BEFORE THE NATIONAL COMPANY LAW TRIBUNAL,

CHANDIGARH BENCH

CA NO. 248 OF 2019

IN
CP(IB) No. 30 /Chd/Pb of 2017

In the matter of:-

F.M. Hammerle Textiles Ltd.
…Corporate Debtor

And In the matter of:-

Mr. Rajeev Goel
…Resolution Professional/Applicant

In the matter of:-

Maharastra State Electricity Distribution
Company Limited (MSEDCL)

…Respondent/ Non-Applicant

Rejoinder on behalf of the

Resolution Professional to the
reply filed by the Respondent/
Non-Applicant.

Respectfully Sheweth:

1. Reply to preliminary objections/submissions:

That the contents of the Preliminary Submission are

wrong and most vehemently denied. The Applicant
reiterates the contents of the main Application.
A. Suppression And Concealment of Material Facts:

1. That the contents of the Para 1 of the Suppression

and Concealment of Material Facts of reply are
wrong and most vehemently denied. It is most
pertinent to state here that the Resolution
Professional/ Applicant is trying his thick and thin
to preserve the Corporate Debtor and to keep it as
a going concern. Further, keeping the Company as
going concern after the initiation of CIRP is the
helm of IBC and the same should be protected and
that is what the Resolution Professional/Applicant
is trying to do whereas, it is pertinent to mention
here that the Respondent has miserably failed to
understand the Code which clearly and specifically
states that essential goods or services to the
corporate debtor shall not be terminated or
suspended. In the present case, the electricity is
an essential service with reference to the
Corporate Debtor whereas, Section 14(2) of the
Code clearly specifies that there shall be no
termination, suspension or interruption of the
supply of the essential goods to the Corporate
Debtor. It is most vehemently submitted that the
Respondent has utterly failed to understand the
law and has filed a frivolous reply as without
electricity the Resolution Professional will be in no
position to keep the Corporate Debtor as a going
concern.

2. That the contents of the Para 2 of the Suppression

and Concealment of Material Facts of reply are
wrong and most vehemently denied. It is most
vehemently stated that the Resolution Professional
 is trying every means to keep the Corporate Debtor
as going concern and is trying very hard to procure
job orders. Further, it is relevant to state here
that the Corporate Debtor had received job work
orders and the processing of the same had started
from 16th January, 2019. The Respondent in his
reply stated that the Applicant has mischievously
suppressed facts while filing the application
whereas, it is pertinent to mention here that the
Respondent has utterly failed to abide with the
order of the Hon’ble Tribunal whereby the order
was passed by this Hon’ble Tribunal to waive off
the late payment charges and the Respondent has
failed to abide with the same. It is rather pertinent
to mention here that the Resolution Professional is
trying every means to pay the dues and has further
paid the dues for the month of January, 2019 to a
tune of Rs. 7,30,825/- and Rs. 3,78,844/-. It would
be very difficult for the Applicant to keep the
Corporate Debtor as going concern if there is no
electricity in the premises and furthermore the
basic helm of the Code could not be protected.

3. That the contents of the Para 3 of the Suppression

and Concealment of Material Facts of reply are
wrong and most vehemently denied. It is most
humbly submitted that the Respondent has utterly
failed to understand the law and on the irony the
Respondent is stating that Applicant has
approached this Hon’ble Tribunal with unclean
hands. To further bring to the notice to the
Respondent, Section 14(2) of the code says that
there must be continuous supply of essential goods
or services during the moratorium period. The
 intention of the Legislature in to see that the
Corporate Debtor functions as a going concern.
Further, Section 20 of the Code clearly says that
the Interim Resolution Professional shall make
every endeavor to manage the operation of
Corporate Debtor as going concern. Further,
Section 23(2) of the Code says that the Resolution
Professional shall exercise powers and perform
duties as are vested or conferred on Interim
Resolution Profession Chapter 2 of the Code.
Therefore, it is most relevant to state here that
the Resolution Professional has possessed due
diligence whilst performing his duties whereas, the
Respondent has utterly failed to abide with the
law.

B. BAR TO RAISE SUBSEQUENT PLEA ON THE SAME CAUSE OF

ACTION AFTER DISMISSAL OF EARLIER CIVIL APPLICATION
NO. 445/2018:

i. That the contents mention in Para I of Bar to raise

subsequent plea on the same cause of action after
dismissal of earlier civil application no. 445/2018
of the reply are completely wrong and most
vehemently denied. It is most pertinent to state
here that the Respondent has failed to abide with
the order of the Hon’ble Tribunal whereby, the
Hon’ble Tribunal specifically directed the
Respondent to waive off the late payment charges
included in the electricity bill. However, Annexure
R-1 has been attached by the Respondent in his
reply whereby, not even a single penny has been
waived off which clearly shows the malice intent of
the Respondent. It is rather most appropriate to
state here that any interruption of supply of
essential services, it may not be possible for the
Resolution Professional to manage the operation of
the Corporate Debtor as a going concern.
Furthermore, it is necessary to reproduce necessary
provisions of Section 14 (2) of the Code and is
reproduce as under:

14. (1) Subject to provisions of sub-sections

(2) and (3), on the insolvency commencement
date, the Adjudicating Authority shall by
order declare moratorium for prohibiting all
of the following, namely:— (a) the institution
of suits or continuation of pending suits or
proceedings against the corporate debtor
including execution of any judgment, decree
or order in any court of law, tribunal,
arbitration panel or other authority; (b)
transferring, encumbering, alienating or
disposing of by the corporate debtor any of
its assets or any legal right or beneficial
interest therein; (c) any action to foreclose,
recover or enforce any security interest
created by the corporate debtor in respect of
its property including any action under the
Securitisation and Reconstruction of Financial
Assets and Enforcement of Security Interest
Act, 2002; (d) the recovery of any property by
an owner or lessor where such property is
occupied by or in the possession of the
corporate debtor.
(2) The supply of essential goods or services
to the corporate debtor as may be specified
 shall not be terminated or suspended or
interrupted during moratorium period.
(3) The provisions of sub-section (1) shall not
apply to such transactions as may be notified
by the Central Government in consultation
with any financial sector regulator.
(4) The order of moratorium shall have effect
from the date of such order till the
completion of the corporate insolvency
resolution process:
Provided that where at any time during the
corporate insolvency resolution process
period, if the Adjudicating Authority approves
the resolution plan under sub-section (1) of
section 31 or passes an order for liquidation
of corporate debtor under section 33, the
moratorium shall cease to have effect from
the date of such approval or liquidation
order, as the case may be.

Furthermore, it is also relevant to reproduce

Regulation 32 of the Regulations as follows:

32. Essential supplies. The essential goods

and services referred to in section 14(2) shall
mean-
(1) electricity;
(2) water; 19
(3) telecommunication services; and
(4) information technology services, to the
extent these are not a direct input to the
output produced or supplied by the corporate
debtor. Illustration- Water supplied to a
corporate debtor will be essential supplies for
 drinking and sanitation purposes, and not for
generation of hydro-electricity.

ii. That the contents mention in Para iv of Bar to raise

subsequent plea on the same cause of action after
dismissal of earlier civil application no. 445/2018
of the reply are wrong and most vehemently
denied. It is most appropriate to state here that
the Respondent has utterly failed to abide by the
order of the Hon’ble Tribunal whereby, it is
specifically stated that the ‘ Late Payment Charges
Included In The Electricity Bill Are Also Waived’ .
Further, the Respondent has again utterly failed to
go through the prayer as mention in the present
application whereby it is specifically prayed that
the Respondent be directed to waive off the
interest charges to a tune of Rs. 5,01,216/- in
respect of the electricity connection; to direct the
Respondent/Non-Applicant to not bill for minimum
charges for the period of temporary connection of
electricity connection i.e. from 09-08-2018 till the
date of reconnection i.e. 05-01-2019 to a tune of
Rs. 32,57,169, during which no supply of electricity
was effected by the MSEDC and to restrain the
Respondent/ Non-Applicant from disconnecting the
electricity supply at the plant. It Is most relevant
to state here that since the Respondent has failed
to abide with the order of the Hon’ble Tribunal and
has issued the notices to the Corporate Debtor for
disconnection of the electricity supply which is an
essential service that is to be provided and is
specifically stated in Section 14 of the Code, the
Applicant was left with no other option than to
 approach the Hon’ble Tribunal to take appropriate
reliefs so that the helm of the Code be protected.

iii. That the contents mention in Para v of Bar to raise

subsequent plea on the same cause of action after
dismissal of earlier civil application no. 445/2018
of the reply are wrong and most vehemently
denied. It is most appropriate to state here that
since the Respondent has failed to abide with the
order of the Hon’ble Tribunal and since the
electricity amounts to essential services without
which it would be difficult for the Applicant to
keep the Corporate Debtor as going concern.
Further, the Applicant was left with no other
option than to approach this Hon’ble Tribunal as
the Respondent had issued impugned notices to the
corporate debtor for the disconnection of the
electricity supply and the notices have been duly
attached with the main Application.

iv. That the contents mention in Para vi of Bar to raise

subsequent plea on the same cause of action after
dismissal of earlier civil application no. 445/2018
of the reply are wrong and most vehemently
denied. It is most humbly submitted before this
Hon’ble Tribunal that the object of the Insolvency
and Bankruptcy Code, 2016 is to maximize the
value of the assets of the Corporate Debtor and to
revive the Corporate Debtors who are in default in
payment of the debts. Furthermore, the Applicant
have parked all ways to procure the job work
orders whereby, if such an essential service is not
provided to the corporate debtor, than the point of
going concern will lead us nowhere than becoming
 a more debt ridden company. Therefore, the only
contention of the Applicant is that such impugned
notices do not stop the working of the Corporate
Debtor and the interest is waived off which has
duly been directed by the Hon’ble Tribunal and the
Respondent has failed to abide with the same.

v. That the contents mention in Para vii of Bar to raise

subsequent plea on the same cause of action after
dismissal of earlier civil application no. 445/2018
of the reply are correct. Further, it is relevant to
state here that the Respondent has failed to abide
with the order passed by the Hon’ble Tribunal and
should be further directed to comply with the same
so that the smooth functioning of the Corporate
Debtor is not halted.

vi. That the contents mention in Para viii of Bar to

raise subsequent plea on the same cause of action
after dismissal of earlier civil application no.
445/2018 of the reply are wrong and most
vehemently denied. It is most relevant to state
here that the Insolvency and Bankruptcy Code, 2016
was enacted with the object to revive the
Corporate Debtors if possible, and, if not possible,
to liquidate the Corporate Debtor by declaring a
period of not less than 180 days as ‘moratorium’
which could be extended up to another 90 day.
Therefore, the object of the later enactment,
namely IB Code is to give some kind of protection
to the Corporate Debtors during the moratorium
period which, as already said, extend to supply of
essential goods. That since, the Respondent has
utterly failed to abide with the order of the
 Hon’ble Tribunal hence, the Applicant were left
with no other option than to approach this Hon’ble
Tribunal as also the impugned notices were
supplied to us.

vii. That the contents mention in Para ix of Bar to raise

subsequent plea on the same cause of action after
dismissal of earlier civil application no. 445/2018
of the reply are wrong and most vehemently
denied. It is most vehemently stated that since the
Respondent had failed to abide with the order of
the Hon’ble Tribunal, the Applicant was left with
no other option than to approach this Hon’ble
Tribunal for seeking appropriate remedy and on the
contrary, the Respondent is issuing impugned
notices to the Corporate Debtor to disconnect the
connection whereby, Section 14 of the code clearly
and specifically states that the essential services
should not be interrupted whilst the CIRP is going
on.

C. CHARGDE OF INTEREST AND THE LATE PAYMENT

CHARGES ARE SEPARATE AND DISTINCT CHARGES
FROM EACH OTHER:

i. That the contents of Para I of the Charges of

interest and the late payment charges are separate
and distinct charges from each other are wrong and
most vehemently denied. It is most vehemently
stated that in view of Section 238 of the Code, no
other provision of the law shall have overriding
effect whereas, Section 238 of the Code clearly
states and is reproduce as follow:
 238. The provisions of this Code shall have
effect, notwithstanding anything inconsistent
therewith contained in any other law for the
time being in force or any instrument having
effect by virtue of any such law.

Therefore, MERC Regulation, 2005 will not be applicable

as per the above provision.

ii. That the contents of Para ii of the Charges of

interest and the late payment charges are separate
and distinct charges from each other are wrong and
most vehemently denied. It is most humbly
submitted that as per the provision as contained in
the Insolvency and Bankruptcy Code, 2016 any
other law which is inconsistent with the provision
of the code shall have no effect and it has been
specifically mentioned in Section 238 of the Code.

iii. That the contents of Para iii of the Charges of

interest and the late payment charges are separate
and distinct charges from each other are wrong and
most vehemently denied. The provision of any
other act will not be applicable and the Respondent
has utterly failed to abide with the law and is
totally reproducing the provision which have no
applicability in the present case.

iv. That the contents of Para iv of the Charges of

interest and the late payment charges are separate
and distinct charges from each other are wrong and
most vehemently denied. In view of Section 238,
any other law which is inconsistent with the
provisions of any other law which the Respondent
 has utterly failed to abide with and the same is not
repeated for the sake of brevity.

v. That the contents of Para v of the Charges of

interest and the late payment charges are separate
and distinct charges from each other are wrong and
most vehemently denied. It is most vehemently
stated that the Respondents are doing nothing but
are moving around the bushes. It is most relevant
to state here that the Applicant/ Resolution
Profession is trying every means to revive the
Company whereas, the Respondent has utterly
failed to abide with the law. It is most humbly
submitted that the Respondent has failed to abide
with the order of the Hon’ble Tribunal and are now
taking out some third meaning of the same
whereby, the Code specifically states that any
other law will have no effect in case they are
incontinent with the provision of the Code.

D. ADJUDICATION OF PRESENT APPLICATION IS

BEYONG THE ADJUDICATORY POWERS OF THIS
HON’BLE TRIBUNAL:

i. That the contents of Para I of the Adjudication of

present application is beyond the adjudicatory
powers of this Hon’ble Tribunal are wrong and most
vehemently denied. It is more vehemently stated
that the Respondent has utterly failed to
understand the law whereby, the present case has
been admitted by the Hon’ble Tribunal under the
Insolvency and Bankruptcy Code, 2016 whereby,
Section 238 of the Code Specifically defines that no
 other law shall have any effect in case they are
inconsistent with the provision of the code.

ii. That the contents of Para ii of the Adjudication of

present application are beyond the adjudicatory
powers of this Hon’ble Tribunal are wrong and most
vehemently denied. It is most pertinent to state
here that the provision of the Electricity Act, 2003
have no effect in case they are inconsistent with
the provision of the code. From the interruption of
electricity supply to the Corporate Debtor is
certainly inconsistent with Section 14(2) of the IB
Code. The object of Insolvency and Bankruptcy
Code, 2016 is to maximize the value of the assets
of Corporate Debtors and to revive the Corporate
Debtors who are in default in payment of debts.
Though there is repugnancy between both namely
The Electricity Act, 2003 and The Insolvency and
Bankruptcy Code, 2016. Further, it is most relevant
to state here that and it is further a settled law
that the Act/Code which is later in point of time
shall prevail over the other.

iii. That the contents of Para iii of the Adjudication of

present application are beyond the adjudicatory
powers of this Hon’ble Tribunal are wrong and most
vehemently denied. It is most humbly submitted
that the Respondent has failed to understand the
basic law whereby, it is settled law that the Act/
Code that came later shall prevail over the other.
It is most humbly submitted that the Insolvency and
Bankruptcy Code, 2016 will prevail over the
Electricity Act, 2003.
E. OBLIGATED TO PAY FOR ESSENTIAL SUPPLIES EVEN
DURING THE MORATORIUM PERIOD:

i. That the contents of Para i of the Obligated to pay

for essential supplies even during the Moratorium
Period are wrong and most denied. It is most
humbly submitted that the Respondent has utterly
failed to abide with the order of the Hon’ble
Tribunal and the same has been annexed as
Annexure RP-6 in the main Application and the
relevant part is reproduce as under:

The learned counsel for the Resolution

Professional submits, on instructions, that
after the workers have joined their duties,
there is likelihood of profits being earned by
the company. In view of the aforesaid
position, we direct the electricity department
to immediately invoke the bank guarantee and
get the amount adjusted from the bank
guarantee towards the present outstanding
electricity charges and in that event to
immediately restore the electricity
connection without insisting upon the balance
amount of electricity reconnection charges.
The 3 CA Nos. 445/2018,587/2018, 571/2018,
406/2018 & 607/2018 IN CP (IB) No.
30/Chd/Pb/2017 (Admitted matter) balance
charges may be added in the future
electricity bills. The compliance be made by
the electricity department, State Bank of
India and the Resolution Professional within a
week of the receipt of this order with
direction to the Resolution Professional to
 keep depositing the electricity bills including
the balance amount of the current
outstanding bill relating to the period post
CIRP process, regularly. This is without
prejudice to the merits of the application for
liquidation of the corporate debtor filed by
the Resolution Professional. Late payment
charges included in the electricity bill are
also waived.

ii. That the contents of Para i of the Obligated to pay

for essential supplies even during the Moratorium
Period are wrong and most denied. It is most
vehemently submitted that Section 14(2) of the code
says that there must be continuous supply of essential
goods or services during the moratorium period. The
intention of the Legislature in to see that the Corporate
Debtor functions as a going concern. Further, Section 20 of
the Code clearly says that the Interim Resolution
Professional shall make every endeavor to manage the
operation of Corporate Debtor as going concern. Further,
Section 23(2) of the Code says that the Resolution
Professional shall exercise powers and perform duties as
are vested or conferred on Interim Resolution Profession
Chapter 2 of the Code. Therefore, it is most relevant to
state here that the Resolution Professional has possessed
due diligence whilst performing his duties whereas, the
Respondent has utterly failed to abide with the law.

iii. That the contents of Para iii of the Obligated to pay

for essential supplies even during the Moratorium
Period are wrong and most denied. It is most
appropriate to state here that the Resolution
Profession/Applicant is trying every way to pay the
 debts of the Corporate Debtor whereby, the
electricity bill for the month of January, 2019 was
duly paid and the same has been annexed in the
main Application at Annexure RP-7 & 8.
Furthermore, to keep the Corporate Debtor as
going concern, it is very important for the
Respondent to supply the essential service as per
the provision of the Code to the Corporate Debtor
to keep the Company as going concern so that the
helm of IB Code is protected.

2. PARAWISE REPLY:

2.1 That the contents of Para 2.1 of the Para wise

reply are wrong and most vehemently denied. It
is most vehemently stated the concept of going
concern after the initiation of the CIRP is the
helm of IB Code and the same should be
protected. Since, the supply of electricity comes
under the ambit of essential service, the same
should be supplied in order to keep the
Corporate Debtor as going concern. Furthermore,
the Applicant is trying its level best to pay all
the dues whereby the dues of January was duly
paid whereas, the Respondent is sending
impugned order to the Corporate Debtor for the
disconnection which is totally outside the ambit
of law and the same should be declared null and
void.

2.2 That the contents of Para 2.2 of the Para wise

reply are correct to the extent the bank
guarantee was en cashed by the Respondent. The
rest of the part of the Para is wrong and denied.
 It is most relevant to state here that the working
of the plant had started again, as due to the
continuous efforts of the Resolution Professional
to keep the Corporate Debtor as going concern,
the Corporate Debtor has received work orders.
It is most relevant to state here that the
Applicant is trying its level best to pay back all
the dues of the Respondent but the same could
have been paid as the work was halted due to
the damage that has been occurred by the
workers at the plant. Furthermore, all the dues
will be cleared as soon as the cash flow is
generated from the work orders.

2.3 That the contents of Para 2.3 of the Para wise

reply are wrong and most vehemently denied. It
is most humbly submitted that the vide order
dated 18 t h December, 2018 the Hon’ble Tribunal
was generous enough to waive off the Late
payment charges included in the electricity bill
and the Respondent has failed to abide with the
order of the Hon’ble Tribunal and should be held
liable for the same.

2.4 That the contents of Para 2.4 of the Para wise

reply are wrong and most vehemently denied.

2.5 That the contents of Para 2.5 of the Para wise

reply are wrong and most vehemently denied. It
is most vehemently stated that any other act
other than the Insolvency and Bankruptcy Code,
2016 will not apply and the same has been
mentioned under Section 238 of the Code
 whereby, the Respondent has utterly failed to
abide with the same.

2.6 That the contents of Para 2.6 of the Para wise

reply are wrong and most vehemently denied. It
is most vehemently stated that the Resolution
Professional is going through thick and thins to
procure the work for the Corporate Debtor and
the same has been under processing.
Furthermore, the Corporate Debtor has duly paid
the electricity charges whenever any amount of
Cash flow is generated from the operation of the
plant. It is further relevant to state here that
the Respondent has failed to abide with Section
14 of the Code and Regulation 32 of the
Regulations. If the Respondent would have
abided with the law, no such cause of action
would have ever been brought into action.

2.7 That the contents of Para 2.7 of the Para wise

reply are wrong and most vehemently denied. It
is most vehemently stated that the Respondent
has utterly failed to abide with the order of the
Hon’ble Tribunal and has failed to even waive off
a single penny from the charges.

2.8 That the contents of Para 2.8 of the Para wise

reply are wrong and most vehemently denied. It
is most humbly submitted that since an order has
been passed by this Hon’ble Tribunal, to abide
with the same is our statutory obligation which
the Respondent has utterly failed to abide with.
2.9 That the contents of Para 2.9 of the Para wise
reply are wrong and most vehemently denied. It
is most vehemently submitted that the Code
specifically states that the Corporate Debtor
should be a going concern which is the helm of IB
Code and the same should be protected.
Furthermore, if the Essential service is not
provided to the Corporate Debtor, he will be in
no position to pay the dues as without the use of
electricity, the Corporate Debtor is in no
position to generate works and consequently
when no work is generated, the paying off the
dues will be difficult for the Corporate Debtor.
Hence, to keep the Corporate Debtor alive, it is
very essential to provide with the essential
services to keep the Corporate Debtor as going
concern.

2.10 That the contents of Para 2.10 of the Para wise

reply are wrong and most vehemently denied. It
is most vehemently stated that if the essential
services are not provide to the Corporate Debtor,
it will eventually be liquidated which is not a
positive sign and to keep the Corporate Debtor
as a going concern, the essential services should
be provided moreover, to abide with the law is
our statutory authority whereas, Section 14 of
the Code clearly specifies and stated that the
essential services should be provided to the
Corporate Debtor as long as the CIRP is going on.

2.11 That the contents of Para 2.11 of the Para wise

reply are wrong and most vehemently denied. It
is most humbly submitted that the Applicant is
 trying to revive the Corporate Debtor and if the
same is done a lot of people at large will be
benefited from the same. It is humbly prayed
before the Hon’ble Tribunal to kindly allow the
prayer as prayed in the main application so as
the helm of IB Code is protected.

3. That the contents of Para 3 of the Para wise reply

are wrong and most vehemently denied. It is most
humbly submitted that the prayer as mentioned in
the main Application may kindly be allowed and the
Respondent be directed to comply with the previous
order passed by the Hon’ble Tribunal.

4. That the contents of Para 4 of the Para wise reply

are wrong and most vehemently denied as the reply
as no merits and is completely against the provision
of the Insolvency and Bankruptcy Code, 2016.

Prayer clause of reply is wrong and denied.

Prayer clause of main application is correct.

It is, therefore, respectfully prayed that the

present main application may kindly be allowed as
prayed for, in the interest of justice, equity and fair
play .

Chandigarh
Date:

Yash Pal Gupta

Advocate
(P/406/2008)
Corporate Jurists, SCO 40-41,
Level-III, Sector 17 A, Chandigarh 160017
 BEFORE THE NATIONAL COMPANY LAW TRIBUNAL,

CHANDIGARH BENCH

CA NO. 248 OF 2019

IN
CP(IB) No. 30 /Chd/Pb of 2017

In the matter of:-

F.M. Hammerle Textiles Ltd.
…Corporate Debtor

And In the matter of:-

Mr. Rajeev Goel
…Resolution Professional/Applicant

In the matter of:-

Maharastra State Electricity Distribution
Company Limited (MSEDCL)

…Respondent/ Non-Applicant

SUPPORTING AFFIDAVIT

AFFIDAVIT of Rajeev Goel, S/o J.N. Goel, aged about 56 years,

having office at BDO Restructuring Advisory LLP, The Palm Spring

plaza, Unit No. 1501 to 08, Sector 54, Golf Course Road,

Gurgaon- 122001, Haryana do solemnly state and affirm as

under:-

1. That I am the Resolution Professional in the matter. I am

well conversant with the facts of the case and can depose
 the same as the present Rejoinder is drafted and being

filed under my instructions.

2. That the contents of Para Nos. 1 to 4 of the Rejoinder to

the Reply of the Preliminary Submissions are based on my

knowledge and belief and I believe them to be true..

Place: Chandigarh (Deponent)

Date:

Verification: It is verified that the contents of the above

affidavit contained in the above paragraphs 1 & 2 are true

and correct to the best of my knowledge and belief and

that no part of it is false and that nothing has been

concealed there-from.

Place: Chandigarh (Deponent)

Date: