Toxic Conspiracy

How Governments are Helping Sterlite Violate the Law

March 2018

By Nityanand Jayaraman, Chennai Solidarity Group

On 01.01.2009, the Ministry of Environment & Forests (MoEF) accorded Environmental
Clearance to Sterlite Industries (now Vedanta Ltd) for setting up an additional 1200 TPD
(tonne per day) copper smelter complex in Thoothukudi, Tamilnadu. This clearance was
granted without counducting a public hearing as prescribed by the Environmental Impact
Assessment (EIA) Notification. Sterlite argued and MoEF agreed that the proposed
project site fell within the existing SIPCOT (State Industrial Promotion Corporation of
Tamilnadu) Industrial Complex in Thoothukudi and would therefore qualify for exemption
from public hearing. Given Sterlite's controversial track record in Thoothukudi, the
company is aware of the opposition its proposal is likely to face in the event of a public
hearing.

SIPCOT also concurred with MoEF and Sterlite that the proposed project fell within the
existing SIPCOT Industrial Complex.

A writ petition challenging the Environmental Clearance and the exemption on grounds
that the project did not fall within the existing SIPCOT Industrial Complex was rejected by
the Madras High Court in April 2016. The High Court decided that “In view of the
consistent stand taken by all the respondents including the 5th respondent SIPCOT that
the 4th respondent [Sterlite] is situated within the SIPCOT complex, we have no difficulty
in holding that exemption from public consultation would certainly apply.”1

On 14.11.2016, Tamil Nadu Pollution Control Board issued Consent to Establish (i.e.
licenses to commence construction) under Air Act and Water Act to Vedanta Ltd's
(formerly Sterlite) proposed 1200 TPD copper smelter in Thoothukudi.

Construction commenced in mid-2017 amidst stiff public opposition by villagers from

Kumareddiyapuram who are fearful that the location of a hazardous polluting unit in close
proximity to their residential area will harm their already ailing health.

New evidence has emerged that reveals that Sterlite, SIPCOT, MoEF and TNPCB had
misled the Madras High Court about the location of Sterlite's proposed project to defend
the exemption from public consultation given to the proposal.

New developments confirm that the proposed project site is not located within the
existing SIPCOT Industrial Complex. Rather, it is contained within a 1616 acre (654
hectare) parcel of land that is only now being proposed to be developed as a standalone
Tuticorin Industrial Park by SIPCOT. Approvals for this project have not yet been
obtained. Development of this project has not commenced.

1 Pushparayan vs Union of India & Ors. WP (MD) No. 13810 of 2009. Common order dated 28.4.2016.
Background

Copper smelters are classified as Large, Hazardous and “Red” Category industries by
MoEF. TNPCB further classifies copper smelters as Ultra Red acknowledging their higher
pollution potential.2 Sterlite's proposal involves the setting up of a 1200 tpd (438,000
tonne per annum) copper smelter with associated facilities producing copper anodes,
copper rods, phosphoric acid, precious metals (gold, silver, platinum, palladium),
selenium, bismuth bisulphate, copper telluride, nickel, sulphuric acid, hydro-fluoro-silicic
acid etc.

Copper smelters are covered by EIA Notification, 2006, and proposals for new projects
are normally subject to public consultation after the preparation of an EIA report.

The EIA Notification contains a clause exempting public consultation for “all projects or
activities located within industrial estates or parks (item 7(c) of the Schedule) approved by
the concerned authorities, which are not disallowed in such approvals.”3

On 10.12.2014, MoEF further clarified through an Office Memorandum that the

exemption was available to “projects or activities or units located within the Industrial
Estates or Parks, which were notified prior to 14.09.2006, i.e. the EIA Notification, 2006,
coming into force.”4

This Memo was also used to argue in Court that the SIPCOT Industrial Complex was in
existence prior to 2006 and that units coming up within that Complex qualified for
exemption from public consultation.

1. Where is Sterlite's proposed project located?

The coordinates for the project area are given in the EIA report submitted by Sterlite5:
Northwest-08°50’29.9”N 78°04’12.9”E
Southwest-08°49’45.3”N 78°04’05”E
Southeast-08°49’32.9”N 78°04’40.7”E
Northeast-08°49’58.8”N 78°04’47.8”E

2 Board Proceedings. B.P. M.S. No. 37 dated 10.03.2010. Tamil Nadu Pollution Control Board. Page 278 of
“Compendium of Government Orders, Board Proceedings & Circulars Relating to Environment and Pollution
Control, Volume I.” http://www.tnpcb.gov.in/pdf_2017/Compendium_Vol_01_11117.pdf Downloaded on
26.03.2018.
3 Section 7(1)(III) Stage 3(i)(b) of EIA Notification, 2006. Ministry of Environment & Forests.
http://envfor.nic.in/legis/eia/so1533.pdf Downloaded 27.03.2018.
4 Office Memorandum OM J-11013/36/2014-IA.I dated 10.12.2014. Ministry of Environment & Forests. Reproduced
in Page 297 of “Compendium of Government Orders, Board Proceedings & Circulars Relating to Environment and
Pollution Control, Volume II (Circulars). http://www.tnpcb.gov.in/pdf_2017/Compendium_Vol_02_11117.pdf
Downloaded 27.03.2018.
5 Environmental Impact Statement for Proposed Copper Smelter Plant-II (1200 TPD Copper/4.38 LTPA Copper) in
the SEZ at SIPCOT Industrial Complex, Therku Veerapandiapuram Village, Ottapidaram Taluka, Thoothukudi
District, Tamil Nadu. For Sesa Sterlite by Vimta Labs Ltd. January 2015.
Further, the Consents to Establish issued by the TNPCB contains the Survey Numbers
covering the project site.

They are: S.F. No. 45/2A, 45/2B, 45/3, 46/1, 46/2, 46/3, 46/4, 46/6, 46/7, 66/1, 66/3,
66/4, 67/1, 67/3, 67/4, 67/6, 67/8, 68/2, 68/3, 68/4, 69/2, 69/4, 69/5, 69/1A, 69/1B,
285/PART, 286/PART, 288/PART, 289/PART, 290/1, 290/2, 290/3, 290/4, 293/1A, 293/1B,
294/1, 294/2, 294/6, 294/3A, 294/3B, 294/4A, 294/4B, 294/4C, 295, 297/1, 297/2, 297/3,
297/5, 297/6, 297/7, 298/1, 298/3, 299/1, 299/2, 299/4, 299/5, 301/2, 302/1, 302/2,
302/3, 302/4, 302/5, 302/6, 303, 304, 305, 306/1, 306/3, 306/4, 306/6, 318/2, 318/3, 319,
320/1, 320/2, 320/3, 322/1, 322/3A, 322/3B, 322/3C, 324/1A PART, 324/1A PART,
324/1A PART, 324/1B1, 324/1B2, 324/2A, 324/2B, 325, 326/2 PART, 326/2 PART, 326/3
PART, 326/3 PART, 328/1, 328/2A, 328/2B, 328/2C, 330/1, 330/2A, 330/2B, 331/1,
331/2, 332/1, 332/2A, 332/2B, 333/1, 333/2, 334, 335/1, 335/2, 336, 337, 338/1, 338/3A,
338/3B, 340/1, 340/2, 340/3, 340/4, 340/6, 340/7, 340/8, 341/1, 341/3
THERKU V P PURAM village, Ottapidaram Taluk and Thoothukkudi District.

2. Does Sterlite's proposed project site fall within the existing SIPCOT Industrial
Complex?
The existing SIPCOT Industrial Complex is established over an area of more than 1032.68
acres.6 The project was conceived on 25.03.1981, when the Government of Tamil Nadu,
Industries Department, issued a Government Order (G.O. 383) sanctioning SIPCOT to
acquire lands to establish a growth centre in Thoothukudi.

In SIPCOT's own words, “SIPCOT Industrial Complex, Tuticorin has been established
during 1985 in land admeasuring about 1083 acres.”7 This is the industrial estate referred
to variously as SIPCOT Industrial Estate, SIPCOT Industrial Complex or simply SIPCOT
complex.

Sterlite's proposed project site is not located within this SIPCOT Industrial Complex.
Rather it lies within lands acquired as part of Phase II scheme. Phase II scheme was
conceived on 18.12.1996, when the Government of Tamil Nadu, Industries Department,
issued another Government Order (G.O. 233) sanctioning SIPCOT to acquire 1616 acres
of lands to set up a new industrial complex as “Phase II scheme” in Therku
Veerapandiapuram and Meelavittan villages, Thoothukudi.

The Survey Numbers of the 1616 acres acquired include the Survey Numbers allotted to
Sterlite for the proposed copper smelter.

Figure 1 shows the location of Sterlite's proposed project site in relation to SIPCOT
Industrial Complex and the Phase II scheme.

6 Brief Industrial Profile of Tuticorin District, 2012-2013. Br.MSME-Development Institute. Ministry of MSME.
Tuticorin. Page 14. http://dcmsme.gov.in/dips/IPS%20Tuticorin%20Revised.pdf Downloaded 26.03.2018
7 Letter No. PO/TUT/Sesa Sterlite/2015, dated 12.1.2015, by Project Officer, Tuticorin, SIPCOT
3. Isn't SIPCOT Phase II, within which Sterlite is setting up, an Industrial Estate or
Park that is approved by concerned agencies?

In 2008, when Sterlite submitted its application seeking environmental clearance and
exemption from public consultation, land acquisition for SIPCOT Phase II had only just
begun. It was only in 2009 and 2010 that 324.53 acres of land was allotted to Sterlite
though three separate lease deeds. As of 2013, only 434 acres of the 1616 acres had
been acquired.8 Moreover, it was only in 2014 that SIPCOT mooted the proposal of
developing the Phase II lands into an Industrial Park.

On 27.10.2014, SIPCOT submitted an application to MoEF in Form 1 of EIA Notification,

2006, seeking Terms of Reference (TOR) for the preparation of an Environmental Impact
Assessment for “establishing an industrial park at Tuticorin, Tamil Nadu.” The proposed
park, named “Tuticorin Industrial Park,” (TIP) was to be set up in the 1616 acres (654
hectares) of lands acquired through the 1996 Government Order.

Curiously, SIPCOT has failed to reveal the fact that 324 acres of the proposed TIP has
already been allotted to Sterlite for a copper smelter complex. Acknowledging that would
expose the stance being taken in Madras High Court by SIPCOT, TNPCB, MoEF and
Sterlite about the latter's location within the existing SIPCOT Industrial Complex.

In its Form 1 application submitted to MoEF for the proposed Tuticorin Industrial Park,
SIPCOT repeatedly withholds information about the presence of Sterlite's proposed
project inside the TIP project boundaries and makes it appear as though no lands have
been allotted to any industries.

The Form 1 application requires project proponents to provide certain information under
oath. Section I (Activities) which deals with “changes in the locality” due to known
production activities (Item 1.13). Despite having allotted 324.53 acres land to Sterlite in
2009-10 for its copper complex, SIPCOT hides this fact and responds saying: “Only on
allotment of land to the industries, this information can be furnished.”

On 15.12.2017, a notice was reportedly published in New Indian Express and Dinamani
announcing a public hearing for the proposed Tuticorin Industrial Park.

On 25.01.2018, the public hearing was held in Thoothukudi. However, the hearing had to
be cancelled in deference to public demand that the hearing should be conducted after
adequate publicity and notice is given.9

This demonstrates that TIP within which Sterlite is located is yet-to-be approved as an

8 Brief Industrial Profile of Tuticorin District, 2012-2013. Br.MSME-Development Institute. Ministry of MSME.
Tuticorin. Page 14. http://dcmsme.gov.in/dips/IPS%20Tuticorin%20Revised.pdf
9 “Proceedings of Public Hearing conducted for the proposed development of SIPCOT Industrial Park for around
654.42 hectares in Meelavittan village. . .by M/s SIPCOT Ltd, on 25.01.2018. . .”
http://www.tnpcb.gov.in/pdf_2018/Minutes_SIPCOT15318.pdf Downloaded on 26.03.2018.
Industrial Estate or Park.

4. What is the law on siting hazardous industries?

For any construction, including setting up of industries and industrial estates and parks,
permission has to be obtained from the Local Planning Authority headed by the District
Collector.

The Thoothukudi Municipal Area was notified as a Local Planning Area in 1975, and
subsequently 29 villages, including Therku Veerapandiapuram, were notified as additional
area to Thoothukudi Local Planning Area in 1983.10

A village area masterplan was prepared and approved as per the Town and Country
Planning Act, 1971 Act. According to the zoning regulations approved by the
Government of Tamil Nadu, masterplans have to clearly demarcate use zones as
residential use, industrial use, commercial use etc. Industrial use zones are further sub-
divided into Controlled Industrial Use Zone, General Industrial Use Zone and Special
Industrial and Hazardous Use Zone.11

The approved land use for Tuticorin Local Planning Area is contained in the Village Area
Land Use Schedule.12 Therku Veerapandiapuram village, within which Sterlite's new
complex is being set up, contains no lands reserved for Special Industrial and Hazardous
Use Zone. Some survey numbers are earmarked as Controlled Industrial Use Zone. But
“industries of obnoxious and hazardous nature by reason of odour, liquid effluent, dust,
smoke, gas, vibration etc. Or otherwise likely to cause danger or nuisance to public health
or amenity” are not permitted in Controlled Use Zones.

As per the approved village area masterplan downloaded from the Thoothukudi Local
Planning Area website, the entire proposed TIP area and Sterlite's proposed site within it
fall in areas marked as “Dry Agriculture” in the legend accompanying the map.13 See
Figure 2.

5. Which agency is responsible for ensuring compliance with Masterplan in the case
of Sterlite and SIPCOT? Has it done its job?

The dangers of locating hazardous industries in close proximity to residential areas were
made evident in the 1984 Bhopal Gas Leak disaster. If built, Sterlite's proposed copper
smelter complex will take total installed capacity of copper production in Thoothukudi to

10 Thoothukudi Local Planning Area website. http://thoothukudi.nic.in/lpa/aboutus.html Downloaded 27.03.2018

11 G.O. MS 1730, Rural Development and Local Administration Department, dated 24.07.1974. Contained in “The
Information Handbook under Right to Information Act: Department of Town and Country Planning. Government of
Tamil Nadu.” http://www.tn.gov.in/rti/proactive/hud/handbook_dtcp.pdf Downloaded 27.03.2018.
12 Village Area Schedule to Masterplan. http://thoothukudi.nic.in/lpa/pdf/Master_Plan/Village_Area_Schedule.pdf
Downloaded on 27.03.2018.
13 Village Area Masterplan, Thoothukudi Local Planning Area (Rural).
http://thoothukudi.nic.in/lpa/pdf/Master_Plan/Village_area_Masper_Plan%28Existing%29.pdf Downloaded on
27.03.2018.
more than 800,000 tonnes per annum. That would make this the world's largest smelter
to come up within a densely populated urban area.

The agency responsible for ensuring proper siting in compliance with the Masterplan is
the Thoothukudi Local Planning Authority headed by the District Collector.

The fact that the District Collector is deploying police force to help Sterlite construct an
Ultra Red category industry in close proximity to residential areas reveals that the Local
Planning Authority is not doing its job. This lapse exposes lakhs of people to the dangers
of routine pollution and episodal events such as disastrous gas leaks.

6. Sterlite has assured that it will operate without polluting the environment, and
that it runs a state of the art facility, and the new facility will cause no harm.

Deploying state-of-the-art technology is required after fulfilling basic siting criteria and
complying with other laws. In this instance, the siting, the environmental clearance and
Consent to Establish that have been obtained are all illegal and fraudulent.

Sterlite's environmental track record in Thoothukudi, and the willful complicity of state
agencies – district administration, SIPCOT, TNPCB and MoEF – provide sufficient reason
to disregard any assurances given by Sterlite or state agencies.

Sterlite's poor environmental track record is confirmed by the Hon'ble Supreme Court
itself which has found Sterlite guilty of pollution, illegal operations and making false
averments while under oath. Abstracts from the Supreme Court's final order in Civil
Appeal 2776-2783 of 2013, Sterlite Industries v. Union of India, highlight the pollution,
illegalities and falsehoods that have characterised Sterlite's operations in Thoothukudi.14

“The NEERI reports of 1998, 1999, 2003 and 2005 show that the plant of the appellant
did pollute the environment through emissions which did not conform to the standards
laid down by the TNPCB under the Air Act and through discharge of effluent which did
not conform to the standards laid down by the TNPCB under the Water Act . . .

“As pointed out by Mr. V. Gopalsamy and Mr. Prakash, on account of some of these
deficiencies, TNPCB also did not renew the consent to operate for some periods and yet
the appellants continued to operate its plant without such renewal. This is evident from
the following extracts from the NEERI report of 2011. . .

“For such damages caused to the environment from 1997 to 2012 and for operating the
plant without a valid renewal for a fairly long period, the appellant-company obviously is
liable to compensate by paying damages. . .

14 https://indiankanoon.org/doc/ Downloaded on 27.03.2018

“Considering the magnitude, capacity and prosperity of the appellant-company, we are
of the view that the appellant-company should be held liable for a compensation of Rs.
100 crores for having polluted the environment in the vicinity of its plant and for having
operated the plant without a renewal of the consents by the TNPCB for a fairly long
period and according to us, any less amount, would not have the desired deterrent effect
on the appellant-company. The aforesaid amount will be deposited with the Collector of
Thoothukudi District, who will invest it in a Fixed Deposit with a Nationalized Bank for a
period of five years. The interest therefrom will be spent for improving the environment,
including water and soil, of the vicinity of the plant after consultation with TNPCB and
approval of the Secretary, Environment, Government of Tamil Nadu. . .

“We now come to the submission of Mr. Prakash that we should not grant relief to the
appellants because of misrepresentation and suppression of material facts made in the
special leave petition that the appellants have always been running their plant with
statutory consents and approvals and misrepresentation and suppression of material facts
made in the special leave petition that the plant was closed at the time the special leave
petition was moved and a stay order was obtained from this Court on 01.10.2010. There
is no doubt that there has been misrepresentation and suppression of material facts made
in the special leave petition but to decline relief to the appellants in this case would mean
closure of the plant of the appellants.”

An Update
On 14.02.2018, Vedanta Ltd applied in Form 1 to the MoEF seeking a fresh
Environmental Clearance for the proposed copper smelter as the Environment Clearance
of 01.01.2009 is set to expire in December 2018. The EIA Notification, 2006, limits the life
of an Environmental Clearance to 10 years, all extensions included.

However, while the 2009 Environmental Clearance was given for a smelter on 92.5 ha, the
fresh application shows the project area as 128.805 ha. The larger area – of 128.805 – has
already been cleared and construction work is underway.

Even in its new application, Vedanta has made a false declaration that the project is
coming up inside the existing SIPCOT Industrial Complex, without revealing that it is
actually coming up inside the yet-to-be-approved Tuticorin Industrial Park.

Conclusion
The 2009 Environmental Clearance obtained by Sterlite by-passing the statutory public
hearing is ultra vires considering that the basis of exemption (namely, the project's
location within an approved industrial estate) is not made out. Sterlite, SIPCOT, MoEF
and TNPCB are guilty of perjury for having misled the Madras High Court on this count.

The licenses to construct the factory issued by TNPCB – the Consents to Establish under
Air and Water Acts – are also based on false declarations and hence lacking in legal basis.
Under the circumstances, the police action of February 2018 against Thoothukudi
residents and the people of Kumareddiyapuram, and the police protection enjoyed by
Sterlite at its illegal project site makes the district administration complicit in the offences
of Sterlite, SIPCOT and the regulatory agencies TNPCB and MoEF.

Further, it is the responsibility of the District Collector, as head of the Local Planning
Authority to ensure that plan approvals and building approvals are in line with land-use
classifications in the approved Masterplan. The failure to challenge the setting up of a
large, Red Category, Hazardous Industry in an area classified as “Dry Agriculture” and in
close proximity to a “Residential” area is illegal, a recipe for disaster.

Recommendations
• Ongoing work to build the new 1200 tpd copper smelter should be stopped
immediately.
• The Environment Clearance granted on 01.01.2009, and the Consent to Establish
granted in 14.11.2016 are invalid as they were obtained on the basis of false
claims. The MoEF and TNPCB should quash the licenses given; officials involved in
granting these illegal permissions should be prosecuted for corruption and
conspiracy as they have conspired to pervert the law to benefit a private
multinational corporation.
• Officials of Sterlite, SIPCOT, MoEF and TNPCB who misled the Madras High Court
and defended Sterlite's exemption from Public Hearing in WP 13810 of 2009 must
be prosecuted for perjury.
• SIPCOT's application for Environmental Clearance for its Tuticorin Industrial Park
should be rejected on grounds that
a) the company withheld information about Sterlite's plans inside its proposed
Industrial Park;
b) its plans to locate hazardous industries on lands classified as “dry agriculture”
in the village area masterplan of Thoothukudi.
• Sterlite's application of 14.02.2018 seeking fresh Environment Clearance must be
rejected on grounds that
a) Sterlite has made a false representation denying the location of its project
within the yet-to-be-approved Tuticorin Industrial Park;
b) Sterlite has failed to disclose that it is violating the approved masterplan for
the area, by locating a hazardous industry in a village that does not have any
area designated as “Special Industries and Hazardous Use Zone.”
• A comprehensive Health and Environmental Impact Assessment should be
conducted in Thoothukudi to assess the cumulative impacts of existing industries,
including Sterlite. The study should also assess the carrying capacity of the region,
with a view to limiting all further development of hazardous industries in the
district.
• Cases filed against Thoothukudi residents and villagers for exposing Vedanta
Sterlite's illegal activities should be withdrawn.
Figure I
Figure II
 ANNEXURE-I

SIPCOT THOOTHUKUDI INDUSTRIAL PARK

LAND ABSTRACT

(Extent in Acres)

Name of the Village Patta Poramboke Total

Stage - I
Therkuveerapandiyapuram 354.24 17.25 371.49
Meelavittan 82.30 2.37 84.67
436.54 19.62 456.16
Stage - II
Therkuveerapandiyapuram 1021.960 26.240 1048.20
Total 1458 45.860 1504.360
Village: Therkuveerapandiyapuram
Taluk : Thoothukudi & Ottapidaram

SURVEY NO EXTENT
PATTA PORAMBOKE TOTAL
285 1.860 1.860
286 1.980 1.980
288 3.080 0.045 3.125
289 3.400 0.950 4.350
290 3.995 3.995
293 5.480 5.480
294 3.665 0.055 3.720
295 1.215 1.215
297 3.690 0.070 3.760
298 1.720 0.040 1.760
299 2.015 0.070 2.085
322 2.140 0.045 2.185
326 1.955 0.060 2.015
328 2.550 2.550
330 4.785 4.785
331 4.215 4.215
333 4.425 4.425
334 3.130 3.130
335 2.070 2.070
329 3.615 3.615
332 4.045 4.045
336 1.725 1.725
337 1.195 1.195
338 6.825 0.060 6.885
340 2.310 0.060 2.370
341 3.565 0.030 3.595
343 2.235 2.235
365 2.015 2.015
45 3.820 0.050 3.870
46 4.330 4.330
66 2.650 0.160 2.810
67 2.290 0.140 2.430
68 2.110 0.160 2.270
69 1.925 0.115 2.040
303 2.240 2.240
304 2.680 2.680
305 4.475 4.475
306 2.735 0.070 2.805
301 7.440 0.100 7.540
302 3.295 3.295
SURVEY NO EXTENT
PATTA PORAMBOKE TOTAL
318 4.020 0.135 4.155
319 2.235 2.235
320 3.325 3.325
324 5.415 5.415
325 3.530 3.530
287 0.235 0.235
291 0.250 0.250
292 0.185 0.185
296 0.260 0.260
321 0.225 0.225
323 0.290 0.290
327 0.290 0.290
339 0.295 0.295
342 0.290 0.290
349 0.285 0.285
364 0.240 0.240
368/1 0.240 0.240
369 0.255 0.255
371/1,2,3 0.350 0.350
362/2 0.295 0.295
370/3 0.085 0.085
372/2 0.100 0.100
374/4 0.400 0.400
Total (A) 143.415 6.985 150.400
(in Acres) 354.24 17.25 371.49
Village : Meelavittan

SURVEY NO EXTEN
PATTA PORAMBOKE TOTAL
45 9.250 9.250
46 1.200 0.185 1.385
47 7.645 0.135 7.780
48 4.215 0.225 4.440
49 2.985 2.985
50 1.530 0.180 1.710
51 1.620 1.620
52 4.875 4.875
40 0.235 0.235
Total (B) 33.320 0.960 34.280
(in Acres) 82.30 2.37 84.67

Grand Total 176.735 7.945 184.680

(A+ B)
(in Acres) 436.54 19.62 456.16
Taluk : Ottapidaram
Village : Therkuveerapandipuram

SURVEY NO EXTEN
PATTA PORAMBOKE TOTAL
70 3.985 3.985
71 2.070 2.070
72 4.795 0.110 4.905
73 4.415 0.090 4.505
74 4.945 0.160 5.105
75 2.135 2.135
76 3.725 0.285 4.010
77 3.120 0.315 3.435
47 4.265 0.075 4.340
62 3.090 0.125 3.215
63 4.440 0.265 4.705
64 1.950 1.950
65 3.295 0.120 3.415
307 2.645 2.645
308 3.300 3.300
309 3.415 3.415
316 2.955 0.200 3.155
317 3.195 0.080 3.275
61 11.070 1.265 12.335
310 3.660 3.660
311 4.635 4.635
312 2.580 2.580
313 4.640 4.640
314 2.510 2.510
315 3.055 0.160 3.215
1 2.810 0.120 2.930
2 2.850 0.325 3.175
3 5.120 0.295 5.415
4 6.395 6.395
6 10.580 10.580
7 1.495 1.495
8 4.150 4.150
9 2.860 2.860
10 5.140 5.140
11 2.555 2.555
17 2.550 0.120 2.670
18 2.590 0.095 2.685
19 5.685 0.225 5.910
21 3.915 0.010 3.925
5 1.150 1.150
82 15.240 15.240
SURVEY NO EXTEN
PATTA PORAMBOKE TOTAL
12 0.405 0.405
13 0.365 0.365
83 3.855 3.855
88 4.525 4.525
84 3.025 3.025
85 1.540 1.540
86 2.575 2.575
87 2.565 2.565
89 3.080 3.080
90 4.490 4.490
124 2.585 2.585
126 2.815 2.815
127 1.970 1.970
128 3.270 0.150 3.420
27 3.490 3.490
28 1.635 1.635
31 4.525 4.525
32 2.995 2.995
33 3.195 3.195
34 3.840 3.840
36 2.775 2.775
37 2.615 2.615
41 2.070 2.070
78 29.250 29.250
79 0.180 0.180
40 3.345 3.345
42 4.615 4.615
43 4.225 4.225
44 3.590 0.065 3.655
49 3.790 3.790
50 3.785 0.180 3.965
51 1.020 0.070 1.090
48 4.700 0.225 4.925
39 6.540 6.540
52 2.990 0.030 3.020
53 2.380 2.380
54 4.725 4.725
57 3.865 3.865
58 1.740 1.740
59 5.000 5.000
60 1.505 1.505
350 2.340 2.340
351 3.430 0.060 3.490
353 0.915 0.045 0.960
SURVEY NO EXTEN
PATTA PORAMBOKE TOTAL
358 5.715 0.175 5.890
359 4.875 4.875
360 4.740 4.740
361 1.855 0.045 1.900
373 4.195 4.195
363 1.065 0.125 1.190
366 3.725 3.725
372 3.820 3.820
374 2.470 0.500 2.970
375 4.465 4.465
376 1.105 1.105
406 0.810 0.810
26 3.005 3.005
33 1.600 1.600
34 6.480 6.480
38 0.810 0.855 1.665
39 2.270 0.200 2.470
41 0.980 0.980
42 1.900 1.900
43 1.690 1.690
44 6.470 0.065 6.535
14 3.665 0.210 3.875
15 4.450 4.450
16 2.090 2.090
20 1.540 1.540
25 4.635 4.635
26 3.410 3.410
30 3.755 3.755
22 0.370 0.370
23 0.195 0.195
24 0.220 0.220
29 0.210 0.210
35 0.215 0.215
55 0.355 0.355
56 0.110 0.110
80 0.130 0.130
81 0.155 0.155
300 0.275 0.275
Total 413.750 10.625 424.375
(in Acres) 1021.960 26.240 1048.20
ANNEXURE-II
 ANNEXURE-III
EXEMPTION FOR PUBLIC CONSULTATION

AIII-24
 ANNEXURE-III
EXEMPTION FOR PUBLIC CONSULTATION

AIII-25
 ANNEXURE-III
EXEMPTION FOR PUBLIC CONSULTATION

AIII-26
 ANNEXURE-III
EXEMPTION FOR PUBLIC CONSULTATION

AIII-27
 ANNEXURE-III
EXEMPTION FOR PUBLIC CONSULTATION

AIII-28
Annexure IV
Annexure IV
Annexure IV
Annexure IV
Annexure IV
Annexure IV
Annexure V