REPORTABLE
IN THE SUPREME COURT OF INDIA
CIVIL APPELLATE JURISDICTION
CIVIL APPEAL NO. 9100 OF 2019
(Arising out of SLP(C) No. 23677 OF 2019)
THE ASSAM PUBLIC SERVICE
COMMISSION & ORS. APPELLANT(S)
VERSUS
PRANJAL KUMAR SARMA & ORS. RESPONDENT(S)
J U D G M E N T
Hrishikesh Roy, J.
Leave granted.
2. This appeal arises out of the Special Leave Petition
(Civil) No. 23677 of 2019. The Assam Public Service
Commission (for short “APSC”) has approached this Court
to challenge the judgment and order dated 8th August, 2019
in W.P. (C) No. 4600 of 2019 whereby the Gauhati High
Court struck down a portion of Clause 12.2 of the Assam
Public Service Commission (Conduct of Business)
Procedure, 2019 (hereinafter referred to as “the 2019
Page 1 of 13
Procedure”). The following portion of Clause 12.2,
incorporated with effect from 1st April, 2019, under the
2019 Procedure, was struck down by the High Court.
“…………and any proceeding in relation to
interviews, selections or competitive
examination pending on the date of
commencement of these Procedures may be
continued and completed in accordance with
the provisions of the Rules in force prior
to such commencement.”
3. The result of the above is that the norms of
selection for an ongoing process gets changed mid-stream
in course of recruitment, for the 65 vacancies of
Assistant Engineer (Civil) under the Water Resources
Department for which, the APSC had issued an
advertisement on 21st December, 2018 (“Annexure P-I”). On
the date of the advertisement, the previous norms i.e.
the Assam Public Service Commission (Procedure and
Conduct of Business) Rules, 2010 (hereinafter referred to
as “the 2010 Rules”), were in operation. The 2010 Rules
provided for assessment of academic merit, special
knowledge, additional relevant qualification, relevant
service experience etc. under Rule 29 and 30, in the
following manner: -
Page 2 of 13
“29. The Commission may determine the
qualifying standard by giving weightage
on academic merit, subject knowledge,
additional relevant qualification,
service experience relevant to the post
etc. for preparing the final order of
select list.
30. In the viva-voce test marks shall
be allocated as below:
(i) 50% on academic/professional
qualification/service experience relevant
to the post/preferential qualification.
(ii) 50% for subject knowledge and
general bearing. Out of this, 20% shall
be for subject knowledge and the
remaining 30% for general bearing.
There shall be five gradings for
Adviser/Expert’s marks viz., ‘Excellent’,
‘Very Good’, ‘Good’, ‘Fair’ and
‘Average’, the value of which shall be
determined by the Commission.”
4. The aforesaid 2010 Rules were challenged by one
Manash Pratim Baruah in the Gauhati High Court through
W.P.(C) No. 1998 of 2017. He contended that the State
Public Service Commission is not empowered to adopt any
Rule in the nature of the 2010 Rules as was done by the
APSC, by invoking the powers under proviso to Article 320
of the Constitution of India. During the pendency of the
Writ Petition, the 2010 Rules were repealed and a new set
of procedure i.e, “The Assam Public Service Commission
(Conduct of Business) Procedure, 2019” came into effect,
Page 3 of 13
from 1st April, 2019. Accordingly, the APSC through their
affidavit filed in the W.P.(C) No. 1998 of 2017 informed
the High Court about adoption of the 2019 Procedure.
5. During that period, acting on the advertisement
(dated 21.12.2018) to fill up the 65 posts of Assistant
Engineer (Civil), the APSC on 12.06.2019 had notified
that an OMR based screening test, with multiple choice
objective type questions, will be conducted on
30.06.2019. The said screening test was conducted under
the 2010 Rules and as such there was no negative marking
which was introduced for the first time by the 2019
Procedure, for the APSC conducted selections.
6. The four respondents had offered their candidature by
responding to the advertisement dated 21st December, 2018
and they appeared in the screening test conducted on
30.06.2019. Nevertheless they also filed the W.P.(C) No.
4600 of 2019 challenging Clause 12.2 of the 2019
Procedure which provided that notwithstanding the repeal
of the 2010 Rules, the action taken under the repealed
Rules including conduct of interview/selection or
competitive examination or declaration of any result
thereof by the APSC, shall be deemed to have been valid
and the pending interviews/selections or competitive
Page 4 of 13
examinations may be continued and completed, in
accordance with the 2010 Rules. The basic challenge
therefore, by the four respondents as writ petitioners,
was to the saving clause for the ongoing recruitment
process conducted under the 2010 Rules. It would be
relevant to mention at this stage that in view of the
adoption of the 2019 Procedure by repealing the 2010
Rules, the earlier W.P.(C) No. 1998 of 2017 was disposed
of as infructuous on 16th July, 2019 by the High Court
reserving the liberty to the writ petitioner to assail,
if aggrieved, the newly formulated 2019 Procedure.
7. The Gauhati High Court on 22.07.2019 issued
returnable notice in the W.P.(C) No. 4600 of 2019 and the
Division Bench after noticing that the APSC is conducting
large number of examinations made an observation that
attempt would be made to dispose of the matter on the
returnable date i.e. 08th August, 2019.
8. The case was next considered on the returnable date
and the High Court under the impugned judgment dated
08.08.2019 held that the 2010 Rules will have no
application for those interviews/selections for which,
exercise has not begun. The Court also observed that the
advertisement issued prior to 01.04.2019 (the date of
Page 5 of 13
commencement of the 2019 Procedure) has no relevance for
the applicability of the 2019 Procedure and accordingly
held that even in a situation where the written
examination was held but interview is yet to be
conducted, the newly introduced 2019 procedure has to be
applied in the interview segment of the selection. It
was finally observed that all pending
interviews/selections and competitive examinations, even
if occasioned by advertisements issued prior to
01.04.2019 shall be guided by the 2019 Procedure. The
Writ Petition of the respondents was accordingly allowed
on 08.08.2019 by the High Court.
9.1 Assailing the legality of the impugned judgment, Mr.
Parthiv K. Goswami, learned counsel submits that
currently the APSC, besides conducting the subject
recruitment/selection for the Water Resources Department,
is also undertaking selection process for the posts of,
inter alia, Computer Operator/Typist, Forest Ranger,
Agricultural Development Officer for which respective
advertisements were issued prior to incorporation of the
2019 Procedure and the process of selection through
screening test/written test were conducted under the 2010
Rules. Insofar as the recruitment for the 65 posts of
Page 6 of 13
Assistant Engineer (Civil) advertised on 21.12.2018, the
learned counsel points out that the last date for
applying for the post was stipulated as 02.02.2019 and
thereafter around 6000 applicants including the four
respondents, appeared for the screening test conducted on
30.06.2019 under the 2010 Rules. Adverting to these
relevant dates, the appellants would argue that the
process of selection in the present case had commenced
with the issuance of advertisement well before the 2019
Procedure was notified with effect from 01.04.2019 and
therefore, the selection should be in accordance with the
2010 Rules which prevailed on the date of the
advertisement.
9.2 The appellant’s counsel then argues that alteration
of the selection norms by the APSC through the 2019
Procedure which has prospective application, should have
no bearing on the ongoing process, on account of the
savings clause incorporated in the 2019 Procedure.
10.1 Per contra Ms. Rekha Pandey, learned counsel
appearing on behalf of respondent Nos. 1 to 4 (writ
petitioners) by referring to the preamble of the 2019
Procedure argues that the new Procedure was adopted to
bring in more transparency in the conducting of
Page 7 of 13
recruitment by the Commission, on account of the
deficiencies noticed in the process in the 2010 Rules.
She accordingly argues that adopting the 2019 Procedure
for the viva-voce segment of the recruitment exercise
would ensure weightage for merit and avoidance of
arbitrary selection, which was possible under the 2010
Rules.
10.2 The respondents counsel then refers to Rules 29 and
30 of the 2010 Rules to highlight that the procedure
envisaged did not provide adequate weightage to test the
merit of the candidates, on their academic/professional
qualification, service experience, etc. and therefore,
the 2019 Procedure should govern the next phase of
selection.
11. To deal with the rival submission, the relevant
clauses in the process of selection envisaged under the
2019 Procedure, will bear consideration. The concept of
negative marking is introduced for the first time under
Clause 4(B)(ii) which provides that for each wrong
answer, @ 0.25 marks are deducted against each question.
Besides the Clause 4(B)(vi) stipulates that marks for the
interview shall not exceed 12.2 per cent of the total
Page 8 of 13
marks. The screening test in which the respondents and
other candidates appeared on 30.06.2019 under the 2010
Rules as earlier noted, had no negative marking and,
therefore, the candidates could take the risk of guessing
the correct answer in the multiple choice test, without
the fear of being penalised for incorrect answer.
12. In the above backdrop, if the next segment of
selection is to be conducted under the 2019 Procedure,
the performance of the candidate in the aforenoted
screening test to the extent of 87.8 per cent of the
total marks, will determine the final selection of the
candidate. The question, therefore, is whether this
would be fair on the candidates when the performance of
few would be determined more by lucky guess and the real
merit may have no role in the aggregate score. The other
relevant question is whether the method of selection
should be permitted to be changed midway, by adopting the
2019 Procedure incorporated with effect from 01.04.2019
for the vacancies, which were advertised on 21.12.2018.
13. The law with regard to applicability of the Rules
which are brought anew during the selection process have
been crystalized by this Court. It has been held that
Page 9 of 13
the norms existing on the date when the process of
selection begins, will control the selection and the
alteration to the norms would not affect the ongoing
process unless the new Rules are to be given
retrospective effect. (See State of Bihar and Others vs.
Mithilesh Kumar1). Similarly in N.T. Devin Katti and
Others vs. Karnataka Public Service Commission and
Others2, this Court held that a candidate has a limited
right of being considered for selection in accordance
with the Rules as they existed on the date of
advertisement and he cannot be deprived of that limited
right by amendment of the Rules during the pendency of
the selection, unless the Rules are to be applied
retrospectively.
14. If we proceed with the above enunciation of the law
in Mithilesh Kumar (supra) and N.T. Devin Katti (supra),
the conclusion is inevitable that for the current
recruitment process for which advertisement was issued on
21.12.2018, the 2019 Procedure (which came into effect
from 01.04.2019) can have no application, particularly
when the first phase of the selection i.e. the screening
test was conducted under the 2010 Rules.
1
(2010) 13 SCC 467
2
(1990) 3 SCC 157
Page 10 of 13
15. One must also be conscious of the savings Clause 12.2
incorporated in the 2019 Procedure which makes it
abundantly clear that the interviews/selection or
competitive examinations pending on the date of
commencement of the Procedure should be continued and
completed, in accordance with the 2010 Rules.
16. In the present case, if the contention advanced by
the respondents is accepted and the next segment of the
process of selection is carried out under the 2019
Procedure, it will give rise to an anomalous situation
inasmuch as the screening test which was conducted
without negative marking, under the 2010 Rules, without
provisions for negative markings, will have a major
bearing in the final outcome of selection. This would
definitely prejudice the candidates who have undertaken
exams under 2010 Rules. The consistent law on the issue
also makes it clear that recruitment process pursuant to
the advertisement issued by the APSC on 21st December,
2018 must necessarily be conducted under the selection
norms as applicable on the date of the advertisement.
Moreover, having regard Rule 29 and Rule 30 of the 2010
Rules, it must also be said that merit of the candidates
would definitely be assessed in the selection exercise,
Page 11 of 13
undertaken by the APSC. The APSC is also capable of
conducting a fair selection and we believe that they will
keep in mind, the lawful expectation and the
constitutional mandate.
17. If the direction in the impugned judgment of the High
Court is to be followed for conducting the next segment
of the selection, for the single recruitment process the
candidates will be evaluated by two different sets of
procedure i.e. the 2010 Rules and the 2019 Procedure and
such dual norms must not in our opinion, govern the
ongoing recruitment process.
18. In view of the foregoing, we are persuaded to hold
that the recruitment process initiated by the APSC
through the advertisement dated 21.12.2018 for the 65
posts of Assistant Engineer (Civil), of the Water
Resources Department should be finalised under the 2010
Rules. Consequently, the direction issued for application
of the 2019 Procedure in the impugned judgment is found
to be not merited and the same is accordingly interfered.
The appeal stands allowed by permitting the APSC to
complete the process of selection for the advertised
posts, by following the 2010 Rules.
Page 12 of 13
………………………………………………J.
[R.BANUMATHI]
………………………………………………J.
[A.S.BOPANNA]
……………………………………………J.
[HRISHIKESH ROY]
NEW DELHI
NOVEMBER 28, 2019
Page 13 of 13
IN THE SUPREME COURT OF INDIA
CIVIL APPELLATE JURISDICTION
CIVIL APPEAL NO. 9100 OF 2019
(Arising out of SLP(C) No. 23677 OF 2019)
THE ASSAM PUBLIC SERVICE
COMMISSION & ORS. APPELLANT(S)
VERSUS
PRANJAL KUMAR SARMA & ORS. RESPONDENT(S)
J U D G M E N T
Hrishikesh Roy, J.
Leave granted.
2. This appeal arises out of the Special Leave Petition
(Civil) No. 23677 of 2019. The Assam Public Service
Commission (for short “APSC”) has approached this Court
to challenge the judgment and order dated 8th August, 2019
in W.P. (C) No. 4600 of 2019 whereby the Gauhati High
Court struck down a portion of Clause 12.2 of the Assam
Public Service Commission (Conduct of Business)
Procedure, 2019 (hereinafter referred to as “the 2019
Page 1 of 13
Procedure”). The following portion of Clause 12.2,
incorporated with effect from 1st April, 2019, under the
2019 Procedure, was struck down by the High Court.
“…………and any proceeding in relation to
interviews, selections or competitive
examination pending on the date of
commencement of these Procedures may be
continued and completed in accordance with
the provisions of the Rules in force prior
to such commencement.”
3. The result of the above is that the norms of
selection for an ongoing process gets changed mid-stream
in course of recruitment, for the 65 vacancies of
Assistant Engineer (Civil) under the Water Resources
Department for which, the APSC had issued an
advertisement on 21st December, 2018 (“Annexure P-I”). On
the date of the advertisement, the previous norms i.e.
the Assam Public Service Commission (Procedure and
Conduct of Business) Rules, 2010 (hereinafter referred to
as “the 2010 Rules”), were in operation. The 2010 Rules
provided for assessment of academic merit, special
knowledge, additional relevant qualification, relevant
service experience etc. under Rule 29 and 30, in the
following manner: -
Page 2 of 13
“29. The Commission may determine the
qualifying standard by giving weightage
on academic merit, subject knowledge,
additional relevant qualification,
service experience relevant to the post
etc. for preparing the final order of
select list.
30. In the viva-voce test marks shall
be allocated as below:
(i) 50% on academic/professional
qualification/service experience relevant
to the post/preferential qualification.
(ii) 50% for subject knowledge and
general bearing. Out of this, 20% shall
be for subject knowledge and the
remaining 30% for general bearing.
There shall be five gradings for
Adviser/Expert’s marks viz., ‘Excellent’,
‘Very Good’, ‘Good’, ‘Fair’ and
‘Average’, the value of which shall be
determined by the Commission.”
4. The aforesaid 2010 Rules were challenged by one
Manash Pratim Baruah in the Gauhati High Court through
W.P.(C) No. 1998 of 2017. He contended that the State
Public Service Commission is not empowered to adopt any
Rule in the nature of the 2010 Rules as was done by the
APSC, by invoking the powers under proviso to Article 320
of the Constitution of India. During the pendency of the
Writ Petition, the 2010 Rules were repealed and a new set
of procedure i.e, “The Assam Public Service Commission
(Conduct of Business) Procedure, 2019” came into effect,
Page 3 of 13
from 1st April, 2019. Accordingly, the APSC through their
affidavit filed in the W.P.(C) No. 1998 of 2017 informed
the High Court about adoption of the 2019 Procedure.
5. During that period, acting on the advertisement
(dated 21.12.2018) to fill up the 65 posts of Assistant
Engineer (Civil), the APSC on 12.06.2019 had notified
that an OMR based screening test, with multiple choice
objective type questions, will be conducted on
30.06.2019. The said screening test was conducted under
the 2010 Rules and as such there was no negative marking
which was introduced for the first time by the 2019
Procedure, for the APSC conducted selections.
6. The four respondents had offered their candidature by
responding to the advertisement dated 21st December, 2018
and they appeared in the screening test conducted on
30.06.2019. Nevertheless they also filed the W.P.(C) No.
4600 of 2019 challenging Clause 12.2 of the 2019
Procedure which provided that notwithstanding the repeal
of the 2010 Rules, the action taken under the repealed
Rules including conduct of interview/selection or
competitive examination or declaration of any result
thereof by the APSC, shall be deemed to have been valid
and the pending interviews/selections or competitive
Page 4 of 13
examinations may be continued and completed, in
accordance with the 2010 Rules. The basic challenge
therefore, by the four respondents as writ petitioners,
was to the saving clause for the ongoing recruitment
process conducted under the 2010 Rules. It would be
relevant to mention at this stage that in view of the
adoption of the 2019 Procedure by repealing the 2010
Rules, the earlier W.P.(C) No. 1998 of 2017 was disposed
of as infructuous on 16th July, 2019 by the High Court
reserving the liberty to the writ petitioner to assail,
if aggrieved, the newly formulated 2019 Procedure.
7. The Gauhati High Court on 22.07.2019 issued
returnable notice in the W.P.(C) No. 4600 of 2019 and the
Division Bench after noticing that the APSC is conducting
large number of examinations made an observation that
attempt would be made to dispose of the matter on the
returnable date i.e. 08th August, 2019.
8. The case was next considered on the returnable date
and the High Court under the impugned judgment dated
08.08.2019 held that the 2010 Rules will have no
application for those interviews/selections for which,
exercise has not begun. The Court also observed that the
advertisement issued prior to 01.04.2019 (the date of
Page 5 of 13
commencement of the 2019 Procedure) has no relevance for
the applicability of the 2019 Procedure and accordingly
held that even in a situation where the written
examination was held but interview is yet to be
conducted, the newly introduced 2019 procedure has to be
applied in the interview segment of the selection. It
was finally observed that all pending
interviews/selections and competitive examinations, even
if occasioned by advertisements issued prior to
01.04.2019 shall be guided by the 2019 Procedure. The
Writ Petition of the respondents was accordingly allowed
on 08.08.2019 by the High Court.
9.1 Assailing the legality of the impugned judgment, Mr.
Parthiv K. Goswami, learned counsel submits that
currently the APSC, besides conducting the subject
recruitment/selection for the Water Resources Department,
is also undertaking selection process for the posts of,
inter alia, Computer Operator/Typist, Forest Ranger,
Agricultural Development Officer for which respective
advertisements were issued prior to incorporation of the
2019 Procedure and the process of selection through
screening test/written test were conducted under the 2010
Rules. Insofar as the recruitment for the 65 posts of
Page 6 of 13
Assistant Engineer (Civil) advertised on 21.12.2018, the
learned counsel points out that the last date for
applying for the post was stipulated as 02.02.2019 and
thereafter around 6000 applicants including the four
respondents, appeared for the screening test conducted on
30.06.2019 under the 2010 Rules. Adverting to these
relevant dates, the appellants would argue that the
process of selection in the present case had commenced
with the issuance of advertisement well before the 2019
Procedure was notified with effect from 01.04.2019 and
therefore, the selection should be in accordance with the
2010 Rules which prevailed on the date of the
advertisement.
9.2 The appellant’s counsel then argues that alteration
of the selection norms by the APSC through the 2019
Procedure which has prospective application, should have
no bearing on the ongoing process, on account of the
savings clause incorporated in the 2019 Procedure.
10.1 Per contra Ms. Rekha Pandey, learned counsel
appearing on behalf of respondent Nos. 1 to 4 (writ
petitioners) by referring to the preamble of the 2019
Procedure argues that the new Procedure was adopted to
bring in more transparency in the conducting of
Page 7 of 13
recruitment by the Commission, on account of the
deficiencies noticed in the process in the 2010 Rules.
She accordingly argues that adopting the 2019 Procedure
for the viva-voce segment of the recruitment exercise
would ensure weightage for merit and avoidance of
arbitrary selection, which was possible under the 2010
Rules.
10.2 The respondents counsel then refers to Rules 29 and
30 of the 2010 Rules to highlight that the procedure
envisaged did not provide adequate weightage to test the
merit of the candidates, on their academic/professional
qualification, service experience, etc. and therefore,
the 2019 Procedure should govern the next phase of
selection.
11. To deal with the rival submission, the relevant
clauses in the process of selection envisaged under the
2019 Procedure, will bear consideration. The concept of
negative marking is introduced for the first time under
Clause 4(B)(ii) which provides that for each wrong
answer, @ 0.25 marks are deducted against each question.
Besides the Clause 4(B)(vi) stipulates that marks for the
interview shall not exceed 12.2 per cent of the total
Page 8 of 13
marks. The screening test in which the respondents and
other candidates appeared on 30.06.2019 under the 2010
Rules as earlier noted, had no negative marking and,
therefore, the candidates could take the risk of guessing
the correct answer in the multiple choice test, without
the fear of being penalised for incorrect answer.
12. In the above backdrop, if the next segment of
selection is to be conducted under the 2019 Procedure,
the performance of the candidate in the aforenoted
screening test to the extent of 87.8 per cent of the
total marks, will determine the final selection of the
candidate. The question, therefore, is whether this
would be fair on the candidates when the performance of
few would be determined more by lucky guess and the real
merit may have no role in the aggregate score. The other
relevant question is whether the method of selection
should be permitted to be changed midway, by adopting the
2019 Procedure incorporated with effect from 01.04.2019
for the vacancies, which were advertised on 21.12.2018.
13. The law with regard to applicability of the Rules
which are brought anew during the selection process have
been crystalized by this Court. It has been held that
Page 9 of 13
the norms existing on the date when the process of
selection begins, will control the selection and the
alteration to the norms would not affect the ongoing
process unless the new Rules are to be given
retrospective effect. (See State of Bihar and Others vs.
Mithilesh Kumar1). Similarly in N.T. Devin Katti and
Others vs. Karnataka Public Service Commission and
Others2, this Court held that a candidate has a limited
right of being considered for selection in accordance
with the Rules as they existed on the date of
advertisement and he cannot be deprived of that limited
right by amendment of the Rules during the pendency of
the selection, unless the Rules are to be applied
retrospectively.
14. If we proceed with the above enunciation of the law
in Mithilesh Kumar (supra) and N.T. Devin Katti (supra),
the conclusion is inevitable that for the current
recruitment process for which advertisement was issued on
21.12.2018, the 2019 Procedure (which came into effect
from 01.04.2019) can have no application, particularly
when the first phase of the selection i.e. the screening
test was conducted under the 2010 Rules.
1
(2010) 13 SCC 467
2
(1990) 3 SCC 157
Page 10 of 13
15. One must also be conscious of the savings Clause 12.2
incorporated in the 2019 Procedure which makes it
abundantly clear that the interviews/selection or
competitive examinations pending on the date of
commencement of the Procedure should be continued and
completed, in accordance with the 2010 Rules.
16. In the present case, if the contention advanced by
the respondents is accepted and the next segment of the
process of selection is carried out under the 2019
Procedure, it will give rise to an anomalous situation
inasmuch as the screening test which was conducted
without negative marking, under the 2010 Rules, without
provisions for negative markings, will have a major
bearing in the final outcome of selection. This would
definitely prejudice the candidates who have undertaken
exams under 2010 Rules. The consistent law on the issue
also makes it clear that recruitment process pursuant to
the advertisement issued by the APSC on 21st December,
2018 must necessarily be conducted under the selection
norms as applicable on the date of the advertisement.
Moreover, having regard Rule 29 and Rule 30 of the 2010
Rules, it must also be said that merit of the candidates
would definitely be assessed in the selection exercise,
Page 11 of 13
undertaken by the APSC. The APSC is also capable of
conducting a fair selection and we believe that they will
keep in mind, the lawful expectation and the
constitutional mandate.
17. If the direction in the impugned judgment of the High
Court is to be followed for conducting the next segment
of the selection, for the single recruitment process the
candidates will be evaluated by two different sets of
procedure i.e. the 2010 Rules and the 2019 Procedure and
such dual norms must not in our opinion, govern the
ongoing recruitment process.
18. In view of the foregoing, we are persuaded to hold
that the recruitment process initiated by the APSC
through the advertisement dated 21.12.2018 for the 65
posts of Assistant Engineer (Civil), of the Water
Resources Department should be finalised under the 2010
Rules. Consequently, the direction issued for application
of the 2019 Procedure in the impugned judgment is found
to be not merited and the same is accordingly interfered.
The appeal stands allowed by permitting the APSC to
complete the process of selection for the advertised
posts, by following the 2010 Rules.
Page 12 of 13
………………………………………………J.
[R.BANUMATHI]
………………………………………………J.
[A.S.BOPANNA]
……………………………………………J.
[HRISHIKESH ROY]
NEW DELHI
NOVEMBER 28, 2019
Page 13 of 13
