Lahu Chogle Chogle
Mumbai, MH, India
it was open to have slum rehabilitation on plots reserved for gardens/open areas in TPS. Reliance was also placed by the SRA on the Schedule II Certificate.
From January 2002
200 of 2002 filed impugning
i. The amended D.C. Regulation 33(10) General Slum Rehabilitation approved on 15-10-1997. (Refer: Exh. 'J' pages 136-146 ).
-13- ii The General Slum Rehabilitation Scheme approved/declared on 1st/9th April 1998 ( Refer Exh.'K' at pages 147-151 )
iii Sections 3(B), 3(C), and 3(D) of the Maharashtra of the Slum Areas Act 1971
Refer Exh. 'M', pages 187-190
iv Sections 3(X) , 3(Y), and 3(Z) of the Maharashtra Slum Areas Second Amendment Act 2001.
Refer: Exh.R,1., page 229-A
v. The Building permissions/commencement certificates & other permissions grabted for constructionof buildings on Plot Nos. 100,102,106 etc. in T.P.S. VI.
58. 5-1-2002: Maharashtra Slum Areas(Improvement, Clearance and Redevelopment) (Second Amendment) Act 2001 ( Maharashtra Act No.10 of 2002) was passed in terms of Ordinance XXVII of 2001 introducing Chapter I-B in the Maharashtra Slum Areas Act 1971 Refer: Petition Exh. R1 page 229-A.
59 7-2-2002: Respondents 9,10, and 11 ( the builders/developers ) and Respondents 12 & 13 i.e. the Janta Rahivasi Mandal joined as Party Respondents to Writ Petition 200 of 2002.
60. 2-5-2002 " Rule issued (in Writ Petition 200 of 2002). .Notice to Advocate General. Respondents waive service. In view of the facts and circumstances of the case etc. interim relief is refused. All actions however will be subject to the final outcome of the Writ Petition."
61. SLP filed by the Petitioners against Order of the Hon'ble High Court refusing interim relief.
62. 16-9-2002. Order of the Hon'ble Supreme Court dismissing the Special Leave Petition, after giving certain directions and observations as follows:
" Under these circumstances and when the Counsel undertake that the developer would abide by the order that would be ultimately passed by the High Court, we see no justification for issuing an order of injunction restraining the developer from developing the vacant land. We, however, make it clear that the developer will...
SRA for Plot No
From November 2001
51 3-11-2001: Evasive reply of Respondent No.1 stating that they have referred the matter to their Advocate who will advise and then suitable reply would be sent. (page761 ).
52 12-12-2001 Intimation of Approval given by SRA for Plot No.1002.
53. 15-12-2001: Commencent Certificate issued for Plot No.100, & 102,
Ref: Petitioner's Rejoinder at page 625-626
Petitioner's Enquiry letter to the Chief Executive Officer (CEO ) of
SRA. Since the Petitioners
From December 2001
noticed that 17 areas have been declared Slum Rehabilitation Areas, the Petitioner's asked whether any similar Notification has been issued in respect of areas covered by T.P.Scheme VI,(Santacruz)
December 2001 - February 2002
issued IOA & C.C. for construction on Plot Nos. 100 & 102. Plot Nos. 102 & 106 are less than 1000 sq.metrs. according to TPS. Even if it is assumed that Plot No.102 & Plot No.100 are more than 1000 sq.metrs., they were encroached upon less than 25%
56. Jan.2002. Construction commenced under the Slum Rehabilitation Scheme on Plots reserved for gardens, open areas in the T.P.Scheme VI.
The Division Bench
From April 2000
4-4-2000: The Division Bench of this Hon'ble Court granted two weeks time.It was further ordered that "We also wish to make it clear that implementation of the aforesaid order shall not be linked up with any scheme which the Govt. may have in mind for rehabilitation of the displaced persons. We also wish to make it clear however that the Govt. is free to provide relief to the persons affected and may even frame a Scheme for the rehabilitation of the displaced persons, if so advised."
29. 24-4-2000: Division Bench of this Hon'ble Court directed that encroachments on the roads be removed by 15th June 2000 and other encroachments by 31-12-2000 failing which proceedings would be initiated under the contempt jurisdiction to punish the defaulting officers.
30. 3-5-2000: Govt. took a decision to implement the Slum Rehabilitation Scheme for the slumdwellers in Daulatnagar.
Ref:Affidavit in reply of Respondent No.1 Para 5, .-
Collector, the letter
From May 2000
31. 25-5-2000:. The hutments in Daulatnagar had not been censused in 1976, nor declared/notified as a slum area under section 4, nor declared/notified as a Slum Rehabilitation Area under section 3 (C)(1) of the Slum Areas Act.The Additional Collector Encroachment however purported to issue an Annexure II Certificate regarding the said hutments.The certificate recorded that the hutments in the Daulatnagar Area had been surveyed from 20-3-1999 to 12-4-1999 by the office of the Tehsildar Encroachments pursuant to the orders of this Hon'ble Court in Writ petition 98 of 1999 and that the Certificate had been prepared on the basis thereof.. ( Note: This Certificate does not help the Respondents because as stated on above, para 11 (iv), according to policy guidelines of 3-6-1992, existing slum is defined as the "area occupied by slumdwellers which are censused and having photopasses as per 1976 census, or those whose names have appeared in the Legislative Assembly Voters List of 1985." (see page 275)
Ref: Exh.'F1' to the Affidavit in reply of Respondent No.1 (page 393)
32. 25-5-2000: i.e. on the same day as the Certificate issued by the Additional
Collector, the letter of Intent was issued by the SRA (see page 236) i.e.hastily after Govt. decision on 3-5-2000.
33. 25-5-2000: On the basis of the said "Certificate", the SRA purported to issue Letter of Intent regarding several final plots in Daulatnagar, including Plot Nos.100,102,106,107,108 (open space) and other plots reserved for gardens, playgrounds, and open spaces.
Ref: Affidavit of Respondent No.1 para 5, internal (page 248)
34 20-7-2000 / 20-9-2000: The layout / amended layout providing for construction of slum rehabilitation buildings on plots reserved for gardens, open spaces in the TPS scheme was purported to be sanctioned by SRA.
Ref.: Affidavit in reply of Respondent No.1 para5 ( internal page17)
(running page 248)
Chief Justice B.P.Singh and Radhakrishnan J
Order of Division Bench
From October 2000
Counsel for the State odf Maharashtra informed the Division Bench of this Hon'ble Court hearing the Writ Petition 98 of 1999 that the Govt. had undertaken "a scheme for the rehabilitation of the encroachers". The Court held/observed as follows:
-10- "We fail to under stand how the Government can justify such a scheme which involves conversion of such plots which are reserved for public utilities into building sites for the purpose of rehabilitating encroachers, which would really amount to bending the law to reward a wrongdoer, at the cost of law abiding citizens who pay for the development and betterment of the area.
"We make it clear that the order of 9th July1999 which has attained finality has to be implemented. We have from time to time extended the time for implementation of that order and 31st October 2000 is the last datefor implementing the said order insofar as it relates to removal of encroachments on public land. We will wait till 31st October 2000 and thereafter will make our own assessment as to the extent to which the order of this Court has been implemented. Thereafter we shall take such action as may be considered expedient in the facts and circumstances of the case. We however make it clear that the Government should not take shelter under any order of this Court to justify its action of converting playgrounds, green belts etc. into building sites for rehabilitation of encroachers under the Slum Rehabilitaion Scheme, because far from that, we would never justify any action of the Government of rewarding wrongdoers at the cost of law abiding citizens. We also fail to understand why , if at all, the Government cannot think of rehabilitating such encroachers in areas where enough land is available to construct planned colonies for such persons, without in any way affecting the rights, interests and facilities provided to law abiding citizens and taxpayers."
From October 2000
31-10-2000 The Govt./Municipality subsequently removed most of the hutments/encroachments from the areas reserved for roads, gardens, Playgrounds, open spaces in the Daulatnagar area i.e. including the roads, and T.P. Plot Nos. 100,102,106,107.
38. 9-11-2000: Janata Rahivasi Mandal filed a Notice of Motion No. 375/2000 seeking clarification that the court's orders be clarified " So as to exclude from its purview slum dwellers who are on the lands which are not reserved for gardens, schools, playgrounds and recreation grounds and that rehabilitation in situ be permitted on such other plots under the Slum Rehabilitation Scheme."
General Slum Rehabilitation for Greater Mumbai
From December 2000
11-12-2000: The Executive Engineer SRA filed an affidavit referring to the amended D.C Regulation 33(10) approved on 15-10-97, the General Slum Rehabilitation for Greater Mumbai approved on 9th April 1998, the decision/ resolution of the Government dated 3-5-2000/12-5-2000 to implement the Slum Rehabilitation Scheme in Plots of TPS VI (Daulatnagar). The SRA contended that
SRA of the Sanctioned Slum Rehabilitation Scheme
From December 2000
26-12-2000: Petitioners sought inspection and copies from the SRA of the Sanctioned Slum Rehabilitation Scheme, Letter of Intent and Sanctioned the Layout Plan re the Plots in Daulatnagar referred to in his affidavit. (Page 750)
41. 15-1-2001: Despite reminders by the Petitioners, inspection/copies were not furnished. Neither documents were kept ready nor amount payable was indicated (Page 751).
42. 18-1-2001: SRA indicated fees and charges (page 752)-43 3-2-2001: SRA's reply: Plot Nos 102, 106 not included in the Scheme. CEO has power to approve SR Scheme under DC 33(10) (Page 754)
44. 18-1-2001: SRA stated that inspection and copies would be given only on payment of charges aggregating to approximately Rs. 14,000/-45. 30-1-2001: the Petitioners replied we are ready to pay under protest requested for amount of charges for LOI, IOA pertaining to Plot Nos. 100, 102, 106, 31, 32, 33, 86 and 89. Intimate to us the exact charges. If 14 member SRA has accorded its approval to have the charges please furnish us certified copies of the minutes of the meeting so that fees may be paid immediately.
46. 18-5-2001: Ordinance XV of 2001 issued introducing Chapter (I) (B) in the Maharashtra Slums Areas Act 1971 (i.e. sections 3X, 3Y, 3Z) statutorily providing that hutment dwellers as on 1-1-1995 would be issued a photopass and that such a protected occupier could not be evicted. The Ordinance further provided that if the Government was of the opinion that it was necessary in the larger public interest to evict the protected occupier, the Government could do so subject to the condition of relocating and rehabilitating them in accordance with the Schemes framed by the State Government in that behalf.
Ref. Exh P to Petition: Pages 203-209
47. 24-8-2001: Ordinance XXVII of 2001 issued substantially in terms o the earlier Ordinance
Ref: Exh Q to Petition: Pages 210-219
48. 12-10-2001:The division Bench of this Hon'ble Court made an Order disposing of...
TPS VI Santacruz (West)
From January 1999
13-1-1999: Petition No.98 of 1999 filed by the Petitioners impugning the GRs of 1976,1980,1985 and 1995 and requiring the Respondents to implement the TPS VI by removing the encroachments from plots reserved for roads, gardens, recreation areas and open spaces in the TPS VI Santacruz (West)
24.: 12-3-1999: The Hon'ble High Court observed that lands meant for public utility should be cleared and used by the public for the purpose for which the same are earmarked.
25.: May 1999: The Janata Rahivasi Mandal was permitted to intervene in Petition No. 98 of 1999.
From July 1999
9-7-1999: Division Bench of this Hon'ble Court issued Rule in Petition No.98 of 1999, restrained the Respondents from extending the cut off date beyond 1-1-1995 and directed the Govt./Respondents to remove all encroachments from the areas demarcated for roads in the TPS by 31-3-2000.
27. 3-4-2000 State Govt. filed an affidavit seeking additional time to implement the Court's orders on the grounds that they had not been able to make provision for rehabilitation of eligible slumdwellers on the concerned plots. Paragraphs 'E' and 'F' of the said affidavits stated as follows:
Para: "E) I say the reservations in question are part of Santacruz TownPlanning Scheme No. VI The said Town Planning Scheme is sanctioned finally in 1958 and the Municipal Corporation in its capacity as the Planning Authority can implement the same."
Para: "F) I say that the Municipal Corporation is not only the Planning Authority for the area, but also the project implementing agency for the implementation of the Development Plan Reservations as well as the Town Planning Scheme."
From April 1998
9-4-1998: The SRA with the permission of the State Govt. notified a " General Slum Rehabilitaion Scheme" for Greater Bombay.
i. Clause 3 provided that Slums which had earlier been censused and notified/declared a s Slums under section 4 or which were declared as a Slum Rehabilitation area under section 3C(!) would be Slum Rehabilitation Areas.
ii. Clause 4 of the Scheme stipulated that hutments which were cenused in 1976 and thereafter in 1980 and in 1985 with slum dwellers whose names appear in the Electoral Roll as on 1-1-1995 and who continue to reside at the same address would be eligible for free housing.
iii. Clause 8 of the Scheme stipulated that slums shall as far as possible be rehabilitated on the same land. However if plot occupied by slum was under non convertible reservation for public purposes, then rehabilitation would have to be done at some other place subject to availability of land.
iv. Clause 16(2) of the Scheme stipulated that "rehabilitation of Footpath dwellers will be made at other places."
REF. Exh. 'K' to the petition pages 147 to 176.
Exh. 'D-1' to affidavit in reply of Respondent No.1 pages 292 to 311.
From October 1997
15-10-1997: ( Exh 'J' at page137) At the direction of Govt. the SRA had proposed modifications to D ..C. Regulation 33 ( 10 ) and had submitted the same to Govt, for its sanction. The Govt. sanctioned the modification to regulation 33(10) framed by the SRA. Govt. did not publish the same in any news papers as required by section 37 sub-section (1-B)
As per the amended D.C.Regulation 33(10):
Annexure (in the said Notification)
i.. Clause II (ii) stipulated that " if any area fulfils the conditions laid down in section 4 of the Mam. Slum Areas Act 1971 to qualify as a slum area and has been censused or declared and notified shall be deemed to be and treated as Slum Rehabilitation Areas "
ii. Clause II (iii) shall also mean any area declared as such by the SRA though preferably fulfilling conditions laid down in the M.S.A. Act to qualify as a slum area.
iii. Clause II (viii) stipulated that Censused shall mean those
Act 4 of 1996 amended the Mah, Slum Areas Act 1971 by the introduction of Chapter (1) (A):- Refer: page 187 of Petition
i. Sections 3(A) & 3(B) provided for the appointment of a "Slum Rehabilitation Authority ( SRA ) for a notified area and the framing of a general "Slum Rehabilitation Scheme " ( SRS ) by the State Govt. or by the SRA with the sanction of the State Govt. for such area.
ii Section 3C(1) of Chapter 1-A inserted by the Amendment Act 4 of 1996 stipulated that after the publication of the General Scheme the Chief Executive Officer on being satisfied that circumstances in respect of any area justified its declaration as a "Slum Rehabilitation Area" under the said Scheme may by an order published in the Official Gazette and which order was also to be given wide publicity by the SRA) declare any area under the said Scheme to be a "Slum Rehabilitation Area"
iii Section 3C (2) provides that any person aggrieved by any such Slum Rehabilitation Order can prefer an appeal to the Tribunal.
Ref: Petition Exh. M page 187-190
See also section 12 for Clearance Order to direct demolition (page 190). They have not made any clearance order but took advantage of Court Orders for demolition. It appears that there was no Clearance Order because there was no declaration of the area as Slum Area or Slum Rehabilitation Area.
18. 16-12-1995: The Gov.of Maharashtra appointed the
" Slum Rehabilitation Authority " ( i.e. the SRA ) under Chapter 1-A of the Slum Areas Act 1971 Under Chapter III of the Municipal Corporation Act and the MRTP Amendment Act 1995, the SRA has been granted the status of a Planning Authority for the purpose of slum Rehabilitation in Greater Bombay.
19. 16-5-1996: Govt. Resolution ( GR ) sanctioning rehabilitation under the Slum Rehabilitation Scheme of "all hutment dwellers in Mumbai from the year 1976,1980 and 1985 as well as those hutment dwellers who came into existence...
From November 1995
23-11-1995: Section 2 (19) of M.R.T.P.Act was substituted by Maharashtra Act 5 of 1996 w.e.f. 23-11-1995, section 4, by which SRA was also included in the definition of "Planning Authority".
The Government of Maharashtra
From June 1992
of Greater Bombay for implementation of lands allocated to various users/designated/reserved sites occupied by slums".
i. The policy guidelines divided the lands in to VII categories
ii. Category II dealt with "land reserved/designated/allotted for existing or proposed non-buildable reservations such as recreational ground, playground, garden, park and any other open user in the Final Development Plan" and for the first time provided that if the reserved/non buildable plot was more than 1000 sq.
mtrs.and the encroachment was more than 25% of the area of the site, the site (although reserved in the Development Plan for a recreational ground, playground, park, and other open user/non-buildable reservation) would be
allowed to be used for redevelopment in accordance with D.C.Regulation 33(10) subject to the condition that the ground area of the land so used would not be
more than 67 % of the reservation, which means they can use 67% of the ground area.
iii. Category VI dealt with lands occupied by existing slums on proposed or existing alignments of Development Plan Roads or road widening proposals and provided that such slums would be rehabilitated on suitable nearby residential zone.
iv The Policy of 1992 Guidelines defined an "existing (page275) as"the area occupied by slum dwellers which are censused and having photopasses as per 1976 census or those whose names have appeared in the Legislative Assembly Voters List of 1985.
v. The Policy Guidelines (Notification dated 3-6-1992 Exh.B to the aff. in reply at page 269) made no reference to Town Planning Scheme areas.
14. 1990-98: Correspondence exchanged between the Petitioners and diverse authorities regarding removal of encroachments from the plots/ lands reserved for roads, gardens, recreation grounds and open spaces in the TPS. By his reply dated 18-2-1991 to the petitioner's letter dated 30-12-1990, the Controller of removal of Encroachments and Unauthorised Structures informed the Chairman of the 1st Petitioners that instructions have been issued to the Deputy Controller of Rem.of Encr.& unau., structures Division III, Andheri (Wesr) to demolish unautahorised structures in the letter of Pet.No1's letter dated 20-1-1991and that "mass demolition programme will be arranged soon and unautahoraised encroachments mentioned in the Petitioner's letter will be demolished". (Page D of Synopsis).
The Under-secretary to the Government of Maharashtra UDD by his letter dated 19-4-1994 informed the Petitioners that steps would be taken to remove the encroachments and implement the work of the sanctioned T.P.S. (Refer: Exhibit A at. However in fact no substantial steps were taken and the encroachments .
36. Against the said order of this Hon'ble Court dated 11th October2000, Special Leave Petitions were preferred to the Hon'ble Supreme Court of India by the State of Maharashtra (SLP Civil No.17411 of 2000 and by the Intervenors (Janata Rahivasi Mandal, Chunabhatti & by the Vikas Welfare Society )
The Hon'ble Supreme Court declined stay and the SLPs were subsequently dismissed as withdrawn.
Development Control Regulations
T. P. Scheme VI Santa Cruz
From July 1985
(D. C. Regulations) framed and sanctioned under the Maharashtra Regional Town Planning Act for implementing the Development Plan (Annexed as Exhibit 1 to affidavit of Rane for the 1st Respondent)
D. C. Regulations 33 (10) provided for grant of FSI of 2.5 for rehabilitation of " censused slums or such slums whose structures and inhabitants whose names appear in the Legislative Assembly Voters List of 1985" (Refer to page 265 )
Regulations for such rehabilitation were contained in Appendix IV to the D. C. Regulations and provided for grant of FSI of 2.5 for Slum Rehabilitation D. C. Regulations 33 (10) (at page 265) as initially framed contained no provision enabling/permitting slum rehabilitation structures to be constructed on plots reserved for gardens, maidans,
recreation grounds or playground or open spaces in the Development Plan or Town Planning Schemes. The slum rehabilitation provision on T.P. Public Amenity Plots came for the first time by notification dated 15-10-1997.
Ref: Exh. 'J' is the Gazette Notification dated 15-10-1997 at page 136 and clause 7.9 of Appendix IV at page 143.
Ref: Exhibit K at Page 147 is the General Slum Rehabilitation Scheme
Exhibit 'L' at page177 is the same Annexure as at page 137
Exhibit A to the Affidavit in reply of Respondent No.1 (Rane's Affidavit) are original D. C. Regulations of 1991 at page 263. Original D. C. Regulations at page 265 protected those structures and persons whose names appear in the Legislative Voters List of 1985. Hence slum dwellers after 1985 were not protected. They came to be protected by government resolution dated 16-5-1996 (Exhibit "I" at page 133) i.e. hutment dwellers who came into existence after 1985 but up to 1-1-1995 and whose names appear in the Voters List as on 1-1-95 and who continue to stay at the same address. Hutments which came after 1995 were to be demolished.
extending protection to hutments constructed till 1980
9. 30-3-1981: Arbitrator submitted 1st Variation Scheme (Final) of
T.P. Scheme Santa Cruz VI. (page 789)
10. 13-5-1985: Notification sanctioning T. P. Scheme 1st Variation to come in to effect from 1-7-1985 (Refer page 789-790)
11. 6-6-1985: Government Resolution extending protection to hutments constructed till1985
TPS VI. Although
Illegal encroachments by Slumlords & hutment dwellers on plots/ lands reserved for roads, gardens, recreation grounds & open spaces in TPS VI. Although provisions existed in the Maharashtra Land Revenue Code, the Maharashtra Regional & Town planning Act, 1966 & the Bombay Municipal Corporation Act, the Slum Areas Act & other Statutes, the Govt. failed to take steps to prevent large scale trespass and encroachment on roads, gardens, recreation grounds and open spaces in the T.P.S.VI
7. 23-12-1978: The Draft Scheme (1st Variation) was sanctioned by ment under notification (Ref: Page 784)
Reservations are shown at pages 202, 773, 776, 777, 779 and 781
Govt.or Brihan Mumbai Municipal Corporation and incorporated
in the records of the land owning authority as having been censused in 1976, 1980 or 1985 or prior to 1st January 1995.
Appendix IV ( at page 138 Exh.'J')
iv. clause 1.3 stipulated tahatrehabilitatkon "may be in situ and in the same plot as far as possible"
v, clause 1.4 however stipulated that "pavement dwellers and hutment dwellers in the slum on lands required for vital urgent public utility/purpose or on the hazardas location, dhallnot be rehabilitated in situ bit in other available plots and in accordance with these Regulations" (page 138 of the Petition)
vi. clause 7.1 stipulated that " slums situated in lands falling under various reservations/zones in the Development Plan shall be developed in accordance with the provisions of the Notification dated 3rd June 1992" as modified by the provisions in the amended Appenix IV (page142 of the Petition)
vii. Clause 7.4 provided that the "stipulation of 33% of area under non buildable reservation may be reduced to the extent necessary where there are height and other reservations"
viii. Clause 7.9 stipulated that " slum rehabilitaion can be taken up on Town Planning Scheme Plots also after they are declared slums/slum rehabilitation areas ".
Ref: Exh.'J' page 138 -144. Same as at Exh. 'L'at pages 177-
Exh. ;C; to the aff.in reply of Respondent No.1
Co-operative Housing Societies
having 960 members residing in 87 pucca lawfully constructed R.C.C.Buildings, accomodating a population of over 5000 persons in the vicinity of Relief Road.
(Refer: Exh. C.D.& E. to the Petition: pages 74-83}
3 1971: Maharashtra Slum Areas ( Improvement, Clearance & Redevelopment ) Act 1971 enacted. The Act provided for declaration of "Slum Areas", improvement of existing slum areas,& prevention of further encroachment./clearance of slum areas.
Under section 4(1) an area could be declared as a "Slum Area" by the Competent Authority by a Notification in the Offficial Gazette. Such a declaration is also required to be given due publicity in the manner prescribed. Any person aggrieved by such declaration could under section 4(3) file an appeal to the Tribunal. Owing to the absence of declaration of Daulatnagar as a "Slum", the aggrieved persons are deprived of the right to appeal.
Since there is no declaration of the area in question as a "Slum Area", the Slum Areas Act does not apply and the Slum Rehabilitation Scheme cannot apply. It is also to be noted that there is no declaration of the area as a "Slum Rehabilitation Area" under section 3(C) of the Slum Areas Art.
4. 18-4-1976: Govt. Resolution protecting hutments put up by encroachers/trespassers till 4.2.1976 and directing that any encroachments
put up after that date be demolished.
5. 1976: Census of hutments in 1976 carried out by the Maharashtra
Housing and Special Assistance Department. Each censused hutment
dweller was given a photopass.
Development charges for Roads
water mains, sewers & 1967storm water drains. An amount of Approx. 77.50 lakhs were paid by all the Societies. Non Agricultural charges were also recovered from the Societies.The marshy lands were reclaimed and converted into habitable plots. Buildings were constructed on the allotted plots. About 26 plots were kept vacant and earmarked for public amenities, and gardens/recreation grounds & open spaces.( Refer: pages 13 to 16 of the petition)
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