JUDGMENT K.S. Radhakrishnan, J. 1. Question that has conic up for consideration in these cases is whether, the countersignature or concurrence is necessary for grant of a temporary permit, on an inter-district route, pending renewal of a regular permit application. 2. Petitioners were operating on the basis Of regular permits for a period of five years. Before the date of expiration of their permits, they submitted applications for renewal of their regular permits. Pending applications for renewal of regular permits, for continuity of service and also for the benefit of the travelling public, they submitted applications for temporary permits. On receipt of applications for renewal of regular permits as well as for temporary permits it is seen that some of the Regional Transport Authorities have sought for countersignature or concurrence from the sister authorities. They are yet to be obtained. Counsel for the petitioners in O.P. No. 6936 of 1998 Sri. A. Inees submitted that Regional Transport Authority has got power under R. 170(d) of the Kerala Motor Vehicles Rules to grant temporary permits without counter signature, pending renewal of regular permit application. Similar is the argument raised by Sri. Santhoshkumar, counsel for the petitioner in O.P. No. 7607 of 1999 and O.P. No. 7909 of 1999 and also Sri. A.K. Abdul Azeez, counsel for the petitioner in O.P.No. 7025 of 1999. 1 also heard counsel for the petitioner in O.P. No. 8369 of 1999, Sri. P. Gopalakrishna Menon. Counsel for petitioners relying on the various provisions in the Motor Vehicles Act and Rules tried to establish that for granting a temporary permit, pending application for renewal of regular permit, no concurrence or countersignature is necessary. Much reliance was made to R. 170(d) of the Kerala Motor Vehicles Rules. 3. Learned Government Pleader Sri. N. Raghuraj submitted that since the route applied for isan inter-district route primary authority has to obtain counter-signature or concurrence from the sister authorities. According to him, it is always open to the sister authorities to reject the application for countersignature or concurrence due to change of circumstance. It is also the contention of the learned Government Pleader that concurrence or countersignature is a pre-requisite for granting permits, either regular or temporary, on an inter District route. 4. The point raised in these Writ Petitions is of considerable importance since it affects the rights of travelling public also. It is also the contention of the learned Government Pleader that concurrence or countersignature is a pre-requisite for granting permits, either regular or temporary, on an inter District route. 4. The point raised in these Writ Petitions is of considerable importance since it affects the rights of travelling public also. An application for regular permit has to be made under S.69 of the Act to the Regional Transport Authority of a region in which it is proposed to use the vehicle or vehicles. If it is proposed to use the vehicle or vehicles in two or more regions lying within the same state, the application shall be made to the Regional Transport Authority of the region in which the major portion of the proposed route or area lies, and in case the portion of the proposed route or area in each of the regions is approximately equal, to the Regional Transport Authority of the region in which it is proposed to keep the vehicle or vehicles. 5. An application for permit in respect of a stage carriage shall contain, among other things, the route or routes or the area or areas to which the application relates. Procedure to he followed by a Regional Transport Authority in considering the application for stage carriage permit is dealt with in S.71. It is always open to the Regional Transport Authority to reject the application for stage carriage permit if an applicant has not complied with the various conditions laid down therein. S. 72 of the Act enables the Regional Transport Authority to entertain an application under S. 70 and grant a stage carriage permit in respect of the region in which it has got jurisdiction. A permit granted by a Regional Transport Authority under S.72 of the Act is valid within the region in which the primary authority has got jurisdiction. Regional Transport Authority can entertain applications for permit on inter-district routes and grant the same. S.88 of the Act, however', validates the permits so granted by the primary authority in other regions as well, after obtaining countersignature or concurrence from the Regional Transport Authorities of other regions. 6. Regular permit granted in respect of a stage carriage by a Regional Transport Authority willvalid for a period of five years. S.88 of the Act, however', validates the permits so granted by the primary authority in other regions as well, after obtaining countersignature or concurrence from the Regional Transport Authorities of other regions. 6. Regular permit granted in respect of a stage carriage by a Regional Transport Authority willvalid for a period of five years. Countersignature or concurrence by the sister authorities willalso be valid for the said period so as to sychronise with the validity of the permit. S. 81 dealsWith duration and renewal of permits. Sub-s. (2) of S. 8 1 says that a permit may be renewedon an application made not less than fifteen days before the date of its expiry. RegionalTransport Authority can also entertain applications for renewal of permit after the last datespecified, if it is satisfied that the applicant was prevented by good and sufficient cause frommaking application within the time specified. Regional Transport Authority may also reject theapplication for renewal on certain grounds. When a permit is renewed after the expiry of theperiod thereof, such renewal shall have effect from the date of such expiry irrespective ofwhether or not a temporary permit has been granted under clause (d) of S.87(1), and where a temporary permit has been granted, the fee paid in respect of such temporary permit shall be refunded. 7. A Regional Transport Authority has power to grant a temporary permit without following theprocedure laid down in S.80 of the Act to be effective for a limited period which shall not in anycase exceed four months to authorise the, use of a transport vehicle temporarily, pendingdecision on an application for the renewal of a permit. This point has already been consideredby this Court in Hassan Kunju v. Regional Transport Authority, 1997 (1) KLT 476 . This Courtheld in the case of S.87(1 )(d) what the authority has to consider is not whether a temporaryneed exists or not, but whether an application for renewal is pending, which pre-supposes theco-existence of temporary and permanent need. In this connection, it is relevant to refer toS.87 of the Act which is extracted below: "87. Temporary permits. (1) A Regional Transport Authority and the State Transport Authority may without following the procedure laid down in S.80 grant permits to be effective for a limited period which shall not in any case exceed four months, to authorise the use of a transport vehicle temporarily. Temporary permits. (1) A Regional Transport Authority and the State Transport Authority may without following the procedure laid down in S.80 grant permits to be effective for a limited period which shall not in any case exceed four months, to authorise the use of a transport vehicle temporarily. (a) for the conveyance of passengers on special occasions such as to and form fairs and religious gatherings, or (b) for the purposes of a seasonal business, or (c) to meet a particular temporary need, or (d) pending decision on an application for the renewal of a permit, and may attach to any such permit such condition as it may think fit." A temporary permit issued by a Regional Transport Authority on an inter-District route under S.87 of the Act could be validated in other region or regions salso in accordance with S.88(7) of the Act, which is extracted below: "88(7) Notwithstanding anything contained in sub-s. (1), a Regional Transport Authority of one region may issue a temporary permit under S.87 to be valid in another region or state with the concurrence given generally or for the particular occasion of the Regional Transport Authority of that other region or of the State Transport Authority of that other State, as the case may be. A conjoint reading of Ss. 87(1)(a) to (c) and 88(7) would indicate that a Regional Transport Authority of one region may issue a temporary permit under S.87 to be valid in another region or State with the concurrence given generally or for the particular occasion. S.88(7) takes in S.87(1 )(a) to (c) and not S.87(1 )(d) which deals with application for temporary permits, pending renewal of regular permit applications. Further S.88(7) gives a discretion to the Regional Transport Authority to issue a temporary permit under S.87 to be valid in another region or State with the concurrence given generally or for the particular occasion. There cannot be a general concurrence for a temporary permit, pending renewal application for regular permit. So also the case of particular occasion. Therefore, in the case of issuance of temporary permit, pending renewal, the statute never envisaged concurrence under S. 88(7) from sister authorities. 8. In this connection, it is also relevant to refer to S.88(1) of the Act, which extracted below: "88. Validation of permits for use outside region in which granted. So also the case of particular occasion. Therefore, in the case of issuance of temporary permit, pending renewal, the statute never envisaged concurrence under S. 88(7) from sister authorities. 8. In this connection, it is also relevant to refer to S.88(1) of the Act, which extracted below: "88. Validation of permits for use outside region in which granted. - (1) Except as may be otherwise prescribed, a permit granted by the Regional Transport Authority of any one region shall not be valid in any other region, unless the permit has been countersigned by the Regional Transport Authority of that other region and a permit granted in any one State shall not be valid in, any other State unless countersigned by the State Transport Authority of that other State or by the Regional Transport Authority concerned. S.88(1) uses the expression 'except as may be otherwise prescribed'. S. 88 takes in both temporary permit and regular permit. The expression 'except as may be otherwise prescribed' takes in R.170 of the Kerala Motor Vehicles Rules. R. 170 of the Kerala Motor Vehicles Rules validates temporary permit granted by a Regional Transport Authority to be operative in other region or regions without countersignature of the Regional Transport Authority of that other region or regions. The said rule is extracted below: "170. Grant of temporary permit for other regions without countersignature.- A temporary permit granted by a Regional Transport Authority shall be valid in any other region or regions in this State without counter signature by the Regional Transport Authority of the other region or regions in the following cases: (a) a temporary permit granted under clause (a) to (c) of S. 87 of the Act fora period not exceeding 20 days. (b) a temporary permit under clause (c) of S. 87 of the Act for a period exceeding 20 days and under clause (b) of S.87 of the Act granted to a contract carriage, (c) a temporary permit under clause (c) of S. 87 of the Act fora period exceeding 20 days and under clause (h) of S. 87 of the Act granted to a contract carriage, provided that prior concurrence of the Regional Transport Authority or Regional Transport Authorities concerned shall have been obtained for the issue of the temporary permit. Provided that such concurrence shall not be necessary for the grant of a temporary permit to perform substitute service in a place of a vehicle already covered by a valid permit for operation on any inter-District route. (d) a temporary permit granted under clause (d) of S.87 of the Act. Provided that the permit in respect of which application for renewal is pending is renewable under these rules without countersignature by the Regional Transport Authority or Regional Transport Authorities concerned". I have already considered the scope of the above rule in Siju v. R. T. A 1998 (2) KLJ 849 and held as follows: "On a combined reading of Ss.87 and 88(7) and R.176 of the Kerala Rules, it is clear that a Regional Transport Authority of a particular region could issue a temporary permit in certain cases to be valid in other region or regions with the concurrence given generally or for the particular occasion of the Regional Transport Authority of other region or regions. A temporary permit granted under clause (a) or (c) of S.87 of the Act, for a period not exceeding 20 days and also a temporary permit granted under clause (c) and (b) of S. 87 of the Act exceeding 20 days is operative in other regions, provided prior concurrence of sister authorities have been obtained." However the question whether a temporary permit could be granted without countersignature or concurrence pending application for renewal of regular permit was not considered in that decision. 9. In order to examine the question we have to read S.87(1)(d) along with S. 88(1) and R.170 (d) and R.171 of the Kerala Motor Vehicles Rules. R.170 as I have already mentioned deals with grant of temporary permits by the Regional Transport Authority for other regions, without countersignature. R.170(d) says that a temporary permit granted under clause (d) of S.87(1) of the Act by a Regional Transport Authority shall be valid in any other region or regions in this State without countersignature by the Regional Transport Authority of the other region or regions provided that the permit in respect of which application for renewal is pending is renewable under the Rules without countersignature by the Regional Transport Authority or Regional Transport Authorities concerned. Therefore, only in cases where application for renewal of a regular permit could be renewable without countersignature, R.170(d) would be applicable. Therefore, only in cases where application for renewal of a regular permit could be renewable without countersignature, R.170(d) would be applicable. A regular permit could be renewed with countersignature or concurrence. A Regional Transport Authority granting a stage carriage permit under sub-r. (2) of R.171 shall before granting the permit obtain the concurrence of the Regional Transport Authority or Regional Transport Authorities of the other region or regions concerned. Therefore, on a reading of R. 170(d) and R. 171(2) it is clear that a Regional Transport Authority could issue temporary permit valid in other region or regions in the State if the regular permit is pending renewable without countersignature but with concurrence as provided under R. 171(2). 10. However, in the case of temporary permit issued under S.87(1 )(d) read with R.70(1 )(d) no countersignature or concurrence is necessary. Legislature has also not used the expression 'prior concurrence' in R.170(d) but at the same time, the expression 'prior concurrence' for temporary permit has been used in R. 170(c) of the Rules. Further in the case of temporary permit coming under S. 87(1)(a) to (c) before grant of the permit, the Regional Transport Authority has to address itself the question as to whether temporary need exists or not. It is a jurisdictional fact, unlike in the case of S.87(1 )(d). But when an application for renewal is pending the pendency pre-supposes the coexistence of a temporary need and permanent need. Therefore, there is no question of the sister authorities assessing the need, thereby granting concurrence or countersignature. It is the duty of the Regional Transport Authority to see that renewal of application is heard and disposed of early. The issuance of temporary is necessitated because of the delay in considering the application for renewal. The delay on the part of the Regional Transport Authority shall not affect the requirement of the travelling public. If concurrence or counter signature for issuance of temporary permit, pending renewal of regular permit, is insisted, it will again delay the matter, thereby putting the travelling public to considerable inconvenience. All this would indicate that the Legislature never intended that Regional Transport Authority should obtain prior concurrence or countersignature for temporary permits on inter-district routes, pending renewal of regular permit applications. 11. The intention of the Legislature is to grant temporary permits pending renewal of regular permit applications so as to safeguard the interests of travelling public. All this would indicate that the Legislature never intended that Regional Transport Authority should obtain prior concurrence or countersignature for temporary permits on inter-district routes, pending renewal of regular permit applications. 11. The intention of the Legislature is to grant temporary permits pending renewal of regular permit applications so as to safeguard the interests of travelling public. In this connection, it is profitable to refer to S.214 of the Act, which enables the appellate authority to direct the operation of the vehicle in spite of the fact of expiration of the permit term specified in the permit. The intention is only to set that general public is not put to difficulties, because of the delay in getting countersignature or concurrence, till the matter is finally decided by the appellate authority. If for granting temporary permit, countersignature or concurrence is insisted upon pending renewal of regular permit applications, it would only delay the matter, and needs of the travelling public could not be met. We have to give a harmonious interpretation to the rules referred to hereinbefore, specially Ss. 87(1)(d), 88(1) and R. 170(d),of the Rules, so as to minimise the hardship to the public and to achieve the object of the Act. 12. Viewed in the above mentioned perspective, I am of the view, Regional Transport Authorities are not right in rejecting the applications submitted by the petitioners for temporary permits pending renewal of regular permit applications, for grant of countersignature or concurrence from the sister authorities. Therefore, prior concurrence or countersignature is nota condition precedent for granting temporary permit, pending renewal of regular permit applications. But once the concurrence or countersignature sought for with regard to regular permit is rejected, temporary permit would also cease to have any legal effect. Accordingly there will be a direction to the Regional Transport Authorities concerned to reconsider the applications submitted, by the petitioners for temporary permit in the light of the above findings at the earliest. Original Petitions are allowed as above. Orders passed by the Regional Transport Authorities rejecting the petitioners' applications stand quashed. When the judgment was delivered, counsel for the petitioners submitted that a direction be issued to the R.T.A. to consider the applications for temporary permit within a time limit. Original Petitions are allowed as above. Orders passed by the Regional Transport Authorities rejecting the petitioners' applications stand quashed. When the judgment was delivered, counsel for the petitioners submitted that a direction be issued to the R.T.A. to consider the applications for temporary permit within a time limit. Under such circumstances, there will be a direction to the R.T.A. to pass appropriate orders on the applications for temporary permit within a period of two weeks from the date of receipt of a copy of this judgment.