Smti.Malathi Biswas v. The Superintending Engineer And ANR

IN THE HIGH COURT AT CALCUTTA

CONSTITUTIONAL WRIT JURISDICTION (CIRCUIT BENCH AT PORT BLAIR) PRESENT: HON'BLE JUSTICE GAURANG KANTH WPA/310/2025 Smt. Malathi Biswas Petitioner Versus.

The Superintending Engineer and another Respondents For the petitioner : Mr. Deep Chaim Kabir, Sr. Adv.

Mr. S.Ajith Prasad Mrs. Monisha Ganguly For the Administration : Mr. S.C. Mishra Heard on : 02.09.2025 Judgment on : 04.09.2025 GAURANG KANTH, J.

1.

The Petitioner, in the present writ petition, is aggrieved by the inaction of the Respondents in not granting them electricity connection to her residential accommodation situated at land bearing Survey No. 288 measuring an area of 500 sq. mtrs situated at Ram Nagar Village, Shaheed Dweep, Sri Vijayapuram Tehsil, South Andaman.

2.

The facts leading to the present writ petition are as follows: 3.

It is the case of the Petitioner that she is an encroacher of the above mentioned Government land, and in the year 2010 she constructed a dwelling unit upon the said land. The Petitioner and her family is staying in the said residential house since then. Significantly, no steps have ever been taken by the

Government of India or the Andaman & Nicobar Administration to evict the petitioner from the said land.

4.

Since the Petitioners are in settled possession of the said land, they applied for the grant of electricity connections to her residence vide application dated 04.06.2025. However, the Petitioner's application for the grant of electricity connection has been rejected by the Respondents based on the letter dated 14.06.2025 issued by the Tehsildar, Port Blair on the ground that the Petitioner is the encroacher of the land in question and granting of electricity connection will lead to the Petitioner claiming ownership of the said land in question. Being aggrieved by the same, the Petitioner preferred the present writ Petition. 5.

The Respondent filed Affidavit in opposition and the Petitioner filed exception to the same.

Submission on behalf of the learned Counsel for the Petitioner . 6.

Learned counsel for the petitioner painstakingly traced the evolution of law in this field before this Court. He submits that the issue of unauthorised occupation of non-forest Government land is peculiar to the Andaman & Nicobar Islands owing to its socio-economic, geographical, and historical factors. In view of the same, the Hon'ble Full Bench of this Court in Abhimanyu Mazumdar v. Supdt. Engineer, 2011 SCC OnLine Cal 362, considered the question:

"Whether unauthorised occupiers, encroachers, or squatters of any

premises are legally entitled to apply under Section 43 of the Electricity Act, 2003, as 'occupiers', and thereby seek electricity supply in the premises constructed on encroached land." The Hon'ble full Bench held that so long as a trespasser or encroacher is not evicted in accordance with law, he is entitled to electricity supply under Section 43 of the Electricity Act, 2003, subject to compliance with the prescribed terms and conditions of supply. Subsequently, co-ordinate Benches of this Court in Sushil Lakra v. Supdt. Engineer (WPA 215/2024, decided on 19.06.2024), M.S. Rajendran v. Supdt. Engineer (WPA 357/2024, decided on 06.09.2024), Krishnawathi Vs UOI (WPA 216/2025, decided on 11.07.2025) followed the principle laid down in Abhimanyu Mazumdar (supra) and directed the grant of electricity connections to encroachers of Government land. In view of the above precedents, Learned Counsel for the Petitioners submits that since the Petitioners are in settled possession of the land in question, they are entitled to electricity connections.

Submission on behalf of the learned counsel for the Respondent 7.

Per contra, learned counsel for the Respondents submits that the writ petition is not maintainable in view of the availability of an alternative remedy under the Joint Electricity Regulatory Commission Regulations, 2019, which require the

Petitioner to approach the Consumer Disputes Redressal Forum and, if necessary, the Ombudsman.

8.

It is further contended that the Petitioners are encroachers on Government land. Relying on the Full Bench decision in Abhimanyu Mazumdar (supra), it is urged that only a person in settled possession is entitled to an electricity connection. The Petitioner has not produced any material to establish settled possession of the premises. 9.

Learned counsel for the Respondents clarifies that compliance with Clause 5.30 of the 2018 Regulations is no longer insisted upon. However, in terms of Abhimanyu Mazumdar (supra), the question of settled possession must be verified by the Revenue Authorities. Accordingly, whenever an encroacher applies for a new connection, the nature of the land is to be ascertained from the Revenue Department. Reliance is placed on a letter dated 18.07.2025 issued by the Assistant Engineer-II (HQ) to the Tehsildar, Sri Vijayapram, and the reply thereto, wherein the Revenue Department stated that the land does not belong to them. It subsequently emerged that the land forms part of a reserve forest.

10. On these grounds, learned counsel of the respondent prays for the dismissal of the writ petition.

Legal Analysis

11. This Court heard the arguments advanced by the learned counsel for the parties and examined the documents and Judgments relied upon by the parties.

12. Article 21 of the Constitution of India guarantees the Right to Life. The Hon'ble Supreme Court has consistently held that this right extends beyond mere animal existence and includes the right to live with dignity. In Maneka Gandhi v. Union of India, (1978) 1 SCC 248, the Hon'ble Supreme Court Court expanded the scope of Article 21 by holding that any law or procedure affecting life and liberty must be fair, just, and reasonable. In Francis Coralie Mullin v. Administrator, Union Territory of Delhi, (1981) 1 SCC 608, the Court held that the right to life includes the right to live with human dignity and all that goes along with it, such as adequate nutrition, clothing, shelter, and facilities for expressing oneself. Similarly, in Olga Tellis v.

Bombay Municipal Corporation, (1985) 3 SCC 545, the Supreme Court held that the right to livelihood is an integral part of the right to life. Further, in Chameli Singh v. State of U.P.

civic amenities such as electricity, sanitation, and water, which are essential to live with dignity.

13. These authoritative pronouncements demonstrate that Article 21 is a living concept that must evolve with the needs of the times. In contemporary society, electricity has become an indispensable necessity.

Without electricity, education, healthcare, livelihood, and even access to information are rendered meaningless. The right to electricity, therefore, is no longer a matter of convenience but an inseparable part of the fundamental right to live with dignity under Article 21. The State is under a constitutional obligation to ensure that this basic facility is not denied arbitrarily.

14. Once the right to electricity is recognized as part of Article 21, the core question is whether persons in settled possession of Government land, though lacking legal title, are entitled to an electricity connection. This issue is no longer res integra in view of the Full Bench judgment of this Court in Abhimanyu Mazumdar v. Supdt. Engineer, 2011 SCC OnLine Cal 362. The Full Bench, after an exhaustive analysis, held that so long as an encroacher or trespasser is in settled possession and not evicted in accordance with law, he is entitled to apply for electricity supply under Section 43 of the Electricity Act, 2003, subject to compliance with the terms of supply. The relevant portion of the said Judgment reads as follows:

"13.

When the Rules of 2006 were introduced, the legislatures had in their aforesaid concept of settled possession which was capable of being defended against any threat of dispossession, even at the instance of the owner, except by due process of law as laid down by the Supreme Court and consequently, introduced the definition of the word 'occupier' as lawful occupier without further defining the word "lawful" therein. Therefore, in the absence of any definition of the word "lawful" in the Rules of 2006, we should apply the principle of "settled possession" laid down by the Supreme Court to the phrase "lawful occupier"

appearing in the Rules for implementation of the object of the Electricity Act, 2003 to construe the same as a person in "settled possession" whose possession can be defended against the threat of dispossession otherwise than due process of law even by the lawful owner. 14.

We, therefore, hold that a person in settled possession of a property as illustrated in the case of Rame Gowda (supra), is free to apply for supply of electricity without the consent of the owner of the same and is entitled to get electricity and enjoy the same until he is evicted by due process of law. 15.

We have already pointed out that either in the Electricity Act, 2003 or in the Rules of 2006, there is no procedure prescribed for resolving the dispute as to the status of an occupier in the property over which the electricity is sought to be brought or over which any work is to be constructed by the licensee for giving connection of electricity to any person. To construe the word "lawful" appearing in the Rule as "having perfect legal title to possess" would lead to absurdity in implementing the object of the Act and the Rules. In that event, at every stage, the licensee would face problem in giving electricity whenever any dispute as to the title of a person to remain in possession would be raised by any other person claiming to be the owner having lawful title over the property in question and the licensee would be required to wait until such a dispute is resolved by a competent court in a protracted litigation. We, therefore, construe the word "lawful occupier" appearing in the Rules as "the person in settled possession". 16.

Since all the lands in these Islands belong to the Union of India, the latter is not required to file a civil suit for eviction of a trespasser and the trespassers can be evicted by taking recourse to the Regulation of 1966. However, so long such a trespasser in settled possession is not so evicted, he should be entitled to get electricity with the aid of Section 43 of the Electricity Act on compliance of the terms of supply as provided under law. It is needless to mention that the enjoyment of such electricity will not confer any right or equity in favour of the trespasser in occupation to defeat the title of the lawful owner. 17.

We, thus, answer the first question of Reference in affirmative provided the encroacher is in settled possession of the property."

15. This Court, in Sushil Lakra (Supra), had occasion to examine the applicability of the amended provisions of Section 43 of the Electricity Act, and the Electricity Supply Code Regulations, 2018 in the context of granting electricity connections to persons in occupation of Government land without title. Although the Full Bench decision in Abhimanyu Mazumdar (supra) and the judgment of the Co-ordinate Bench in Santosh (supra) were not brought to the notice of the learned Single Judge, the Court nonetheless undertook an extensive analysis of the statutory framework. It was categorically held that Clauses 5.29 and 5.30 of the 2018 Regulations cannot be construed in a manner so as to deny electricity to persons in settled possession, since such denial would amount to depriving them of the basic necessities of life. The relevant observations of the Court read thus:

"A perusal of Clauses 5.29 and 5.30 indicates that the same merely provide modalities to get electricity connection. Clause 5.30 (7) stipulates that the applicant is required to produce a 'No Objection' Certificate from the owner of the premises.

However, the heading of Clause 5.30 is that any of the documents mentioned thereunder shall be considered as acceptable proof of ownership or occupancy of premises, out of which No Objection Certificate is only one.

Hence, the argument of the respondent that non-furnishing of No Objection Certificate vitiates the right of the applicant to get electricity connection cannot be accepted as tenable in the eye of law.

It is well-settled that even if the possession of a person is tainted by illegality, a person in settled possession of a property is entitled to get electricity connection. Such position of law is sanctioned by the language of Section 43 of the Electricity Act, 2003 as well, which envisages that either the owner or the

occupier, even if the occupier is not the owner, is entitled to get electricity connection in his/her own right.

As such, the provisions of Clause 5.30 (7), which is part of a Regulation enacted by the Joint Electricity Regulatory Commission under the aegis of the Electricity Act, 2003, cannot be construed in a manner so as to override and negate the applicability of the parent statute itself.

Moreover, electricity is a basic necessity and it has been held by different High Courts and the Supreme Court time and again that the same pertains to the right to life of a person as enshrined in Article 21 of the Constitution of India. As such, the Regulation framed under the Electricity Act, 2003 cannot override such right of a person to get electricity connection. Thus, Clause 5.30 of the Supply Code, in no manner whatsoever, fetters the right of an occupant to get electricity connection even without any no objection certificate being produced from the owner.

Coming to the second objection of the respondents, it is seen that the Consumer Grievances Redressal Forum and Ombudsman Regulations, 2019 provides modalities and a forum for adjudication of consumer disputes.

Clause 16 thereof merely provides that a complainant under the said provision can approach the designated forum with a grievance/complaint under the said Regulation. The term "grievance" has been defined in Clause 3(e) to mean and include any complaint, relating to any fault, imperfection, shortcoming or inadequacy in the quality, nature and manner of performance which has been undertaken to be performed by a licensee in pursuance of a license, contract, agreement or under the JERC Electricity Supply Code 2018 as amended from time to time or in relation to the Distribution Performance Standards of the licensees, as specified by the Commission, and includes billing disputes of any nature and matters related to safety of the distribution system having potential of endangering life or property; or a dissatisfaction of a Consumer arising out of failure of the licensee to register or redress a complaint etc.

Thus, the premise of the expression "grievance" takes into consideration only cases where there is an existing relationship of consumer and licencee between the distribution licensee and another person. An applicant for electricity connection is yet to have such jural relationship with the licencee and as such, cannot be termed as 'consumer' to come within the purview of the said provisions.

In any event, the non-grant of electricity connection pertains to the basic right which is a component of the fundamental right to life and thus, provides for Constitutional redressal within the contemplation of Article 21 of the Constitution of India. Since the Constitution is the grundnorm of the country, no provision of any statute promulgated under the same, less so in

case of Rules and Regulations framed under such statute, can fetter the right conferred by provisions of the Constitution. Moreover, grievances contemplated in the Regulation of 2019 revolve around disputes relating to deficiency of services. Non-giving of electricity connection is not a deficiency of service in the true sense of the term but is a challenge to the fundamental right of an occupant of the property. Since Section 43 of Electricity Act, 2003 does not create any fetter for an occupant to get electricity connection, the writ court's hands are not bound by the provisions of 2019 or 2018 Regulations from granting such relief to the occupant. Seen from such perspective, there is no reason as to why the purported remedy available before the Consumer Redressal Forum, which is not applicable in the present case, can be an impediment for this court to issue a Rule of Mandamus against the distribution licencee".

16. The very same issue was again examined by a Co-ordinate Bench in M.S. Rajendran v. Supdt. Engineer (WPA 357/2024, decided on 06.09.2024). In that case, the Court specifically considered the binding effect of the Full Bench judgment in Abhimanyu Mazumdar (supra) against the backdrop of the amendment to Section 43 of the Electricity Act, 2003 and the promulgation of the Electricity Supply Code Regulations, 2018. After a detailed discussion, the Court unequivocally held that the ratio laid down in Abhimanyu Mazumdar (supra) has not been rendered inapplicable by the statutory amendments or by the 2018 Regulations. The Court reiterated that so long as a person is in settled possession, the right to seek electricity supply cannot be denied. The relevant portion of the judgment reads as follows:

9. After hearing the parties and considering the materials on record including the Supply Code, 2018, I find that the term 'occupier' is defined in clause 2.3 (52) of the Supply Code, 2018

and means an owner or person in occupation of the premises where energy is used or proposed to be used. The terms 'applicant', 'application' and 'application form' has been defined in clauses 2.3 (4)(5)(6) respectively. The 'applicant' means an owner or occupier of any land/premises who files an application form with a "Licensee" for supply of electricity. 'Application' means, an application form complete in all respect in the appropriate format, as specified under the Supply Code, 2018.

10. It is, therefore, apparent that in the Supply Code, 2018, the Joint Electricity Regulatory Commission, has used the word "occupier" without qualifying the same word "lawful" to mean that electricity connection is available only to a lawful occupier. This point was elaborately dealt with in Abhimanyu Mazumdar (supra) after considering the definition of occupier in the Electricity Act, 2003 (in short 2003 Act) and the Work of Licensees Rules 2006.

The Hon'ble Special Bench in Abhimanyu Mazumder (supra) came to the conclusion that the word 'occupier' therein cannot mean only a lawful occupier. The Special Bench also took into its consideration the encroachers and encroachment as in Andaman and Nicobar Islands.

11. After considering all the possible category to which an applicant for a new electricity connection may belong that is he may be the owner, a lawful occupier or an occupier simpliciter, the Hon'ble Special Bench in Abhimanyu Mazumdar (supra) concluded that even an encroacher in a settled possession is entitled to electricity till he is not dispossessed by due process of law. The learned Single Judge in Santosh (supra) did not take note of this deduction in Abhimanyu Mazumdar (supra) which led to the findings therein.

12. On a reading of Santosh (supra), it appears that the learned Coordinate Bench, while passing the judgment dated 21.03.2024, in Santosh (supra) did not consider the observations made in Abhimanyu Mazumdar (supra) as to the definition of "occupier" which led to the conclusion that any applicant for new electricity connection if is in settled possession of the property in question will be entitled to the enjoyment of electricity so long as such applicant is not dispossessed from such property by due process of law, though the said judgment was cited before the Coordinate Bench.

13. With regard to the arguments made by the respondents by relying upon the judgment and order of Santosh (supra) that the ratio of Abhimanyu Mazumdar (supra) is no more applicable as it was passed by considering the unamended provision of Section 43 of the Act of 2003 and 2006 Rules particularly when the said section being subsequently amended and on being read with the Supply Code, 2018 promulgated in the context of the amended provisions section 43 of the 2003 Act. Unless the applicant provides any of the documents mentioned in clause 5.30 of the Supply Code, 2018 the application is not acceptable and is not required to be processed which leads to the inevitable conclusion that such an applicant will not get a new electricity connection.

14. The amendment brought in Section 43 of the Act of 2003 does not alter the definition of 'occupier' by qualifying it with the word 'lawful'. Unless such qualification is provided in the 2003 Act, there is no difference in the definition of "occupier"

that was considered in Abhimanyu Mazumdar (supra), in such a situation the Supply Code, 2018 which is promulgated in exercise of the powers conferred under the 2003 Act qualify an "occupier" as a lawful occupier by disclosing the documents as in clause 5.30 thereof when the parent Act does not make such distinction The provisions of the Supply Code, 2018 cannot override the provisions of the principal Act i.e 2003 Act or qualify any words used therein by imposing restrictions.

15. The Supply Code, 2018, as discussed herein above, has been promulgated in exercise of the power conferred under the Act of 2003 and in particular under Section 50 read with Section 3(24) thereof. In absence of any provision under the Act of 2003 to deny electricity to an applicant who is not a lawful occupier, the Supply Code, 2018 cannot have a overriding effect over the parent Act being the source of its existence. By interpreting the provision of clause 5.30 of the Supply Code, 2018 in a restricted manner as contended by the respondents, the new electricity connection cannot be limited to a lawful occupier only. The Coordinate Bench in Sushil Lakra (supra) has also opined that the Supply Code, 2018 cannot be construed in any manner so as to override and negate the applicability of the concerned parent statute.

16. The peculiar facts and circumstances prevailing in Andaman and Nicobar Islands is also required to be considered while dealing with the aspect of new electricity connection to an occupier. In these Islands, encroachment of government revenue land and forest land is a common phenomenon. This issue fell for consideration before the Hon'ble Supreme Court in the year 1995. Pursuant to the directions given by the Hon'ble Supreme Court in its order dated 07.05.2002, the Government of India has taken a policy decision to allot one hectare of land to the encroacher who have encroached even a forest land prior to 31.12.1978.

Despite such policy decision, it is often found that the encroachers have not yet been issued the licence of the alternative land or even if allotted, physical possession thereof has not been made over to the encroacher as a result whereof the encroacher is still occupying the encroached land without any document as specified in clause 5.30 of the Supply Code, 2018. This may be also the case in respect of government revenue land. In such a situation, an encroacher who is occupying the encroached land will not be in a position to produce any of the documents enumerated in clause 5.30 of the Supply Code, 2018 then, an encroacher who is occupying a land/premises and falls within the definition of occupier as appeared in Abhimanyu Mazumdar (supra), will never be entitled to apply and get a new electricity connection.

By giving such restrictive construction, as to the word "occupier" who is in settled possession, one cannot also render the ratio laid down by the Hon'ble Special Bench in Abhimanyu Mazumdar (supra) redundant when the amendment to section 43 of the Act of 2003 has not brought any change to the definition of "occupier".

17. One further point is to be taken note of. The electricity distribution company who is approached by an applicant is a "licensee" and/or a distribution licensee under the Act of 2003. It has no power and authority to decide on right, title and interest in the land/premises wherein the new electricity connection is sought for. By interpreting the provisions of clause 5.30 of the Supply Code, 2018 in a restrictive manner is

attempting to decide the right, title and interest of the applicant in the said land/premises ignoring the ratio laid down in Abhimanyu Mazumdar (supra), which is impermissible in law and can be construed as an act in excess of jurisdiction.

18. In the light of the discussion as aforesaid, I am of the view that the ratio laid down in Abhimanyu Mazumdar (supra) has not become inapplicable in view of the amendment brought to section 43 of the Act of 2003 after passing of the said judgment and promulgation of Supply Code, 2018 as opined by a Coordinate Bench in Santosh (Supra). On the contrary I am in agreement with the view expressed by other Coordinate Bench in Sushil Lakra (Supra)".

17. Very recently, another single bench of this Court examined the same question in Krishnawathi (supra), and by order dated 11.07.2025, held as follows:

"In the present case it is not denied that the petitioner is not in occupation of the premises in question. The electricity connection has been denied as the petitioner has not provided the documents as required under Clause 5.30 of JERC Regulation, 2018. The similar issue was considered by the Coordinate Bench of this Court in WPA/213/2025 wherein this Court considered that clause 5.30 does not in any manner fetter the right of occupant to get electricity connection.

Considering the above this Court finds that the petitioner is in occupation of the government revenue land and has constructed the house and required electricity connection. This Court also finds that it is not possible for the illegal occupier to obtain the document which is required under the Clause 5.30 of the JERC Regulation, 2018. The authority have made an attempt by notifying the rule only to prevent the illegal occupier for grant of electricity. Thus, this Court hold that the document as prescribed under Clause 5.30 is not required to be produce by the illegal occupier who has constructed the house in the government revenue land. Accordingly, the impugned order passed by the Assistant Engineer- II (HQ) dated 14.02.2025 is set aside and quashed. The Assistant Engineer-II (HQ), Electricity Department is directed to provide electricity connection to the petitioner within a period of four weeks from the date of receipt of this order on compliance of all formalities."

18.

From the aforesaid decisions in Sushil Lakra (supra) M.S. Rajendran (supra) and Krishnawathi (supra), it clearly emerges that the legal position enunciated by the Hon'ble Full Bench in Abhimanyu Mazumdar (supra) continues to hold the field notwithstanding the subsequent amendment to Section 43 of the Electricity Act, 2003 or the promulgation of the Electricity Supply Code Regulations, 2018. Co-ordinate Benches have authoritatively held that denial of electricity supply to persons in settled possession, even if such possession is over Government land, would amount to an infringement of their right to live with dignity under Article 21 of the Constitution. Thus, the attempt to read Clauses 5.29 and 5.30 of the 2018 Regulations as an absolute bar stands rejected, and the entitlement of such persons to electricity supply is firmly reaffirmed.

19.

It is also to be noted that another co-ordinate bench of this Court in Santosh v. Supdt. Engineer (WPA 194/2024), held that in view of the subsequent amendment to Section 43 of the Electricity Act, 2003 and the Electricity Supply Code Regulations, 2018, the ratio in Abhimanyu Mazumdar (supra) is no longer applicable. It is argued that Clause 5.30 of the 2018 Regulations and Clause 11(c) of the prescribed application form mandate a "No Objection Certificate" (NOC) from the landowner, which the Petitioners cannot produce. This submission, however, has been considered and rejected in M.S. Rajendran (supra).

The Co-ordinate Bench in M.S. Rajendran (supra) specifically examined the applicability of the 2018 Regulations and concluded that the ratio in Abhimanyu Mazumdar (supra) continues to hold the field, notwithstanding the subsequent legislative and regulatory developments.

20.

In view of the law laid down by the coordinate Bench in Sushil Kumar Lakra (supra) M.S Rajendran (supra), and Krishnawathi (supra) it is now no more res integra that the absence of an NOC from the owner of the premises cannot be an absolute bar to the grant of electricity, since denial of such a basic facility would amount to violation of the right to life and dignity under Article 21 of Constitution of India.

21. This Court is in respectful agreement with the views expressed in Sushil Lakra (supra), M.S. Rajendran (supra)and Krishnawathi (supra). It is accordingly held that the law laid down by the Full Bench in Abhimanyu Mazumdar (supra) remains binding, and neither the amendment to Section 43 nor the 2018 Regulations dilute its applicability. 22.

In light of the above, and in view of the constitutional jurisprudence laid down by the Hon'ble Supreme Court in Maneka Gandhi (supra), Francis Coralie Mullin (supra), Olga Tellis (supra), and Chameli Singh (supra), this Court is of the considered opinion that denial of electricity to persons in settled possession, even on Government land, would be a direct

infringement of their fundamental right to life with dignity under Article 21.

23.

It is further clarified that, in view of the law laid down by the Hon'ble Full Bench of this Court in Abhimanyu Mazumdar v. Supdt. Engineer, 2011 SCC OnLine Cal 362, which was followed by co-ordinate Benches of this Court in Sushil Lakra v. Supdt. Engineer (WPA 215/2024, decided on 19.06.2024), M.S. Rajendran v. Supdt. Engineer (WPA 357/2024, decided on 06.09.2024), and Krishnawathi v. Union of India (WPA 216/2025, decided on 11.07.2025), a No Objection Certificate/clarification from the concerned Revenue Department is not required to establish the settled possession of the petitioner over the land in question.

The Respondent Electricity Department may accept documents such as a ration card, electoral identity card, Aadhaar card, Driving license, passport, or any other similar Government issued document, bearing the same address, as proof of occupancy of the premises for the limited purpose of establishing settled possession for the grant of electricity connection. It is further clarified that such documents shall be considered only for the purpose of granting an electricity connection, and not as proof of title or for any other purpose.

24. Accordingly, the present writ petition is disposed of with a direction to the Respondents to process the Petitioner's application for the grant of new electricity connection in accordance with law and grant electricity connections within a

period of four weeks from the date of this order, provided the application is otherwise complete in all respects except for the production of an NOC from the Government.

25.

With these directions, the writ petitions stand disposed of. (GAURANG KANTH, J.)