bench of this Hon’ble Court.

After detailed deliberation, it was decided that the

reservoir should be regulated in such a way that the

level in the Mullai Periyar Dam remains 2 to 3 ft. below

the permitted water level of 142 ft. during the current

spill of rains and the situation could be reviewed after

one week. Accordingly, the water level is presently kept

at +140 ft. A copy of the Minutes of the meeting held on

17.08.2018 is annexed herewith and marked as

ANNEXURE: IV (Page Nos. 33 to 38). Presently the

inflow into Mullai Periyar Dam has drastically reduced

and the spill is meagre.

14. As regards the claim of the Petitioner for bringing the

water level to 139 ft., I state that as per the Judgment Bar & Bench (www.barandbench.com)

10 of this Hon’ble Court, after the completion of remaining

strengthening works, and after review by independent

experts, the water level in the Dam could be restored to

FRL of +152 ft. However, Kerala is obstructing Tamil

Nadu from carrying out the balance strengthening

works. I state that if FRL could have been restored to

+152 ft., the quantum of release from Mulla Periyar

dam would have been much less and there would have

been no room to create panic in the minds of the

people living downstream. The Mullai Periyar dam is

hydrologically, and structurally safe for MWL condition

of +155 ft. as per the Report of the Empowered

Committee, which was accepted by this Hon’ble Court.

(2014) 12 SCC 696 (Para 201).

15. I state that there has been a proper and meaningful

coordination between the States. The State of Tamil

Nadu duly informed the counterpart of Kerala since the

water level in the Dam reached +136 ft. Thereafter,

when the water level reached +138 ft., +140 ft., +141 ft.

& +142 ft., suitable warnings were issued and the

quantum of discharge were also intimated. Thus the

State took all the required measures before water was

released from the Dam. I submit that, since the Bar & Bench (www.barandbench.com)

11 downstream area of Mullai Periyar Dam is in Kerala,

the Disaster Management Plan has to be prepared and

made public by the State of Kerala in proper

coordination with the Central Committee and the State

of Tamil Nadu. In fact the entire events were being

managed by the Centre on real time basis.

Response to Submissions

16. The averments made in para 1 with regard to not

permitting the height to cross 139 ft. is denied. The

Petitioner has stated that the water level has raised

from 139 ft. to 142 ft. in few hours, while it has taken

more than 12 hours. The inflows into the Mullai

Periyar Dam from 14.08.2018 and the further spilled in

Mullai Periyar Dam from 14.08.2018 to 21.08.2018 is

annexed herewith and marked as ANNEXURE: V (Page

Nos. ….. to …….).

17. With regard to para 2, I state that the Petitioner is

misinterpreting the permitted storage level of 142 ft. as

the maximum limit for accommodating flood, which is

totally incorrect and contrary to facts. The Constitution

Bench of this Hon’ble Court categorically held that

MWL of Mullai Periyar Dam is +155 ft. and thus a flood

cushion of 13 ft. (155 ft. – 142 ft.) is available. Bar & Bench (www.barandbench.com)

12 However, due to the obstructionist attitude and non

cooperation of Kerala, this cushion could not be

utilized in the present scenario.

18. The averments made in para 3 is totally incorrect and

is denied. I submit that the Role of the Supervisory

Committee is to allay the fear psychosis artificially

created by persons like the Petitioner, who has got

vested interest in protecting the encroachers who have

illegally occupied the water spread area of the Mullai

Periyar Dam between the contour levels +142 ft. and

+155 ft. The State of Tamil Nadu has filed a Suit O.S.

No. 4 of 2014 before this Hon’ble Court for removing

the encroachment besides objecting to the Mega Car

Park works in the water spread area leased to Tamil

Nadu. The averment of the Petitioner is an attempt to

misguide this Hon’ble Court.

19. With regard to para 4, I submit that the rules (1939)

for the working of the Periyar Regulator was rechecked

and relooked and reviewed in 1974. In any event, the

CWC has checked and approved the flood routing of

Mullai Periyar Dam in 2001 and again reviewed in

2012 at the request of Empowered Committee

appointed by this Hon’ble Court. Bar & Bench (www.barandbench.com)

13

20. With regard to para 5, I submit that there is a

permanent Office for the Supervisory Committee, which

is located in a rented building at Kumily town, near the

Dam site, where Supervisory Committee and Sub

Committee meetings are held. The Supervisory

Committee meets as and when required, and the Sub

Committee formed to assist the Supervisory

Committee, conducts periodic inspection & meetings,

approximately once a month, and report the status to

the Supervisory Committee. Thus, the Petitioner has

made incorrect statements before this Hon’ble Court.

21. With regard to para 6, I state that the Mullai Periyar

Dam was constructed, operated and maintained by

Tamil Nadu by virtue of the Lease Deed of 1886

Agreement and the Supplemental Agreements of 1970.

Further, the operation of the dam and the storage

structures falls exclusively within the domain of the

State of Tamil Nadu. The prayer of the Petitioner

requesting to direct the National Executive Committee

(NEC) to take over Mullai Periyar Dam is wholly

misconceived and the intent of the Petitioner to divest

the control and operation of the dam from the State of

Tamil Nadu shows the malafide of the Petitioner. The Bar & Bench (www.barandbench.com)

14 State of Tamil Nadu is properly coordinating the

operation of the dam and regulating the flows.

22. The averment of the Petitioner in para 7 is denied. The

Mullai Periyar Dam is being managed well by Tamil

Nadu and there has been a proper coordination

between all the concerned agencies to meet the

situation faced due to the unprecedented heavy rains

which occurred in the State of Kerala.

23. The averments made in para 8 is totally misconceived.

It is submitted that it is the responsibility of the

downstream State to demarcate the flood prone area

and inform the public, and remove the encroachment

along the river course / banks, as stated in the Report

of the Empowered Committee, 2012, which has been

affirmed by this Hon’ble Court in the decree dated

07.05.2014. In any event, adequate announcement and

warnings are to be issued by State of Kerala to avoid

any inconvenience/ destruction/damage to

downstream State.

24. The submission of the Petitioner in paras 9 and 12 for

issuance of directions to decommission the Dam, is

contrary to the Judgment of Constitution Bench dated Bar & Bench (www.barandbench.com)

15 07.05.2014. The Petitioner in utter disregard to the

Judgment is seeking such a prayer which shows the

lack of bonafide of the Petitioner. The Petitioner,

claiming to be concerned with the natural disaster in

Kerala, filed application only with regard to Mullai

Periyar dam that too on 16.08.2018 as though the

entire cause of the disaster is only on account of the

releases from the Mullai Periyar Dam, which shows the

lack of bonafide on the part of the Petitioner. I submit

that the two State Governments have taken adequate

care and took all necessary measures during flood.

Reply to Application filed on 16.08.2018.

25. The averments made in paras 1 to 3 are all general

statements about the State of Kerala on account of the

severe floods. It has no bearing with status of Mullai

Periyar Dam. It only depicts the ground realities on

account of unprecedented rains during the current

monsoon season.

26. The averments made in para 4 on the life span and

safety of the dam is denied. This Hon’ble Court in its

order dated 11.01.2018 has clearly held that the

directions contained does not anyway remotely suggest

that there is any doubt about the safety or the life span Bar & Bench (www.barandbench.com)

16 of the dam. This Hon’ble Court only ordered to

constitute separate Sub-Committees under Act, 2005

and not as sought to be interpreted by the Petitioner.

27. The averments made in paras 5 to 8 are matters of

record and do not call for any reply.

28. The averments made in para 9 is incorrect and is

denied. I submit that the Sub - Committee of the

National Executive Committee (NEC) constituted under

Act, 2005 held its 1st meeting on 04.06.2018 at New

Delhi and later on 17.08.2018 as per directions of this

Hon’ble Court, under the Chairmanship of the

Secretary (WR, RD & GR). The details have been

already set out hereinabove which are reiterated. The

Petitioner who shows concern about the Mullai Periyar

Dam has not made any averment with regard to the

Disaster Management Plan below the Idukki Dam

mainly in the lower Periyar region of Kerala where large

flood fury occurred due to heavy rainfall in the current

South West monsoon period. Further, the statement of

the Petitioner about the displacement of persons is a

bald statement without any material or basis.

Bar & Bench (www.barandbench.com)

17 29. The averments made in para 10 is denied. The State of

Tamil Nadu denies the statement of the Petitioner that

the actual quantity stored has been understated on

many occasions and that Kerala has no idea regarding

necessary warnings issued to the people. Daily water

level readings and inflow and outflow are

communicated to the Supervisory Committee and its

Members and to the Chairman, Sub Committee who is

from CWC & its Members from the State of Tamil Nadu

& Kerala. Further, whenever there is going to be some

release through the spillway, it is informed in advance

to the Collector of , Government of

Kerala and the concerned officials and the Engineers of

Kerala.

30. The averments made in para 11 is totally denied. The

Petitioner has alleged that out of 39 dams in Kerala,

33 dams have been opened as a result of large volume

of water flow which has affected transportation,

communication etc. The dams of Kerala have been

opened from first week of August 2018 as they have

reached maximum level, but Mullai Periyar dam

spillway was opened on 14th August 2018 only. In any

event, the spillage from Mullai Periyar Dam is too small Bar & Bench (www.barandbench.com)

18 as stated above, when compared to the overall flood

flows in Kerala during this monsoon up to 19th August,

2018. The allegation that action was taken by the

Respondent State only after the water level in the dam

crossed the permitted storage of +142 ft., is denied. In

fact, the dam gates were opened when the reservoir

level was at +140 ft. and thereafter the discharge was

stepped in stages after giving sufficient warnings, in

order to avoid flash floods. The initial surplus quantity

at +140 ft. was 4489 cusecs and thereafter stepped

upto 8905 cusecs, when the water level was 141 ft. and

the spillway was regulated further considering the rate

of inflows to avoid flash flows. In any event the

quantity spilled from Mullai Periyar Dam is very small

when compared to the quantity spilled by the 39 dams

of Kerala. The flood warnings issued by officials of

Tamil Nadu to officials of Kerala is annexed as

ANNEXURE: VI (Page Nos. 39 to 44).

31. The averments made in paras 12 & 13 are denied. The

Petitioner has alleged that the water level of Dam has

to be reduced to 139 ft. without any basis and without

considering that release of water from the Mullai

Periyar reservoir to the downstream to Idukki dam, Bar & Bench (www.barandbench.com)

19 would cause more problem when the downstream area

of Periyar basin is already facing heavy floods. The

Chief Minister of Tamil Nadu has responded on

16.08.2018 to the Chief Minister of Kerala’s letter

dated 15.08.2018 stating that the water is regulated in

such a way that it does not harm the downstream

people of the State of Kerala. The copies of the letter

dated 15.08.2018 and 16.08.2018 are annexed as

ANNEXURE: VII (Page Nos. 45 to 50). There is no

chilling effect situation as alleged by the Petitioner and

has been made only to create sensation and confusion

amongst the Inhabitants in the downstream of the

Mulla Periyar Dam.

32. The averments made in para 14 is totally incorrect and

denied. The Sub-Committee has already met and

transacted business as stated elsewhere.

33. The averments made in paras 15 & 16 to the effect that

a worst disaster that is likely to happen is due to the

Mullai Periyar Dam, is totally incorrect. The safety of

the Dam has been reviewed repeatedly by many

Experts Committees, at different points of time, and

found to be safe in all respects. The Constitution

Bench of this Hon’ble Court has found that the dam is Bar & Bench (www.barandbench.com)

20 Hydrologically, Seismically and Structurally safe. The

Petitioner has projected himself as though he is the

only person concerned with the life of the people living

downstream of Mullai Periyar Dam. On the contrary,

this Hon’ble Court has dealt with the safety aspects of

Dam elaborately by appointing an Empowered

Committee under the Chairmanship of Dr. Justice A.S.

Anand, Retired Chief Justice of India. The utter

disregard shown by the Petitioner to the above deserves

to be condemned. The Supervisory Committee

appointed by this Hon’ble Court, vide, its Order dated

07.05.2014 and Sub-Committee inspects the dam

periodically and after checking the vital parameters,

found the dam to be safe. The News Report referred to

by the Petitioner are all exaggeration, which are

incorrect and this Hon’ble Court may not give any

credence to such reports.

34. The averments made in para 17 are totally denied.

Periodical warnings were issued since the water level

reached 136 ft. for every two feet raise, and from 140

onwards for every one foot raise, and well advance

intimation regarding the release of water from the

spillway of the dam was given. Bar & Bench (www.barandbench.com)

21

35. The averments made in para: 18 and the expression

used like catastrophe, sleepless nights, etc., are only

an attempt to create sensation and exaggerate the

issue.

36. The averments made in paras: 19 & 20 are totally

incorrect and denied. The Petitioner has referred to the

incidences of the 2017 (actually the occurrence of flood

was in 2015) in Chennai due to unprecedented rain in

the city of Chennai, which was tackled by the State

Government in record time. In any event, the release of

water from Mullai Periyar Dam was very little when

compared to the water released from Idukki dam and

other large number of dams in Kerala due to

unprecedented rainfall. The Petitioner is attempting to

sensationalise the issue and misguide this Hon’ble

Court, which should not be permitted. The direction

sought for by the Petitioner from this Hon’ble Court for

directing the Central Government and State

Governments to act within few hours as though these

Governments are not functioning, is highly improper

when both Governments are co-ordinating and doing

their best in the hours of this crisis situation, and not

like the Petitioner who seeks to utilise the opportunity Bar & Bench (www.barandbench.com)

22 to create a conflict of good relationship prevailing

between the neighboring States.

In view of the above, this Hon’ble Court may be pleased to dismiss the application and render justice.

Filed by Drawn by: G. Umapathy, Advocate. (K.V. IJAYAKUMAR) Filed on: 24.08.2018. Advocate on Record State of Tamil Nadu

IN THE SUPREME COURT OF INDIA CIVIL ORIGINAL JURISDICTION M.A. No. 2219 OF 2018 IN Writ Petition (Civil) No. 878 of 2017 In the Matter of: Russel Joy ::Petitioner Versus Union of India & Ors., :: Respondent AFFIDAVIT I, M. Selvaraju, son of Shri. S.C.Muthusamy, aged 61 years, having my office at Water Resources Department, Government of Tamil Nadu, No. 406, Pantheon Road, Egmore, Chennai–600 008, presently having come down to New Delhi, do hereby solemnly affirm and state as under:

1. I am the Member, Cauvery Technical Cell cum Inter State Waters Wing, Water Resources Department, Chennai, Tamil Nadu and as such I am conversant with the facts of the case and competent to swear the present affidavit.

2. I have perused the averments made in the reply to the Miscellaneous Application and submissions filed by the Petitioner and state that the facts stated therein are true Bar & Bench (www.barandbench.com)

23 and correct and are based on records maintained by the State of Tamil Nadu. The legal submissions made are based on the legal advice of the counsel, which are believed to be true.

3. I state that the annexures filed along with the application are the true copies of the respective originals.

DEPONENT VERIFICATION Verified that the contents of the above are true and no part of it is false and nothing material has been concealed therefrom.

Verified at New Delhi on August, 2018. DEPONENT

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