JUDGMENT : As the issues raised in these cases are the same, these writ petitions (Civil) are disposed of on the basis of this common judgment. For the sake of convenience, the sole petitioner in Writ Petition (Civil) No. 12906 of 2020, the sole petitioner in Writ Petition (Civil) No. 12926 of 2020 and the sole petitioner in Writ Petition (Civil) No. 12947 of 2020 is described hereinafter as 1st petitioner, 2nd petitioner and the 3rd petitioner, respectively. The case set up in Writ Petition (Civil) No. 12906 of 2020 is as follows : That the petitioner, who is the owner of an extent of 33 cents of land situated in RS No.114/11-4 of Amarambalam Village has beseeched this Court aggrieved by Ext.P7 proceedings of the 2nd respondent. By virtue of Ext.P2 order, the petitioner obtained necessary sanction for conversion in terms of Section 27A(2) of Act 29 of 2018. Subsequent thereto, the petitioner remitted the necessary fees as prescribed. Thereafter, Ext.P2 order happened to be revoked by the 2nd respondent as per Ext.P3 invoking Section 27A(11) of the Act relying on Ext.P4 report of the Tahsildar. Ext.P4 report was to the effect that the 5th respondent had allegedly deposited some soil in the property and therefore has violated the conditions in Ext.P2. However, a blanket revocation order was passed in respect of the properties belonging to the petitioner, the 5th respondent and also the brother of the 5th respondent who all had been the beneficiaries of Ext.P2 proceedings. Taking note of this anomaly in Ext.P3 and also taking cognizance of Ext.P1 report of the Village Officer which led to the passing of Ext.P2, this Court passed Ext.P5 judgment setting aside Ext.P3 revocation order. Now by virtue of Ext.P7, again the very same perverse order passed by virtue of Ext.P3 order has been reiterated. Quite surprisingly, the 2nd respondent presiding in her capacity as Chairperson of the District Level Authorized Committee and undersigning as the Sub Collector/RDO seemingly in compliance of Ext.P5 judgment passed the impugned Ext.P7 order setting aside Ext.P2. As a matter of fact, the District Level Authorized Committee has no jurisdiction whatsoever to consider the issue going by the scheme of Act 29. This court has not issued any direction to the said authority. As a matter of fact, the District Level Authorized Committee has no jurisdiction whatsoever to consider the issue going by the scheme of Act 29. This court has not issued any direction to the said authority. That apart, when in Ext.P2 conversion order, there is a categorical finding that the property is an unnotified land and there is no embargo for granting an order of conversion in terms of Section 27A(2) of Act 29. Therefore, Ext.P7 would operate as an estoppel against the 2nd respondent from taking a diametrically opposite stand in Ext.P7, reiterating Ext.P3, which already stood set aside by virtue of Ext.P5 judgment. So much so, the orders passed as per Ext.P3 and Ext.P4 only gives an impression that merely because the formalities pertaining to change in revenue records are yet to follow through, the absence of the same will cause hindrance to 'free flow of water' and therefore the petitioner violated the conversion order. The 2nd respondent seems to be ignorant about the basic principles governing the conversion under the Kerala Land Utilization Order or under Section 27A(2) of the Kerala Conservation of Paddy Land and Wet Land Act, 2008 and the consequent change of assessment in the Basic Tax Register under the provisions of the Kerala Land Tax Act, 1961. That apart, the erroneous assumption of facts resulting in Ext.P7 proceedings has effected valuable rights of the petitioner, who has been literally taken for a ride. It is nothing short of a colourable exercise of powers conferred under the Act and the same is a clear infringement of Article 300A of the Constitution of India. It is in the light of these averments and contentions, the petitioner has filed Writ Petition (Civil) No. 12906 of 2020 with the following prayers : “(i). To issue a writ of certiorari or any other appropriate writ calling for the records leading to Ext.P7 and quash the original of the same in so far as it relates to the petitioner's property situated in Survey No.114/11-4 and Block 121 of Amarambalam Village (ii). Issue a writ of mandamus or any other appropriate writ, order or direction to the respondents 2 to 4 not to initiate any coercive steps in furtherance of Ext.P7 pending disposal of this writ petition. (iii). Issue a writ of mandamus or any other appropriate writ, order or direction to the respondents 2 to 4 not to initiate any coercive steps in furtherance of Ext.P7 pending disposal of this writ petition. (iii). Declare that Ext.P7 proceedings of the 2nd respondent revoking Ext.P2 orders in respect of the petitioner's property situated in Survey No.114/11-4 and Block 121 of Amarambalam Village is bad in law and opposed to the scheme of the KLUO 1967 (iv). Grant such other reliefs which this Honourable court may deem fit and proper in the circumstances of this case, including the cost of these proceedings.” The case set up in Writ Petition (Civil) No. 12926 of 2020 is as follows : That the petitioner who is the owner of an extent of 18 cents of land situated in RS No.114/11-3 of Amarambalam Village, has beseeched this Court aggrieved by Ext.P7 proceedings of the 2nd respondent. By virtue of Ext.P2 order, the petitioner obtained necessary sanction for conversion in terms of Section 27A(2) of Act 29 of 2018. Subsequent thereto, the petitioner remitted the necessary fees as prescribed. Thereafter, Ext.P2 order happened to be revoked by the 2nd respondent invoking Section 27A(11) of the Act relying on Ext.P4 report of the Tahsildar. Ext.P4 report was to the effect that the 5th respondent had allegedly deposited some soil in the property and therefore has violated the conditions in Ext.P2. However, a blanket revocation order was passed in respect of the properties belonging to the petitioner, the 5th respondent and also the brother of the 5th respondent, who all had been the beneficiaries of Ext.P2 proceedings. Taking note of this anomaly in Ext.P3, and also taking cognizance of Ext.P1 report of the Village Officer which led to the passing of Ext.P2, this Court passed Ext.P5 judgment setting aside Ext.P3 revocation order. Now by virtue of Ext.P7, again the very same perverse order passed by virtue of Ext.P3 order has been reiterated. Quite surprisingly, the 2nd respondent presiding in her capacity as Chairperson of the District Level Authorized Committee and undersigning as the Sub Collector/RDO seemingly in compliance of Ext.P5 judgment passed the impugned Ext.P7 order setting aside Ext.P2. As a matter of fact, the District Level Authorized Committee has no jurisdiction whatsoever to consider the issue going by the scheme of Act 29. This court has not issued any direction to the said authority. As a matter of fact, the District Level Authorized Committee has no jurisdiction whatsoever to consider the issue going by the scheme of Act 29. This court has not issued any direction to the said authority. That apart, when in Ext.P2 conversion order, there is a categorical finding that the property is an unnotified land and there is no embargo for granting an order of conversion in terms of Section 27A(2) of Act 29. Therefore, Ext.P7 would operate as an estoppel against the 2nd respondent from taking diametrically opposite stand in Ext.P7 reiterating Ext.P3 which already stood set aside by virtue of Ext.P5 judgment. So much so, the orders passed as per Ext.P3 and Ext.P4 only gives an impression that merely because the formalities pertaining to change in revenue records are yet to follow through, the absence of the same will cause hindrance to 'free flow of water' and therefore the petitioner violated the conversion order. The 2nd respondent seems to be ignorant about the basic principles governing the conversion under the Kerala Land Utilization Order or under Section 27A(2) of the Kerala Conservation of Paddy Land and Wet Land Act, 2008 and the consequent change of assessment in the Basic Tax Register under the provisions of the Kerala Land Tax Act, 1961. That apart, the erroneous assumption of facts resulting in Ext.P7 proceedings has effected valuable rights of the petitioner, who has been literally taken for a ride. It is nothing short of a colourable exercise of powers conferred under the Act and the same is a clear infringement of Article 300A of the Constitution of India. It is in the light of these averments and contentions that the petitioner has filed Writ Petition (Civil) No. 12926 of 2020 with the following prayers : “(i). To issue a writ of certiorari or any other appropriate writ calling for the records leading to Ext.P7 and quash the original of the same in so far as it relates to the petitioner's property situated in Survey No.114/11-3 and Block 121 of Amarambalam Village (ii). Issue a writ of mandamus or any other appropriate writ, order or direction to the respondents 2 to 4 not to initiate any coercive steps in furtherance of Ext.P7 pending disposal of this writ petition. (iii). Issue a writ of mandamus or any other appropriate writ, order or direction to the respondents 2 to 4 not to initiate any coercive steps in furtherance of Ext.P7 pending disposal of this writ petition. (iii). Declare that Ext.P7 proceedings of the 2nd respondent revoking Ext.P2 orders in respect of the petitioner's property situated in Survey No.114/11-3 and Block 121 of Amarambalam Village is bad in law and opposed to the scheme of the KLUO 1967 (iv). Grant such other reliefs which this Honourable court may deem fit and proper in the circumstances of this case, including the cost of these proceedings.” The case set up in Writ Petition (Civil) No. 12947 of 2020 is as follows: The petitioner herein is aggrieved by Exhibit P6 order passed by the 2nd respondent/RDO, whereby P2 conversion order granted in terms of Section 27A(2) of Act 29 of 2018 was cancelled by invoking Section 27A(11). The petitioner is the owner of an extent of 18 cents of land situated in Resurvey No.114/11-2 of Amarambalam Village and he preferred an application seeking conversion of his property. As per Exhibit P2 proceedings, the 2nd respondent/RDO granted sanction for conversion for putting up a commercial building subject to conditions. In Exhibit P2, there is a clear finding that the conversion will not affect any cultivation or free flow of water. Thereafter, the 2nd respondent/RDO passed Exhibit P3 cancellation order by invoking Section 27A(11) of Act 29 of 2018 on the basis of Exhibit P4 report which alleges that the petitioner deposited some earth in his property pursuant to Exhibit P2 conversion order, and has thereby violated conditions in Exhibit P2 conversion order. As a matter of even assuming that the said allegation is true, the same is not a violation of the conversion order in the eye of law as Section 27C(2) clearly provides that the reassessment would follow the the conversion of land. In the present case the allegation is only putting of earth by the petitioner and not even a whisper as regards any specific violation or infraction of any of the conditions in Exhibit P2 conversion order. Thus, the 2nd respondent passed Exhibit P3 order cancelling the previous order granting sanction for conversion. On a mistaken notion, the petitioner preferred an appeal and no order whatsoever has been passed thereon. Thus, the 2nd respondent passed Exhibit P3 order cancelling the previous order granting sanction for conversion. On a mistaken notion, the petitioner preferred an appeal and no order whatsoever has been passed thereon. As a matter of fact, no appeal is provided in the statute as against a cancellation order passed under Section 27A(11) and Section 27B which provides for an appeal before the District Collector, deals only with an order of the RDO under Section 27A(2) alone. However, the 5th and 6th respondents herein who also suffered similar cancellation orders akin to Exhibit P3 order, approached before this Court and the same resulted in Exhibit P5 common judgment. Therefore, in Exhibit P5 judgment, the impugned orders passed akin to Exhibit P3 in those cases were set aside by this Court as against the petitioners therein alone, and the 2nd respondent was directed to reconsider the same. Now, Exhibit P6 order (common order against all three persons including the petitioners is passed on the same lines as Exhibit P3) is passed taking a roundabout from the categorical findings of facts in Exhibit P2 conversion order and on perusal of Exhibit P6, it seems as if the alleged putting of earth is a violation of conditions in Exhibit P2 order and due to such act, suddenly the same affects nearby cultivation and free flow of water etc. Presently, there are two cancellation orders pertaining to the very property of the petitioner, one passed earlier as Exhibit P3 and now Exhibit P6 which is after Exhibit P5 judgment. Exhibits P3 and P6 are nothing but absolutely illegal and manifestly arbitrary and passed without any application of mind. The same is a clear infringement of Article 300A of the Constitution of India. It is in the light of these averments and contentions that the petitioner has filed Writ Petition (Civil) No. 12947 of 2020 with the following prayers : “(i). To issue a writ of certiorari or any other appropriate writ calling for the records leading to Exhibits P3 and P6 and quash the original of the same in so far as it relates to the petitioner's property situated in Survey No.114/11-2 and Block 121 of Amarambalam Village (ii). To issue a writ of certiorari or any other appropriate writ calling for the records leading to Exhibits P3 and P6 and quash the original of the same in so far as it relates to the petitioner's property situated in Survey No.114/11-2 and Block 121 of Amarambalam Village (ii). To declare that Exhibits P3 and P6 proceedings of the 2nd respondent revoking Ext.P2 order in respect of the petitioner's property situated in Survey No.114/11-2 and Block 121 of Amarambalam Village is bad in the eye of law (iii) to issue such other writ, order or direction which this Honourable court may deem fit and proper in the circumstances of this case.” 2. Heard Sri.K.Shibili Naha, learned counsel appearing for the petitioners in Writ Petition (Civil)No. 12906 of 2020 and Writ Petition (Civil)No.12926 of 2020, Sri.V.V.H.Gokul Das, learned counsel appearing for the petitioner in Writ Petition (Civil)No.12947 of 2020, Sri.K.J.Manu Raj, learned Government Pleader appearing for the respondent in Writ Petition (Civil)No.12947 of 2020, and Sri.Saigi Jacob Palatty, learned Senior Government Pleader appearing for respondents in Writ Petition (Civil)Nos. 12906 of 2020 and Writ Petition (Civil)No.12926 of 2020. 3. The factual aspects in these three cases are broadly similar. Ext.P3 issued in Writ Petition (Civil)Nos. 12906 of 2020 and Writ Petition (Civil)No.12926 of 2020 has already been interdicted by this Court in Ext.P5 common judgment produced in these three cases, whereas challenge in Writ Petition (Civil)Nos. 12906 of 2020 and Writ Petition (Civil)No.12926 of 2020 is solely directed against the impugned Ext.P7 proceedings subsequently passed by the 2nd respondent-Sub Collector consequent to the remit made in the said judgment. Whereas the petitioner in Writ Petition(Civil)No.12947 of 2020 had not separately challenged Ext.P3 therein (which is similar to Ext.P3 in the first two cases), as the matter was already remitted by this Court pursuant to the abovesaid Ext.P5 common judgment in the first two cases, and therefore challenge in the third case is directed both as against Ext.P3 therein as well as Ext.P6 therein, which is broadly similar to the impugned Ext.P7 judgment in the first two cases. 4. 4. The case of the petitioners herein is that, they separately own and possess the property to the extent of 13.34 Ares (33 cents), 7.28 Ares and 7.28 Ares respectively and the said properties though contiguously lying as nilam/paddy land in the Basic Tax Register, have been converted as garden land/purayidam much prior to 12.08.2008 (coming into force of Kerala Conservation of Paddy Land and Wet Land Act, 2008). Further that these three properties have not been included in the Land Data Bank prepared as per the provisions of the 2008 Act and that there are no neighbouring paddy lands in the vicinity, where paddy cultivation is being undertaken. Thereupon, the petitioners have submitted separate applications before the 2nd respondent-RDO/Sub Collector in Form No.6 seeking for statutory permission for change of user of land as conceived under Section 27A(1) of the 2008 Act. As per the procedural norms, the 2nd respondent has secured report in the matter from the 4th respondent-Village Officer (referred to as Item No.3 in Ext.P2) wherein, it was found that the subject properties are have been included in the Land Data Bank and there are no paddy lands anywhere in the locality and that there are no water log lands also in the nearby vicinity, and that the conversion sought by the petitioners will not in any manner detrimentally affect the free flow of water in the neighbouring lands etc. After hearing the petitioners, the 2nd respondent-RDO/Sub Collector has passed a considered order as per Ext.P2 dated 20.03.2019, in each of these three cases granting statutory permission to each of them for change of user of the land as conceived in Section 27A(1), and consequently, the petitioners have paid requisite prescribed fees as envisaged in Section 27A(3) Rule12(9) of the Rules, which is at the prescribed rate based on fair value of the subject properties, as notified under Section 28A of the Kerala Stamp Act. Ext.P2 produced separately in these three cases are identically worded. Ext.P2 in Writ Petition (Civil)No.12947 of 2020, reads as follows:- xxx xxx xxx 5. Page No.2 of Ext.P2 contains the various conditions attached to the said order. Ext.P2 produced separately in these three cases are identically worded. Ext.P2 in Writ Petition (Civil)No.12947 of 2020, reads as follows:- xxx xxx xxx 5. Page No.2 of Ext.P2 contains the various conditions attached to the said order. Thereafter, it appears that, the 2nd respondent-RDO/Sub Collector has issued notice to the petitioners on the ground that complaints have been received that the 3rd petitioner has put some soil in his land and that it would amount to violating the conditions of Ext.P2, inasmuch as it would impede the free flow of water etc. It appears that inspection has been conducted by the 3rd respondent-Tahsildar, which is referred to as item No.2 of Ext.P3, and the said inspection has been carried out without notice to the petitioners. Even a copy of the said inspection report has also not been given to the petitioners. The petitioners have secured a copy of the said report dated 12.6.2019 referred to as item No.2 of Ext.P3 under RTI proceedings subsequently to the issuance of Ext.P3, and copy of the said report of the Tahsildar is marked as Ext.P4. By Ext.P3 order dated 22.06.2019, the 2nd respondent/RDO has found that the act of the 3rd petitioner in putting soil/ordinary earth in his property after the issuance of Ext.P2 would amount to violation of the conditions of Ext.P2 order, inasmuch as it would impede the free flow of water etc. On this basis the nd respondent has passed Ext.P3 common order in these three cases on 22.06.2019 purportedly under Section 27A(11), whereby Ext.P2 order has been cancelled on the ground that the conditions of Ext.P2 have been violated. The first two petitioners challenged Ext.P3 before this Court by filing WP(C)Nos.21347 of 2019 and 21350 of 2019, which this Court has disposed of as per Ext.P5 judgment dated 15.10.2019. According to the petitioners, without even affording any reasonable opportunity of being heard to the petitioners, the 2nd respondent has later passed the impugned Ext.P3 common order dated 22.6.2019. This Court held in Ext.P5 judgment that the impugned action of the 2nd respondent in passing an adverse order, Ext.P3, without affording a reasonable opportunity of being heard to the petitioners is illegal and unlawful, and that the matter has to be remitted to the 2nd respondent for consideration and decision afresh. This Court held in Ext.P5 judgment that the impugned action of the 2nd respondent in passing an adverse order, Ext.P3, without affording a reasonable opportunity of being heard to the petitioners is illegal and unlawful, and that the matter has to be remitted to the 2nd respondent for consideration and decision afresh. According to the 3rd petitioner, in view of the above said remit made as per Ext.P5 common judgment by this Court, he had not separately challenged Ext.P3 order. Thereafter, the petitioners were afforded reasonable opportunity of being heard and the 2nd respondent has again passed an order in the nature of the impugned common order dated 27.02.2020 (produced as Ext.P7 in the first two cases and Ext.P6 in the third case), whereby it has been held that Ext.P2 order will stand cancelled purportedly under Section 27A(11) of the Act, as the petitioners have violated the conditions of the order. The petitioners would point out that it is only after being served with the impugned Ext.P7/Ext.P6 orders respectively, that they came to know that the same has been rendered after conducting some inspection by the Agricultural officer concerned, and the Senior Superintendent of the office of the 2nd respondent and such inspection has been conducted without any prior notice to the petitioners. The copies of such inspection report referred to as item No.5 and 6 of Ext.P7/Ext.P6 have also not been furnished to the petitioners. 6. After hearing both sides, it is found that Ext.P4 is a prior report of the 3rd respondent-Tahsildar, which led to the passing of Ext.P3 order. The main allegation in Ext.P3 is that, the 3rd petitioner has put ordinary earth/soil in his land, which has affected the free flow of water. Presumably on the ground that all the three properties are contiguous, an allegation is also made in Ext.P4, that as a matter of fact the properties should not have been excluded from the Land data Bank and that the same has to be included in Land Data Bank and also that, if the property is converted, it will detrimentally affect the free flow of water to the neighbouring lands etc. Though the 3rd respondent-Tahsildar has stated in Ext.P4 report that the subject property should not have been excluded from the Land Data Bank etc., and that the conversion order would lead to impeding the free flow of water etc., those aspects are not even taken cognizance of by the 2nd respondent in Ext.P3. However, in impugned Ext.P7 in the first two cases and Ext.P6 in the third case, the 2nd respondent -RDO would place reliance not only on the version that the act of the 3rd petitioner in putting ordinary earth/soil in his land would amount to all the three petitioners violating the terms and conditions of Ext.P2 order, inasmuch as it would lead to impeding the free flow of water etc. She has also further held that the subject properties covered by Ext.P2 in these three cases should not have been excluded from the Land Data Bank and that the conversion order would lead to impeding the free flow of water etc. and therefore, Ext.P2 order is liable to be cancelled purportedly under Section 27A(11). At the outset it has to be held that both Ext.P3 and impugned Ext.P6/P7 as the case may be, are liable for interdiction solely on the ground of flagrant violation of principles of natural justice. In the case of Ext.P3, the same has been rendered even without even affording any reasonable opportunity of being heard to the petitioners. Moreover, Ext.P3 order has been passed mainly placing reliance on Ext.P4 report of the Tahsildar and the inspection, which led to Ext.P4, has been conducted behind the back of the petitioners and even copies of the inspection reports as per Ext.P4 have not been given any of the petitioners prior to the rendering of Ext.P3 common order. So also, a reading of the impugned Ext.P6/P7 as the case may be, would also conclusively show that the same has been rendered mainly placing reliance on two other inspection reports one of the agricultural officer concerned and another of the Senior Superintendent of the office of the 2nd respondent. Such inspections have been conducted behind the back of the petitioners and even copies of those two reports have not been given to the petitioners. Such inspections have been conducted behind the back of the petitioners and even copies of those two reports have not been given to the petitioners. Therefore, it is now well settled that where the decision making authority and the enquiring authority are two distinct persons and the decision maker places reliance on any adverse report given by the enquiry officer, then certainly the party who is to be so adversely affected, should be notified of such proceedings and copy of the enquiry report/inspection report shall also be given to the party/parties prior to the rendering of the decision by the decision maker. Therefore, it is only to be held that Ext.P3 common order as well as Ext.P7 in the first two cases and Ext.P6 in the third case, are liable for interdiction in this judicial review proceedings solely on account of blatant violation of the principles of natural justice and fairness. As a matter of fact Ext.P3 has already been interdicted by the motion of the first two petitioners, as can be seen from Ext.P5 common judgment. 7. That apart, it is profitable to refer to the provisions in Section 27A and its various sub-sections as well as Sections, 27A, 27B and 28 of the Kerala Conservation of Paddy Land and Wetland Act, 2008, which provide as follows: “27A. Change of nature of unnotified land.-(1) If any owner of an unnotified land desires to utilise such land for residential or commercial or for other purpose, he shall apply to the Revenue Divisional Officer for permission in such manner as may be prescribed. (2) Notwithstanding anything contained in any judgment, decree or order of any court or Tribunal or any other authority, the Revenue Divisional Officer may, after considering the reports of the Village Officer concerned, pass such orders as deemed fit and proper on such applications, ensuring that there is no disruption to the free flow of water to the neighbouring paddy lands, if any, through such water conservancy measures as is deemed necessary: Provided that, if the area of such parcel of land where the application is allowed is more than 20.2 Ares, ten per cent of such land shall be set apart for water conservancy measures. (3) If the application is allowed, the applicant shall be liable to pay a fee at such rate as may prescribed: Provided that, no such fee shall be collected if the applicant proves that the land where the application is allowed is, filled up or naturally filled up before the 4th day of July, 1967, the date of commencement of the Kerala Land Utilisation Order, 1967, after completing such procedure, as may be prescribed. (4) If the application is allowed, the Revenue Divisional Officer shall ensure that the reclamation of the unnotified land shall not adversely affect the cultivation of paddy or any other crops, if any, in the adjoining land and shall specify such water conservancy measures as its necessary to ensure such cultivation. Provided that in specifying such water conservancy measures, the Revenue Divisional Officer may, if he deems fit, refer to satellite maps of the area maintained by Government agencies. (5) No permission under this section shall be necessary where the purpose for which the unnotified land is converted or attempted to be converted or utilized or attempted to be utilized is for paddy cultivation (6) Notwithstanding anything contained in the Kerala Panchayat Raj Act, 1994 (13 of 1994) or in the Kerala Municipality Act, 1994 (20 of 1994), no permission under this section shall be necessary for constructing a residential building having a maximum area of 120 square meters in a maximum extent of 4.04 ares of land or a commercial building having a maximum area of 40 square meters in a maximum extent of 2.02 ares of land: Provided that the construction of a housing complex or complexes, or flats or multistoried residential complexes shall not come within the meaning of residential building specified in this subsection. Provided further that this exemption shall be granted only once. (7) The exemption under sub-section (6) shall be applicable only to owners of unnotified lands under the Kerala Conservation of Paddy Land and Wetland (Amendment) Act, 2018. Provided that if the area of the residential building or commercial building exempted under sub-section (6) is subsequently increased by new extension, the exemption under sub-section (6) shall cease to have effect and the owner of the land as on the date of detection of the new extension shall be liable to pay fee as per sub-section(3). Provided that if the area of the residential building or commercial building exempted under sub-section (6) is subsequently increased by new extension, the exemption under sub-section (6) shall cease to have effect and the owner of the land as on the date of detection of the new extension shall be liable to pay fee as per sub-section(3). (8) Where conversion of an unnotified land is required for any public purpose, the Revenue Divisional Officer shall submit a report to Government outlining the measures to be adopted to ensure that the reclamation shall not disrupt the free flow of water to the neighbouring paddy lands, if any, and shall suggest such water conservancy measures as is necessary to ensure this. (9) The Government may, on receipt of a report under sub-section (8), issue permission to reclaim unnotified land for public purpose: Provided that where permission is granted, the Government may make necessary modifications to the recommendations of the Revenue Divisional Officer as deemed fit: Provided further that, if the area of such parcel of land where the application is allowed is more than 20.2 Ares, ten per cent of such land shall be set apart for water conservancy measures. (10) The order issued under sub-section(2) and (9) shall clearly indicate the survey number of the lands and the extent of the land in each survey number for which sanction has been accorded, the extent of the land in which water conservancy measures are to be adopted by the applicant and a sketch of such land indicating the aforementioned details shall be appended to the order. (11) The Revenue Divisional Officer may, either suo motu or on the application of any aggrieved party, cancel any order issued under sub-section(2) if the conditions specified in the order issued therein are not complied by the applicant, either fully or partially. (12) No order of cancellation under sub-section(11) shall be made by the Revenue Divisional Officer unless the applicant thereof has been given an opportunity of being heard in the matter. (13) Any application received for the change of nature of unnotified land from the date of commencement of the Kerala Conservation of Paddy Land and Wetland (Amendment) Act, 2018 shall be considered and disposed of only in accordance with the provisions of the Act. (13) Any application received for the change of nature of unnotified land from the date of commencement of the Kerala Conservation of Paddy Land and Wetland (Amendment) Act, 2018 shall be considered and disposed of only in accordance with the provisions of the Act. 27B.Appeal.-(1) Any person aggrieved by an order of the Revenue Divisional Officer under sub-section (2) of Section 27A may prefer an appeal to the District Collector within thirty days from the date of receipt of the order. (2) Every appeal preferred under sub-section (1) shall be accompanied by a certified copy of the order appealed against and an appeal fee of rupees five hundred (3) The District Collector may, after giving an opportunity to the appellant to be heard, dispose of the appeal as expeditiously as possible (4) The order in appeal shall be final and shall not be challenged in any Civil Court. xxxxxxxx 28. Revision.-The Government may either suo motu or on application from any aggrieved party call for the records of any act or proceedings of the Collector in any case under this Act, and pass such orders thereon, as it may deem fit.” 8. A reading of sub-sections (1), (2) and (4) of Section 27A would make it clear that it is a bounden statutory duty of the 2nd respondent-RDO to consider and be satisfied that there would be no disruption to the free flow of water to the neighbouring lands, if any, through such water conservancy measures as is deemed necessary, while considering the issue of passing orders on the plea for conversion orders. Sub-section(4) Section 27A would also mandate that the RDO has to ensure that the application under Section 27A alone is allowed, then the reclamation of the unnotified land/subject property shall not adversely affect the cultivation of paddy or any other crops in the adjoining lands etc. Therefore, it is only after being satisfied about these crucial aspects and parameters that the 2nd respondent could have passed the order as per, Ext.P2. Therefore, it is only after being satisfied about these crucial aspects and parameters that the 2nd respondent could have passed the order as per, Ext.P2. A reading of Ext.P2 would make it clear that the officer has followed the statutory procedure and also obtained a report from the Village Officer concerned as is the consistent procedural norms, who has made site inspection and clearly reported that there are no adjoining paddy lands in the locality and that the subject properties have been converted prior to the 2008 Act and that the subject properties have not been included in the Land Data bank, and further that if the conversion is permitted, it will not in any manner affect the free flow of water to the neighbouring paddy lands etc. It is based on these conclusive fact findings in the said inspection that the 2nd respondent-RDO has exercised statutory discretion and passed orders granting permission to each of these petitioners as per Ext.P2. Consequently, the petitioners have paid the requisite high amounts as demanded as per amended Rules of the 2008 Act. Sub-section (11) of Section 27A would empower the RDO to either suo motu or on an application of any aggrieved party, cancel the order of permission granted under sub-section (2) if the conditions specified in the said order issued therein are not complied with by the applicant concerned, either fully or partially. The said power under Section 27A(11) is extremely limited in nature and the same can be exercised either suo motu or on an application of any aggrieved party by the RDO, only if the officer is satisfied that the conditions in the order passed under Section 27A(2) have not been complied with by the party concerned either fully or partially. The power under Section 27A(11) cannot be invoked on the ground that the discretion under that conversion order as per Section 27A(2) was previously issued by exercising the discretion wrongly and that the subject property should have been included in the Land Data Bank as paddy land and that the conversion order would lead to impeding the free flow of water into the neighbouring paddy lands etc. Those are all matters on the merits of the matter and those matters cannot be relevant or germane while exercising the limited power under Section 27A(11), after order has been passed under Section 27A(2) by exercising discretion thereof. Those are all matters on the merits of the matter and those matters cannot be relevant or germane while exercising the limited power under Section 27A(11), after order has been passed under Section 27A(2) by exercising discretion thereof. Therefore, the main ground in Ext.P7 that the subject property should not have been excluded from the land data bank and that it should have been actually included in the land data bank and that the conversion order if given, would lead to impeding the free flow of water etc, are not relevant or germane at the stage of Section 27A(11). Once an order under Section 27A(2) is passed, then any aggrieved person can file a statutory appeal to challenge such an order of conversion before the District Collector concerned in terms of Section 27B of the Act and that too, within a period of thirty days, etc. The appellate jurisdiction that is available under Section 27B to the District Collector concerned cannot be invoked by the 2nd respondent-Revenue Divisional Officer, after having passed an order in the nature of Ext.P2 by purportedly taking resort to Section 27A(11). Such an exercise of power under Section 27A(11) is totally impermissible and is without jurisdiction and the legal position in that regard is accordingly ordered and declared. The only ground on the basis of which an order in the nature of Section 27A(11) can be passed so as to cancel the conversion order granted under Section 27A(2) is that the applicant concerned has not complied with the conditions attached to conversion order as per Section 27A(2) either fully or partially. From a reading of Section 27A, it can be seen that the conditions in relation to water conservancy measures etc., as conceived in Section 27A (2) and its proviso could be pressed into service only if the total extent of the subject property, for which conversion order, is sought, is more than 20.2 Ares, in which case ten percent of such land shall be set apart for water conservancy measures. Therefore, the issues of water conservancy, as conceived in Section 27A may not be germane in this case, for the simple reason that, what is involved is 3 separate properties of three separate petitioners and each of the said properties covered by Ext.P2 order is much less than the threshold limit of 20.2 Ares. Therefore, the issues of water conservancy, as conceived in Section 27A may not be germane in this case, for the simple reason that, what is involved is 3 separate properties of three separate petitioners and each of the said properties covered by Ext.P2 order is much less than the threshold limit of 20.2 Ares. Then what remains is as to whether the petitioners have violated the conditions of Ext.P2 order, passed under Section 27A(2). The said conditions are given in page No.2 of Ext.P2. At the outset it has to be noted that the allegation is that 3rd petitioner has unloaded some ordinary earth/soil in his property and therefore, it would impede the free flow of water and therefore, all the three petitioners have violated the conditions of Ext.P2 etc., cannot be pressed into service as against the first and second petitioners. This is for the simple reason that the allegation is mainly directed as against the 3rd petitioner. That apart, the main ground for justifying such an allegation is that the said act of the 3rd petitioner in having unloaded ordinary earth/soil in his property after the issuance of Ext.P2 has been done before getting the Basic Tax Register corrected and altered as envisaged under Section 27C of 2008 Act r/w Section 6A of the Kerala Land Tax Act, 1961. At the outset it has been held that immediately after the party concerned gets statutory order of permission under Section 27A(2), then he is lawfully permitted to deal with the property for effecting the conversion. The mere act of unloading ordinary earth/soil in the property of the 3rd petitioner cannot be an unlawful act, merely because he has done it after Ext.P2 order but before getting BTR corrected. The action in getting the BTR corrected is only a clerical formality. Immediately after securing the statutory order of permission in terms of Section 27A(2), the party is lawfully permitted to effectuate the conversion, provided that the conditions in the Act and the conditions in the grant are not otherwise violated. The action in getting the BTR corrected is only a clerical formality. Immediately after securing the statutory order of permission in terms of Section 27A(2), the party is lawfully permitted to effectuate the conversion, provided that the conditions in the Act and the conditions in the grant are not otherwise violated. In a case where the subject property is exceeding 20.2 Ares and there are directions for water conservancy measures by setting apart of ten percent of the said property and if the act of filling up of the remaining property would lead to impeding the free flow of water to the ten percent of the property which is set apart for land conservancy measures etc., as per Section 27A(2) proviso etc., then those aspects could possibly be relevant grounds for consideration for action under Section 27A(11). Such a scenario does not come into play in this case for the simple reason that the extent of each of the three separate properties is below the threshold limit of 20.2 Ares, as envisaged in proviso to Section 27A(2). Therefore, the abovesaid allegation against the 3rd petitioner in having allegedly unloaded ordinary earth/soil in his property after the issuance of Ext.P2 order and before getting the BTR altered/corrected etc., by itself cannot be a relevant ground for action under Section 27A(11). That apart, the reading of sub-section(2) of Section 27C would indicate that where the paddy land or unnotified land is duly converted as per the provisions of the abovesaid Act, then it is the bounden duty of the Tahsildar to asses the land tax under Section 6A of the Kerala Land Tax Act, 1961 and make necessary entries in the revenue records relating to such lands. Therefore, sub-section (2) would mandate that after due conversion of the property as per the provisions of the 2008 Act, it is the bounden duty of the Tahsildar to re-assess the land tax under Section 6A of the Kerala Land Tax Act, 1961. Therefore, the mere omission of the petitioners in not having filed formal application before the Tahsildar for getting the BTR entries altered, cannot be used as against them. Therefore, the mere omission of the petitioners in not having filed formal application before the Tahsildar for getting the BTR entries altered, cannot be used as against them. Once the substantive permission is obtained in terms of Section 27A(2) for conversion of the property, then the incidental procedure of effectuating such conversion are also part and parcel of such rights and incidents flowing out from such conversion order in the nature of Ext.P2 passed under Section 27A(2). 9. A reading of the conditions given on page 2 of Ext.P2 would indicate that allegations raised in Ext.P6/P7 as the case may be, will not disclose any violation of any one of the abovesaid conditions. Further, it can be seen that from a reading of Ext.P6/P7 that the said impugned proceedings has been initiated and finalised not by the 2nd respondent/Revenue Divisional Officer, but by the Chairman of the District Level Authorised Committee. The powers under Section 27A(2) as well as 27A(11) can be exercised only by the Revenue Divisional Officer concerned. The District Level Authorized Committee is conceived in Section 9 of the Act 2008. A reading of Section 9 would indicate that the said Committee will consist of Revenue Divisional Officer and Principal Agricultural Officer and three paddy cultivators to be nominated by the District Collector and the RDO shall be its Chairman and the Principal Agricultural Officer shall be its Convenor and where there are more than one Revenue Divisional Officer in a District, then the Collector shall nominate one among them to the District Level Authorised Committee. May be so that the officer holding the post of 2nd respondent-Revenue Divisional Officer may also be nominated by the District Collector as the Chairman of the District Level Authorized Committee., but the powers and functions of the District Level Authorised Committee are different and distinct compared to the powers and duties associated with Section 27A more particularly, sub-section (2) and (11) thereof. No power is conferred anywhere in the Act to the Chairman of the District Level Authorized Committee to unilaterally take any action. Moreover, the duties and functions of the District Level Authorized Committee are mainly in the matter of granting permission for reclamation of paddy land for construction of residential building to the owner of the paddy land etc. No power is conferred anywhere in the Act to the Chairman of the District Level Authorized Committee to unilaterally take any action. Moreover, the duties and functions of the District Level Authorized Committee are mainly in the matter of granting permission for reclamation of paddy land for construction of residential building to the owner of the paddy land etc. and that presupposes that the subject property should fulfill the definition of 'paddy land' as per Section 2(xii) of the Act as on 12.08.2008 (date of coming into force of the Kerala Conservation of Paddy Land and Wet Land Act,2008), whereas , Section 27A would deal with the unnotified land in cases where subject properties which were earlier paddy land had been duly converted prior to 12.08.2008 or not included in the Land Data Bank etc. Therefore, it is not known as to for what reasons the impugned Ext.P6/P7 has been rendered by the Chairman of the District Level Authorised Committee. Such a procedure is totally impermissible as per the provisions of the abovesaid Act. Very strangely, there is yet another direction in Ext.P6/P7 that the Local Level Monitoring Committee should immediately take action to include the subject property covered by Ext.P2 in the Land Data Bank. Such a procedure is absolutely unheard of and is totally beyond the scope and ambit of the provisions of the Act. Once discretion is exercised under Section 27A(2) and order Ext.P2 is passed, then an order under Section 27A(11) cannot be passed by citing the grounds mentioned in the impugned proceedings. Any such aspects on the merits of the matter regarding the exercise of discretion under which it led to the passing of Ext.P2 order, cannot be considered under Section 27A(11) and all such matters may fall within the provisions of appellate jurisdiction before the District Collector under Section 27B of the Act. For that purpose the aggrieved party concerned will have to file statutory appeal under Section 27B before the District Collector within the time limit. It appears that there is no power conferred for condoning delay in filing the appeal. As against any decision taken by the District Collector, the same would be challenged by taking resort to the revisional remedy under Section 29 of the Act before the Government, who may exercise the power either suo moto or an application by an aggrieved party concerned. As against any decision taken by the District Collector, the same would be challenged by taking resort to the revisional remedy under Section 29 of the Act before the Government, who may exercise the power either suo moto or an application by an aggrieved party concerned. But, the said power of revision can be directed only as against the considered decision of the District Collector concerned. 10. Further the respondents have also raised a contention that since the impugned orders herein are passed under Section 27A(11), the petitioners have an alternative efficacious statutory remedy by filing appeal under Section 27B before the District Collector. After hearing both sides, it is to be noted that the appeal remedy as per Section 27B(1) can be invoked before the District Collector only for the limited purpose of impugning order passed under Section 27A(2), going by the specific provision in Section 27B(1). So also, the revisional remedy under Section 28 can be pursued before the State Government, only to challenge a considered decision of the District Collector and not a decision rendered by the RDO. Hence, the petitioners cannot challenge the present impugned order passed under Section 27A(11) by 2nd respondent-RDO either by filing appeal as per Section 27B(1) or by resort to revision as per Section 28. Hence, resorting to the public law remedy of writ remedy cannot be faulted. In the light of all these aspects, it is only to be held that the impugned proceedings have been passed totally beyond jurisdiction and is a colourable exercise of power and is totally beyond the permissible parameters of exercise of power under Section27A(11) of 2008 Act. In that view of the matter, it is ordered that Ext.P7 orders in WP(C)No.12906 of 2020 and WP(C)No.12926 of 2020 and Ext.P3 and Ext.P6 orders in W.P(C)No. 12947 of 2020 will stand set aside and quashed. 11. The learned counsel for the petitioners would point out that direction may also be given by this Court to the 3rd respondent-Tahsildar to ensure that the process of alteration of the BTR as envisaged in Section 27C(1) is also duly completed and finalised after hearing the petitioners etc. That aspect of the matter may not fall strictly within the subject matters of the present writ proceedings. That aspect of the matter may not fall strictly within the subject matters of the present writ proceedings. But needless to say, since the impugned orders have been quashed by this Court and in view of Ext.P2 statutory orders/permission already secured by the petitioners under Section 27A(2), it for them to file requisite applications under Section 27C of 2008 Act r/w Section 6A of the Kerala Land Tax Act, 1961, before the 3rd respondent-Tahsildar seeking for reassessment of the subject property so as to secure additional entries in the BTR, to show the correct nature of the land as 'garden land'/'purayidam' instead of earlier entry in the BTR as 'nilam'/'paddy land' and thereupon, it shall be the statutory obligation of the 3rd respondent-Tahsildar to act thereon, strictly in accordance with law in the light of the observations and findings made by this Court hereinabove. 12. The petitioners will produce certified copies of this judgment along with copies of the Memorandum of these W.P(C)s along with all the exhibits before both the 2nd respondent-RDO/Sub Collector and the 3rd respondent-Tahsildar, for necessary information and further action. With these observations and directions, the above Writ Petitions (Civil) will stand finally disposed of.