Complaint Against Sundaram Group

Beach Minerals

Jan 17 2014

Respected Sirs,


Sub: Abuse and misuse of their position of being Retired

         I.A.S. Officers  by Mr.V. Sundaram and Mr. M.G.

         Devasagayam towards aiding   and abetting one Mr.

         Dhayadevadas in all his misdeeds like illicit –

         mining of garnet sand, other connected anti-national

         and anti-social   activities – Action to be taken against

         them under National Security   Act and also terminate

         their pension and other retirement benefits–Requested-

         Representation – Submitted.


We submit the following representation and request you to initiate appropriate legal and administrative action against Mr. V. Sundaram, I.A.S. (Retd.) and Mr. M.G. Devasagayam, I.A.S., (Retd.) for the abuse and misuse of their enviable position towards abetting,  aiding and shielding one Mr. Dayadevadas in all his misdeeds such as illicit mining clandestine, transportation and unauthorized sale of garnet sand from Tiruchirappali district, Tamil Nadu and thereby render justice to us.

The Constitution of India provides adequate security of service and immunity to the Officers of Indian Administrative and other allied cadre services against all their acts done only in good faith.  Likewise, the criminal justice system  too as enshrined in the Cr.P.C. and I.P.C. confers magisterial status upon them to discharge certain essential duties under emergent situations.   Albeit these special status accorded exclusively to Indian Administrative and other allied cadre officers is tantamount to perpetuating the colonial legacy of British raj, they are considered absolutely essential only in the context of good governance and administration.  One has to tolerate whatever these cadre officers do while they happen to be in service even if their doings are not in good public interest.  After the retirement of these officers from service, if they indulge in some activities with the same old pre-retirement mind set as the agent and tout of their pay masters – other masters which are detrimental to the overall national interest, such activities should not only be condemned by the severest of terms but also such officers should be brought to book and justice under National Security Act for their such excesses.  All of their after retirement benefits should also be withdrawn forthwith in the national interest.

Adverting to the specific actions of these  retired cadre  officers concerned in the recent years, it is submitted that Mr. V. Sundaram, a Tamilnadu cadre I.A.S officer and Mr. M.G. Devasagayam, a Haryana cadre I.A.S. officer and these two retired officers who are acting as the agent and tout of one Mr. Dayadevadas who is a garnet sand mining lessee in Tamilnadu and  are aiding, abetting him in all his illicit mining,  transportation and sale of garnet sand thereby causing several crores of rupees loss of revenue both to the Central and State governments.  The primary assignments of these two officers are not only to shield and protect Mr. Dayadevadas from all his unauthorized activities but also send baseless allegation petitions against other lessees in Tamil Nadu and on his behalf, make representations before the Central and State Government authorities by virtue of their being retired I.A.S. officers on behalf of Mr. Dayadevadas.  Mr. V. Sundaram has gone a step further to file an implead petition in a P.I.L. in the Hon’ble High Court of Judicature at Madras against all the mining lessees of Tamilnadu which has been summarily dismissed after exposing his motive and his being an agent of Mr. Dayadevadas.

Formation and Evolution of Mines and Minerals (Development and Regulations) Act, 1957.

After independence, the legislature of the Dominion of India enacted “The Mines and Minerals (Regulation and Development) Act, 1948 which was brought into force on October 25, 1949.

In 1957, Parliament decided that the Regulation and Development of Mines and Minerals should be governed by a separate Act and consequently, the Mines and Minerals (Regulation and Development) Act was renamed as Mines and Minerals (Development & Regulation) Act, 1957.

The Mineral Concession Rules, 1960 was framed by the Central Government under Section 13 of the said Mines and Minerals (Mines and Minerals (Development & Regulation) Act, 1957.

The minerals are classified as ‘Major’ and ‘Minor’ as enshrined under Section 3 of Mines and Minerals (Mines and Minerals (Development & Regulation) Act, 1957 under the caption “De-function”.

Under Section 15 of Mines and Minerals (Mines and Minerals (Development & Regulation) Act, 1957, the State Governments are statutorily empowered to frame their own policy and rules governing grant of mineral concessions only in respect of minor minerals.

In respect of major minerals, the powers to frame suitable policy, Act and Rules are vested only with the Central government.

State Governments are empowered to grant mineral concerns in respect of all minerals except those minerals which are specified in the I Schedule of Mines and Minerals (Development & Regulation) Act, 1957.  However, as per the proviso clause to sub-section (b) of Section 5 (1) of Mines and Minerals (Development & Regulation) Act, 1957, the State Government shall not grant a mining lease to any person in respect of I schedule minerals except with the previous approval of the Central government.  These are all the statutory provision as exist in the Mines and Minerals (Mines and Minerals (Development & Regulation) Act, 1957 and Mineral Concession Rules, 1960 in force.

Geological facts about the occurrence of rare minerals (Beach sand minerals)

Our country has a long coastal tract extending for a distance of about 7,000 Kms both on eastern and western sides.  In the coastal areas of Tamil Nadu, Kerala, Andhra, Orissa, Maharashtra, etc  States, rare minerals are being constantly washed ashore and got deposited periodically.  From time immemorial, these rare mineral deposits were lying unexploited and unutilized upto 1940s.

Realizing the importance of the utilitarian and export value of these minerals, the Central government established M/s. Indian Rare Earths Ltd (IREL) , a subsidiary of Government of India.  Their organization was mining and selling rare minerals only in raw form.  Subsequently since there was no competitor upfront in this field of mining of these rare minerals taking advantage of their holding monopoly over the supply of these minerals, the unscrupulously and self centered officials of M/s. Indian Rare Earths Ltd. were selling these minerals to the locals at a low price without adopting tender process regarding fixation of price for these rare minerals.  Among the various private companies which were regularly getting these minerals for such low price from M/s. Indian Rate Earths Ltd., the company called M/s. Indian Garnet Sand Co. owned by one Mr. Dayadevadas is one of them.  In this respect both the company and the Central government had sustained a huge loss of good amount  income on account of the above said practice adopted by Tvl. Indian Rare Earths Ltd.  The private company Indian Garnet Sand Company, on the contrary,  earned enormous profits.

The unique and peculiar feature of these beach sand deposits of rare minerals is that whenever there is transgression of sea water through constant wave actions,  deposition of these minerals on the coast line  takes place.  When there is regression of sea water, large quantity of these deposits is taken back into the sea in equal measure.  This is a constant process taking place almost on daily basis.  The intensity of this action increases during full moon and new moon days.  Researches have shown that these deposits are also transported due to strong under current in the sea bed into far off places well-nigh from one shore to another shore of other countries as well.  One such deposition of rare minerals in a place called “Pulmodai” in Sri Lankan coast is being profitably exploited by the Sri Lankan Government for their development.

Considering the huge availability of such resources of beach minerals (rare minerals) in the coastal areas of this country and also taking into reckoning the limitations in the exploitation of resources by the State and Central Government undertakings and also considering the demand for these minerals both in domestic and overseas markets, the Central Government announced a ‘National Mineral Policy’, 1993 exploitation on beach mineral resources.   The notification has been issued so as to facilitate removal of unnecessary regulations causing restrictions on mining of these mineral resources.  Prior to such notification, even Indian owned private companies were not permitted to mine/handle Ilmenite, Rutile, Zircon, Leucoxene etc. minerals.  They were allowed to mine/handle only garnet sand.  As per the recommendations of the committee constituted under the new policy on beach minerals, the Indian owned private companies were also permitted to mine/handle all the beach sand minerals.  This policy has facilitated several  dynamic Indian owned private companies to explore market abroad for all types of rare minerals, export them to foreign countries thereby earning enormous foreign exchange to the Central government. In order to encourage export of these minerals, Ministry of Commerce., Government of India established ‘CAPEXIL’ through which awards are being presented to the largest export annually.  The ‘CAPEXIL’ on its part, organizes periodical meeting to hear the view points of the exporters from all fields and espouse their cause of export of minerals and other commodities by initiating action to remove the bottlenecks ,if any ,faced by them in this regard.

The Department of Science and Technology, Government of India also earmarked a sum of Rs.10/- crores to unearth garnet sand deposits and to encourage export of them.  Various universities have carried out investigation for identifying the occurrence of these deposits and submitted report to the Government.

If these mineral deposits are not caused to be properly utilized, there is likelihood of these minerals being filtered away as waste sand or washed away into the sea bed once again without  being useful to anyone..

In the beach mineral sand production, the countries like U.S.A., Australia and South Africa had occupied top three positions in that order.  Despite the fact that India has large resources of these rare minerals, it had once ranked 14th in the above list.  Due to the tangible and practical steps taken by the Government of Tamilnadu in the matter of grant of mining leases without any delay, issue of transport permits and helping the lessees in all possible ways, India is able to secure top position at present.

After being dethroned from the top position, these countries spread a net to woo and catch unscrupulous businessmen in our country to destabilize our legitimate business in this filed thereby destroying our economy as well.  One such company which has fallen into the evil of design of the foreign countries is a company owned by one Mr. Dayadevadas who has already been an established and notorious illicit mining don in the Tiruchirapalli district of Tamil Nadu.  In order to hush up all legitimate actions against him, Mr. Dayadevadas had initially taken the help and support of a former Member of Parliament and a Central Government minister by offering him a partnership in his company.  After the said M.P. lost in the general elections thereby losing his ministerial position as well, Mr. Dayadevadas, disowned him and sought the help and support of two retired I.A.S. officers namely Mr. V. Sundaram and Mr. M.G. Devasagayam.  One retired railway official also has been his accomplice.   Mr. V. Sundaram does not invest the money illegally obtained from Mr. Dayadevadas in India.  He has been        stashing away the black money in the name of his daughter in Singapore.

The primary assignment given to them by Mr. Dayadevadas is to send false petitions against all the beach mineral mining lessees except Dayadevadas repeatedly to various departments of both Central and State Governments only with the oblique motive to stop the legitimate mining operations thereby crippling the entire business.  This act will tacitly help the foreign companies to flourish in their business thereby facilitating them to restore their previous position in the business ladder.  These anti national people who are working against the national interest should not only be brought to book and justice under National Security Act but also the news should be disseminated and spread widely through electronic and print media. 

Lot of money is being spent to engage some Members of Parliament also to raise questions on the floor of Parliament against us.  If the Parliament records are caused to be perused, the master minds of Mr. V. Sundaram, Mr. M.G. Devasagayam and Mr. Kalyanasundaram, a retired railway official behind such questions can be easily decoded.

The following are the clarifications based on the Mines and Minerals (Development & Regulation) Act, 1957, Customs Act, etc. on the baseless allegations of these “trio” retired officers.

          a)  The export of any mineral is not governed by Mines and Minerals (Development & Regulation) Act, 1957 as it does not fall within the purview and ambit of the said Act.  There is no restriction in the said Act to purchase any mineral from the legitimate and lawful mine owner and export the same.  We are mining and exporting beach sand minerals from our own legitimate and lawful mining leasehold areas.  On the contrary, Mr. Dhyadevadas, who is being aided, supported, abetted, and protected by these three retired officers alone  has indulged in illegal mining, clandestine transportation and unauthorized exporting of garnet  mineral.

          b)  In terms of ‘EXIM’ policy, a lawful Indian citizen is free to export all commodities including mineral except those which are banned or prohibited.  These three officers are conspicuously silent on all these legitimate business of us.

          c) In order to encourage export, the Central government has introduced ‘Export oriented unit’ plan.  There is no hard and fast rule in the Mines and Minerals  (Development & Regulations) Act, 1957 that mining lease is a must or necessary for establishment of an ‘EOU’. Even an E.O.U. holder can run his/her unit successfully by purchasing the required raw material from the legitimate and lawful source of mining.  These retired officers raise their baseless and false allegations against the EOU units that without citing any rule under which they  raise their allegations.

d)  They raise false allegations that V.V.Mineral is encouraging illegal mining without even bothering to mention the details such as S.No., village, etc. from where they are carrying out such illegal mining.

e)  They do not also mention the details about the quantity they have exported and the quantity for which they have obtained transport permits.  These details are absolutely necessary to corroborate and establish the quantity that any individual/company has exported illegally.

f)  V.Sundaram, Devasagayam and Kayanasundram influence certain officials of the State Government by virtue of their previous enviable key positions to file counter affidavit to suit their purpose.  On his part, Mr. Dayadevadas has been using these statement only to threaten the officials to further his illegal business interest.  Further, they know pretty well that V.V.Mineral have been carrying out their mining operations only after obtaining all necessary clearances from the appropriate authorities of both Central and State Governments but they do not deliberately want to mention all these facts..

g)  In order to exaggerate matters to alarming proportions, they intentionally complain that ‘Thorium’ is being illegally exported for the simple reason that ‘Thorium’ has radioactive properties. They know that it is not that easy process to obtain ‘Thorium’ from raw monazite ore.  It requires ‘Reactors’ which can be set up only by the Central Govt.  They know these technological facts but deliberately feign ignorance in this regard. They use their brains only in a crooked manner for destructive purposes. The Department of Atomic Energy issued press release No. 10/2012 which can be downloaded from the following link :

h)  It is a well known and established fact that beach mineral  sands are replenishable deposits.  The deposition  of these minerals in the coastal areas take place and also varies according to the intensity of wave and wind action.  These criminal minded people know these facts fully well but they deliberately suppress these facts and conspicuously remain silent on these they know that facts since these facts do not help their sinister motive and cause.

Mr. Dayadevadas has taken photographs with Hon’ble Prime Minister and Central ministers in some public functions or a social gathering.  He uses these photographs only to threaten the officials of both central and state government to show that he is  close to the higher circles in the centre.  The three criminal minded officers are working in tandem with this illegal don Mr. Dayadevadas.

In a PIL filed in the Hon’ble High court of Madras, the Hon’ble court has ordered a probe into the averments contained in the PIL and accordingly, the District collector, Tiruchirapalli had constituted a team of officials of Revenue, Forest, Geology and Mining, Environment, P.W.D., E.B., etc. Departments which have brought out the following startling facts and revelations against Mr. Dayadevadas, that  –

i)  he has obtained mining leases by suppressing several facts and executed the lease agreement without fulfilling the basic essential guidelines imposed the Ministry of Mines, Government of India.

ii)  he has obtained a mining lease for an area which has no sand deposit at all but contains only rocks.

iii)  He has paid royalty only for a quantity of about 2.75 lakhs tonnes but has illegally transported about 39 lakh tonnes.  The district officials have seized red handed about 14 lakhs tonnes.

iv)  The Ministry of Environment and Forests have stipulated a condition that mining of garnet shall be carried out only upto 5cm according to which stipulation that only 4000 to 15,000 tones could have been mined by him.  But Mr. Dayadevadas has mined lakhs and lakhs of garnet sand with the support of these corrupt retired officials.

v)  Because of large scale illicit and indiscriminate mining of Mr. Dayadevadas, the entire stream course is reported to have been obliterated, agricultural operations and drinking water sources affected, the check dams across the stream course damaged, embankments, culverts, etc. damaged.

vi)  Inspite of these ground realities, Mr. Dayadevadas continues to carry out illicit mining in Tiruchirappli District only with the patronage and support of these two retired I.A.S. officers because these two I.A.S. officers are able to exert pressure and wield tremendous influence on the down line officers in the State administration by virtue of their former official position.

In this context, we only request you to visit the website to find out the veracity of our statement that these three retired officers are working in tandem with the illicit mining don Mr. Dayadevadas. Mr. V. Sundaram, in particular, has filed a PIL in support of Mr. Dayadevadas. Mr. V. Sundaram, Mr. M.G. Devasayagam and Mr.  Victor Rajamanikkam all three are participating in all the discussions and interviews against us in the same news channel and print media as proxy for Mr. Dayadevadas.  This fact also can be verified by visiting the website

In the light of the facts submitted above, we humbly request that necessary strong action may be initiated against

a) Mr. V. Sundaram, Mr. M.G. Devasagayam and Mr.Kalyanaraman to bring them to book and justice under National Security Act for their complicity, withdraw all their retirement benefits forthwith.

b)  Mr. Victor Rajamanikkam has worked in several central government and state government organizations.  Therefore, his involvement in the multi-crore expenditure in those organizations must be ordered to be probed by a competent audit team.

c)  Action maybe initiated against Mr. V. Sundaram for his stashing of ill-gotten money in Singapore in his daughter and his son-in-law name and all the black money must be brought back to India.  The concerned persons must also be arrested and brought to India for detailed interrogation and facing trial.

d)  The foreign company involved in such bribery must also be brought to book with the help of ‘Interpol’ and persons responsible for this flight of money from India must be arrested and brought to India for enquiry and facing trial.

e)  The master brain of Mr. Dayadevadas who is behind all these anti-national activities must be arrested under National Security Act.  The scope of this investigation should be extended up to the Central Ministers as well  who are found responsible to help Mr. Dayadevadas in all his illegal activities.

f)  A blanket order may be passed both the Central government and State Government of Tamil Nadu not to consider the mining lease applications of M/s.Nila mines since the company is working in close association with Mr. Dayadevadas in all his above said illegal activities.

g) Action may be caused to be initiated against one Mr. Anil Subramanian, Under Secretary to Govt., Ministry of Mines, Government of India, New Delhi who is also intimately involved in the deep seated conspiracy with Mr. Dayadevadas and also against Mr. Ashishkumar, I.A.S., Tamilnadu who has helped Mr. Dayadevadas and M/s.Nila mines in all of their illegal activities in Thoothukudi district.

We therefore request your dispassionate action on our above representation and bring all the above mentioned culprits to book and thereby cleaning the system in the field of mining of rare minerals in Tamil Nadu and protecting all those who are carrying out their mining operation in lawful manner.

Awaiting your favourable immediate action,

Thanking you, Sir,

Yours  Truly,



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