(1.) Yesterday i.e. 26.8.89 by about 6.15 p.m. when the Mill Spinning Superintendent Thiru.Vasudevan Nair, Personnel Officer Thiru.A.Natarajan and Maintenance Manager Thiru.S.S.Mohanram were returning home from finishing their work in the mill with a Ambassador car bearing Regn.No.TAA595 which belongs to the Mill, you have blocked our car between Pagaiyani village and Nemmaalli Village (Ramanathapuram-Devakottai Main Road) in a narrow bridge with two cycles and you had intention to attack them.
(2.) At about 6.30 PM when the mill car driver byname Bhagavathy after seeing the cycles blocking the road on the bridge, he had no way to drive the car and stopped. At that time S.Chelladurai, A.Mohanram, K.Palanisamy and S.Muthuraman who were assembled and appeared suddenly before them them with dangerous weapons like knife, Aaruval Velkambu and sticks. S.Chelladurai opened the car door and asked the driver to come out of the car, pulled his hand and pushed him out of the car. Then all of you joined together and along with one K.Ramasamy who was ex employee of the mill and abandoned the service, attacked the car driver and inflicted severe wounds. Further you have threatened the car driver; Not to move from this place otherwise we will kill you.
(3.) In continuance of the incidents narrated in para 2 above you have threatened the Mill Superintendent Vasudevan Nair shouting with the words ;what you are thinking of us? you are fighting with us without knowing our self, you have refused to negotiate with us regarding the wages issue, and you are handling the machines without out knowledge. You are deliberately degrading us in the mill. Take this for all your misdeeds; and pulled down from the car and three him on the road. In addition to this you have pulled out the Personnel Officer. A Natarajan and Maintenance Manager N.S.Mohanram from the car and threw them on the road.