1) I made an application for the Silver Sand Island AWHO project during the demand survey phase

around the year 2005. Initially, the proposal consisted of duplex independent units with an
estimated cost of approximately 15 lakhs. However, AWHO subsequently decided to construct a
multi-storey building due to the large number of applicants. Finally, in 2009-10, the current
project was finalized, and my response to the demand survey was converted into an application
with an initial deposit. Meanwhile, the price was revised multiple times and eventually fixed at
65,30,000/-. Subsequently, a payment plan was introduced, and I diligently fulfilled all my
payments. I took possession of the flat C-2104.

2) To the best of my knowledge, three parties were involved in the construction process:
(a) AWHO, the vendor mentioned in the sale deed who sold the property to me.
(b) Silpa Projects & Infrastructure (India) Private Limited, located at 3rd Floor, North Avenue,
Paramara Road, Cochin, Kerala, India 682 018, which undertook the construction.
(c) M/s Ajith Associates, situated at KPCC Junction, Mahatma Gandhi Rd • 0485 403 2517,
who served as architects and consultants for the project.

3) Various common issues emerged, such as water leakage into the basement through the side
walls, falling granite cladding from lift walls, cracks in the staircases, and damages in the sun
shades of the rescue area in the common area of the C Tower. Attempts were made to address
these issues, primarily in a superficial manner. However, in 2019, the team from Silpa Projects &
Infrastructure (India) Private Limited vacated the premises, and further defects, including
structural concerns, started to arise. Cracks and rusted iron bars became visible in common
areas, indicating the compromised state of some pillars and beams. The granite on the lift walls
continued to fall, and rain shades of nearby flats exhibited signs of cracking and detachment.
Additionally, the leakage into the basement through the retaining wall worsened, becoming
evident along the entire wall by 2021. At this time, the Management Committee of the
Residents' Welfare Association (RWA) sought the assistance of various agencies, including
Bureau Veritas India Ltd, NIT Rourkela, and CET Trivandrum, to assess the structural integrity and
overall condition of the buildings. Reports from these agencies are in the possession of the
management committee and can be obtained by the Court of Inquiry. I have attached summary
reports from Bureau Veritas India Ltd and CET Trivandrum as appendices A and B, respectively, to
support my statement. It is evident to me that mere refurbishment or repair will not serve as a
permanent solution to the problem. Accepting repair as an alternative would inevitably render
me homeless during the twilight years of my retirement. When I made the payment for the flat, I
expected a good quality of life and future value for the property in which I invested. Concrete
buildings constructed with quality materials and adherence to proper procedures are expected
 to have a lifespan exceeding 100 years. However, in this case, Towers B and C of the AWHO
project are on the brink of collapse as soon as the buyers took possession, indicating gross
negligence during the execution of works and a severe compromise in construction standards.

The structural defects can be categorized into two stages: pre-possession and post-possession.
Identifying the causes of structural defects in the pre-possession stage is relatively straightforward due to
the availability of several technical reports as evidence.

During the pre-possession stage (construction phase), the following technical reports should be
consulted:

(a) Nov 2020 report from Bureau Veritas India Limited.

(b) May 2021 reports from Bureau Veritas India Limited.

(c) Reports from Bureau Veritas India Limited (date unknown), based on the MoU of Dec 2022.

(d) Mar 2022 report from the Government Engineering College Thiruvananthapuram.

(e) Feb 2021 reports from IIT Madras.

(f) Reports from Ajit Associates (dates not specified).

(g) July 2021 report from the Chief Engineer (MES).

Based on the aforementioned reports and the observed incidents of defects and damages since June
2018, the following reasons can be attributed to the pre-possession stage as causes of the structural
defects:

(a) Usage of water with high chloride (salt) content during construction and curing processes.

(b) Utilization of poor-quality or adulterated aggregates with high chloride (salt) content for construction.

(c) Use of low-quality borewell water for construction and curing processes.

(d) Incorporation of inferior-quality reinforcement rods for RCC construction.

(e) Flawed design by providing insufficient cover, which falls below standard specifications for coastal
regions.

(f) Passage of fire-fighting hydrant pipes through RCC beams, leading to structural weakening.
(g) Alteration of columns in the basement from the original design and inclusion of corbels with
inadequate bearing capacity.

(h) Modification of building layouts or orientations from the original design and drawings.

(i) Installation of heavy, long-span beams without sufficient support.

(j) Failure to maintain mandatory quality control and necessary documents throughout the construction
project.

The observations made by various technical experts and authorities mentioned above clearly indicate
widespread malpractices and corruption at all levels of the organization. This case should have been
promptly investigated from both technical and criminal perspectives. However, officials of AWHO, in
collusion with the officials of RWA, chose to conceal these reports from me and other owners. As a
result, the buildings continued to deteriorate, causing further structural damage and reaching a state
where they are deemed "beyond economical repairs" and unsafe for human occupation. Every individual
involved in the execution of the project should be held accountable for the structural defects in the
buildings.

Post-possession Stage:

The defects and damages that arose during the pre-possession stage were identified soon after the
possession was granted to me. If AWHO had taken appropriate action at that time, the issue could have
been addressed, and the buildings could have been saved. However, due to the continued and deliberate
negligence of AWHO, further structural defects occurred, leading to severe deterioration and the current
state of "beyond economical repairs" (BER). The following paragraphs explain the facts and individuals
responsible for this situation.

Overall Management and Approach of AWHO:

It can be established from the actions and omissions that both AWHO and the RWA management
committee (RWA MC) were equal partners in the misconduct, as elaborated in the subsequent
explanation. AWHO and RWA MC conspired and collaborated to manipulate and conceal the serious
structural defects. Their collective actions resulted in a failure to properly understand the situation,
leading to additional structural damages and ultimately pushing the buildings into the BER state.
The RWA MC made an illegal agreement with AWHO and withheld information to which I am entitled as
an owner. I have the right to access all communications between AWHO and RWA MC, especially
considering that AWHO chose that channel to communicate with me. However, RWA MC failed to share
critical communications and neglected to share my own correspondence with AWHO. This failure in
communication regarding the structural defects caused delays in taking timely action, resulting in further
structural damages in the buildings. One particular instance of improper collusion between AWHO and
RWA MC is as follows:

(i) RWA MC colluded with AWHO to select BVIL in a predetermined manner, bypassing proper
procedures. This is the primary reason for the repeated failure of technical tests and the delay in
assessing damages over the years, which contributed to further structural defects. It should be noted
that BVIL was not even the lowest bidder for the project, as explained in subsequent paragraphs.

(ii) RWA MC colluded with AWHO to manipulate the first test report conducted by BVIL, resulting in the
failure of the tests. The report explicitly mentions the names of team members who oversaw and
controlled the tests, holding these RWA MC members accountable. By colluding with AWHO, RWA MC
committed cheating and breached the trust of the owners by manipulating the test results.

(iii) RWA MC colluded with AWHO to manipulate the second test report conducted by BVIL, leading to
the failure of the tests. The report clearly states the names of the members present during the tests,
making these RWA MC members responsible for cheating and breaching the owners' trust.

(iv) RWA MC colluded with AWHO and proceeded with a third round of tests by BVIL, even though BVIL
had previously cheated the owners twice. It was RWA MC's responsibility to safeguard the owners'
interests and ensure that no further tests were conducted by BVIL due to their prior misconduct. Instead
of blacklisting BVIL, both AWHO and RWA MC colluded to award them a massive contract worth
approximately Rs. 60 lakhs for the third round of tests. AWHO and RWA MC share equal responsibility for
this irregular action.

(v) RWA MC, in collaboration with AWHO, failed to share with me the recently prepared structural
analysis report by AWHO/BVIL (the third test report based on the MoU). RWA MC absurdly claimed that
AWHO had not granted permission, which is an unjustifiable statement since the MC had access to the
report and every owner had the right to obtain a copy. The intention behind this action is to assist AWHO
and prevent owners from uncovering any manipulation in the report.
(vi) RWA MC approved the BVIL report without any recommendation, approval, or endorsement from
AWHO. Even AWHO did not endorse the report, yet RWA MC proceeded to approve it. This act of
collusion is an unthinkable form of cheating and criminal breach of trust towards the owners, as it clearly
indicates a partnership with AWHO to shift responsibility onto me and other innocent owners. This has
resulted in concealing the true extent of structural damage from me.

(vii) RWA MC failed to provide me with the report from the Chief Engineer (MES), which caused further
delays and additional structural damage. Taking timely action based on the CE report could have
prevented further deterioration. AWHO and RWA MC bear responsibility for this failure.

It is evident that these actions have resulted in further structural damages and continued deterioration
during the post-possession stage. AWHO and RWA MC are accountable for the post-possession structural
damage. If appropriate measures, such as cathodic protection, had been taken in a timely manner when
the defects were initially identified, corrosion could have been controlled, and the buildings could have
been saved. Therefore, all officials of AWHO and RWA MC since 2018 should be held responsible for the
post-possession structural damages.

Essentially, RWA MC employed a double-edged strategy, appearing supportive on paper to satisfy the
owners while practically supporting AWHO. Although proving this collusion may be challenging due to
the clever documentation managed by both AWHO and RWA MC, an experienced individual familiar with
similar investigations can identify the malicious intent from the subsequent paragraphs. To assign
responsibility, it is crucial for the CoI to thoroughly investigate each aspect.

The first major scam and conspiracy orchestrated by these vested interests involved the selection of the
testing agency for conducting structural tests on the buildings. Some owners, led by Col Unnithan and
others, engaged a team from MACE Kothamangalam, a reputable engineering college in Kerala, under
the guidance of Prof. Elson, who holds a Ph.D. from IIT Madras. They conducted a preliminary inspection
and submitted a report.

However, there was a coordinated political effort to discredit this work to prevent MACE from being
selected for the expert testing and analysis. RWA MC, driven by their premeditated strategy, engaged in
a campaign of political mudslinging to undermine the credibility of the MACE report.
AWHO and RWA MC succeeded in sabotaging MACE's involvement. By deliberately discrediting the
MACE report and recommending BVIL and other unreliable firms, RWA MC caused delays and failures in
taking necessary actions to rectify the defects, leading to further structural damage and pushing the
buildings into a state of "beyond economical repairs" (BER). AWHO and RWA MC should be held
accountable for their improper selection.

The first testing conducted by BVIL was manipulated by the syndicate of RWA MC and AWHO, resulting in
a report that favored AWHO. The individuals who controlled the testing are identified in the report,
clearly indicating their responsibility for the test failures. These failures led to delays in rectification and
further structural damage.

Despite AWHO never endorsing the report, RWA MC accepted the BVIL report and proceeded with its
processing. It was entirely inappropriate for RWA MC to handle the BVIL report without AWHO's
endorsement. However, a tacit understanding was reached to avoid blaming AWHO for the failed report,
shifting the blame onto BVIL instead. By creating a false facade that BVIL was solely responsible for the
failure, AWHO and RWA MC successfully concealed their own accountability. They are responsible for
this failure.

Finally, a decision was made to conduct a retest, which revealed further manipulation during the second
round of testing. The evaluation report highlighting the deficiencies in the BVIL report is in the
possession of AWHO and RWA MC. GEC Thiruvananthapuram also identified flaws in the BVIL report. The
team members of AWHO and RWA MC who managed the testing are named in the report, indicating
their responsibility for the testing failures.

I once again recommended engaging IIT or another reputable agency for further tests. However, with the
help of RWA MC, AWHO awarded the contract to BVIL for approximately Rs. 60 lakhs without following
proper procedures or transparent tendering for such a significant and valuable project. Improper
conditions were included, allowing for arbitrary scope increases. An additional Rs. 10 lakhs were added
to the contract after its award. This raises serious concerns of irregularity and significant corruption.

In this regard, RWA MC failed miserably as they should never have permitted BVIL, who had previously
cheated the owners twice. Thus, the deliberate conspiracy is evident, and RWA MC's actions amount to
cheating and breach of trust instead of safeguarding the owners' interests.
Following the second testing, the buildings were inspected, and the BVIL report was evaluated by GEC
Thiruvananthapuram. However, necessary documents were not provided to GEC, resulting in their
inability to complete the work. GEC stated that BVIL's work was incomplete, while BVIL claimed that
GEC's work was unfinished. AWHO and RWA MC accepted BVIL's version because it suited their interests.
AWHO, supported by RWA MC, created complete chaos. Instead of raising objections to AWHO's
decision, RWA MC went along with them and discredited GEC's report without any scientific justification.
The failure of GEC's work was deliberately caused by AWHO and RWA MC by withholding necessary
documents and impeding a thorough on-site inspection. Officials of AWHO and RWA MC should be held
responsible for this failure.

The Chief Engineer (MES) inspected the buildings and identified serious findings, which were also
communicated during the inspection meeting:

(a) Poor-quality borewell water was used for construction.

(b) Faulty structural and concrete cover design.

(c) Fire hydrant pipes were installed through RCC beams.

(d) Corbels with low bearing capacity were provided.

(e) Long-span beams without adequate bearing capacity were installed.

AWHO and RWA MC conspired together, and despite my repeated requests, they did not provide me
with the report, to which I am entitled. If I had received the report, I could have suggested remedial
measures with the help of IIT or other agencies, potentially saving the structure. Officials of AWHO and
RWA MC should be held responsible for withholding the report.

The project management consultant, Ajit Associates, reported serious malpractices and corruption
during the project's execution. It is evident that AWHO HQ was well aware of these malpractices. RWA
MC should have vigorously pursued an investigation by AWHO. Despite their habit of forming teams for
various tasks, RWA MC deliberately neglected to form a team to investigate Ajit Associates' allegations,
aiming to keep them concealed. This collusion between RWA MC and AWHO resulted in further delays
and additional structural damages. Officials of AWHO and RWA MC should be held responsible for this
delay and failure.
The aforementioned actions of AWHO and RWA MC are just a few instances of collusion and conspiracy.
With more time and additional documents, I can provide further evidence of collusion between AWHO
and RWA MC, demonstrating their intent to cheat the owners and cause irreparable structural damages.
This unholy alliance between AWHO and RWA MC is the primary reason for the structural damages in
the post-possession stage that persist to this day. Blaming AWHO alone may not be appropriate, as
communications from RWA MC would establish that all decisions were made jointly with AWHO and not
by AWHO alone. AWHO and RWA MC should be held accountable for their malicious actions that have
led to structural damages over the past five years.

Even now, despite the CoI being ordered, AWHO and RWA MC have not provided me with the latest
technical reports, to which I am entitled as an owner. Their adamant attitude and disregard for the law
demonstrate their overconfidence that they can manipulate the court proceedings without
consequences. If the level of structural damage during the construction stage was 50% and has now
increased to 75%, officials of AWHO and RWA MC dealing with the case in the post-construction stage
are responsible for the additional 25% increase in damages (the percentages used here are hypothetical
for explanatory purposes).

The present test report is also not entirely reliable and valid. There is no evidence of scientific sampling
prior to the tests, and damages to the RCC slabs inside apartments have not been accurately recorded.
The foundation has been deemed okay without any scientific study. To conceal these deficiencies in the
report, it has been withheld from me. Any work conducted based on this report without third-party
verification from a reputable institute such as IIT would lack established validity and could have
disastrous consequences. Structural damages continue to occur due to the deliberate delays caused by
AWHO.

4) In light of the aforementioned circumstances, I am compelled to pursue one of the following

options as a purchaser of the property from AWHO:
(a) Complete demolition and reconstruction of the affected buildings (presently identified
as Tower B and Tower C) and associated infrastructure at no additional cost to the
owner.
(b) Refund of the price paid to AWHO, including transfer charges and interest, for owners
who are willing to relinquish their rights over the property.

5) AWHO, herein referred to as the Promoter, explicitly pledged to deliver the fully completed
project comprising 264 Dwelling Units (DUs), an amenity hall, a Sewage Treatment Plant (STP),
Pump Houses, and various other common amenities by December 2016. However, it has come
to light that the aforementioned project remains unfinished and has not been handed over even
after the lapse of five years subsequent to the acquisition of the door number and the
 subsequent receipt of the Occupancy Certificate (OC) and Completion Certificate (CC) from the
esteemed Thripunithura Municipality in March 2018. The contemplation of AWHO, its Managing
Director, and Chairman resorting to acts tantamount to criminal breach of trust against serving
personnel, retirees, and war widows, who, it must be noted, form an integral part of their own
brethren, has exceeded the bounds of my wildest imagination. This gross mismanagement of the
project, compounded by an inordinate delay, has resulted in substantial financial losses and
poses a genuine threat to our very lives. The perilous condition of Tower C, the edifice that
houses my residence, can be attributed to the utilization of substandard materials, corroded iron
bars, the employment of bore well water contaminated with alarmingly high levels of Chlorine,
an imbalanced mixture of cement and sand in the reinforced concrete employed for columns,
beams, and slabs, and sundry other cost-cutting measures implemented by Colonel
Muralidharan Nair (Retd), the esteemed Project Director (PD), and Director of Planning, Colonel
Atul Mohan (Retd), both of whom were hand in glove with the Developer, namely M/s Silpa
Projects & Infrastructure India Pvt Ltd, whose registered address is situated at 65/847-848, 3rd
Floor, North Avenue, Paramara Road, Eranakulam North, Kerala-682018 (CIN-
U70102KL2007PTC021063), governed by two Directors, Thundassery Surendran Sanil and
Palickal Karunakaran Shoney. It is crucial to acknowledge that the lives of countless proprietors
and occupants, including my own family, hang precariously in the balance, imperiled by the
grave corrosion that has manifested over the past five years.
6) The initial manifestations of distress became apparent to the owners in August 2018, a mere five
months subsequent to the issuance of the Occupation Certificate and Completion Certificate by
the Municipality. A formal complaint was duly lodged with the esteemed Project Director (PD),
Colonel Muralidharan Nair (Retd), and AWHO, drawing attention to the leakages observed in the
basement during heavy downpours, as well as the reappearance of conspicuous cracks on the
external walls of Tower B, specifically on the fourth and fifth floors, which were previously
concealed through substandard patchwork. Thereafter, the Resident Welfare Association (RWA)
embarked upon a continuous endeavor to apprise AWHO of the persisting defects plaguing the
towers. These anomalies included corrosion-induced cracks in the reinforced concrete (RC)
elements, such as beams and columns, primarily concentrated within the basements of Towers B
and C, in addition to the stairwell waist slabs on the upper levels. Moreover, the RWA highlighted
instances of leakage, seepage, and dampness within the basement's Retaining Wall (RW) owing
to heavy rainfall, as well as widespread spalling of concrete throughout the structures. It was
readily apparent, upon visual inspection of the distressed areas, that the corrosion of reinforced
bars served as the underlying causative factor. Regrettably, Colonel Muralidharan Nair (Retd), the
PD, consistently undertook patchwork measures devoid of addressing the fundamental issue of
corrosion, leading to the recurrence of cracks in previously repaired sections within a matter of
weeks.

7) Significant cracks have consistently emerged across all three towers, namely Towers A, B, and C,
as well as the Amenity Block. The subterranean basement has endured substantial leakage, with
 water infiltrating through cracks in the concrete walls. This distressing state of affairs can be
attributed to the corrosion of embedded steel bars, resulting in severe vertical cracks on
columns, beams, and slabs. The recurrence of cracks in previously patched areas, coupled with
considerable water leakage from the basement's retaining walls, has contributed to the
detachment of cladding granite in numerous locations within the elevator areas. Furthermore,
large fragments of cement concrete have been routinely dislodged from various parts of the
towers, even from significant heights, thereby posing severe threats to residents, visitors,
employees, and vehicles, and potentially giving rise to fatal accidents. One such incident
occurred, narrowly avoiding tragedy, when a concrete piece plummeted from an elevated
position onto a resident's terrace. To ascertain the gravity of the corrosion issue, a committee
headed by the present President, Maj Gen Rajagopl, in conjunction with other qualified and
competent owners such as Lt Col Anil Raj, an M.Tech in Civil Engineering from IIT Roorkee, and
Col Jassar, the Chief Works Engineer (CWE), conducted an exhaustive investigation, culminating
in a detailed report dated 09 August 2020 spanning 44 pages. A copy of said report has been
transmitted separately via email to the Presiding Officer, given its substantial size. Unfortunately,
no remedial action was undertaken by the Deputy Managing Director (Technical), the Managing
Director of AWHO, the Director of Planning, or their counterparts, thereby exacerbating the
situation of severe corrosion.

8) Owing to the complete lack of action by the initial Resident Welfare Association (RWA) under the
leadership of the former President, Brigadier Sunil Kumar, and the Managing Director (MD) of
AWHO, a few owners took it upon themselves to arrange for a thorough inspection of the three
corroded towers. This inspection was conducted by a competent and qualified Civil Engineer,
Professor (Dr) Elson John, Ph.D., from the Civil Engineering Department of Mar Athanasius
College of Engineering (MACE), Kothamangalam, Eranakulam. The report provided by Professor
John contains significant revelations regarding the extent of corrosion already present and offers
crucial recommendations. I respectfully request the court to review the contents of his report
and recommendations. It is worth noting that neither the RWA nor AWHO took any action based
on this report; instead, it was disregarded and left dormant. Attached herewith is a letter dated
06 October 2020 from Associate Professor (Dr) Radhakrishna Pillai of IIT, Chennai, addressed to
the former President of the RWA, Brigadier Sunil Kumar. The wise counsel provided in his letter,
stating, "The more you delay, the costlier and more challenging it will be to carry out proper
rehabilitation work," has indeed proven to be accurate after a three-year delay.

9) In response to persistent complaints regarding the severity of rusting in load-bearing columns,

beams, and slabs, AWHO found itself compelled to commission technical testing of the three
towers through the private firm Bureau Veritas Limited (BVL). However, it was revealed that the
testing process had been manipulated by the Developer (Contractor), M/s Silpa Projects &
Infrastructure India Pvt Ltd, who colluded with the Project Director (PD), Colonel Muralidharan
 Nair (Retd), Director of Planning Colonel Atul Mohan (Retd), and AWHO, the promoter, with the
ulterior motive of concealing the extensive corrosion in the three towers, thereby jeopardizing
the lives and properties of the residents.

10) The distorted and manipulated BVL report was subjected to evaluation and review by two
owners of CK, both highly qualified civil engineers: Colonel Ciby George (owner C0301), who
holds a Ph.D., and Colonel Anil Raj (B0803), an M.Tech in Civil Engineering from IIT Roorkee.
Their report, dated 05 December 2020, provides a comprehensive analysis of the flaws and
demands clarifications concerning the BVL report, including:

i. Non-disclosure of the work order and its terms and conditions, signed by the
General Manager of the Contractor rather than the PD, to the RWA until the
present date.
ii. Inadequate documentation of previous damages, repairs, sketches,
photographs, etc.
iii. Inaccurate and incomplete recording of work sheets.
iv. Inaccuracy and incompleteness in distress mapping, as indicated in paragraphs
10, 11, and 12 of their report.
v. Lack of evidence of a scientific procedure for sample selection for testing, as
discussed in paragraphs 14 and 15 of their report.
vi. Need for a complete review of the interpretation of test results, as significant
variations were observed when compared to relevant Indian Standards (IS/BIS).
vii. General nature of the inferences drawn by BVL, with a lack of specific and
scientific conclusions.
viii. General nature of the suggested restoration and corrective measures,
necessitating further detailed studies for specific areas, quantities, and
estimates.
ix. Lack of validity and reliability in the current form of the report, rendering it
inadequate for further action.
x. Necessity for a review of the concluding remarks pertaining to the structural
soundness, quality, and strength of the concrete.

11) Associate Professor (Dr) Radhakrishna Pillai from IIT, Chennai, and Professor (Dr) Elson John from
MACE, Kothamanagalam, Chennai, also evaluated the BVL report of November 2020.
Additionally, samples of the corroded concrete, extracted by BVL, were tested at the Civil
Engineering Department Laboratory of IIT, Chennai. Attached herewith is a review of the BVL
report and the results of chloride tests, dated 14 December 2020, provided by Associate
Professor (Dr) Radhakrishnan Pillai of IIT, Chennai, and Professor (Dr) Elson John of MACE,
 Kothamanagalam. Both experts possess authoritative knowledge in the field of corrosion and the
cathodic protection process. Their report exposes the manipulated and deceptive nature of the
BVL report, orchestrated by Colonel Muralidharan Nair (Retd), the Project Director who
collaborated with the Developer (Contractor of the Project), M/s Silpa Projects & Infrastructure
India Pvt Ltd, as well as Colonel Atul Mohan (Retd), the Director of Planning, in a concerted effort
to conceal the corrosion issues with active connivance from AWHO. The chloride test conducted
by IIT, Chennai, on the concrete samples revealed chloride content ranging from 2.46 kg/m3 to
4.94 kg/m3, which significantly exceeds the permissible limit of 0.6 kg/m3 according to Table 7
of the IS456 standards. The compromised BVL report falsely states the chloride content as 0.028
kg/m3 to 1.12 kg/m3, deliberately deceiving the owners—a clear and egregious breach of trust
committed by the PD, AWHO, and the Contractor, M/s Silpa.

12) The dire condition of the three towers poses a significant threat to the safety of individuals and
their property. Consequently, the former President of the Resident Welfare Association (RWA),
Brigadier Sunil Kumar, took the initiative to engage the expertise of Associate Professor (Dr)
Radhakrishna Pillai from IIT, Chennai, to conduct a thorough inspection of all three towers,
including the basement and water tanks, on 19 January 2021. Professor (Dr) Elson John from
MACE and Er Abhilash from IIT, Chennai, accompanied him during the inspection. The ensuing
report outlined several critical findings:
i. Numerous patch repairs have been carried out on columns, beams, and slabs.
ii. Repairs conducted using micro concrete and undercutting without proper
electrochemical treatment have led to the recurrence of corrosion.
iii. The source of chloride contamination could be attributed to the mixing and/or
curing water and/or fine aggregates.
iv. To accurately ascertain the level of contamination across different parts of the
buildings and recommend suitable repair strategies, further sample collection
and field/laboratory tests are necessary.
v. It was strongly recommended to conduct retesting and appropriate repairs
before the onset of the monsoon in June-September 2021. However, the Project
Director (PD), RWA, and Managing Director (MD) of AWHO failed to take any
further action despite receiving the report via email addressed to Maj Gen Vikal
Sahani (Retd), MD & Dy MD (Tech), in my individual capacity, and from the RWA,
which remained unanswered.

13) In response to the compromised report issued by Bureau Veritas Limited (BVL), the President of
the RWA, Brigadier Sunil Kumar, lodged a complaint with the National Accreditation Board for
Testing and Calibration Laboratories (NABL). As a result, BVL was compelled to conduct retesting
of all three corroded towers, including columns, beams, facades, and slabs, free of cost in
March-April 2021. The retested report by BVL was submitted on 15 May 2021 and unveiled
 severe mismanagement of the project, such as incomplete repair details, absence of structural
drawings and MEP drawings, lack of original test reports on soil and water used, insufficient
information on reinforcements, inadequate specifications and test reports on concrete and
plastering materials, excessive chloride content in the cover concrete, utilization of substandard
materials, and the use of saline/brackish water, among other issues. However, it is noteworthy
that the second round of BVL testing did not cover specific distressed locations on the higher
floors of Towers B and C, resulting in a wastage of precious time. Consequently, the corrosion of
the towers escalated further after the monsoon period of June-September 2021, contrary to the
advice provided by IIT, Chennai.

14) The activities subsequent to the second round of BVL tests conducted in March-April 2021 are as
follows:

i. On 3 July 2021, a Chief Engineer (CE) from the Kochi Zone conducted a technical
assessment of all three towers and subsequently submitted a report to AWHO
and HQ Southern Command, Pune. The brief summary of the report highlighted
the following key points:

Some primary beams in the basement area were found to lack proper column support, resulting
in shear cracks. Provision of supports at the beam junction should be explored.
(ii) The peripheral beams of Towers B and C have spans that are excessively long, leading to
tensile cracks. Additional support should be provided to reduce the span.
(iii) The penetration of fire pipes into the tension region of peripheral beams contributes to the
structural distress.
(iv) The design mix for pile foundations, as per the structural drawings, suggested the use of M30
Grade concrete. However, the CE opined that the mix design should have accounted for M40
concrete.
(v) The majority of cracks observed are of a structural nature.
(vi) The high chloride content detected in the tests indicates the possible use of brackish water
during concrete production.
(vii) The requirement for reinforcement cover, as per the relevant Indian Standard (IS), has been
compromised.
(viii) Excessive deflection and poor concrete quality in RCC beams may lead to the recurring
formation of cracks.
(ix) Effective treatment on the positive side is necessary to address the cracks in the RCC
retaining wall of the basement.
 (x) The distress exhibited by the three towers, such as cracks, peeling plaster, exposed rusted
reinforcement bars, facade cracks, falling granite cladding, and rusted rebars in the floors, is
primarily attributed to major deficiencies in quality control.
(xi) The repair work should be carried out comprehensively rather than relying on patchwork
solutions.

b) The submission of Bill of Quantity (BOQ) 1 took place in December 2021. The second round of
testing conducted by BVL was intended to identify the root causes of the severe corrosion and
distress that occurred within one year of the door numbers being allotted/completion of the
project. The owners, Colonel Ciby George (C0301), who holds a Ph.D., and Colonel Anil Raj
(B0803), an M.Tech in Civil Engineering from IIT Roorkee, found the tests conducted to be wholly
inadequate. Based on the report dated 15 May 2021, it took BVL an additional seven months to
prepare an incomplete and insufficient BOQ1, which only covered the minimum tested
distressed locations and excluded the higher floors entirely. As anticipated, the negligent actions
of the Managing Director, Deputy Managing Director (Technical), Director of Planning, and the
AWHO staff responsible for handling the matter resulted in a failure to take further action on
both the BOQ1 and the technical assessment report by the Chief Engineer (CE) from the Kochi
Zone, dated 3 July 2021. This resulted in the loss of valuable time, while the condition of all
three towers continued to deteriorate.

15) Visit by Esteemed Consultants. On the 19th of March 2022, a team consisting of Professor Pradip
Sarkar from the Department of Civil Engineering, NIT Rourkela, Professor Robin Davis from NIT
Calicut, and Assistant Professor Kiran CJ from Government Engineering College (GEC), Barton
Hill, Trivandrum, conducted a comprehensive inspection of all three towers. Accompanied by Lt.
Col. Arun Shekar, the Project Director (PD), Rear Admiral Ashokan (Retd), then President of the
Resident Welfare Association (RWA), Col. VK Pillai (Retd), former Secretary of the RWA, and the
technical team represented by Maj. Gen. Rajagopal (Retd) (Ex President & present President), Lt.
Col. Salin Kumar, and Mrs. Bindya Suthan, all owners and technically qualified individuals. The
findings of the inspection report highlighted significant flaws in the design and construction of
the towers. Regrettably, the report was not shared with the RWA. However, a copy of the
feedback provided by Rear Admiral Ashokan P (Retd), then President, in his letter No
113/CATAOA/AWHO/SSI/HTO dated 23 March 2022, was submitted to the Managing Director
(MD) of AWHO, with copies sent to the Adjutant General (AG), Chairman of AWHO, DG D(C&W),
GOC DB Area, GOC K & K Sub Area, Regional Director of AWHO, Southern Command, Pune,
Deputy MD (Tech) of AWHO, and the PD of AWHO Kochi. The revelations from the feedback are
as follows:
 i. According to the second report by BVL, the cracks in the building were attributed
to high salinity content in the concrete, carbonation of concrete reaching the
reinforcement level, and poor workmanship.
ii. The observations made by the Chief Engineer of the Kochi Zone focused on
structural distress and design deficiencies.
iii. The rectification process requires a hybrid approach involving corrosion and
carbonation treatment at various locations, as well as addressing structural
issues. To ensure quality control, it is imperative to appoint a qualified Project
Management Consultant (PMC), Project Director (PD), and a specialized
contractor with experience in executing similar works.
iv. The preparation of BOQ 2 for structural aspects lacks clarity, as Assistant
Professor Kiran C J stated that it was not mandated as per the Memorandum of
Understanding (MoU). This came as a surprise to the RWA and the technical
team, considering that the latest communication from the DG(C&W) on 28th
January 2022 mentioned that the work in the complex was tentatively scheduled
to commence by 15th March 2022 and be completed no earlier than December
2022. The ambiguity surrounding the agency responsible for preparing the BOQ
for retrofitting and rehabilitation work, as well as other activities such as tender
preparation, identification of a specialized contractor, supervising agency, and
tendering work, indicates that the targeted dates specified by the AG's Branch
are unlikely to be met. Furthermore, upon a detailed examination of the MoU
between AWHO and Government Engineering College, Thiruvananthapuram
(Paragraph 4), it is understood by the RWA that the BOQ will be finalized by BVL
after taking inputs from the design report.
v. The BOQ 1 for rehabilitation was prepared in April 2021, almost a year ago.
Additional quantities must be included to address the increased corrosion. This
has been confirmed by Assistant Professor Kiran CJ of GEC.
vi. Asst Prof Kiran CJ mentioned "Catholic Protection" as an option for long-term
protection, without providing further details on efficacy and methodology.
vii. The consultants recommended that AWHO must obtain a minimum warranty of
10 years and 5 years from the executing agency for those areas where
retrofitting and rehabilitation will be undertaken, as part of the contractual
agreement.
viii. The consultants have explicitly stated that no assessment can be made of the
future. The ongoing rehabilitation work is limited to areas where distress has
been observed. Considering the very high salinity levels and carbonation of
concrete reaching the reinforcement level, the possibility of distress in other
areas cannot be ruled out over time. Therefore, owners require a guarantee for
the original design life of 50 years. It is of utmost importance to incorporate
testing and future maintenance costs into the risk and expense of the original
contractor, M/s Silpa Infrastructure India Pvt Ltd. Adequate funds should be
retained for periodic monitoring and repairs, as the current rectification cannot
 be considered final. The responsibility for future repairs resulting from the
contractor's negligence should not be borne by the owners, both present and
future. It is strongly recommended that the complete funds of the contractor
(Silpa) and the structural consultant, in any form such as a bank guarantee or
any other instrument, be retained given the serious state of the towers. AWHO
should prudently prepare a legal document reflecting these considerations and
share it with the RWA. As stated by the consultants, the presence of high
chloride content and carbonation reaching the reinforcement levels necessitates
the provision of adequate funds to meet future requirements.
ix. A realistic timeframe for the repairs should be indicated. While the DG's
aforementioned letter mentions a duration of nine months, Assistant Professor
Kiran CJ opines that the scope of work would require 12 to 18 months.
x. Sharing of Documents:
The RWA requested a copy of the consultants' report, which was denied.
(ii) AWHO must share the BOQ and Rectification Plan as soon as they are ready.
k) Repair of Retaining Wall: It is reiterated that repeated repairs from the negative side have not
yielded the desired results. Therefore, the adopted solution should include repairs from the
positive sides as well to mitigate the issue to the maximum extent.
l) Completion of Balance Activities Before Commencement of Repairs: Further activities such as
tender preparation, identification of a specialized contractor and consultant, and contract award
will require a significant amount of time. However, due to the rapid deterioration of the affected
areas and the impending monsoon season, these activities cannot be delayed.

16) Subsequent to the Non-Destructive Tests (NDTs) conducted in April 2020 and March-April 2021,
additional damages resulting from corrosion have occurred. Consequently, it is imperative to
conduct fresh tests to ensure the correct implementation of rectifications. A work order for the
expanded scope has been requested from AWHO. The third round of tests conducted by BVL
commenced on the 18th of January 2023, and the report was submitted to AWHO in May 2023.

17) AWHO neglected to pursue any follow-up actions subsequent to the submission of the report by
GEC, Trivandrum, and NIT Rourkela to BVL in early April 2022. BVL only provided a report on 13th
October 2022, failing to include the BoQ 2. Several significant and grave conclusions can be
enumerated as follows.

18) Corrosion of Slab in C601. As recent as 14th May 2023, Lt. Lissy Cherian (Retd) discovered
corroded steel reinforcement beneath her floor tiles while replacing the severely rusted and
broken tiles.
19) Corrosion of Slab in C0501. A similar occurrence transpired in Flat No C0501, owned by Col Vimal
Varghese, wherein severe corrosion in slabs was observed. In a letter to AWHO, Col Vimal
Varghese described the distressing experience of loose tiles dating back to May 2018, and by
August 2020, corroded bars were visible beneath the floor tiles. Despite the evidence pointing to
corrosion as the cause of the tiles popping up, AWHO hesitated to acknowledge the issue,
thereby further delaying the urgently required rectification.

20) The third instance of significant corrosion was detected in flat No C0303, owned by Mr. Shankar
Saje. AWHO, in a dismissive manner, shifted the responsibility onto the owner for rectification.

21) The latest report from BVL, which was submitted to AWHO and RWA approximately two months
ago, has not been shared with the owners along with the BoQ. Both entities have failed to fulfill
their obligation of disseminating the report to the concerned parties.

22) Inadequate adherence to construction process management, as mandated for large-scale

construction projects, was evident from the contractor, project director, and AWHO's negligence.
The corrosion of concrete and resulting spalling can be attributed to one or more of the
following reasons:
i. Substandard construction quality leading to porous cover concrete, heightened
permeability to water/moisture, and other harmful materials and chemicals that
cause corrosion in steel reinforcement.
ii. Excessive water-to-cement ratio used in the concrete mix, resulting in porous
concrete with increased permeability and reduced structural durability.
iii. Inadequate compaction of concrete leading to porosity.
iv. Utilization of poor-quality water for mixing and curing purposes, including the
use of saline water such as bore well water (multiple bore wells exist in the CKAT
complex).

23) The former President, Rear Admiral Ashokan P (Retd), and the current President, Maj Gen
Rajagopal, have refused to share a copy of the latest BVL structural report and the most recent
BoQ dated 15th June 2023. They provided the feeble excuse that permission from AWHO is
required to disclose more than 145 annexures and a report spanning over 7000 pages. It is
requested that the court examines the findings, opinions, and recommendations presented in
the report to ascertain the responsibilities for the complete mismanagement of the CK project.
 An unsigned summary of the BVL Structural report (12 pages) was found in the CK WhatsApp
group originating from the RWA. Notable conclusions from the report are listed below.

24) Conclusions by GEC, Trivandrum:

i. As AWHO/PD did not share the original design document and numerical model
for the towers, GEC had to create them based on the good-for-construction
drawings provided.
ii. Astonishingly, there was no record of quality control procedures implemented
during the construction of the towers by AWHO, which is a matter of concern.
iii. Although Tower B and Tower C share a similar architectural layout, significant
variations in the structural layout adopted for both towers were observed. The
reasons for such deviations remain unknown. These structural layout differences
between Tower C and Tower B have contributed to the increased distress
experienced by Tower C.
iv. Numerous revisions were made to the records of Tower B and Tower C after the
finalization of the good-for-construction drawings, but the rationale behind
these changes was not documented.
v. While GEC was provided with copies of the original structural drawings verified
by IISC Bangalore, not all good-for-construction drawings carried the
endorsement of proof checking from IISC Bangalore.
vi. It was also noted that the orientation of Tower C had been altered from the
orientation specified in the proof-checked drawings.
vii. Deviations from the initial set of good-for-construction drawings were observed
in the structural layout of the parking area. Certain columns were replaced with
corbels attached to the tower columns during this process. Distress has been
observed in all locations where columns were substituted with corbels.
viii. The primary cause of structural distress is attributed to accelerated steel
reinforcement corrosion. This is due to the high chloride content in the concrete
and the rapid carbonation of the cover concrete, as indicated by the test results
provided in the BVL Report (April 2021). It is recommended to incorporate
proper cathodic protection for the steel reinforcement during the retrofitting
process.
ix. The high chloride content in the concrete, as determined by BVL, is present
throughout the entire structure. It is worth noting that only the cover concrete
of the basement and stilt floor columns is accessible for retrofitting. The upper
floors, obstructed by internal walls, are non-accessible. Retrofitting structural
members above the stilt floor may prove highly impractical and uneconomical.
x. NDT has not been conducted on the inner walls. The execution of retrofitting in
the duct areas presents difficulties due to their inaccessibility in the current
condition, with plumbing and electrical pipes located within the duct areas.
 xi. Serious design issues, such as torsional irregularities in the building structure
and the inability of a significant percentage of structural members to bear loads,
have been identified.
xii. The preparation of the BoQ cannot be based on the methodology submitted by
GEC, Trivandrum.
xiii. The contractor selected for the retrofitting process must provide a
warranty/guarantee for a minimum period of 15 years.
xiv. The retrofitting proposed in this report addresses the current distress state of
the structure. However, if additional distress (beyond what is mentioned in this
report) occurs at a later stage, suitable retrofitting and rehabilitation work must
be designed and implemented, which falls outside the scope of our study.
xv. The design and instrumentation required for monitoring the retrofitment are
beyond the scope of our study.
xvi. No information regarding legal actions taken related to the distress has been
shared with us.

25) BVL Conclusions:

i. The scope of BVL's work is limited to reviewing the Structural Assessment of
Tower B & C and the adopted methodology by GEC for the assessment. BVL's
responsibility is to provide the BOQ for retrofitting works and propose three
contractors for the retrofitting work. However, it should be noted that BVL's
decision on the retrofitting contractors and the status of the building with
distress and continued distress is not binding, as it remains the sole
responsibility of AWHO.

ii. The Structural Assessment Report provided by AWHO, prepared by GEC,

includes the design basis report, ETABS results for demand vs capacity
evaluation without distress, and distress conditions assumed due to corrosion of
reinforcement for existing Tower B.

iii. The building is situated in an environment classified as "very severe" as per

IS456, Clause 8.2.2.1 and Table 3. From the drawings, it is evident that the cover
provided for columns and walls is insufficient, which directly impacts the
durability of the structure.
 iv. GEC provided the capacity and demand analysis for columns and shear walls for
only a few floors under distress conditions. However, no information was
provided regarding horizontal floor plate structural components, such as beams
and slabs, foundation, and retaining walls of Tower B. It should be noted that
ETABS stands for "extended 3D Analysis of Building Systems."

v. The time period calculation based on the minimum base shear as per Table 7,
Clause 7.2.2 of IS 1893-2016 indicates that the actual Base Shear exceeds the
minimum base shear, and the time period evaluation needs to be rechecked.

vi. The reinforcement used for evaluating the capacity and demand of columns and
shear walls in Tower B without distress is based on the GFC drawings provided to
us.

vii. The furnished ETABS model by AWHO, prepared by GEC, is applicable for the
condition without distress for Tower B. However, the report only contains the
demand vs capacity ratio for distress conditions up to the first floor.

viii. While demand vs capacity without distress is provided from the basement floor
to the terrace level in Chapter 2 of the GEC report, the available reinforcement is
only considered up to the first floor level in the ETABS model. The available
reinforcement should have been applied for all the floors in the ETABS model.

ix. Demand vs capacity with distress is provided from the basement floor to the
ground floor and from the ground floor to the first floor in Chapter 3 of the GEC
report. However, the demand/capacity ratio for columns and shear walls of the
above floors is not furnished, making the GEC report incomplete.

x. The conclusion that it may be highly impractical and uneconomical to plan

retrofitting structural members above the stilt floor needs to be revisited.
Strengthening should be considered as per design requirements for any floor
where strengthening is deemed necessary.
 xi. The report lacks information on strengthening above the first-floor level.
Strengthening, wherever required as per design requirements, needs to be
provided floor-wise for both distress and without distress conditions.

xii. The complete details of the demand and capacity evaluation for all structural
components of the building with distress are not furnished. The furnished
details are limited to columns and shear walls for a few floors, making it
impossible to draw conclusive findings with incomplete information.

xiii. AWHO/GEC has not provided details of beams and slabs and their distress
condition. Any required strengthening for beams and slabs should be evaluated,
although it falls outside the scope of BVL.

xiv. The calculation for the capacity of strengthened structural members from all
four sides is not furnished and should be submitted by AWHO.

xv. AWHO/GEC has not provided the ETABS model for analysis and design for each
case, adequacy evaluation of the foundation, capacity evaluation of columns and
shear walls after strengthening, adequacy of slabs and beams, and adequacy of
retaining walls.

xvi. The strength and quality assessment of the piles and pile caps could not be
carried out due to the high water table.

xvii. The cover meter study reveals inadequate cover concrete provided to the rebars
at most locations.

xviii. The Half Cell Potential Tests indicate a probability of corrosion ranging from
"Uncertainty of Corrosion" to "High Probability of Corrosion."
 xix. Carbonation test results indicate that carbonation in concrete has reached the
reinforcement level in most of the tested RC members, which signifies a loss of
alkalinity essential to protect the rebars from corrosion.

xx. Chloride content test results in the tested RC members exceed the permissible
limit of 0.6 kg/cm3.

xxi. The groundwater quality in the area does not meet the requirements for
plain/reinforced concrete.

xxii. Out of 12 columns and 37 shear walls, almost all shear walls, except the lift wall,
are overstressed (with a demand-to-capacity ratio greater than 1).

xxiii. Many beams and slabs do not satisfy the deflection criteria. Specifically, 8 out of
32 slabs on the ground floor, 9 out of 24 slabs on the first floor, and 45 out of
552 slabs from the second to the 22nd floor require reinforcement.

xxiv. Anti-carbonation treatment is required for all the RC members.

xxv. BVL is not responsible for the distress of the structural members or any
continued distress. If any retrofitting works are required, AWHO must appoint
experienced retrofitting contractors as proposed by GEC, Trivandrum.

xxvi. The main cause of distress to the structure is attributed to the accelerated rate
of corrosion of steel reinforcement, resulting from the high chloride content in
the concrete and rapid carbonation of the cover concrete. During the retrofitting
process, it is recommended to provide proper cathodic protection to the steel
reinforcement to prevent future corrosion.

26) The reprehensible actions of M/s UNITECH & AMRAPALI (whose Managing Directors and
Directors are currently incarcerated) pale in comparison to the callousness, negligence, inaction,
and unprofessional conduct exhibited by the parties involved in the matter at hand, including the
President of the Board of Governors (BOG) of the Army Welfare Housing Organization (AWHO),
General MM Narvane, and 41 aggrieved owners, myself included. On February 22, 2021, we
 submitted a formal representation to the aforementioned individuals, highlighting ten serious
grievances related to the CK complex and urging a thorough investigation. Astonishingly, it took
more than two years for the present Staff Court of Inquiry (CoI) to be initiated, and even then,
Tower A (consisting of 56 dwelling units) was excluded from its purview. Meanwhile, the real
culprits, namely the former Project Director (PD), Col Muralidharan Nair (Retd), who was
removed on March 31, 2021, and Col Atul Mohan (Retd), the Director of Planning (a contractual
staff), were allowed to escape the consequences of their actions with minimal repercussions
imposed by AWHO. It is now imperative that the staff CoI identifies those responsible for the
situation and recommends appropriate measures for recovery. This miscarriage of justice is a
disgrace, considering that AWHO, an organization purportedly dedicated to welfare, along with
M/s Silpa Infrastructure, the contractor involved, are the true perpetrators who have managed
to evade accountability thus far. The real victims of this travesty are 264 active and retired
Armed Forces personnel and their dependents, who have been betrayed by an organization that
claims to operate on a "No Loss No Profit" basis but has, in reality, profited immensely from
most of its projects.

27) The inspection reports reveal compelling evidence of severe corrosion within the towers and the
consequent damages, pointing to nothing short of criminal negligence on the part of AWHO,
particularly its Managing Director, Deputy Managing Director (Technical), the former Project
Director, Col Muralidharan Nair (Retd), the former Director of Planning, Col Atul Mohan (Retd),
and the contractor firm, M/s Silpa Infrastructure. The actions of this group amount to numerous
criminal offenses, including the use of substandard materials, poor workmanship, flawed design,
inadequate supervision, absence of quality control measures, insufficient record-keeping,
utilization of bore well or brackish water, and the list goes on. Such deliberate acts and omissions
at various levels indicate a clear breach of trust, cheating, criminal negligence, corruption,
passing the blame, and even illicit enrichment on the part of all the individuals mentioned
above. Professor Ajit, the Project Management Consultant (PMC), rightfully accused the former
Project Director and the contractor of engaging in "malpractices that compromised the quality,
involved illicit gratifications, and amassed wealth." Consequently, only a comprehensive
investigation can uncover the complete truth behind these allegations (Professor Ajit has also
demanded a Vigilance inquiry), and any delay in taking action would pose significant risks and
dangers to the lives and property of the residents.

28) AWHO, the promoter responsible for numerous other malpractices and criminal breaches, has
made life unbearable for innocent and unsuspecting followers. Several instances exemplify this
misconduct:
i. The land conveyed through the sale deed was supposed to be free from
encumbrances. In reality, the accused had already created third-party interests,
such as the Kochi Metro Rail Ltd (KMRL), on the land sold to me and the other
 264 allottees. Despite their awareness of this fact, the accused concealed it from
us, resulting in the loss of approximately 22 cents of land without our knowledge
or consent, amounting to crores of rupees. AWHO committed a serious criminal
breach of trust by withholding this crucial information from us (the 264 owners).
KMRL has not provided any compensation to date, including rent for utilizing the
land since 2013.
ii. Despite repeated requests, various approvals and clearances, including the
necessary Coastal Regulatory Zone (CRZ) clearance and the conversion of land
from wetland to a suitable area for construction in the revenue records, have
not been provided. This deception has left us feeling completely cheated,
deceived, and devastated during our twilight years. The Revenue Divisional
Officer (RDO) of Fort Kochi demanded a sum of Rs 5,13,21,000 for land
conversion in their letter dated January 13, 2021.
iii. The former Project Director, Col Muralidharan Nair (Retd), entered into a
contract with Prof Br Ajit, the PMC, using the Power of Attorney obtained from
AWHO, and unlawfully spent approximately Rs. Forty-Five lakhs of the owners'
funds, including mine, to construct a road outside the project site on land
owned by Prof Ajit, in collusion with AWHO. This clear case of criminal breach of
trust resulted in significant losses to me and the other owners.
iv. The former Project Director, Col Muralidharan Nair (Retd), and AWHO sold 29
guest car parks for substantial profit. To compensate for the deficiency, the
common area was encroached upon, resulting in additional car parks for guest
use. AWHO has failed to resolve this issue, and the matter is currently with the
CK Plan Approving Authority, i.e., the Thripunithura Municipality.
v. AWHO promised green building facilities, such as solar water heaters and solar
lights. However, these amenities were either not provided or rendered
inoperable, causing significant financial losses for me and the other owners.
Additionally, the former Project Director attempted to extort Rs. 10,000 each
from the owners to issue green building certificates, which were supposed to be
issued free of charge by AWHO. Only after the intervention of the then
Chairman of AWHO was the certificate finally issued. Complaints against the
former Project Director were swept under the rug, and no action was taken
against him by AWHO.
vi. The former Project Director, Col Muralidharan Nair (Retd), facilitated the
unauthorized conversion of two dwelling units owned by a senior retired Army
officer (father) and a serving Army officer (son) into a duplex by cutting open the
floor and installing an internal staircase. AWHO refused to take action against
the Project Director and the violators, dismissing my complaint.
 29) Considering the aforementioned facts and circumstances, it becomes evident that all 264 owners
of the dwelling units have fallen victim to widespread fraud, embezzlement, and criminal breach
of trust committed by the former Project Director, the former Director of Planning, the Managing
Director, the Deputy Managing Director, and the Contractor, acting in concert. Each of these
individuals has engaged in criminal acts resulting in substantial harm, losses, and constant fear
for the lives of myself, my family, and other residents. I respectfully implore the court to record
the statements of as many owners as possible to unravel the intricate web of collusion and to
recommend a Central Bureau of Investigation (CBI) inquiry to bring the perpetrators to justice.

30) In truth, all 264 residents of the apartments within the complex have equally endured the
consequences of criminal actions. The offenses involve substantial monetary value, and there is
a genuine threat to the lives of hundreds of occupants in the complex. This situation is highly
distressing, as the building weakens over time and with changes in climate, posing a looming
catastrophe. The potential loss of lives for hundreds of residents, including senior citizens,
veterans, war widows, and children, is a grave concern.

31) The occurrence of such significant distress within a year of the building's handover has caused
immense anxiety among owners who placed their trust in AWHO and invested their life savings.
Over five years have elapsed since the initial complaint was lodged with AWHO, yet no
restorative action has been initiated thus far. With each passing day, the condition of the towers
further deteriorates. It is crucial that remedial work commence without delay. Moreover, the
unsatisfactory or untested parameters highlighted in the test results conducted by BV will
continue to pose challenges even after the proposed restoration. The responsibility for
addressing these defects rests solely with AWHO and the builder and cannot be shifted onto the
owners. Therefore, adequate funds must be allocated for future requirements in addition to the
initial rectification work.

I hereby affirm that the above statement is true to the best of my knowledge, and I sign it as accurate.