* CHRONICLE - PENSIONERS CONVERGE HERE, DISCUSS ISSUES OF THEIR CHOICE * CHRONICLE - WHERE EVEN THE CHAT COLUMN PRODUCES GREAT DISCUSSIONS * CHRONICLE - WHERE THE MUSIC IS RISING IN CRESCENDO !

               
                                   

Friday, February 07, 2014

COUNTER AFFIDAVIT TO REPLY OF LIC DATED 31-1-2014

IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN

                 JAIPUR BENCH AT JAIPUR
                                  ***
S.B. Civil Contempt Petition No. 760 of 2010
                                  in
S.B. Civil Writ Petition No. 654 of 2007
                                  ***
Krishna Murari Lal Asthana                                 Petitioner
                                  Versus
Shri T.S. Vijayan and others                        Respondents
                                  
COUNTER AFFIDAVIT TO THE REPLY OF THE RESPONDENTS DATED 31/1/2014

         I, Krishna Murari Lal Asthana, aged about 74 years, son of Shri Ram Saran Lalji Asthana, resident of B-8, Shanti Nagar, Ajmer Road, Jaipur, do hereby take oath and state as under:
1.      The Pension is a constitutional right of the Petitioner and is not a bounty but the Respondents are acting as if they are giving any bounty to the Pensioners who are beggars and the Respondents are the bestowers.  They are duty bound to make payment of the Pensioners as has been adjudicated by this Hon’ble High Court, Chandigarh High Court and Delhi High Court and as affirmed by the Hon’ble Supreme Court.

2.      That at the outset the Petitioner begs to submit that the present Contempt Petition is in S.B.C.W.P. No. 654/2007, which was entirely for the revision of pensions as on 1/8/1997, 1/8/2002 and 1/8/2007 by substitution of pay scales. The relief sought in the writ petition No. 654/2007 was to the effect that (i) all pensioners form one class and differential treatment of pensions on the basis of date of retirement is violative of Article 14 of the Constitution of India and (ii) direct the Respondent Corporation to fix the pay of the Petitioners in the substituted pay scales equivalent to their stag of pay in the scrapped pay scale on the date of retirements and pay pension at the rate of 50% of each basic pay as arrived at on and 1-8-92/1-11-193 and on and from 1/8/1997 and thereafter on and from 1/8/2002 with all consequential benefits and (iii) to correspondingly enhance the pension payable to the retirees as and when pay scales are revised irrespective of their dates of retirement. This writ petition was allowed by Hon’ble Mr. Justice M.N. Bhandari in the following manner:
         “The legal position in that regard is quite clear. In view of the catena of judgments of the Hon'ble Apex Court, if there is a change in the benefit of existing pensioners, change has to be made effective to all without a cut off date inasmuch as cut off date in such cases are held to be arbitrary. In a case where pension is allowed for the first time, then a cut off date can be provided. My attention was drawn towards the judgment of the Hon'ble Apex Court in the case of V. Kasturi Vs. State Bank of India reported in AIR 1999 SC 61 wherein aforesaid issue has been dealt with. Same view has been expressed by the Hon'ble Apex Court in the case of Union of India Vs. Dr. Vijayappurapu Subhayamma reported in AIR 2000 SC 3113 and was even reiterated in the case of Subrata Sen Vs. Union of India reported in (2001) 8 SCC 71. In reference to aforesaid judgments, it was urged that there can be no difference in the benefit of dearness allowance to the employees retired before 31.7.1997 and those retired after the aforesaid date.

“Learned counsel for petitioners has further submitted that there exists anomaly even in regard to the revision of the pay scale. The benefit of revision in the pay scale from time to time was not extended to the pensioners. In view of aforesaid, even an officer retiring in the higher pay scale started getting less pension than to the employee retiring subsequently in lower pay scale. Aforesaid aspect was also considered along with the first issue, by the Board in its meeting held on 24.11.2001 and following decision was taken:-
“In view of the several judgments of the Hon'ble Apex Court, issue regarding cut off date for providing pensionary benefits can be summarized in the following manner:-

i)       If there are change in benefit of pension then no cut off date can be provided. The benefit on account of change in pensionary benefits would have retrospective effect.

(ii)     If the pension is introduced for the first time, a cut off date can be fixed.

“Aforesaid issue has been settled by the Hon'ble Apex Court in various judgments cited by learned counsel for petitioners.
Nakara judgment has itself drawn a distinction between an existing scheme and a new scheme. Where an existing scheme is revised or liberalized all those who are governed by the said scheme must ordinarily receive the benefit of such revision or liberalization and if the State desires to deny it to a group thereof, it must justify its action on the touchstone of Article 14 and must show that a certain group is denied the benefit of revision/liberalization on sound reason and not entirely on the whim and caprice of the State. The underlying principle is that when the State decides to revise and liberalize an existing pension scheme with a view to augmenting the social security cover granted to pensioners, it cannot ordinarily grant the benefit to a section of the pensioners and deny the same to others by drawing an artificial cut-off line which cannot be justified on rational grounds and is wholly unconnected with the object intended to be achieved. But when an employer introduced an entirely new scheme which has no connection with the existing scheme, different considerations enter the decision making process. One such consideration may be the financial implications of the scheme and the extent of capacity of the employer to bear the burden. Keeping in view its capacity to absorb the financial burden that the scheme would throw, the employer would have to decide upon the extent of applicability of the scheme. That is why in Nakara case this Court drew a distinction between continuance of an existing scheme in its liberalized form and introduction of a wholly new scheme; in the case of the former all the pensioners had a right to pension on uniform basis and any division which classified them into two groups by introducing a cut off date would ordinarily violate the principle of equality in treatment unless there is a strong rational discernible for so doing and the same can be supported on the ground that it will subserve the object sought to be achieved. But in the case of a new scheme, in respect whereof the retired employees have no vested right, the employer can restrict the same to certain class of retirees, having regard to the fact-situation in which it came to be introduced, the extent of additional financial burden that it will throw, the capacity of the employer to bear the same, the feasibility of extending the scheme to all retirees regardless of the dates of their retirement, the availability of records of every retiree, etc. It must be realized that in the case of an employee governed by the CPF scheme his relations with the employer come to an end on his retirement and receipt of the CPF amount but in the case of an employee governed under the pension scheme his relations with the employer merely undergo a change but do not snap altogether. This is the reason why this Court in Nakara case drew a distinction between liberalization of an existing benefit and introduction of a totally new scheme. In the case of pensioners it is necessary to revise the pension periodically as the continuous fall in the rupees value and the rise in prices of essential commodities necessitates an adjustment of the pension amount but that is not the case of employees governed under the CPF scheme, since they had received a lump sum payment which they were at liberty to invest in a manner that would yield optimum return which would take care of the inflationary trends. This distinction between those belonging to the pension scheme and those belonging to the CPF scheme has been rightly emphasized by this Court in Krishena case”.

Perusal of aforesaid Paras reveals that there exists difference between introduction of new Scheme then the existing Scheme. In the light of the aforesaid, if the facts of this case are looked into, then it becomes clear that amongst the pensioners there exists discrimination more specifically when the pension has been made admissible to the employees who retired on or after 1.1.1986. In view of aforesaid, there can be no different basis for dearness allowance or other benefits to those retired on or before 31.7.1997. The existing pensioners are entitled for the benefit of dearness allowance with the same measure as is admissible to the pensioners on or after 31.7.1997. The discrimination amongst the pensioners on that count is not permissible and if there exists rule, making discrimination amongst the existing pensioners, it is held to be violative of Articles 14& 16 of the Constitution of India.

The respondent Corporation has already taken up the aforesaid issue in its Board meeting and a resolution was also passed on 24.11.2001 after taking note of the fact that three different rates for different groups of pensioners exist depending upon their dates of retirement. It is not only causing administrative inconvenience but creating anomaly amongst the pensioners also. Accordingly, decision was taken but was made subject to final approval by the Central Government.

In fact, implementation of the Board's resolution would take away discriminatory treatment amongst the pensioners apart from keeping the LIC away from the administrative inconvenience. Thus, in the light of the aforesaid discussion, there cannot be a cut off date for existing pensioners for providing benefits but further fact is that to cure the aforesaid mistake, the Board's resolution should have been given effect to, which will otherwise redress the entire grievance of the petitioners. In the facts and circumstances of the case, I am of the view that resolution passed by the Board of LIC does not need approval of the Central Government thus the Corporation may give effect to its resolution dated 24.11.2001 to avoid discrimination amongst existing pensioners.

In light of the discussion made above, both the writ petitions are allowed. The respondent Corporation is directed to take a decision for implementation of the resolution dated 24.11.2001 passed by the Board. The respondent Corporation cannot provide different criteria for grant of dearness allowance to the existing pensioners based on cut off date i.e. 31.7.1997. The benefit arising out of the directions above would, however, be considered by the respondent Corporation so that every retired employee may get the same benefit. Costs made easy. ”
 Please click below to continue.

3.      That in this view of the aforesaid judgment the pension of the Pensioners has to be revised from time to time as and when the pay scales are revised. Since the Petitioner does not have the data of all the pensioners he is giving example in his case. With regard to the cadre of Adm. Officer to which the Petitioner belonged and was drawing pay at the maximum of pay in the pay scale of Rs. 10055-360-14735 as on the date of retirement i.e. 31/12/1997 and as such after adding other eligible additions as per the Pension Rules, namely, Computer allowance equivalent to the last increment i.e. Rs. 230=00 vide Notification dated 22nd June, 2000 effective from 1/8/1997.  These pay scales were revised vide Notification dated 5th September, 2005 effective from 1/8/2002 and the pay scale of Adm. Officer was substituted as Rs. 14890-540-18670-560-22030.  Thus the pay of the Petitioner came to be revised at Rs. 22030 with addition of basic pay of Rs. 22030 + 560 = 22590 50% of which comes to Rs. 11,295 with effect from 1/8/2002. Again these pay scales were revised with effect from 1/8/2007 which was Rs. 23120-34460 the last increment being Rs. 910.  With this addition the pay reckonable for purposes of pensions comes to Rs. 35,370=00. The rate of pension has been notified in the Pension Rules is 50% of the average emoluments and allowances as defined in the Pension Rules.  This is what the Petitioners had demanded and the same has been allowed by the Hon’ble Single Judge in the judgment dated 12/1/2010, which has been affirmed in DB Special Appeal, DB Review Petition and in SLPs twice by the Hon’ble Supreme Court. In view of the above judgments these facts have come to be settled and the judgment of the Hon’ble Single Judge dated 12/1/2010 has become absolute and has to be implemented without challenge.  The present Contempt Petition has been filed for the implementation of the said judgment since the same has become unassailable but the Respondents are deliberately and intentionally avoiding the implementation of the judgment on unsustainable grounds, which is not permissible in law and amounts to contempt of court.

4.      That the writ petition No. 6676/1998 was filed challenging the Appendix IV of the Pension Rules whereby it has provided for slabs of Dearness Relief which provides lesser rate of DR while the rate of DR for subsequent periods is the same for in-service employees and Pensioners and this writ petition was also allowed by the Hon’ble Single Judge, which has also attained finality with the passage of litigation as above and is not assailable now. The Board’s Resolution dated 24/11/2001 was a matter of fact but in the subsequent writ petition No. 654/2007 there is no mention of the same nor could have been so since the pay scale and new DR rate 0.23% per slab as on 1/8/1997 had come into effect and which has to be applied. Only the anomaly with respect to DR for the period before 1/8/1997 has to be  rectified.

5.      That though the two writ petitions were decided by common judgment but the subject matters are different. The writ petition No. 6676/1998 was in the matter of Dearness Relief and the subject matter of writ petition No. 654/2007 is in respect of revisions of pension commensurate with the substituted pay scales and after fixing the pay at the stage in the concerned cadre where the concerned employee was borne as on the date of retirement. Thus there is clear cut difference between the two subject matters.

6.      However, the Respondents taking advantage of the decision of the two writ petitions have always been defying the judgment in SBCWP 654/2007 irrespective of the fact that the same was not the subject matter of the contempt petition. At the time of deposits of the amounts in the Registry of this Court as were directed by the Hon’ble Supreme Court the same game was played by them.  Objections to this effect were taken then and there.

7.      That in this view of the factual position of the present case the Respondents were required to implement the judgment dated 12/1/2010 in so far as it relates to the revision of pensions from time to time and any payment made in the matter of Dearness Relief alone and consequential alleged revision of pension as on 1/8/1997 does not mitigate the contempt as stated in the above captioned petition No. 760 of 2010.

8.      That on the subject of the informations sought by this Hon’ble Court vide order dated 22/1/2014 with regard to implementation of the Board’s Resolution dated 24/11/2001 in the form of affidavit it is submitted that the Respondents have concealed the correct reply and have thus further committed contempt by making false averments on affidavit. The Petitioner submits about non-compliance of the order dated 22/1/2014 as under;
8.1.   This Hon’ble Court directed the Respondents to submit the copy of the Resolution of the Board dated 24/11/2001 but the same has not been filed with the affidavit as directed by this Hon’ble Court.
8.2.     This Hon’ble Court had specifically directed the Senior Counsel to submit any decision that the L.I.C. may have taken for implementation of the Resolution dated 24.11.2001 but there is no reply. The fact is that no decision has been taken so far for the implementation of the Board Resolution dated 24/11/2001.
8.3.     This Hon’ble Court also desired to emphatically state whether the amount is being deposited in consonance with or contrary to the Resolution dated 24.11.2001. The reply is full of suspense since except filing the detailed lists no reply in emphatic terms has been given. In this connection it is submitted that the amounts have not properly been deposited even as per the Board’s Resolution dated 24/11/2001 for the reasons -
i)            The alleged amount has been deposited for only 20 persons while there are 28 petitioners;
ii)      It has been shown that the Pension of the Petitioner has been upgraded to Rs. 6663/00 as on 1/8/1997. For this the 50% of the eligible emoluments of Rs. 9320/00 have been taken and with this the DR as applicable in January 1997 has been added while the DR was thereafter revised in February 1997 and has to be taken into account but this has not been done and thus even according to their own statement less amount has been taken into account. This shows that 100% neutralization of DR as approved by the Board has not been taken into account.
iii)     The effect of 100% neutralized DR has not been given effect to.
iv)         The weightage of 11.25% as has been decided by the Board has not been given effect.
v)           The Board Resolution has to be effective from 1/11/1993 but the calculations have been shown from 1/8/1997 not from 1/11/1993 or the date of retirement whichever is later.
vi)         As per the Board’s Decision dated 24/1/2001 and the judgment dated 12/1/2010 on the pension of the Petitioner of Rs. 4660=00 the DR payable comes to Rs. 2413=00 as on 1/8/1997 and not Rs. 2003.03 as has been added.
vii)       By this method the ultimate pension has been reduced because on the so-called upgraded pension the rate of DR has been reduced to 0.23% per slab from 0.35% upto 2400 and 0.29% for pension between 2400 to 3850. This is mischievous method of reducing rather than giving benefit.
viii)      The same rate of DR as was being paid without applying the Board Resolution dated 24/11/2001 i.e. Rs. 13.534 per slab has been applied while as per the Board’s Resolution after neutralization the rate of DR of Rs. 16.31 per slab has to be applied and this will make vital difference in the total pension as on 1/8/1997.
ix)         The DR has not been revised on Quarterly basis in line with the formula as applicable to in-service employees as on the date of payment of pension.
9.      That the total arrears as on 31/12/2013 comes to about Rs. 11,53,516=00 in the case of the Petitioner as against which only an amount of Rs. 1,04,391=00 has been deposited. In case quarterly revision of DR rates is applied this amount of arrear will be much more than the above amount.

10.    That after implementation of the judgment the Pension of the Petitioner has to be settled at Rs. 17,480=00 with corresponding Dearness Relief as applicable from time to time. A chart has already been placed on the record of the application dated 14/8/2013.

11.   The amounts were never deposited as per the directions of the Hon’ble Supreme Court.  The objections were then and there filed by the Petitioner but no care was taken even to submit their clarifications or justification for not depositing the correct amount. Those objections still remain undecided.
a)          In the first order dated 14/11/2011 the Hon’ble Supreme had granted stay only on the condition of deposit of the amount due to the employees in the Registry of this Court within eight weeks.  But the amount deposited was for only 20 persons and not for the employees.  As per the Pension Rules a Pensioner is an employee, therefore, the amount should have been deposited for all the Pensioners who are covered under the Board Resolution.
b)          The effective date was arbitrarily taken to be the date of Judgment dated 12/1/2010 while the Resolution made it to be effective from 1/11/1993.
c)           The calculations were not correctly made as per the judgment dated 12/1/2010.
d)          There is no deposit in respect of seven Petitioners even while as per the order the amount should have been deposited in respect of all the Pensioners as per the order of the Hon’ble Supreme Court since the Contempt Petition was in SBCWP No. 654/2007 which was exclusively for revision (upgradation/ updation by whatever name called) of pensions as and when pay scales were revised and the Hon’ble Court had directed to be effective for all the Pensioners accordingly.
e)           At the time of the second deposit the Hon’ble Supreme Court had directed by its order dated 17/10/2012 for deposit of the retiral benefits from the due date of retirement. Since this stay was on the present Contempt petition there was no question of deposit as per the Board Resolution and the amount in respect of the retrial benefits of 28 petitioners being the amount of difference on account of neutralization for the period from the date of retirement upto 31/7/1997 and then on account of revision of pensions in accordance with the revised pay scales as on 1/8/1997, 1/8/2002 and 1/8/2007  should have been deposited, but still the LIC had deposited from 1/8/1997 and not from the date of retirement nor on account of revised pensions.
f)            Again, since the amount was not deposited from the date of retirement it was not compliance of the order as a consequence there was no stay. In case for any reason whatsoever it be taken then it amounted to contempt of the Hon’ble Supreme Court.
g)           Objections were filed then and therefore, but there is no reply. This again is a contempt of court
12.    A copy of the Board’s Resolution as was filed with the writ petition and as has been reproduced in the judgment dated 12/1/2010 is submitted herewith, as desired by the Hon’ble Court in its order dated 22/1/2014 and the same is marked as ANNEXURE ‘CA’ to this Counter affidavit.

13.    That by Notification dated 14th May, 1999 the power to determine the Dearness Relief has been vested in the Board. Therefore, it is redundant rather arbitrary to say that the Board’s Resolution required any approval from the Board. A copy of the Notification dated 14th May, 1999 is submitted herewith and the same is marked as ANNEXURE ‘CB’ to this affidavit.


14.    It is thus clear that the Board’s Resolution and the judgment dated 12/1/1010 take care of the revision of pensions as and when the pay scales are revised and the cut off date has no place when the matter of revision of pensions come.  But by still insisting on the old unrevised pattern the Respondents are committing nothing but grievous contempt of this Hon’ble Court as well as the Hon’ble Supreme Court and the Delhi High Court and Chandigarh High Courts whose cases have been clubbed with the Jaipur HC case and made applicable in rem.

15.    That while on the subject of contempt the Petitioner submits that the reply to show cause notice as given to the present Respondents makes out a complete case of contempt, inter alia, for the following reasons:
15.1. In their reply the main contention of the Respondents is that since they have filed SLP there is stay. This amounts to contempt since by this the Respondents are seeking to override the order dated 30/9/2013 whereby the stay on implementation of the judgment dated 12/1/2010 has specifically and categorically been rejected and the law applicable in this respect. This shows that they have no respect for the Hon’ble Courts.  The law with regard to execution of the judgment is very clear and settled.
         Order XX Rule 1 of the Supreme Court Rules provides that filing of an appeal shall not prevent execution of the decree or order appealed against.     
In the case “Dr. Sajad Majid vs Dr. Syed Zahoor Ahmed And Anr” decide on 30 March, 1989 it has been held s under:

“Mere preferment of an appeal does not automatically operate as a stay of the decision under appeal and till an application for stay is moved and granted by the appellate Court, or, in the alternative, the Court which rendered the decision is moved and grants an interim stay of the decision pending the preferment of an appeal and grant of stay by the appellate Court, the decision continues to be operative. Indeed, non-compliance with the decision on the mere ground that an appeal is contemplated to be preferred or is actually preferred, and that, therefore, the matter is sub-judice, may amount to contempt of Court punishable under the Contempt of Courts Act, 1971.

Similarly Order 41 Rule 5 Civil Procedure Code provides that An appeal shall not operate as a stay of proceedings under a decree or order appealed from except so far as the Appellate Court may order, nor shall execution of a decree be stayed by reason only of an appeal having been preferred from the decree.
In these circumstances the contention of the Respondents is not tenable.
15.2. The other ground is on merits which has already been decided by the Hon’ble Single Judge and upheld by the Hon’ble Division Bench twice, by the Hon’ble Supreme Court, P&H High Court. Therefore non-implementation is contempt of the Court.
15.3. Furthermore the merits of a case cannot be considered in execution proceedings.
15.4.          After dismissal of SLP and rejection of prayer for stay on the implementation of the judgment the question of deposit does not arise. The payment has to be made to the pensioners. Since the amount has not been paid this is contempt of the Court.
15.5. On the one hand they are raising the question of approval of the Central Government while it was stated on the part of the Central Government that there is no need of approval and the Board is competent to take its own decision. The Union of India being a party the said statement was never challenged by it.
15.6. The Central Government or the State Government are not above the Court and when an umbrella has been provided by the Court the Respondents have no option but to implement the judgment even if the Central Government does not approve the same.
15.7. This contention of approval by the Central Government is contrary to the procedure as would be apparent from the Circular dated 18th October, 2005 when the amendment in the Pension Rules were made by the Corporation on its own.  In this circular it has been stated that the Corporation in exercise of powers conferred upon it vide rules 36, 37 and 39 of the Life Insurance Corporation of India (Employees) Pension Rules, 1995 has amended the relevant provisions of the Rules and the Chairman in exercise of powers conferred upon him under Rule 55 of the said Pension Rules has issued the direction to implement the relevant provisions. When the Corporation itself has amended the Pension Rules at a later date, where was the question of approval of the Pension Rules of the Central Govt. in the case of the other Pensioners.  Thus this is a false ground for non-compliance of the judgments which amounts to contempt of the Court.  A copy of the Circular dated 18/10/2005 is submitted herewith and marked as ANNEXURE CC.
15.8. Again when Circular dated 9th December, 2010 when they revised the pensions of those who retired after 1/8/2007 only were revised the Circular dated 9th December, 2010 shows that Pension Rules were amended by the Corporation itself in exercise of the powers conferred under Rules 36, 37 and 39 of the Pension Rules. A copy of the Circular dated 9/12/2010 is submitted herewith and the same is marked as ANNEXURE CD.
15.9. Thus it is clear that the Corporation admittedly is competent to amend the Pension Rules, then the ground of approval of the Central Government of the Board’s Resolution dated 24/11/2001 is redundant and false more particularly when this issue has become absolute. This  amounts only to clear cut contempt of the Court.
16.  The Pensioners are employees as per the Pension Rules therefore they are entitled to the same pay as would be applicable as on the date of payment of pension and 50% thereof is payable to them as Pension as per the Pension Rules.
17.  The Hon’ble Single Judge had allowed the prayer for revision of pensions not only for Petitioners but for the Pensioners;
18.     Thus it is clear that the Respondents have been trying to play an unfair game deliberately and intently with not only this Hon’ble Court but also the Hon’ble Supreme Court. The Respondents never had the intent to comply with the directions and for this reason they have been pursuing litigation after litigation on flimsy and untenable grounds, even when that issue has already been decided at least four times against the Respondents and that too again in disregard to the National Litigation Policy.
19.     The Respondents are in the habit of harassing the employees and not complying with the directions of the Courts.  In the recent past only after imposition of penalty by the Hon’ble Supreme Court the compliance was made. Reference is invited to the case L.I.C. of India & others vs. Retired L.I.C. Officers and others [(2008) 3 SCC 382.
20.     The Respondents have been harassing and torturing the Petitioner therefore he is entitled to adequate compensation for all the toils and tortures.
21.     The Respondents have been earning on the amount withheld in respect of the arrears not paid therefore, the Pensioners are also entitled to interest at the rate of 12% per annum as prayed for and also awarded by P&H High Court, which is a judgment solely based on the judgment of this Hon’ble Court.

Deponent
VERIFICATION
         I, Krishna Murari Lal Asthana, deponent above named, do hereby verify that the contents of paras 1 to 21 above are correct to my knowledge, nothing material has been concealed therefrom and no part of it is false. SO HELP ME GOD.
         Verified at Jaipur this 7th day of February, 2014.

Deponent
IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN

                 JAIPUR BENCH AT JAIPUR
                                  ***
S.B. Civil Contempt Petition No. 760 of 2010
                                  in
S.B. Civil Writ Petition No. 654 of 2007
                                  ***
Krishna Murari Lal Asthana                                 Petitioner
                                  Versus
Shri T.S. Vijayan and others                        Respondents
                                  ***
I N D E X
Sl. No.       Particulars                                           Page Nos.

1.              Counter affidavit to the
                 affidavit filed by the Respondent
                 Nos. 6 to 8 on 31/1/2014

                 ANNEXURES

2.      CA    Copy of the Board’s Resolution
                 dated 24/11/2001

3.      CB    Copy of the Notification dated
                 14/5/1999

3.      CB    Circular dated 18/10/2005

4.      CC    Circular dated 9/12/2010




Petitioner
Jaipur

February 7, 2014