BEFORE MR.

DHAN MOHAN, ADVOCATE

LD. SOLE ARBITRATOR
AT DELHI INTERNATIONAL ARBITRATION CENTRE
(DIAC)

CASE REF. NO. DIAC/7500/01-24

IN THE MATTER OF:
Hansraj & Anr. ...Claimant
Versus

M/S GTL Infrastructure Ltd. ...Respondent

INDEX

S. No. Particulars Page Nos.

1. Statement of Defence being filed on
behalf of the Respondent No.1 alongwith I I i
supporting affidavit
2. ANNEXURE R/1
Copy of the Letter of Authority dated 2
09th Feb 2024.
3. ANNEXURE R/2
Copy of the License Agreement dated ,, , „,
27th Aug 2008 read with Tripartite ' 1— 1
Agreement dated 02nd Feb 2010.
4. Vakalatnama 35

THROUGH
it9e,taau
(SWETA K SHANTANU & PRATAP SHANKER)
COUNSELS FOR THE RESPONDENT
D-21, 3rd Floor, Jangpura Extension,
New Delhi — 110014
Mob.: 9818058809; 9891200224;

Place: New Delhi

Dated: 01 .0(f .2024
 BEFORE MR. DHAN MOHAN, ADVOCATE
LD. SOLE ARBITRATOR
AT DELHI INTERNATIONAL ARBITRATION CENTRE
(DIAC)
CASE REF. NO. DIAC/7500/01-24

IN THE MATTER OF:

Hansraj & Anr. ...Claimant

Versus

M/S GTL Infrastructure Ltd. ...Respondent

STATEMENT OF DEFENCE BEING FILED N BEHALF

OF THE RESPONDENT

MOST RESPECTFULLY SHOWETH:

That the present Statement of Defence is being filed on behalf of

the Respondent through its Authorised Representative/ Signatory

namely Sh. Shalender Kumar Thakur duly authorized vide Letter

of Authority dated 09.02.2024. A copy of the Letter of Authority

dated 09.02.2024 is annexed herewith as ANNEXURE-R/1.

PRELIMINARY OBJECTIONS

1. That the present claim is a misconceived one and the same

has only been filed with the intent to mislead the Ld.

Tribunal and to harass the Respondent herein. That the

present statement of claim would be barred in view of the

 latest Judgement of Hon'ble Supreme Court titled as "M/s

N.N Global Mercantile P Ltd vs M/s Indo Unique Flame

ltd and ors " as the license agreement is un stamped.

2. That, at the outset, it is submitted that the present claim is

not at all maintainable and is liable to be dismissed as

there is no cause of action against the Respondent nor has

the same been set out in the Statement of Claim. It is

submitted that the Claimant has chosen not to place the

true facts before this Ld. Tribunal. Thus, the present Claim

before the Ld. Arbitrator is liable to be dismissed.

3. That the present Claim made by the Claimant is hopelessly

time barred and hence is liable to be dismissed in

accordance with law. It is pertinent to submit herein that

the Claimant by way of the present Claim is very cleverly

trying to recover the rentals since the year 2016 which is

way beyond the limitation period of three years.

4. That the present Claim is not at all maintainable in as

much as the reliefs, which have been sought by the

Claimant are nothing but a misconceived one in as much

as the relief, as prayed, cannot at all be adjudicated upon

by this Arbitral Tribunal. It is submitted that none of the

 Claim of the Claimant herein has been substantiated by

any documentary evidence or proof and the same are

nothing but only bald averments.

5. That it is respectfully submitted that the Claimant and

Respondent herein with their open eyes entered into the

License Agreement dated 27.08.2008 and thereby agreed

to follow the terms and conditions of the same in totality.

It is submitted that the Claimant had entered in to License

Agreement dated 27.08.2008 voluntarily and as per her

own free will. Moreover, the said agreement is a

commercial contract and has been made after many rounds

of negotiations. The Claimant has neither raised any

concern over any clause of the License Agreement nor

challenged any clause of the same in the present

proceedings. It is therefore, construed that both the parties

to the present Agreement have vowed to adhere strictly

with its terms and conditions in its true letters and spirit.

As per Clause 6 (f) of the License Agreement dated

27.08.2008, it has been agreed between the parties that in

any event the Licensee shall not be liable to pay any

License fee during the period in which the Licensee was

unable to use the Licensed property for any reason

whatsoever (including any Court Order etc.). The relevant

portion of Clause 6 (f) of the aforesaid License Agreement

is reproduced hereinbelow for the ready reference of this

Hon'ble Tribunal:

"f In the event the Licensed property is not allowed to be

used by the Licensee for any reason whatsoever during

the terms of this license agreement or any renewal

thereof, then the licensee shall be entitled to terminate

this agreement with immediate effect. In any event the

Licensee shall not be liable to pay any License fee during

the period in which the Licensee was unable to use the

Licensed property for any reason whatsoever (including

any Court Order etc.). The Licensee shall also be entitled

to seek refund of security deposit from Licensor. Further,

the Licensee shall also be entitled to seek damages from

the Licensor of all the charges and expenditure incurred

in finding another location and/or for setting up a

similar by the Licensee as was available at the Licensed

property. The Licensor shall pay the charges so

claimed/demanded by the Licensor without any objection,

demur, protest or contestation within 3 (three) days of

receipt of the demand being made by the Licensee."

 S
It is a matter of fact that the mobile tower of the answering

Respondent herein was wrongfully sealed by the

Municipal Corporation of Delhi.

6. That it is respectfully submitted that there is an express

term well in the License Agreement with respect to

suspension of License Fee on the happening of any event

as stipulated in the abovementioned Clause 6(f) of the

License Agreement dated 27.08.2008. Hence, the present

Claim of the Claimant is not at all maintainable and is

liable to be dismissed with heavy costs. Copy of the

License Agreement dated 27.08.2008 is annexed herewith

as ANNEXURE R/2.

7 That it is respectfully submitted that the Claimant herein,

further, also created hindrance in giving access to the

mobile tower in question in the garb of some malafide and

unlawful demands which is contrary to Clause 4 (C) of the

License Agreement dated 27.08.2008. Contents of Clause

4 (C ) are being reproduced hereinbelow for the ready

reference of this Ld. Tribunal:

"The Licensor(s) shall ensure twenty four (24) hours a day

access to the Licensee, its employees, agents, associates,

security guards etc. to the licensed property and further

ensure that the access is not denied to the licensee, its

 6
employees, agents associates, security guards etc. at any

time including sundays, National and other holidays and

night time."

8. That it is submitted that the present Claim filed by the

Claimant is nothing but an abuse of the process of law in

as much as the Claim is based upon a false and concocted

story making numerous vague and baseless allegations

against the Respondent.

9. That the present Claim is barred by the Doctrine of

Estoppel, Acquiescence as well as waiver.

10. That the present Claim filed by the Claimant is not at all

maintainable in as much as the same has not been signed,

verified and instituted by the Claimant in accordance with

law and as such the same is liable to be dismissed.

PARA WISE REPLY:

1. That the contents of para 1 of the claim are wrong, false

and hence denied. It is denied that the Claimants, in

addition to the statement of claim are filing documents in

support of their Claim. It is most respectfully submitted

that the the Claimants have not filed any document in

support of their Claim. Further, the contents of the

 Preliminary Objections raised hereinabove are reiterated

and reaffirmed.

2. That the contents of para 2 of the claim are wrong, false

and hence denied. It is denied that the Statement of Claim

is being filed on account of non-payment of the

outstanding amount of License Fees of Rs.29,40,000/-

(Rupees Twenty Nine Lakh Forty Thousand Only)

alongwith interest @ 24% per annum from the due date of

License Fees, i.e., 01.01.2016 till now, as per the

license/principal agreement dated 27.08.2008 read with

Tripartite Agreement dated 02.02.2010 and Supplementary

Agreement dated 09.12.2010 executed between the parties.

It is most respectfully submitted that the allegations made

in the corresponding paragraph are completely false,

frivolous and concocted in nature and the Claimant be put

to strict proof upon the same. It is further submitted that

the Claim made by the Claimant is miserably time barred

and against the settled terms and conditions of the

Agreement dated 27.08.2008. Further, the contents of the

Preliminary Objections raised hereinabove are reiterated

and reaffirmed.

3. That the contents of para 3 of the claim are a matter of

record and hence need no reply. Further, the contents of

 the Preliminary Objections raised hereinabove are

reiterated and reaffirmed.

4. That the contents of para 4 of the claim are a matter of

record and hence needs no reply. Further, the contents of

preliminary objections raised hereinabove are reiterated

and reaffirmed.

5. That the contents of para 5 of the claim are wrong, false

and hence denied. It is denied that the present dispute has

arisen on account of non-payment of the License Fees by

the Respondent to the Claimants under the

License/Principal Agreement dated 27.08.2008, Tripartite

Agreement dated 02.02.2010 and Supplementary

Agreement dated 09.12.2010 entered into between the

Claimants and the Respondent-GTL Infrastructure Ltd.,

whereby the Respondent had agreed to pay an amount of

Rs. 30,000/- per month as License Fees for leasing of the

terrace of the property bearing no. 64-A situated at Main

Chowk, Badarpur, New Delhi-110044, for the purpose of

setting up and operation of its telecommunication tower on

the said ceiling. It is most respectfully submitted that the

Respondent has made payments to the Claimant as per the

agreed terms and conditions of the Agreement dated

27.08.2008 and there is nothing due and payable at the end

 9
of the Respondent. It is further pertinent to mention herein

that the mobile tower of the Respondent was illegally

sealed by the Municipal Corporation of Delhi in the year

2015. Further, the contents of preliminary objections

raised hereinabove are reiterated and reaffirmed.

6. That the contents of para 6 of the claim are a matter of

record and hence needs no reply. Further, the contents of

preliminary objections raised hereinabove are reiterated

and reaffirmed.

7. That the contents of para 7 of the claim are a matter of

record and hence needs no reply. Further, the contents of

preliminary objections raised hereinabove are reiterated

and reaffirmed.

8. That the contents of para 8 of the claim are a matter of

record and hence need no reply. Further, the contents of

preliminary objections raised hereinabove are reiterated

and reaffirmed.

9. That the contents of para 9 of the claim are a matter of

record and hence need no reply. Further, the contents of

preliminary objections raised hereinabove are reiterated

and reaffirmed.

10. That the contents of para 10 of the claim are a matter of

record and hence need no reply. Further, the contents of

 t0

preliminary objections raised hereinabove are reiterated

and reaffirmed.

11. That the contents of para 11 of the claim are wrong false

and misconceived in nature and hence are vehemently

denied. It is denied that as per the Supplementary

Agreement, the Respondent paid License fees to the

Claimants till December 2015 and, thereafter, abruptly

stopped paying the License Fees without any reason.

Further, the contents of preliminary objections raised

hereinabove are reiterated and reaffirmed.

12. That the contents of para 12 of the claim are wrong, false

and hence denied. It is denied that the Claimants addressed

several communications to the Respondent requesting the

latter to pay the outstanding License Fees in terms of the

License/Principal Agreement dated 27.08.2008, Tripartite

Agreement dated 02.02.2010. and Supplementary

Agreement dated 09.12.2010, however, all went in vain

and the Respondent did not make the payment of the

outstanding amount. It is further denied that aggrieved by

the non-responsive nature of the Respondent, the

Claimants served legal notices dated 06.02.2017 and

16.01.2018 to the Respondent demanding the payment of

the outstanding License Fees, however, the Respondent

 I
neither replied to the said notices nor made any payment to

the Claimants. It is most respectfully submitted that the

site in question of the Respondent was illegally sealed by

the MCD and the same was well within the knowledge of

the Claimants. Moreover, it was only the Claimants who

created obstruction in the access of the mobile tower and

hence, further, violated the terms and conditions of the

License Agreement. Further, the contents of Preliminary

Objections raised hereinabove are reiterated and

reaffirmed.

13. That the contents of Para 13 of the Claim are wrong, false

and hence denied. It is denied that the Claimants were

constrained to prefer a Civil Suit. It is most respectfully

submitted that the Civil Suit was filed by the Claimants

only with an intent to harass the Respondent herein.

Further, the contents of preliminary objections raised

hereinabove are reiterated and reaffirmed.

14. That the contents of para 14 of the claim are a matter of

record and hence need no reply. Further, the contents of

preliminary objections raised hereinabove are reiterated

and reaffirmed.
15. That the contents of para 15 of the claim are a matter of

record and hence need no reply. Further, the contents of

preliminary objections raised hereinabove are reiterated

and reaffirmed.

16. That the contents of para 16 of the claim are a matter of

record and hence need no reply. Further, the contents of

preliminary objections raised hereinabove are reiterated

and reaffirmed.

17. That the contents of para 17 of the claim are a matter of

record and hence need no reply. Further, the contents of

preliminary objections raised hereinabove are reiterated

and reaffirmed.

18. That the contents of para 18 of the claim are a matter of

record and hence need no reply. However, it is vehemently

denied that the issue which was raised by the Respondent

vide its reply to Legal Notice, was never raised during the

continuance of the agreement and was only a ruse to run

away from the liability. It is most respectfully submitted

that the Respondent had no access to the mobile tower in

question. Further, the contents of preliminary objections

raised hereinabove are reiterated and reaffirmed.

 3

19. That the contents of Para 19 of the Claim are wrong, false

and hence denied. It is denied that the Respondent, in

order to improve upon their case, further sent a letter dated

04.03.2020 to the Claimants asking the latter to withdraw

the legal notice dated 12.02.2020 by falsely claiming that

the arbitration clause cannot be invoked because the

agreement is not sufficiently stamped, an issue which was

absolutely contrary to its own application filed under

Section 8 of the Arbitration and Conciliation Act, in the

above said civil suit, wherein the Respondent stated that

the suit of the Claimants is not maintainable in view of the

arbitration clause contained in the agreement dated

27.08.2008 and the matter has to be referred to arbitration.

Further, the contents of Preliminary Objections raised

hereinabove are reiterated and reaffirmed.

20. That the contents of para 20 of the claim are a matter of

record and hence need no reply. Further, the contents of

preliminary objections raised hereinabove are reiterated

and reaffirmed.

21. That the contents of Para 21 of the Claim are wrong, false

and hence denied. It is denied that the Respondent is liable

to pay an amount of Rs. 29,40,000/- to the Claimants

 towards the unpaid License Fees for the period 01.01.2016

to February 2024 along with interest @2% per month from

the due date of the License Fees. It is further vehemently

denied that the Claimants are entitled to be

compensated/reimbursed for the License Fees from the

Respondent during the abovesaid period and this has

resulted in unjust enrichment and benefit to the

Respondent and unfair losses to the Claimants. It is most

respectfully submitted that there is nothing due and

payable at the end of the Respondent as per the agreed

terms and conditions of the License Agreement. Moreover,

the Claim of the Claimants are time barred. Further, the

contents of Preliminary Objections raised hereinabove are

reiterated and reaffirmed.

22. That the contents of Para 22 of the Claim are wrong, false

and hence denied. It is most respectfully submitted that the

cause of action for filing the present Claim never arose in

favour of the Claimants and against the Respondent in as

much as it is the Claimants who have breached the terms

and conditions of the License Agreement. Further, the

contents of Preliminary Objections raised hereinabove are

reiterated and reaffirmed.

 cs
23. That the contents of Para 23 of the Claim are wrong, false

and hence denied. It is most respectfully submitted that the

Claim of the Claimants are miserably time barred.

24. That the contents of Para 24 of the Claim are wrong, false

and hence denied. Further, the contents of Preliminary

Objections raised hereinabove are reiterated and

reaffirmed.

25. That the contents of Para 25 of the Claim are wrong, false

and hence denied. Further, the contents of Preliminary

Objections raised hereinabove are reiterated and

reaffirmed.

26. That the contents of Para 26 of the Claim are wrong, false

and hence denied. Further, the contents of Preliminary

Objections raised hereinabove are reiterated and

reaffirmed.

27. That the contents of Para 27 of the Claim are wrong, false

and hence denied. Further, the contents of Preliminary

Objections raised hereinabove are reiterated and

reaffirmed.
 (6
28. That the contents of Para 28 of the Claim are wrong, false

and hence denied. Further, the contents of Preliminary

Objections raised hereinabove are reiterated and

reaffirmed.

29. That the contents of para 29 of the claim being the prayer

clause are wrong false and hence denied. It is most

respectfully submitted that the present claim may not be

allowed in favour of the Claimant in the interest of Justice,

equity and good conscience. Further, the contents of

preliminary objections raised hereinabove are reiterated

and reaffirmed.

30. That the contents of Para 30 of the Claim are wrong, false

and hence denied. Further, the contents of Preliminary

Objections raised hereinabove are reiterated and

reaffirmed.

PRAYER

That in light of the above-stated facts and circumstances it

is most respectfully prayed that this Hon'ble Tribunal be

pleased to:

(a) Dismiss the present Claim with exemplary cost;

and/or
 (b) Pass any other or further Order(s) in the interest of

justice.

THROUGH

(SWETANK SHANTANU & PRATAP SHANKER)

COUNSELS FOR THE RESPONDENT
D-21, 3rd Floor, Jangpura Extension,
New Delhi — 110014
Mob.: 9818058809; 9891200224;

Place: New Delhi

Dated: CI .09 .
 Is
BEFORE MR. DHAN MOHAN, ADVOCATE

LD. SOLE ARBITRATOR

AT DELHI INTERNATIONAL ARBITRATION CENTRE

(DIAC)

CASE REF. NO. DIAC/7500/01-24

IN THE MATTER OF:

Hansraj & Anr. ...Claimant

Versus

M/S GTL Infrastructure Ltd. ...Respondent

AFFIDAVIT

lender Kumar Thakur, S/O Sh. Jagdish Chand, aged about

, Circle Head of GTL Infrastructure Limited, having its

t 20/4, 3rd Floor, Palm Court, MDI Chowk, Near Sector-

4 HUDA Park, Gurgaon, Haryana-122001, presently at New

Delhi, do hereby solemnly affirm and declare as under:

1. That the Deponent is the Authorized Representative of the

Respondent Company in the above mentioned case and as

such fully conversant with the facts of the case and is

competent to swear this affidavit.

2. That the accompanying Statement of Defence has been

drafted by my counsel under my instructions and contents of

the same are not being reproduced herein for the sake of

brevity. The contents of the same are true and correct to the
 19
best of my knowledge. The contents of the same may be

read as part and parcel of this affidavit.

VERIFICATION:

9 APR 2024
ied at New Delhi on this day of ,2024

the contents of the above affidavit are true and correct to my

owledge and no part of it is false and nothing material has

been concealed there fro

AT Ire r)
o N0 L5iBLic DEPONENT
4 ( DIA
.`• di
(b.
.i.to coii,
szIN .q.$
1 9 aR 744_
es 0

9.•
.%k. Iti
* co 4
,4b
 eTe
INFRASTRUCTURE

Date: 09/02/2024 GIL/DELHULEGAU2024/0373

LETTER OF AUTHORITY

TO WHOMSOEVER IT MAY CONCERN

Whereas GTL Infrastructure Limited (the Company) is engaged inter itito ittihe business of
providing passive shared infrastructure services in telecom and other related activities all over
India having its registered office at 3'd Floor, Global Vision, Electronic Sedan 11, ruc, M1DC
Area, Mahape, Navi Mumbai — 400710, and Delhi Circle office at 20/4, 3RD Floor, Palm Court
Sukhrali Chowk, Sector-14, Gurgaon-122001

And whereas the Board of Directors of the Company vide its resolution dated 10"1 November,
2022 have authorized Ms. Pratibha Nlula and Mr. Bhupendra Kitty as authorized Signatories
give further authorization to one or more persons for attending, .to various matters of the
Company;

Tn exercise of the above authority, we hereby authorize Mr. Shalentler Kumar Thakur, (Circle
Operational Head) of GTL Infrastructure Limited, Delhi. Circle to do the following Deeds,
Things, and Acts etc in the state of Delhi/NCR/Haryana.

1. To present the company before the 1-lon'ble High Court of Delhi, District Courts,
Mediation/Arbitration Centre, and other competent court/tribunal/Authority, in the
matter of "HANSRAJ & ANRS VS GTL INFRASTRUCTURE LIMITED" CASE
REF NO. DIAC/7500/01-24" LISTED BEFORE THE SOLE ARBITRATOR MR..
DIIAN MOHAN ADVOCATE AT DELHI INTERNATIONAL ARBITRATION.
CENTRE (DIAC) OF DELHI HIGH COURT.

ro-sign and execute vakalatnama's defend and or initiate legal proceeding, Civil,
Criminal, Consumer Forum and to that effect file, to make, sign, execute, verify and
register various applications, papers, documents, statements, petitions, affidavits; in the
Interest of the Company etc. before any Hon'ble Court and to Engage lawyer for
representing the case of the Company and to do all such thingS and deeds as May be
required in pursuance of the above.

To carry out any act(s), deed(s), matter(s) or thing(s) which are incidental tlItolttat
necessary and in furtherance of the foregoing intention.

The_ Contgany .does hereby undertake to ratify and confirm for itself and its Siteeessorsand
assigns and/or covenants to ratify and confirm all and whatsoever the said Attorneys shall
lawfully do or cause to be done in or about the premises by virtue of these presents and declare
that these presents shall at all times be conclusively binding in favor of thirdparties.

For GTL Infrastructure Limited,

Pilaf ha Mule Bhui t Klny

Authorized Signatory An_t_lprtied Signatory

GTL INFRASTRUCTURE LIMITED

Regd Off: Global Vision 3rd Floor Electronic Sedan - II I1IOC 17C Industrial Area Mahape Nevi Mumbal - 400 710 India
Tel: +91-22-6829 3500 Fax: +91-22-6829 3545 www.gtlinfra.com CIN-174210MH2009PLC144367
Corp Off: 412 lanmabhoomi Chambers 29 Walchand lilrachand Marg Ballard Estate Mumbal - 400 001 India
Tel: +91-22-2271 5000 Fax: +91-22-2271 5332
 2_1
.67 7- 0'77

NDRE PE

.001,....)t rt
100100 1 00 i
0..„0„, i „,„,
f
...„),„ (:)0 .., „,„:„
i c),„, „:„„:, i , N,..,
)
,
1 00,1 „Dr) 1 -
J. 1 0 0 1 17,K...) 1 : '
QC? 1 '...
- '3:114', •-:.+'

rt DELHI LICENSE AGREEMENT F 482724

TIIIS LICENSE AGREEMENT is made and entered into at Delhi on this 24%y of
2008 by and between:

MM. Sa.ikL \(_sr, t14,444,14,: MK. c)0iYAot# eA,14.4L4' , aged about 43 sLys S/DNVNVd
off,t4- Su: Pi 6-4444.1. tet.; s ocU et. Rio 6 ti A, T-44 Prey r3 tA.4-.24.4k.., 141C41e,
(Areinafter referred to as "Licensor", which expression shall unless repugnant to the context "*D ` ""
mean and include his legal heirs, successors, assigns, nominees and representatives etc.) of
thi ONE PART.

AND

Mite, Ltd., a Company incorporated under the provisions of the Indian Companies Act, 1956
arid having Registered Office at 5th Floor, Spencer Plaza, 769-Anna Salai, Chennai — 600 002 t.
a Circle Office at 8, Local Shopping Center, Sector-B, Pocket-7, Nelson Mandela Marg,
V sant Kunj, New Delhi 110070, (hereinafter called the "Licensee", which expression shall tr
unless repugnant to the context mean and include the group companies, successors-in-
business, administrators, executors, and permitted assigns etc.) represented by Mr. 4'011 )(441tv, v P
AX+, the authorized signatory of the company, of the OTHER PART,
—
[The Licensor and the Licensee shall jointly be referred to as the 'Parties" and individually as
"arty" in reference to the context.]

VVEREAS the Licensor(s) has represented that they are the sole and lawful owner/co-owner
and in the sole and exclusive possession of approximate area of 8004 14- of Built up
ppperty bearing no. - eto-bvq. Pe,daktwt Pg6Sit with its Roof Top and
possessing unhindered, unrestricted, unencumbered Terrace Rights (hereinafter referred to as
"the Said Property").
1„ rm
;1>

Far Ai el ,Limited

AUthorisedSiOnabne
S/0, 010, W/0„
ADO .

PURPOSE IN FAVOUR or,

OAVINOER SINGH KUMAR L. NO ,
234-A, CHWL.AZA. SANT NAGAP
N E.LHI -110065
AND WHEREAS the Licensee is a Unified Access Service License holder and provides cellular
mobile telecommunication services in the telecom circles for which it has obtained the requisite
licenses and for the aforesaid purpose requires to set-up Cellular mobile transmission
equipment gCMTE" and other related equipments and for the aforesaid purpose requires to use
the said Property.

AND WHEREAS the Licensee is desirous of the using on Leave and License basis the Roof
Top admeasuring 800 Sq. ft as described in the schedule of the Property (hereinafter referred
to as "the Licensed Property") for the purposes of providing cellular mobile telecommunication
services.

AND WHEREAS the Licensor has thus agreed to permit the use of the Licensed Property by the
Licensee on the terms and conditions hereinafter contained.

NOW THIS LICENSE AGREEMENT WITNESSETH AND IT IS HEREBY AGREED BY AND

BETWEEN THE PARTIES HERE TO AS UNDER:

1. OWNERSHIP OF THE LICENSED PROPERTY AND INDEMNITY BY LICENSOR:

a. The Licensor hereby declares and confirms that the Licensed Property (including the
structure, if any on which it is installed) is free from all encumbrances, court attachments
and other charges of whatsoever nature and the Licensor has good, clear and
marketable right, title and interest in the said Licensed Property and has no objection to
grant the license of the Licensed Property in favor of Licensee. The Licensor is sole and
lawful ovvner/co-owner and in the sole and exclusive possession of approximate area of
‘302) Sq. -Ft of Built up property bearing no,
-A , tAA•Q441.1t, i-r•-•-a-Axict,k‘c• • .).iltitl.k.-1-tk-t , along with its Roof Top
and possessing unhindered, unrestricted, unencumbered Terrace Rights,

b. The Licensor hereby declares and confirms that all the documents submitted / shown by
the Licensor regarding the Licensed Property and the Said Property are true and correct
to the Originals and nothing false and wrong has been submitted or conveyed to the
Licensee.

The Licensor undertakes and declares that he/they has/have good right, title and interest
in the Said Property and has full power and absolute authority to give the Licensed
Property on License to the Licensee. In case any body else have any objection of
whatsoever nature as regards the arrangements arrived at between the Licensor and the
Licensee in respect of the Licensed Property, the Licensor shall indemnify and keep
indemnified the Licensee against all costs, charges, expenses, compensation and
damages, if any, at any time.

2. GRANT OF RIGHT.

a. The Licensor hereby grants permission / License to the Licensee for the Licensed
Property admeasuring 800 sq. ft. more particularly described in the schedule
hereunder written for the development and expansion of its cellular mobile
telecommunication services. The Licensor hereby grants the right to the Licensee to
bring its belongings and things (including for telecommunication network equipment) for
using at the Licensed Propsrty during the term of this License without any hindrance or
disturbance of any ngr,W, atsoever.
i
4, 4.110171" ‹

imited
 The Licensor agree and confirm that the Licensed Property can and may be used by the
Licensee or any of the group Companies of the Licensee and the same shall not amount
to violation of this License agreement.

c. The licensee is entitled to have reciprocal Multi Operator arrangements/ agreements

with other entities for the sharing, use of its equipment etc. installed in the said premises
under the provisions of Law. In accordance with the arrangements, such entities shall
be entitled to put in their equipments in the said Premises and hence all such equipment
shall be deemed to be the Equipment of Licensee. No additional permission shall be
claimed nor any objection shall be raised by the Licensor at any point of time, for the
above purpose. Further the licensor would not be entitled to claim any additional license
fee on account of the said multi-operator arrangement,

Licensee is also entitled to lay OFC (Optical Fibre Cable) from the ground /pathways
through the available route to the Licensed premises as and when it is required by the
Licensee. No additional permission shall be required from the Licensor nor any
additional compensation / license fees will be paid to the licensor.

LICENSEE COVENANTS

The Licensee shall not to do or permit to be done, anything which may create or cause
nuisance or annoyance or disturbance to other occupiers in the vicinity of the Licensed
Premises.

The Licensee shall not damage the Licensed Property in any manner (usual wear & tear
excepted). However, in case of any damage/breakage caused due to acts of the
Licensee at the Licensed Property the same shall be repaired/ restored at the risk and
cost of the Licensee.

c. The Licensees, their servants, agents, employees shall be entitled to use the Licensed
Property together with the right to access thereto and/or all passages, entrances. stairs,
lobbies, lifts, porches, landings, gates or to other pathways for and ingress thereto and
ingress there from to the main road, which shall be held unless exclusively
held/appurtenant, in common with other entitled to similar use, and without causing any
disturbance to other.

d. The Licensee shall in consideration of the license hereby granted by the Licensor pay to
th Licensor the licent:ee of Rs. MY-r3-1--/- (Rupees tV-C,.\-1---c.„/".„
on y) per month (hereinafter referred
to as 'License Fee') subject to applicable' Tax Deduction at Source, during the
subsistence of the license and the compensation is payable in favor of the Licensor(s)
on a monthly basis on or before 10th of the each English calendar month it relates to.
The Compensation/License fee shall be deemed to have started from the date the Letter
of Permission to Use duly signed by the Licensee is handed over to the Licensor,

e. The said license fee shall be enhanced by 10% at the expiry of every 5--(five-years of
the last license fee paid.

The Licensee shall als deposit with the Licensors interest free refundable security
deposit of Rs. Sam 7,(Rupees 'F'd""Y
 15

only) equivalent to 3 months license fee/compensation which shall be refunded on the

day of the expiry or earlier determination of this Agreement without any deduction there
from along with the unadjusted amount of advance license fees, if any, paid to the
Licensor.

The Licensee will make all payments pertaining to licensee fee/compensation under this
License agreement by issuing account payee cheques /bank transfer, in favor of the
Licensor(s).

4. LICENSOR COVENANT

a. The Present and future taxes levied by the municipality, House tax department or any
other Statutory or Government body shall be borne by the Licensor only_ If the Licensor
has not paid or fails to pay any Governmental or statutory dues, the Licensee can pay or
fulfill those statutory obligations and recover Iadjust the same from the Licensor from
the license fee payable to the Licensor.

The Licensor has clearly understood and agreed that any / all present and future liability
in relation to Tax Demands, as Licensee may receive on account of this agreement
including any additional demand shall be the sole responsibility of the Licensor only and
the Licensor shall keep the Licensee indemnified and agrees to pay to Licensee such
sums in this respect.

The Licensor(s) shall ensure twenty four (24) hours a day access to the Licensee, its
employees, agents, associates, security guards etc to the Licensed Property and further
ensure that access is not denied to the Licensee, its employees, agents associates,
security guards etc at any time including Sundays, National and other holidays and
night time.

In the event of breach by Licensor of any of the terms contained herein, the Licensor]
shall be responsible for and shall pay to the Licensee such amount as damages as the
Licensee may suffer in smoothly and effectively carrying on its business.

0. The Licensor shall not during the currency of this license interfere with the peaceful use
of the Licensed Property by the Licensee and nor shall the Licensor install, or cause or
allow to be installed on the Licensed Property any communication facilities / equipment,
or tower which, in the judgment of the Licensee, may interfere with the working of the
Licensee peaceful use of the Licensed Property during the term of the License.

The Licensor shall give duplicate set of keys for access to the Licensed Property as well
as for gaining entry into the Licensed Property to the Licensee The Licensee shall not
alter or suffer to be altered the existing locking devices for which the said keys are
handed over to it, without prior permission of the Licensor(s).

TERM

This License shall commence from — 2008 and be in force fora period
of 20 (Twenty) years i.e, till - 2028

TERMINATION OF THE LICENSE AGREEMENT

j.11,44. t1/4
 By efflux of time this License Agreement will be terminated on;the date as mentioned in
this agreement,

The Licensee shall be entitled to terminate, without assigning any reason thereof by
giving the Licensor, this License Agreement by giving 3 (Three) months prior notice in
writing.

The Licensor shall be entitled to terminate this agreement during the Term only if the
Licensee fails to pay compensation for 3 months consecutively and despite written
demand being made by the Licensor to the Licensee for payment,

The Licensor shall grant the Licensee a non-chargeable/free grace period of 60 days
from the date of termination / expiry of this Agreement for removal of its furniture, and
belongings owned by the Licensee from the. Licensed Property.

e. The Licensee shall carry out the necessary building Isoil stability test to confirm the
building/soil is in compliance with the Licensee's requirement after being put into use
during the term of this license. However, if the stability test reports have adverse
remarks about the Licensed Property, then the Licensee shall be entitled the following;
i. to terminate this License Agreement with immediate effect;
II. stop payment of any further Licensee fee with immediate effect;
iii, seek refund of security deposit.
iv, vacate the Licensed Property upon receipt of the sums dues to the Licensee from
the Licensor.

In the event the Licensed Property is not allowed to be used by the Licensee for any
reason whatsoever during the terms of this License Agreement or any renewal thereof,
then the Licensee shall be entitled to terminate this agreement with immediate effect. In
any event the Licensee shall not be liable to pay any licensee fee during the period in
which the Licensee was unable to use the Licensed Property for any reason whatsoever
(including any court order etc.). The Licensee shall also be entitled to seek refund of the
security deposit from Licensor. Further, the Licensee shall also be entitled to seek
damages from the Licensor of all the charges and expenses incurred in finding another
location and/or for setting up a similar set up by the Licensee as was available at the
Licensed Property. The Licensor shall pay the charges so claimed / demanded by the
Licensor without any objection, demur, protest or contestation within 3 (three) days of ra
receipt of the demand being made by the Licensee.

CONSEQUENCES OF TERMINATION

a. Upon termination or early determination of this. Agreement, the Licensee shall cause Tr
itself and its employees and officers to vacate the Licensed Property and remove there
from all its furniture and belongings brought in by the Licensee in the Licensed Property.

b. The Licensor shall refund the said Security Deposit to the Licensee on the expiry or
earlier termination / determination of this Agreement subject to deduction, if any, of
arrears of License Fee / compensation payable and other amounts simultaneously on
the Licensee vacating the Licensed Property. In the event the Licensor is unable to
refund the Security Deposit, Licensor shall be disentitled from asking the Licensee to
give vacant possession of the Licensed Property and the Licensee shall be entitled to
use the Licensed Prope any liability towards payment of the monthly License

For Aircet limited

 Fee / compensation or any other charges payable by the Licensee under this agreement
until repayment of the Security Deposit Further, the Security Deposit will carry interest
@ 24% per annum compounded every month from the date on which the refund is due
to the Licensee from the Licensor till its repayment and the Licensor shall be liable to the
repayment of the Security Deposit along with the interest. This shall be without
prejudice to the Licensee's rights and remedies available in law to seek refund of the
Security Deposit.

8. INDEMNITY

The Licensor shall indemnify and agrees to continue indemnifying the Licensee for each
and all loss, damage, actions, proceedings, etc. as the Licensee may face or incur due
to directly or indirectly any act of omission of the Licensor and/or any violation of any
provision of this Agreement by the Licensor. In case any body else have any objection
of whatsoever nature as regards the arrangement arrived at between the Licensor and
the Licensee in respect of the Licensed Property, the Licensor shall indemnify and keep
indemnified the Licensee against all costs, charges, expenses, compensation and
damages, if any, at any time.

AMENDMENTS

Except as otherwise provided in this Agreement, the provision of this Agreement may be
amended at any time by mutual consent of the Parties hereto,

10. NOTICE

Any notice or communication with reference to this Agreement, unless otherwise

specified herein shall be deemed to be validly sent if dispatched by registered post
acknowledgement due / approved courier / Speed Post acknowledgement due to the
other party at ie following respective addresses:

LICENSOR j,,,< c''./17

C.. ti -A , IkWN1 ators,-0-v-- ,
b..,_,L5,04,A. ,-. , NJ,.t.so 0,1.1.„,.-.. t....1/4,,,
<

LICENSEE
AIRCEL Ltd.
8, Local Shopping Center,
Sector-B, Pocket-7,
Nelson Mandela Marg, Vasant Kunj,
New Delhi 110070.

Either party may by a similar written notice to the other party change his / her / its / their
address aforesaid.

11. DISPUTE RESOLUTION AND APPLICABLE LAWS

In the event of any dispute arising by and between the parties hereto, the same shall be
amicably resolved by Conciliation, failing which, by Arbitration conducted by a sole
 arbitrator duly nominated by the Licensee, in accordance with the provisions of the
Arbitration & Conciliation Act, 1996(as amended). The venue of the Arbitration shall be
Delhi The decision of the arbitrator shall be final and binding on the parties, All disputes
shall be subject to the jurisdiction of NIL,* courts. The governing law shall be laws of
India.

12. MISCELLANEOUS

a. The Licensor has and shall continue to comply with all laws By-Laws, Rules,
Regulations, Orders, Notifications, Directions, Conditions of the Government whether
Central, State, Local or Municipal with respect to the Licensed Property.

If at any time during the continuance of the License, the Licensed Property or any part
thereof be destroyed or damaged by fire, earthquake, tempest or other Act of God or by
riot, war, air-raid, or any irresistible force (not caused by any willful act or default on the
part of the Licensee, its servants, agents or workmen) so as to become unfit for use for
the purpose for which it was, the Licensee shall be at the option to terminate the
agreement immediately, but in the event of the Licensee desiring to continue the license,
the Licensee shall vacate the whole or such portion of the Licensed Property as may be
required to enable the Licensor to repair or to restore to its former state of condition and
in such event the whole or proportionate part of the License fees as the case may be
shall abate till the Licensed Area or any part thereof is restored to its former condition to
the Licensee, and the Licensee shall only continue to pay the full License fees from the
date of such restoration.

At the expiry of the term hereof parties hereto may extend the duration of this Agreement
on the same terms and conditions for such further periods as the parties may mutually
agree.

The Licensee shall not be responsible or liable in any manner whatsoever for any injury
or damage which may be caused to any employee of the Licensor or any other person
allowed by the Licensor to gain access to the Licensed Property who illegally tampers
with the belongings of the Licensee.

e. If any party fails to require performance by the other party of any obligation it shall not
affect the right of such party to require performance of that obligation subsequently.

f. Nothing herein contained shall be construed as creating any tenancy or sub-tenancy in

favor of the Licensee or its offices and / or employees in or over or upon any part of the
Licensed Property, other than the right of use hereby granted or as entitling the Licensee
to the exclusive possession of the Licensed Property. It is the express intention of the
parties hereto that this Agreement shall be a mere license and the Licensor shall always
be deemed to be in possession thereof.

g. This Agreement and the contents here of supersedes each and all previous agreements,
arrangements, understandings, letters, correspondence, representations, etc, between
the parties hereto only with respect to the subject matter herein.

That the Licensee shall keep the original copy of the License agreement.

,,elqArt
 za

In this License Agreement, unless the context otherwise requires any references to
words importing the singular shall include the plural and vice versa, words importing a
gender include every gender and references to persons include bodies corporate and
unincorporated.

SCHEDULE OF THE LICENSED PROPERTY

Property bearing No. (ti A - 144 dmeasuring Xv sq. ft. being bounded by
PI(X4' C)kACAlet4..
North N e,, 19.0.1„ t--1 •
South
West a-ere() 0/04-wit_ 4a-k-s-49—'k,`4A-
10East ht.

IN WITNESS WHEREOF THE PARTIES HERETO HAVE EXECUTED THESE PRESENTS

THE DAY AND YEAR FIRST HEREINABOVE WRITTEN.

SIGNED for and on behalf of

Licensor by: 6,ItAi1/43
Name:
}

Particulars: 6 (4 A , (1 r„.14.01
c.cOctir tow,
in the presence of:

1\16 !I)
doPA. A- R vA6c!

SIGNED for and on behalf of

Licensee by:
Name: kk•V‘; kkaNtm

Designation: i21111 (1)Ai O

in the presence ti

' k iv -
ikAAlt;
 AC;RU1:1411:N°1'

11'hi s Tripartito ;\greenwitt tor sub litulion of 1'a 1, Agreonwrd" is ern

t
20 10 at

Betwevn
rtel (Z. sl so tom apo
fo r,/ \11,0' t rs P801-11rn Gftytstrt 1,4 v444Z /sNlaved
bou vor,
ii/0„Av„, 0,d,t0 R‘o 4rik4 Lev\ r4, r t#lslt"IL.
thoreinaliei roforrod to as "Transferor" \vhich'INillaallrINFN -4'reptionain to or
nits011Sisterit with [he context, moan and includu, his I ,q,a1 utovs, adinutiqr=i1
legal ropresontati\ es and assigns) ol the FIRST PART,

‘,nd
J4iir4SIZAT
l\ rs. typi 611 (6H-A 1.-411 0 A .ARer:7. god about \
kir/N1rs. aod about voars, on (1 \,1 r,
Eosiding at 2-,,OALPATIA MOM um fooi seivr,k fa, i1)(,,r:einditer reterad to Gas ". transfervt,"
whit h torn) shall, uttless repugnant to or inconsislont llw contest, on'an and nil
their respective 1,egat heirs, executors, administrators, rept esontati os and +It
tho'4F('OND ['ART.

And
1
'c)e,10.v

6104.,./5
 31

St.441 Ar
Lico.st, No.- 64
AIRCid EJMITFD, a company in( orporated under the ("ompanies Art', 1956, havuT
- egistered office 769, Spencer 11a/a, 5th How, Anna S'alai, Chennai - 600002 and °flit e at
Plot `Co 2 & 3, Local Shopping (enter, (;;I„sclor-P), Pocket- I, Vacant Kunj, New - 11007(3
t,liereinalfer referred to as 1.icetisve'', which expression shall, wherever the tontexl so
0,„,fuits, mean and include its, its so kidiaries (Dishnet ireless Limited and Airco!
Cellular Limited), group conyanies, its affiliates, sutcessors and permitted assigns),
"11110 its Aulhorfrl'd Signatory RtsA aopi dathOlized Viki(
Of Y.TH PA RT,

insteror, Transferee and License( are hereinafter' 1 'Taffy

t,k,(1:\Idy the "Parties".

tiVIPAIAS the fronsferor wat, the absolute owner and in possession of properly hir,ning
intncit=mt no, elf. - A land underneath ).„3-4,3 sq. tats Le. IraSq(12- sq• Into,
ablated tt PIA, 04 ND 16(4
, oma Z -11-1. c.onstrucled „
., found floor area about sq. nib's & first floor, second floor, third floor ith to:; t
,f bout so, intrs and hounded as under:

(3kr .1-1 b9 PALn. Dp_c _s 6r c

C_F NITRA L la4ott, OF ► bi `i U-
WI 44d tL eryil+scut
t LA BA i kti-f In R azt-c-E7

it tortilla ler relerred to a - th(' Sid I Ptopertv )

ANI) WI fEREAS the Transferor had entered, We and executed I ik. t f ,y greof net.' \flii
Ireensee dated ai L Atli 7111 . 7) (hereinafter referred to as " Said Lce
itusgrycnwrit"),
A
original el wii;-, -11 is at 'ltd d!t Akinyxtire 7 A, .for use and of, collation tm I edx.r artf.
iicense haSis the Roof Top admoaSuring C4:6-0 Sq. it (I te,:et naf tit.; r ,','rn ,d le ;1,"'th e
Licensed Vroportv"1 Tor the .purtr),;es of providing better servicet, to i ,il ORWOS 101Cplionc.
1)tortiot and other customers, Aide sub-clause t of clause f? ot the .sa.iit ,i,it::,,,,
\greefffetft, the I ransicror has the right to transfer / convey the ",.--;a id Propert‘ prey',
that all the rights and liabilities 01 the Said Licence Agreement devolve upon the pun haw;
i.e, are dtterned by the said Hoyt haser.

\ND the" rtn5 ,g)iti his rights, Wit, and interest en tin '1014,
to the 'frinsferee by way of Sale i)eed duty regisloret1 as re,gi-dration iii c)20,
nook IV, I V01 130,4) cirri . r'r :'.{"t t:C. r(t t he .'• 24111--Rogicfrar - 0011,H 00
12.700i:,

AkNi) ILIZIAS the Pat ackneNvledge that with effect from the IH I
icen.se Agreement 4iall no downed to no 4.arnultancenclv amended ant' ‘10 ,,ey, ' fovt.o ,
:la;1 ,rat,
of Transferee and Transferee shall acsunte the rights, Ileltelik,
 83

obligaticms of the rransferor under the Said license Agreement and from the l'Ifectil.,,
Date the Transferor shall be released of its rights, benefits, citifies/ liabilities and obligations
under the Said License Agreement subject to and on the terms and conditions contained
herein,

-1.NI) WHEREAS pursuant to transfer sif the Said Property the Tr, nsferee intends to step
Into the shoes of the '1ransferot in the Said I.ionse Agreement. ffor Which all the Parties
have consented,

Now, therefore, in consideration of the mutual premises and the mutual cot 1,11thl
herein contained, (he Parties agree as follows.

I ; flectiv e 1 )ate:

this ,Agreement shall be effective from die date 01 eyet rtdon of this Agreement.

I of the fransferor, transferee and licensee hereby respectively agrees that, in

,:onsideration of the respective undertakings and releases set forth in this Clouse (the
sufficiency of all of which is hereby acknowledged), with effect on and frdm the kflective
late, the Said License Agreement shall be and be deemed to be novaied in favour of
transferee as follows:

ca) Transferor acknowledges that subject to Clause (c) and (d) below, from the F.fiectivt,
Pate onwards, his obligations, duties and liatiiitties under said ‘nse
Agreement shall he undertaken and perlormed:_by 'FransforOe;

) Subject to Clause (d) and .(e) below, rransferee releases and dis( barges the
fransferor fume the Fffective Date onwards from its future obligations, duties and
liabilities: under the Said license Agreement;

shall remain liable to Licensee for all liabilities

h runsleror ich flow from any act
or omission of the Transferor towards its obligations under the Said License
Agreement up to the Fffectiye Date (regardless of when that liability actually arises
or not).

(d) Transferor shall indemoilv the Licensee from and against any costs; claims
demands made by any person. for 'w in respo.'t of the failure of the Transferor to
observe sand perform its obligations under the Said License Agreement up to the
llfective 1)a le;

Mutual Covenants:

It 'Hie Said License Agreement .appended as Annexure - A has ken road and
understood by the Parties and shall form part and parcel this Ap, roolnonl. 'rho
 3t1

Transfera,. and. the I jcensee agree to abide by all (tic terms, t on( iti Jou 0;,k • tit

as Contained in the Said .1,i(rfiSe 1\

llii Agreement is irrevot able In the Tramferor Antler an circunpit upon

e\

)3 1110 EicerNce tlik$ :(1011051i With the f I-41P; fer00 at inkireSi. Ire Ocur n.,: deposit 01 Rs.
i
/411 6-pr - (R uocos 1-7 0 tytti ti -{-1 v 6 1.-t (AY-sit-Kip
(three) months" license fee/coiii pensation Which shall be retruidett 0)I i\aiiT t l° (tie
expiry or c;irlier determination of this Agreement without a ov ded uct jolt ther, from
alone, with the taiddiLIStOd amount, of advance license fees, if any, paid 11 the
licensor-, upon receipt of the Security Deposit amount from the transfei et, l ire it'd
that the Transteror has refunded the entire SecuritY Peposit amount withein ,nr,„.
dediwtions / dlieS I demand to the licensee.

Upon execution al this Agreement,. the Licensee will make all pax monk
tit lit inset' fee/coin pensation under the Said License Agreement (iv issuing ,l4 `t et

tiak i!t• /13.(tnk transler, in ra vor of the Ilditsicrec

\ 1v1Pc. acti and NIT/ Mrs. , (4.tirbi,,t.11,- in
proportions.

This Agreement shall become the integral part tot the Said License ; greealitm silttl
shall co 4ot-whim's together with !he Said !,icense
complete understanding between the Partie, ith >poi I' , ;
horvol,

IN WYENESS VV1 VREC)Ic the Parties hereto have exeutted this Agrees int on the
above ruentionee

sferor: lcufrt4g. ro)n-i

PLO4Ar-1._

rtinsferee: ,
5tItrti
J3 I-is iz11,1
I iCenSee:

Ityitnrsst's:
 35

BEFORE THE LD. ARBITRATOR MR. DHAN MOHAN

ADVOCATE, 'DELHI INTERNATIONAL ARBITRATION
CENTRE OF DELHI HIGH COURT.

Case Ref No.DIAC/7500/01-2024

IN THE MATTER OF:

HANSRAJ & ANRS .......CLAIMANT

versus
GTL INFRASTRUCTURE LTD. .....RESPONDENT

KNOW ALL to whom these present shall come that I, Shalender Kumar Thakur
(Authorised Signatory) of the above named Respondent GTL Infrastructure Limited
do hereby appoint (herein after called the advocate/s) to be my/our Advocate in the above
noted case authorized him/her :-

Mr. Swetank Shantanu(D/1896-C/99), Pratap Shanker(D-1613/02)

Advocates
D-21, 3RD FLOOR, JANGPURA EXTENSION, NEW DELHI- 110014
Mob. 9818058809, 9891200224

To act, appear and plead in the above-noted case in this Court or in any other Court in which the
same may be tried or heard and also in the appellate Court including High Court subject to payment
of fees separately for each Court by me/ us.

To sign, file verify and present pleadings, appeals cross objections or petitions for execution
review, revision, withdrawal, compromise or other petitions or affidavits or other documents as may
be deemed necessary or proper for the prosecution of the said case in all its stages. To file and take
back documents to admit and/or deny the documents of opposite party.
To withdraw or compromise the said case or submit to arbitration any differences or disputes that
may arise touching or in any manner relating to the said case.
To take execution proceedings. The deposit, draw and receive money, cheques, cash and grant
receipts thereof and to do all other acts and things which may be necessary to be done for the
progress and in the course of the prosecution of the said case.
To appoint and instruct any other Legal Practitioner, authorizing him to exercise the power and
authority hereby conferred upon the Advocate whenever he may think it to do so and to sign the
Power of Attorney on our behalf. And I/We the undersigned do hereby agree to ratify and confirm
all acts done by the Advocate or his substitute in the matter as my/our own acts, as if done by me/us
to all intents and purposes.
And I/We undertake that I / we or my /our duly authorized agent would appear in the Court on all
hearings and will inform the Advocates for appearance when the case is called.
And I /we undersigned do hereby agree not to hold the advocate or his substitute responsible for the
result of the said case. The adjournment costs whenever ordered by the Court shall be of the
Advocate which he shall receive and retain himself.
And I /we the undersigned do hereby agree that in the event of the whole or part of the fee agreed
by me/us to be paid to the Advocate remaining unpaid he shall be entitled to withdraw from the
prosecution of the said case until the same is paid up. The fee settled is only for the above case and
above Court. I/We hereby agree that once the fee is paid. I /we will not be entitled for the refund of
the same in any case whatsoever. If the case lasts for more than three years, the advocate shall be
entitled for additional fee equivalent to half of the agreed fee for every addition three years or part
thereof.

IN WITNESS WHEREOF I/We do hereunto set my hand to these presents the contents of which
have been understood by me/us on this 9/ th day of, 2024.
t raw
\'() Advocate (s) Clientf -^ •