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1 1 Presented on: Subject PIL TO CONSTITUTE A GRIEVANCE REDRESSAL MECHANISM AGAINST SEXUAL HARASSMENT AS PER DIRECTIONS OF THE HONOURABLE SUPREME COURT IN VISHAKA V. STATE OF RAJASTHAN AND THE SEXUAL HARASSMENT OF WOMEN AT WORKPLACE (PREVENTION, PROHIBITION AND REDRESSAL) ACT, BEFORE THE HON BLE HIGH COURT OF KERALA AT ERNAKULAM W.P.(Civil)No. of 2018 (Special Original Jurisdiction) Women in Cinema Collective and another : Petitioners Vs. State of Kerala and others : Respondents MEMORANDUM OF WRIT PETITION (CIVIL) FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA C.F. Rs. /- is paid SANTHOSH MATHEW(S-204) ARUN THOMAS(A-1056) VIJAY V. PAUL (V-684) KARTHIKA (K. 514) VEENA RAVEENDRAN (V 713) & ANIL SEBASTIAN PULICKEL (A.1886) COUNSEL FOR THE PETITIONER

2 2 BEFORE THE HON BLE HIGH COURT OF KERALA AT ERNAKULAM W.P.(Civil)No. of 2018 (Special Original Jurisdiction) Women in Cinema Collective and another : Petitioners Vs. State of Kerala and others : Respondents I n d e x Sl. No. Contents Page Nos. 1. Synopsis A D 2. Memorandum of Writ Petition (Civil) Affidavit Exhibit P1: True copy of the judgment of the Honourable Supreme Court in Vishaka v. State of Rajasthan reported in (1997) 6 SCC Exhibit P2: True copy of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, Exhibit P3: True copy of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, Exhibit P4: True copy of a newspaper report dated which appeared in Mumbai Mirror which reports the steps taken by the Producers Guild of India and the Screenwriters Association Dated this the 15 th day of October, Sd/- COUNSEL FOR THE PETITIONER

3 3 BEFORE THE HON BLE HIGH COURT OF KERALA AT ERNAKULAM W.P.(Civil)No. of 2018 (Special Original Jurisdiction) Women in Cinema Collective and another : Petitioners Vs. State of Kerala and others : Respondents SYNOPSIS Sexual offences carry with them a great deal of shame, embarrassment and guilt for the victim and the other family members. It is not easy, and it requires courage and confidence for the victim to speak up and disclose the offence - Judgment dated of the Honourable High Court of Delhi in State of NCT of Delhi v. Sumit Kumar, Crl.A. No. 223/2018 The Petitioners herein are approaching this Honourable Court in public interest, seeking for the establishment of a grievance redressal mechanism against sexual harassment within the 3 rd Respondent Association, in line with the Vishaka Guidelines that have been laid down by the Honourable Supreme Court and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, Women in Cinema Collective, the 1 st Petitioner herein, works for the welfare of women in Indian cinema, including to ensure their dignity in their workspaces by promoting awareness of and preserving their rights as guaranteed under the Constitution of India. The 2 nd Petitioner is the President of the 1 st Petitioner. Association of Malayalam Movie Artistes (A.M.M.A), the 3 rd Respondent herein, is the predominant association of Actor Artistes in the Malayalam film industry.

4 4 The failure of the 3 rd Respondent to implement a grievance redressal mechanism for its members against sexual harassment at the workplace leaves its members helpless and without any adequate remedy against sexual harassment directed against them in the professional context. This omission of the 3 rd Respondent Association is striking at a time when revelations of widespread sexual assault and harassment of women in film industries across the country have come out. The Honourable Supreme Court in Vishaka v. State of Rajasthan reported in (1997) 6 SCC 241, in the absence of enacted law to provide for effective enforcement of the basic human rights of gender equality and guarantee against sexual harassment and abuse, more particularly against sexual harassment at workplaces, laid down guidelines and norms for due observance at all workplaces or other institutions, until a legislation is enacted for the purpose. Further, while laying down the guidelines, the Honourable Supreme Court stated that It is necessary and expedient for employers in workplaces as well as other responsible persons or institutions to observe certain guidelines to ensure the prevention of sexual harassment of women. Similarly, the definition of workplace in Section 2 (o) of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, includes any private sector organization or a private venture, undertaking, enterprise, institution, establishment, society, trust, non-governmental organization, unit or service provider, carrying on commercial, professional, vocational, educational, entertainmental, industrial, health services or financial activities including production, supply, sale, distribution or service. Thus, the directions of the Honourable Supreme Court in Vishaka v. State of Rajasthan as well as the provisions of the Sexual

5 5 Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act are squarely applicable to the 3 rd Respondent Association and cast an obligation on it to constitute a grievance redressal mechanism in the form of a complaints committee against sexual harassment. Already, other associations that are similarly placed as the 3 rd Respondent Association have taken steps to provide a grievance redressal mechanism to members against sexual harassment. The 3 rd Respondent Association is not State under Article 12 of the Constitution of India. However, the absence of a grievance redressal mechanism against sexual harassment by the 3 rd Respondent Association, which is a registered association, is violative of the fundamental rights of its members. The Vishaka guidelines are intended to apply to private associations, and the Honourable Supreme Court while entertaining a writ petition against a similar association in Charu Khurana v. Union of India reported in (2015) 1 SCC 192 held that the aforesaid decision in Vishaka case [Vishaka v. State of Rajasthan, (1997) 6 SCC 241 : 1997 SCC (Cri) 932] unequivocally recognises gender equality as a fundamental right. The discrimination done by the Association, a trade union registered under the Act, whose rules have been accepted, cannot take the route of the discrimination solely on the basis of sex. It really plays foul of the statutory provisions. It is absolutely violative of constitutional values and norms. Thus, this Writ Petition is maintainable. The 3 rd Respondent Association s omission violates the member s fundamental rights under Articles 14, 15, 19 and 21 of the Constitution of India. Additionally, the nature of the work undertaken by actor artistes is such that they have no alternatives to seek similar redressal. Further, the 3 rd Respondent Association is obliged by its own bye-laws to protect the rights of its members and act as arbitrators in disputes between them.

6 6 Therefore, on all the abovementioned grounds, the Petitioners are approaching this Honourable Court for the preservation of their right to work with dignity and safety and for the implementation of the directions issued by the Honourable Supreme Court. Dated this the 15 th day of October, Sd/- COUNSEL FOR THE PETITIONER

7 7 BEFORE THE HON BLE HIGH COURT OF KERALA AT ERNAKULAM Petitioners:- W.P.(Civil) No. of 2018 (Special Original Jurisdiction) 1. Women in Cinema Collective (Reg No. EKM/TC/643/2017) Mamangam Arts Collective, Stadion 68, 3 rd Floor, Behind Kaloor International Stadium, Palarivattom, Kochi Represented by its authorised signatory J. Padmapriya 2. Rima Kallingal Rajan President, Women in Cinema Collective, 1111, 11 th Floor, Purvankara Grandbay, Marine Drive, Ernakulam Vs. Respondents:- 1. State of Kerala, Represented by the Secretary, Cultural Affairs, Cultural Affairs Department, 1 st Floor, South Block, Government Secretariat, Thiruvananthapuram The Special Secretary, Department of Women and Child Development, Government of Kerala 1 st Floor, South Block, Government Secretariat, Thiruvananthapuram Association of Malayalam Movie Artistes (A.M.M.A), P.T.C. Road, Thycaud P.O., Thiruvananthapuram Represented by its General Secretary MEMORANDUM OF WRIT PETITION FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA The Address for service of notice and process to the petitioners is that of their counsel M/s Santhosh Mathew, Arun Thomas, Vijay V. Paul, Karthika Maria, Veena Raveendran & Anil Sebastian

8 8 Pulickel, M/s. Ninan & Mathew Advocates, S1, 2 nd Floor, Empire Building, High Court East End, Cochin-18. The address for service of notice on the respondent is as stated above. STATEMENT OF FACTS 1. The Petitioners herein are approaching this Honourable Court in public interest, seeking for the establishment of a grievance redressal mechanism against sexual harassment within the 3 rd Respondent Association, in line with the Vishaka Guidelines that have been laid down by the Honourable Supreme Court and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, The 1 st Petitioner herein is a society registered under Section 12 of the Travancore-Cochin Literary, Scientific and Charitable Societies Registration Act, 1955, bearing registration number EKM/TC/643/2017. It works for the welfare of women in Indian cinema, with the objectives of ensuring equal space and equal opportunities for all women working in cinema with respect to all creative and other processes and activities concerning the making of cinema and all related events, and also ensuring the dignity of women working in cinema in their workspaces by promoting awareness and preserving the rights of women as guaranteed under the Constitution of India. The 2 nd Petitioner is the President of the 1 st Petitioner. The 1 st Petitioner is represented by its authorized signatory who is a member of the 1 st Petitioner Society as well as the 3 rd Respondent Association. The 2 nd Petitioner was a member of the 3 rd Respondent Association but resigned in protest over the inaction on the part of the Executive Committee of the 3 rd Respondent Association on a complaint made by the survivor of an assault. 2. It is submitted that the 3 rd Respondent is an Association registered under the provisions of the Travancore-Cochin Literary, Scientific and Charitable Societies Registration Act, Its membership is restricted to Actor Artistes in Feature Films. As per its

9 9 bye-laws, some of the objectives of the 3 rd Respondent Association are to protect the rights of its members, to insist, maintain and develop self-discipline and professional and social ethics among members, to find out the issues concerning the artistes, to analyse them and to find out possible remedies, and to act as arbitrators in all disputes that may be submitted to them for arbitration by the members and others in film industry. The 3 rd Respondent is the predominant association of Actor Artistes in the Malayalam film industry. 3. It is submitted that the 3 rd Respondent Association in spite of being the dominant professional association for Actor Artistes in the Malayalam film industry has failed to implement a grievance redressal mechanism for its members against sexual harassment at the workplace. This omission of the 3 rd Respondent Association is striking at a time when revelations of widespread sexual assault and harassment of women in film industries across the country have come out. It leaves the members of the 3 rd Respondent Association helpless and without any adequate remedy against sexual harassment directed against them in the professional context. The inaction of the 3 rd Respondent Association in setting up a grievance redressal mechanism against sexual harassment is also in breach of the Vishaka Guidelines laid down by the Honourable Supreme Court and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, It is submitted that the Honourable Supreme Court in Vishaka v. State of Rajasthan reported in (1997) 6 SCC 241, in the absence of enacted law to provide for effective enforcement of the basic human rights of gender equality and guarantee against sexual harassment and abuse, more particularly against sexual harassment at workplaces, laid down guidelines and norms for due observance at all workplaces or other institutions, until a legislation is enacted for the purpose. The Honourable Supreme Court categorically held that whether or not such contact constitutes an offence under law or a breach of the service rules, an appropriate complaint mechanism should be

10 10 created in the employer s organization for redressal of the complaint made by the victim. Such complaint mechanism should ensure time bound treatment of complaints. The Honourable Supreme Court further held that the Complaints Committee should be headed by a woman and not less than half of its members should be women. Further, to prevent the possibility of any undue pressure or influence from senior levels, such Complaints Committee should involve a third party, either NGO or other body who is familiar with the issue of sexual harassment. A copy of the judgment of the Honourable Supreme Court in Vishaka v. State of Rajasthan reported in (1997) 6 SCC 241 is produced herewith and marked as Exhibit P1. 5. It is submitted that the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 was promulgated by the Parliament and as per Notification dated , came into force with effect from A copy of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 is produced herewith and marked as Exhibit P2. The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013 were also promulgated on A copy of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013 is produced herewith and marked as Exhibit P3. 6. It is submitted that as per Section 2 (o) of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, workplace has been defined as follows:- 2 (o) workplace includes (i) any department, organization, undertaking, establishment, enterprise, institution, office, branch or unit which is established, owned, controlled or wholly or substantially financed by funds provided directly or indirectly by the appropriate Government or the local

11 11 authority or a Government company or a corporation or a co-operative society. (ii) Any private sector organization, or a private venture, undertaking, enterprise, institution, establishment, society, trust, non-governmental organization, unit or service provider, carrying on commercial, professional, vocational, educational, entertainmental, industrial, health services or financial activities including production, supply, sale, distribution or service; (iii) Hospitals or nursing homes; (iv) Any sports institute, stadium, sports complex or competition or games venue, whether residential or not, used for training, sports or other activities relating thereto; (v) Any place visited by the employee arising out of or during the course of employment including transportation provided by the employer for undertaking such journey; (vi) A dwelling place or a house. 7. It is further submitted that as per Section 2 (f) of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, employee is defined as follows: Employee means a person employed at a workplace for any work on regular, temporary, adhoc or daily wage basis, either directly or through an agent, including a contractor, with or without the knowledge of the principal employer, whether for remuneration or not, or working on a voluntary basis or otherwise, whether the terms of employment are express or implied and includes a coworker, a contract worker, probationer, trainee, apprentice or called by any other such name.

12 12 8. It is submitted that as per Section 3 of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, no woman shall be subjected to sexual harassment at any workplace and the following circumstances among other circumstances if it occurs or is present in relation to or connected with any act or behavior of sexual harassment may amount to sexual harassment: (i) implied or explicit promise of preferential treatment in her employment or (ii) implied or explicit threat of detrimental treatment in her employment; or (iii) implied or explicit threat about her present or future employment status; or (iv) interference with her work or creating an intimidating or offensive or hostile work environment for her, or (v) humiliating treatment likely to affect her health or safety 9. It is submitted that the directions of the Honourable Supreme Court in Vishaka v. State of Rajasthan as well as the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act are squarely applicable to the 3 rd Respondent Association and cast an obligation on it to constitute a grievance redressal mechanism in the form of a complaints committee against sexual harassment. In spite of this, and despite requests made by the Women in Cinema Collective to the 3 rd Respondent Association about the need for the same, the 3 rd Respondent Association has not constituted such a complaints committee. 10. It is submitted that other associations that are similarly placed as the 3 rd Respondent Association have taken steps to provide a grievance redressal mechanism to members against sexual harassment. It has been reported that the Producers Guild of India has set up a special committee to address harassment at the workplace within the industry, and that the Screenwriters Association has formed

13 13 an internal committee to address sexual harassment and formulate policies to safeguard employees and members. A copy of a newspaper report dated which reports the steps taken by the Producers Guild of India and the Screenwriters Association is produced herewith and marked as Exhibit P Hence, aggrieved by the absence of a grievance redressal mechanism in the form of a complaints committee against sexual harassment in the 3 rd Respondent Association, and left with no other efficacious and alternative remedy than to approach this Hon ble Court, on the following mainly among other: GROUNDS A. The failure of the 3 rd Respondent Association to constitute a grievance redressal mechanism for its members in the form of a complaints committee against sexual harassment is arbitrary, illegal and violative of the fundamental rights of its members. B. The failure of the 3 rd Respondent Association to constitute a grievance redressal mechanism for its members in the form of a complaints committee against sexual harassment is in breach of its obligations as per the directions of the Honourable Supreme Court in Vishaka v. State of Rajasthan reported in (1997) 6 SCC 241 and under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, C. Although the 3 rd Respondent Association is not a State under Article 12 of the Constitution of India, the same would not bar the Petitioners from obtaining relief from this Honourable Court as the absence of a grievance redressal mechanism against sexual harassment by the 3 rd Respondent Association, which is a registered association, is violative of the fundamental rights of its members. The Honourable Supreme Court while entertaining a writ petition against a similar association, namely the Cine

14 14 Costume Make-up Artists and Hair Dressers Association, in Charu Khurana v. Union of India reported in (2015) 1 SCC 192 made the following observations: a. Paragraph 38: At this stage, it is seemly to note that the Association is not a State under Article 12 of the Constitution of India. It is submitted by Ms Meenakshi Arora, learned Senior Counsel appearing for the National Commission for Women, that the Association is not a State or may not be amenable to writ jurisdiction under Article 226 of the Constitution of India, but its constitution and the bye-laws which have been accepted/ratified by the Registrar of Trade Unions, who have been authorised by the competent Government cannot violate the mandate of the Act or any of the constitutional commands. In essence, the submission of the learned Senior Counsel is, that it has to be in consonance with the statutory framework and the Association, by incorporating certain stipulations, cannot create a discrimination for women which is contrary to the international treaty, that has been ratified by India and further debar all qualified and eligible women to enter into the film industry to carry their profession as make-up artists, which in the ultimate eventuate, stifle and smother their sources of livelihood. Mr Rao, learned Additional Solicitor General, supporting the said submission, would further contend that this Court in Vishaka [Vishaka v. State of Rajasthan, (1997) 6 SCC 241 : 1997 SCC (Cri) 932] has clearly observed that violation of the fundamental rights of gender equality, right to life and liberty and right to practise profession, attract the remedy under Article 32 for enforcement of these fundamental rights of women.

15 15 b. Paragraph 50: From the aforesaid enunciation of law, the signification of right to livelihood gets clearly spelt out. A clause in the bye-laws of a trade union, which calls itself an Association, which is accepted by the statutory authority, cannot play foul of Article 21. c. Paragraph 52: Thus, the aforesaid decision in Vishaka case [Vishaka v. State of Rajasthan, (1997) 6 SCC 241 : 1997 SCC (Cri) 932] unequivocally recognises gender equality as a fundamental right. The discrimination done by the Association, a trade union registered under the Act, whose rules have been accepted, cannot take the route of the discrimination solely on the basis of sex. It really plays foul of the statutory provisions. It is absolutely violative of constitutional values and norms. If a female artist does not get an opportunity to enter into the arena of being a member of the Association, she cannot work as a female artist. It is inconceivable. The likes of the petitioners are given membership as hair dressers, but not as make-up artist. There is no fathomable reason for the same. It is gender bias writ large. It is totally impermissible and wholly unacceptable. D. As per Section 2 (o) of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 workplace includes "any private sector organization, or a private venture, undertaking, enterprise, institution, establishment, society, trust, non-governmental organization, unit or service provider, carrying on commercial, professional, vocational, educational, entertainmental, industrial, health services or financial activities including production, supply, sale, distribution or service".

16 16 E. The Honourable Supreme Court in Vishaka v. State of Rajasthan reported in (1997) 6 SCC 241 held that in the absence of enacted law to provide for the effective enforcement of the basic human right of gender equality and guarantee against sexual harassment and abuse, more particularly against sexual harassment at workplaces, we lay down the guidelines and norms specified hereinafter for due observance at all workplaces or other institutions, until a legislation is enacted for the purpose. This is done in exercise of the power available under Article 32 of the Constitution for enforcement of the fundamental rights and it is further emphasised that this would be treated as the law declared by this Court under Article 141 of the Constitution. Further, while laying down the guidelines, the Honourable Supreme Court stated that It is necessary and expedient for employers in workplaces as well as other responsible persons or institutions to observe certain guidelines to ensure the prevention of sexual harassment of women. Therefore, the Vishaka Guidelines as laid down by the Honourable Supreme Court are wholly binding on the 3 rd Respondent Association. F. The absence of a grievance redressal mechanism against sexual harassment for members of the 3 rd Respondent Association violates their fundamental rights under Articles 14, 15, 19 and 21 of the Constitution of India. G. There is a pressing need for a grievance redressal mechanism against sexual harassment to be instituted within the 3 rd Respondent Association in the light of the recent expose of several abusive practices and sexual harassment that women who work in the film industry are forced to become victims of. This is particularly so as the nature of the work undertaken by actor artistes is such that once the production of a film is over, there is no longer a workplace for that film where such

17 17 grievances can be pursued. Thus, there are no alternatives to the 3 rd Respondent Association when it comes to instituting a mechanism to address sexual harassment-related grievances. H. As per its bye-laws, the objectives of the 3rd Respondent Association includes protecting the rights of the members and acting as arbitrators in all disputes that may be submitted to them for arbitration by the members and others in the film industry. Therefore, the 3 rd Respondent Association is legally obliged to constitute a complaints committee to enquire into allegations relating to sexual harassment. On these and other grounds to be urged at the time of hearing, it is most humbly prayed that this Hon ble Court may be pleased to allow this Writ Petition by granting the following: RELIEFS 1) Issue a writ of mandamus or any other writ order or direction declaring that the 3 rd Respondent Association is legally obliged to constitute a complaints committee against sexual harassment for its members in accordance with the guidelines laid down by the Honourable Supreme Court in Vishaka v. State of Rajasthan reported in (1997) 6 SCC 241 and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013; 2) Issue a writ of mandamus or any other appropriate writ order or direction compelling the Respondents to appoint a complaints committee against sexual harassment, comprising of suitable and independent members, for the 3 rd Respondent Association in accordance with the guidelines laid down by the Honourable Supreme Court in Vishaka v. State of Rajasthan reported in (1997) 6 SCC 241 and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 within a time limit prescribed by this Hon ble Court;

18 18 3) Issue such other appropriate writ, order or direction which this Hon ble Court may deem fit and just in the circumstances of the case INTERIM RELIEF Appoint a complaints committee against sexual harassment, comprising suitable and independent members, for the 3 rd Respondent Association in accordance with the guidelines laid down by the Honourable Supreme Court in Vishaka v. State of Rajasthan reported in (1997) 6 SCC 241 and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, pending disposal of this Writ Petition Dated this the 15 th day of October, Sd/- 2. Sd/- PETITIONERS Sd/- COUNSEL FOR THE PETITIONERS

19 BEFORE THE HON BLE HIGH COURT OF KERALA AT ERNAKULAM W.P.(Civil)No. of 2018 (Special Original Jurisdiction) Women in Cinema Collective and another : Petitioners Vs. State of Kerala and others : Respondents AFFIDAVIT I, J. Padmapriya, aged 38 years, D/o. V.K. Janakiraman, residing at Plot 122, Bank Colony, RK Puram, Secunderabad, Telangana , do hereby, solemnly affirm and state as follows:- 1. I am the authorized signatory of Women in Cinema Collective (Reg. No. EKM/TC/643/2017), Mamangam Arts Collective, Stadion 68, 3 rd Floor, Behind Kaloor International Stadium, Palarivattom, Kochi the 1 st petitioner in the above Writ Petition (Civil) and I am fully conversant with the facts of the case. I am swearing to this Affidavit on behalf of the 1 st Petitioner as I am competent to do so. I am also swearing to this affidavit on behalf of the 2 nd petitioner, as duly authorized by her. 2. The averments contained in the above Writ Petition (Civil) are true to the best of my knowledge, information and belief. 3. The Exhibits produced along with the above Writ Petition (Civil) are true copies of its originals. 4. We have not filed any other Petition before this Hon ble Court, seeking the same relief earlier. 5. We are seeking to espouse a public cause and we have no personal or private interest in the matter and there is no authoritative pronouncement by the Supreme Court or the High Court on the question raised and that the result of the litigation will not lead to any undue gain to ourselves or to anyone associated with us

20 20 It is therefore prayed that this Hon ble Court may be pleased to grant the reliefs prayed for in the above Writ Petition (Civil). The above facts are true, Dated this the 15 th day of October, Sd/- Deponent Solemnly affirmed and signed before me by the deponent on this the 15 th day of October, 2018, in my office at Ernakulam. Sd/- Santhosh Mathew Advocate