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1 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
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 Periyar Dam 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 Kerala 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 Dams 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 Idukki District, 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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