ORDER : (per Hon’ble Sri Justice R.Raghunandan Rao) Heard Sri L. Ravichender, learned Senior Counsel appearing for Sri Srinivas Bobbili, learned counsel for the petitioners in W.P.(PIL).No.4 of 2017, Sri Srinivas Bobbili, learned counsel appearing for the petitioners in W.P.Nos.14105 of 2017, Sri E. Madan Mohan Rao, learned Senior Counsel for respondent No.17/M/s. Indian Farmers Fertilizer Cooperative Limited in W.P.(PIL).No.4 of 2017 and learned counsel for the petitioners in W.P.No.16482 of 2020, Sri C.V. Mohan Reddy, learned Senior Counsel for respondent No.18/M/s.IFFCO Kisan SEZ Limited in W.P.(PIL).No.4 of 2017, Sri Ms. Saroj, learned counsel for respondent Np.19/Hindustan Coca Cola Beverages Private Limited in W.P.(PIL) No.4 of 2017, Sri. B. Vijayasen Reddy, learned Senior Counsel for Respondent No.20/M/s.Gamesh Renewable Private Limited in W.P.(PIL).No.4 of 2017 and the learned Advocate General appearing for respondents 1 and 2 in W.P.(PIL).No.4 of 2017. The parties to these writ petitions are being referred to as they are arrayed in PIL No. 4 of 2017. 2. Respondent No.17 M/s. Indian Farmers Fertilizer Cooperative Limited (IFFCO), a Cooperative Society, which operates fertilizer plants in India had sought to establish an Ammonia-Urea plant in Nellore District, with an estimated cost of Rs.2000 crores (approximately). An extent of 2776.23 acres of land is said to have been allotted to the 17th respondent in various villages of Alluru and Kodavaluru Mandals of erstwhile Nellore District. The land is said to have been handed over to the 17th respondent by the 9th respondent Special Tahsildar on 07.05.1997. 3. The Petitioners in W.P.(PIL).No.4 of 2017 challenged the handing over of the said land to the 17th respondent apart from various concessions and incentives given to the 17th respondent and the subsequent 18th respondent. It is the case of the petitioners in W.P.(PIL).No.4 of 2017 that the transfer of the said land apart from various concessions given by the authorities are actuated by malafides and with an intention to help the 17th respondent which is actually a private entity interested in making profits. The petitioners also assail the said transfer apart from the other incentives on the ground that the said transfer of land and grant of incentives suffer from various infirmities which are set out in detail below. 4. The petitioners also assail the said transfer apart from the other incentives on the ground that the said transfer of land and grant of incentives suffer from various infirmities which are set out in detail below. 4. The petitioners in W.P.No.14105 of 2017 are said to be persons whose lands have been taken over by the Government for the purposes of handing over the same to the 17th respondent, without payment of proper compensation to the petitioners and the same is arbitrary, illegal and consequently the Government should either pay compensation @ 56 lakhs per acre or the land should be given back to the petitioners therein. 5. The 18th respondent had sought permission for a company called M/s E.V. Mia Electrical Private Limited, to establish a unit in the SEZ of the 18th respondent. The Development Commissioner informed the 18th Respondent, by a letter dated 13.08.2020 that the said application would be kept pending till PIL No. 4 of 2017 and the other cases pending before this court are decided. Aggrieved by this communication the 18th Respondent had filed W.P.No.16482 of 2020. 6. It is necessary to look at the time line of events before considering the grounds raised by the petitioners. 7. The 17th respondent, for the purpose of establishing an Ammonia-Urea plant had sought an extent of about 2000 acres to be allotted to it in the year 1994. In response, the Government issued G.O.Ms.No.407 dated 19.08.1995 directing the transfer of 2672.05 acres of land. This G.O also recorded that there is a dispute in relation to about a thousand acres of land and the said dispute had been resolved in favour of Sri Kodanda Rama Swamyvari Temple, Kovur. However, this land was also directed to be handed over in advance. Subsequently, advance possession was handed over to the 17th respondent by way of G.O.Ms.No.794 and proceedings of the Special Tahsildar dated 23.09.1997. 8. The 17th respondent-M/s.IFFCO subsequently dropped the proposal to construct the fertilizer plant and sought to convert the entire land into an SEZ. For this purpose, the 18th respondent was incorporated and the entire extent of 2776.23 acres of land was transferred to the 18th respondent, by way of a registered deed of transfer dated 02.04.2018 for a consideration of 30.32 corers approximately. Thereafter, the 18th respondent obtained necessary permissions for establishing the SEZ in the entire area. For this purpose, the 18th respondent was incorporated and the entire extent of 2776.23 acres of land was transferred to the 18th respondent, by way of a registered deed of transfer dated 02.04.2018 for a consideration of 30.32 corers approximately. Thereafter, the 18th respondent obtained necessary permissions for establishing the SEZ in the entire area. The Government of Andhra Pradesh also issued G.O.Ms.No.168 dated 25.02.2010 permitting the utilization of lands for SEZ, subject to the conditions set out therein. The relevant conditions were that the land should be used for the purpose of industry or multi products for fertilizer only, the land should be utilized within three years from the date of the order and that the 17th respondent- M/s.IFFCO should pay 10% of the value, for conversion of the land from agricultural purpose to non agricultural purpose, under Section 4(1) of the Andhra Pradesh Agricultural Land (Conversion for Non Agricultural Purposes) Act, 2006. Later the Government of Andhra Pradesh issued G.O.Ms.No.394 dated 05.05.2010 wherein the condition of using land for fertilizer plant was changed by deleting the word “for fertilizer plant”. Under G.O.Ms.No.28, the Government of Andhra Pradesh had also exempted the 17th respondent from paying 10% o the value of the land towards conversion charges. 9. The 18th respondent had subsequently allotted some land to respondents 19 and 20 for the purposes of establishing their units. 10. The petitioners, on the basis of the above facts contend that the above allotment of lands and concessions have been given to the 17th/18th respondent in violation of law and in violation of principles governing the allotment of land in the following manner: A) Allotment of land: i) The Government of Andhra Pradesh had allotted 2776 acres of land to the 17th respondent. This allotment was only by way of a proceedings of the Special Tahsildar (land acquisition) IFFCO, Nellore bearing Rc.A.56/97 dated 23.09.1997. In the absence of any transfer document, the transfer is not completed and as such, the land still belongs to the Government; ii) The 2776 acres of land allotted to the 17th respondent consisted of the following extends of land; 1. Patta land which was acquired under the provisions of land Acquisition Act Ac.229.78 cents 2. Assigned land which has been resumed without paying Compensation or ex gratia to the assignees Ac.1129.82 cents 3. Government land Ac.406.82 cents 4. Patta land which was acquired under the provisions of land Acquisition Act Ac.229.78 cents 2. Assigned land which has been resumed without paying Compensation or ex gratia to the assignees Ac.1129.82 cents 3. Government land Ac.406.82 cents 4. Land belonging to Sri Kodanda Rama Swamyvari Temple without paying any compensation is- Ac.1009.81cents iii) The assigned land of Ac.1129.82 cents which was given to various assignees was taken over by the Special Tahsidlar-9th respondent by way of resumption without paying any compensation or ex gratia to the assignees and without following any procedure. The said resumption and subsequent handing over of the land to the 17th respondent suffers from lack of jurisdiction and is in violation of rule of law as the assignees would be entitled to compensation on par with private owners of land in the adjoining areas which had also acquired for the purpose of handing over the same to the 17th respondent. iv) The Government land of Ac.406.82 cents can be allotted and handed over to the 17th respondent only by the Government, but the 9th respondent-Special Tahsildar, on his own, handed over this land to the 17th respondent-M/s.IFFCO and as such, the handing over of the said land is clearly illegal and that too when the land is handed over to a private profit making institution such as the 17th respondent. The said handing over would also suffer from lack of jurisdiction. v) Sri Kodanda Ramaswamy vari temple owns Ac.1009.81 cents of land and the said land was handed over to the 17th respondent-M/s.IFFCO even after the jurisdictional authority under the Inams Act, had declared that the said land belongs to the temple. The land was handed over without paying any compensation to the temple and consequently the entire exercise is illegal. vi) Acquisition of land by the Government is illegal as the said acquisition was not for a public purpose and was for the benefit of a private entity. As such, the provisions of land Acquisition Act could not have been invoked. 11. Apart from the above contentions in the affidavits, Sri L. Ravichander, learned Senior Counsel would also argue that the procedure adopted by the Government of Andhra Pradesh and the Revenue Authorities in simply handing over the land at the request of the 17th respondent is not in accordance with the procedure that needs to be followed in such cases. 11. Apart from the above contentions in the affidavits, Sri L. Ravichander, learned Senior Counsel would also argue that the procedure adopted by the Government of Andhra Pradesh and the Revenue Authorities in simply handing over the land at the request of the 17th respondent is not in accordance with the procedure that needs to be followed in such cases. He contends that the Government ought to have processed the request of the 17th respondent in accordance with the Swiss challenge method and in any event the government ought to have conducted a price discovery exercise by way of a public auction of the land or by notifying the request of the 17th respondent and by seeking proposals from any other interested party for setting up the fertilizer plant. B) Change of use of land: The petitioners contend that the land was allotted to the 17th respondent-M/s.IFFCO only for the purpose of establishing a Urea plant and the subsequent application of the 17th respondent for change of use of land for setting up an SEZ instead of Urea plant should have been rejected. Consequently, the land should have been returned to the assignees, the temple and to the persons from whom the land had been acquired under the provisions of the Land Acquisition Act. The action of the Government of Andhra Pradesh in permitting the change of land use is without any basis and is an arbitrary decision taken solely to benefit the 17th respondent, with consequent loss of revenue to the Government. C) Concession given to the 17th/18th respondent: The Government of Andhra Pradesh had accepted the change of land use and the establishments of an SEZ. However, this consent was subject to the condition of payment of conversion charges @10% of the market value, exclusive use of the land for a fertilizer SEZ and establishment of the SEZ within three years. All three conditions were given a go bye. The Government of Andhra Pradesh not only condoned the violation of these conditions, but also relaxed the three conditions in favor of the 17th/18th respondents thereby causing huge loss to the public exchequer. Apart from this, the said actions have been undertaken solely to benefit 17th /18th respondent and not for any public purpose. 12. The Government of Andhra Pradesh not only condoned the violation of these conditions, but also relaxed the three conditions in favor of the 17th/18th respondents thereby causing huge loss to the public exchequer. Apart from this, the said actions have been undertaken solely to benefit 17th /18th respondent and not for any public purpose. 12. The allotment of land to respondents 19 and 20 is in violation of the SEZ Act, apart from being violative of the condition set out by the Government of Andhra Pradesh, which permitted the change of land use subject to the condition that the land would be used only for establishing agro based units in the SEZ. The allotment of land is a violation of this condition as both respondents 19 and 20 are not establishing agro based units but are establishing a coco-cola plant and a solar power manufacturing unit which have nothing to with agricultural or an agro based industry. 13. The Government of Andhra Pradesh not only permitted the transfer of land to the 19th respondent but also gave a permission to 19th respondent to draw an inordinate extent of water from the nearby reservoir for the purpose of manufacturing carbonated drinks and the same is also a sign of the manner in which the Government of Andhra Pradesh has benefitted the 17th/18th respondents and the units that are sought to be established in the area handed over to these entities. 14. The respondents 1 to 3, 5, 7, 11, 17, 18, 19 and 20 have all filed their counter affidavits. In these counter affidavits, the respondents disputed and denied the allegations and the grounds raised by the petitioners herein. The contentions raised by the respective respondents are being dealt with while considering the above grounds raised by the petitioners. 15. The respondents 1 and 2 and respondents 17 and 18, apart from raising their defences have also raised an issue affecting the maintainability of the W.P.(PIL).No.4 of 2017. It is the case of the respondents that there has been suppression of fact by the petitioners in W.P.(PIL).No.4 of 2017, which was filed by four petitioners claiming to be public spirited persons who are agitating on behalf of the assignees and local farmers who are not in a position to fight for themselves. It is the case of the respondents that there has been suppression of fact by the petitioners in W.P.(PIL).No.4 of 2017, which was filed by four petitioners claiming to be public spirited persons who are agitating on behalf of the assignees and local farmers who are not in a position to fight for themselves. A specific declaration was made that the writ petition is being filed by way of Public Interest Litigation and the petitioners do not have any personal interest in the matter. Another declaration given by the petitioners was that the petitioners had not filed any petition which was similar or identical to the PIL being filed by them. However, there has been a spate of litigation in relation to the allotment of the land in favor of the 17th respondent including W.P.No.4956 of 2012, W.P.No.12780 of 2012 and W.P.No.26443 of 2012. The 2nd petitioner herein is petitioner No.24 in W.P.No.4956 of 2012, in which the petitioners therein had sought a direction to the Government of Andhra Pradesh to resume the land on various grounds. A learned Single Judge of the erstwhile High Court of Andhra Pradesh by a Judgment dated 10.03.2014 had dismissed the W.P.No.4956 of 2012. In fact all the other Writ Petitions mentioned above were also dismissed in 2012. The respondents contend that the 2nd petitioner has deliberately suppressed the fact that he is one of the persons who has been affected by the acquisition of land, under the provisions of the Land Acquisition Act and had filed W.P.No.4956 of 2012 for resumption and return of his land which had been rejected by the erstwhile High Court of Andhra Pradesh. 16. The respondents contend that this suppression of fact is sufficient to non suit the petitioners in W.P.(PIL).No.4 of 2017. The respondents would also contend that the present P.I.L has not been filed by way of Public Interest Litigation but is actually private litigation sponsored by a person who had been a sub contractor involved in the execution of certain works for the establishment of the SEZ. 17. In the normal course, the aforesaid suppression of fact would be sufficient to non suit the petitioners herein. However, W.P.No.14105 of 2017 filed by the assignees has raised similar issues and it would be more appropriate to consider and dispose of the rival submissions on merits. 17. In the normal course, the aforesaid suppression of fact would be sufficient to non suit the petitioners herein. However, W.P.No.14105 of 2017 filed by the assignees has raised similar issues and it would be more appropriate to consider and dispose of the rival submissions on merits. Accordingly, this Court refrains from dismissing the writ petition on the ground of suppression of fact, despite such a circumstance being made out. Consideration of the Court: Allotment of land: 18. The first objection raised by the petitioners was that around Ac.1129.82 cents of land which had been assigned to various landless persons had been resumed by the 9th respondent- Special Tahsildar without paying any compensation or ex gratia for the said land and such resumption is clearly illegal and impermissible. The official respondents contend that a large number of the assignees were in violation of the conditions of assignment requiring the assignees to commence agricultural operations within the specified time after the land had been assigned to them and to continue to conduct agricultural operations. The official respondents contend that as a large number of the said assignees were in violation of these directions, lands assigned to them were resumed after due notice. The official respondents also contend that the eligible assignees were paid ex gratia. It may be noted that some of the said assignees had challenged the order of resumption and handing over of land to the 17th/18th respondent, by way of W.P.No.26443 of 2012. A learned single judge of the erstwhile High Court of Andhra Pradesh had dismissed this writ petition holding that lands had been resumed in 1995 itself and the assignees cannot seek re-allotment of land on the ground that they had ceased to be assignees even before the land had been allotted to the 17th respondent. Another set of assignees had moved W.P.No.12780 of 2012 on the same grounds. The learned single judge had again held that lands assigned to these persons had already been resumed by the government in the year 1995 and had dismissed the Writ Petition on 14.10.2014. These judgments have become final. In that view of the matter, the question of whether the resumption of land by the revenue authorities, prior to allotment of the same to the 17th respondent, is now covered by the judgment of the learned single judge which had become final. 19. These judgments have become final. In that view of the matter, the question of whether the resumption of land by the revenue authorities, prior to allotment of the same to the 17th respondent, is now covered by the judgment of the learned single judge which had become final. 19. The petitioners contend that the government land of Ac.406.00 cents had been handed over by the 9th respondent- Special Tahsildar and the same Is illegal as such handing over of land can be done only by the government. This contention does not appear to be correct as G.O.Ms.No.586 dated 09.07.1997 directed the transfer of the entire Ac.2672.00 cents of land including government land, assigned land which is to be resumed, Inam Land and dispute and private patta land subject to payment of market value fixed by the government. In such circumstances, the contention that transfer of land was done by the 9th respondent- Special Tahsildar on his own cannot be accepted. Further, private lands to an extent of Ac.229.78 cents had been acquired under various proceedings of the Land Acquisition Land culminating in awards under which the affected persons have been paid compensation. It may also be noted that some of this land belonged to Sri Kodanda Rama Swamyvari temple and an appeal filed against the determination of quantum of compensation had also failed. 20. The petitioners contend that Ac.1009.81 cents of land belonging to Sri Kodanda Rama Swamyvari temple was handed over to the 7th respondent even though the said land had been declared to be the property of the temple under the Inam Act by the jurisdictional authority. It may be noticed that the litigation relating to the question of ownership for this land has culminated in the order of this Court dated 23.02.2024 in W.P.No. 30379 of 2023. Under these orders, the claim and ownership of the government over the said land has been affirmed by this Court and as such, this allegation does not survive. 21. The petitioners contend that the acquisition of land by the government is illegal as the said acquisition was not for a public purpose. The land was sought by the 17th respondent for the purpose of setting up Urea fertilizer plant. At that point of time, in the years 1994 to 1998, the 17th respondent was a Co-operative Society consisting of a huge number of farmers as well as public bodies. The land was sought by the 17th respondent for the purpose of setting up Urea fertilizer plant. At that point of time, in the years 1994 to 1998, the 17th respondent was a Co-operative Society consisting of a huge number of farmers as well as public bodies. The establishment of a fertilizer plant for the benefit of the farmers in the area and by an organization which cannot be treated as a private profit making body, at that point of time, cannot be said to be private purpose. Such a purpose would definitely fall within the meaning of public purpose. In such circumstances, invocation of the provisions of Land Acquisition Act for the purpose of acquiring land from private patta holders has been done for a public purpose and the contention of the petitioners in this regard has to fail. 22. Sri L. Ravichander, the learned senior counsel appearing for the petitioners has raised an issue not set out in the pleadings. He contends that the government could not have simply initiated proceedings to hand over the land to the 17th respondent even if it is for a public purpose. He would submit that when such a proposal was submitted by the 17th respondent, it was the duty of the State Government to see if there could be a better offer by any other person and the State Government should have applied the method of Swiss challenge procedure before accepting the request of the 17th respondent. 23. It must be remembered that the transfer of land by the government was in the year 1997 when the concept of Swiss challenge was not available even if such a concept is to be applied. The said method would not be applicable to a case of allotment of land for establishing a fertilizer plant. A Swiss challenge method is followed where a party approaches the government with the proposal of doing something which has not been done earlier and by usage of certain special technology over which the proposing party has proprietary rights. In such a situation, the government could have to notify the proposal and call upon any interested party to match the said proposal or to give a better proposal. It may also be noted that, the Swiss challenge method had now been formalized by way of an Act of the State namely Andhra Pradesh Infrastructure Development Enabling Act, 2001. In such a situation, the government could have to notify the proposal and call upon any interested party to match the said proposal or to give a better proposal. It may also be noted that, the Swiss challenge method had now been formalized by way of an Act of the State namely Andhra Pradesh Infrastructure Development Enabling Act, 2001. In the present case, there is no such fact situation which would attract the requirement of the government to apply the Swiss challenge method. 24. In the alternative, Sri L. Ravichander, the learned senior counsel contends that the government before allotting the lands, should have conducted a price discovery exercised by offering the lands on public auction and thereby maximize returns to the State. He would submit that the fixation of an arbitrary price by the government is incorrect and is not in the interest of the State. As contended by the learned Advocate General, the Hon'ble Supreme Court in the cases of Kasturi Lal Lakshmi Reddy & Ors. vs. State of J & K, (1980) 4 SCC 1 (para No.22), A.P. Dalit Mahasabha vs. Government of Andhra Pradesh & Ors., 1999 (2) ALD 275 (para Nos.40 to 50 & 57), A.P. Dalit Mahasabha vs. Government of Andhra Pradesh & Ors., 1999(6) ALD 63 (para Nos.35, 36 to 46 & 47) and Natural Resources Allocations, In Re., (2012) 10 SCC 1 (para Nos.108 & 120 to 131) had held that the State has the discretion to decide the best process of allocation or alienation of land or any natural resources and the method of auction cannot be the only process where maximization of revenue is not the main purpose and where land or such natural resources are sought be allotted for ensuring industrial development. These judgments are binding on this court and accordingly, this contention of the petitioners would have to be rejected. Change of Use of Land: 25. The petitioners contend that the 17th respondent after obtaining allotment of a huge extent of land for the purposes of establishing a fertilizer plant switched the purpose and converted the land for use as an SEZ which was impermissible as the land had been allotted for a specific purpose. Change of Use of Land: 25. The petitioners contend that the 17th respondent after obtaining allotment of a huge extent of land for the purposes of establishing a fertilizer plant switched the purpose and converted the land for use as an SEZ which was impermissible as the land had been allotted for a specific purpose. It is contended that the State of Andhra Pradesh should have refused any change of land of use and should have taken the land back in the event of such change of land use. 26. The contention of the 17th respondent as well as the State of Andhra Pradesh is that the land had initially been allotted for the purposed of establishment of a fertilizer plant. However, this plant could not be set up as the Central Government had refused to permit the establishment of such a plant. This refusal is on account of the huge subsidies, the Central Government would have to bear. The Central Government took the view that in view of the high prices of Naphtha and other raw materials needed for manufacture of Urea fertilizer, it would not be possible for the Central Government to pay out necessary subsidies to ensure that the manufacture of such Urea fertilizer is economically viable. It is contended that since the 17th respondent was unable to establish the factory due to reasons beyond its control, the land was sought to be used for another public purpose namely the establishment of a Kisan SEZ with focus on agricultural products and processing of agricultural products. It is the contention of the State of Andhra Pradesh that it had considered the request of the 17th respondent for such a change of use and had accepted the said change after due deliberations. It is contended that huge amounts of money had already been expended by the 17th respondent apart from the fact that the establishment of an SEZ with focus on agricultural products would be beneficial to the farmers of the area. 27. While the petitioners may have an alternative view, the fact remains that the State Government after due deliberations had arrived at this decision. 27. While the petitioners may have an alternative view, the fact remains that the State Government after due deliberations had arrived at this decision. The scope of judicial review of such decisions is to verify whether the process of decision making is arbitrary and whether the decision itself is so arbitrary or violative of the provisions of Constitution or the fundamental rights, that the Court has to interfere. In the present case, this Court does not find any such arbitrariness in the decision to permit the 17th respondent to use the lands allotted to it as Kisan SEZ. Concessions given to the 17th respondent/18th respondent: 28. The petitioners contend that the Government of Andhra Pradesh had accepted the change subject to certain conditions. However, all the conditions have been violated by the 17th respondent or relaxed by the State of Andhra Pradesh itself and such violations or relaxations are arbitrary and have been done only for the purpose of helping the 17th respondent. 29. The petitioners contend that the 17th respondent was required to pay a conversion charge @ 10% of the market value on the entire land allotted to him. As such, payment was required under the A.P Conversion of Land from Agricultural purposes to Non Agricultural Purposes Act, 2006. This conversion fee which would have run into hundreds of crores were waived by the Government of Andhra Pradesh, by way of G.O.Ms.No. 168, dated 25.02.2010, which is clearly for malafide reasons. This charge is countered by the official respondents as well as the 17th/18th respondent on the ground that the requirement of paying conversion charges was exempted for all SEZs in the State of Andhra Pradesh and consequently exemption was granted to the 17th respondent. G.O.Ms.No.377, dated 9.11.2010 and G.O.Ms.No. 67 dated 26.02.2002, issued by the Government of Andhra Pradesh, grant such exemption for all lands falling within SEZs. In such circumstances, there is no special favour granted to the 17th/18th respondent. 30. The second charge raised by the petitioners is that the SEZ is for fertilizer plant and the same has been removed without any reason. A perusal of the initial approval given by the Central Government for establishment of the SEZ would show that the said approval was for establishment of an SEZ for agricultural produce and processing of agricultural produce. The second charge raised by the petitioners is that the SEZ is for fertilizer plant and the same has been removed without any reason. A perusal of the initial approval given by the Central Government for establishment of the SEZ would show that the said approval was for establishment of an SEZ for agricultural produce and processing of agricultural produce. In the circumstances, the clause that it should be used for fertilizer SEZ, would run contrary to the permissions given by the Central Government and appears to be a typographical error. As such, the removal of the requirement that the SEZ should be used for as a fertilizer SEZ cannot be faulted. 31. The 17th/18th respondents after obtaining permission for establishing an SEZ for agricultural produce had allotted land to respondents 19 and 20 for the purposes of setting up a Coca-Cola plant and a Solar Power Production Plant which is contrary to the provisions of the SEZ Act as well as the permissions given for establishment of the SEZ. 32. The 17th/18th respondents as well as the 19th and 20th respondents, in their counters, contend that the lands allotted to the 19th and 20th respondents were land which had been removed from the SEZ zone and had been converted into domestic tariff area under the SEZ Act. The 17th/18th respondents would also contend that to the extent of the said land which has been removed conversion charges had been paid, under the A.P Land Conversion Act to the extent of land which has been exempted from the SEZ area. In such circumstances, the question of allotment of land to the 19th and 20th respondents being contrary to the SEZ permissions could not stands scrutiny. 33. The petitioners would also contend that 19th respondent has been given permission for drawing an inordinate extent of water from a nearby reservoir for the purpose of manufacturing carbonate drinks which should not have been done and is a reflection of a manner in which the 17th/18th respondents are being promoted at the cost of the State exchequer and the cost of drinking water units of the people in the area. 34. The 19th respondent has filed a counter affidavit in which it is stated the total extent of water being utilized by the 19th respondent is far below the quantities alleged by the Petitioners. 34. The 19th respondent has filed a counter affidavit in which it is stated the total extent of water being utilized by the 19th respondent is far below the quantities alleged by the Petitioners. The allegation of the petitioners was that the 18th respondent was being permitted to draw about 1.4 tmc of water from Kanagiri reservoir and Somasila, while G.O.Ms.No. 8, dated 25.01.2010 had allowed the 18th Respondent to draw about 10 MGD per day and the same would translate into .059 tmc. The 19th Respondent also stated that the water requirement of the 19th Respondent would be about .95 Million Gallons per day. There is no cogent reply, from the petitioners, to the workings set out by the 19th respondent in this regard. 35. For all the aforesaid reasons, Writ Petitions No. 14105 of 2017 and W.P. (PIL) N0. 4 of 2017 are dismissed. W.P.No. 16482 of 2020 is closed with the observation that the condition in the letter of the Development Commissioner, Visakhapatnam, dated 13.08.2020, stands complied as all the cases before this court have been closed. As a sequel, pending miscellaneous petitions, if any, shall stand closed.