High Court of KeralaSingle JudgeAR Nos. 69/2022, 70/2022, 71/2022 and 77/2022 d...
AR Nos. 69/2022, 70/2022, 71/2022 and 77/2022, In the High Court of Kerala at Ernakulam
Case / Petition Number:AR Nos.69/2022, 70/2022, 71/2022 and 77/2022
Case Details & Bench
- Court
- High Court of Kerala
- Hon'ble Judges
- N. Nagareesh
- Judgment Date
- 2022-10-07
- Court Decision / Holding
- The Arbitration Requests are allowed; Sundaram Govind (Retired District Judge) is appointed as the sole arbitrator; the arbitrator may rule on jurisdiction; the seat of arbitration is Kollam; the Registry to communicate; disclosure statements to be obtained under Section 11(8) read with Section 12(1); Fourth Schedule fees apply; parties to appear before the arbitrator; all contentions reserved to be raised before the arbitrator.
- Final Disposition
- AR Nos. 69/2022, 70/2022, 71/2022 and 77/2022 disposed in favor of proceeding to arbitration; appointment of a sole arbitrator; seat fixed at Kollam; jurisdictional questions to be decided by the arbitrator; compliance with Section 11(8) read with Section 12(1) and Fourth Schedule to be ensured.
Parties to the Case
Appellants / Petitioners
- M.A. Hakkim
- Abhinandu VS
- Mohammed Kaise
- Rahumath Beevi
Respondents
- M/S Patanjali Agro India Pvt. Ltd
- Patanjali Agro Pvt. Ltd
Legal Representation & Advocates
Counsels for Petitioners
- • Johnson Gomez
- • Mohamed Sheharan
- • Viswanath Jayan
- • Sanjith Johnson
- • Sree Devi S. Dinoop
- • P.D. Sanjay Johnson
- • John Gomez
- • S. Biju (Kizhakanela)
- • Parshath S.R.
Counsels for Respondents
- • Raghul Sudheesh
- • K. J. Glaxon
- • J. Lakshmi
- • Bini Das
Case Synopsis & Summary
Four arbitration requests (AR Nos. 69/2022, 70/2022, 71/2022 and 77/2022) were heard in the Kerala High Court. The petitioners, M.A. Hakkim, Abhinandu VS, Mohammed Kaise and Rahumath Beevi, entered into sale contracts with Patanjali Agro India Pvt. Ltd and Patanjali Agro Pvt. Ltd for raw cashew nuts. Disputes arose after delivery when quality samples by RBS Maritime Services indicated substandard quality and short weight; debit notes were issued, though the respondent admitted liability for short weight and disputed the quality reports. The contracts contained arbitration clauses: Ext. P1 fixed Haridwar as the seat and jurisdiction; Ext. P2 High Sea Sale Agreements provided Kollam as the seat with English language proceedings. The respondents argued for Haridwar; the petitioners argued that the two agreements show joint intent to Kollam. They invoked Section 11 of the Arbitration and Conciliation Act and urged purposive interpretation guided by the Supreme Court authorities in DLF Universal and Mankastu. After hearing, the court held that the joint intent reflected in the Contingent Ext. P1 and Ext. P2, and the explicit seat in Ext. P2, fix Kollam as the seat. It appointed Sundaram Govind, a retired district judge, as the sole arbitrator, empowered to rule on jurisdiction, with fees governed by the Fourth Schedule and directions to obtain disclosure under Section 11(8) read with Section 12(1). All contentions remain open for the arbitrator.
Provisions of Law Cited
Arbitration and Conciliation Act, 1996, Section 11(5)Arbitration and Conciliation Act, 1996, Section 11(8)Arbitration and Conciliation Act, 1996, Section 12(1)Arbitration and Conciliation Act, 1996, Fourth Schedule
Legal Doctrines & Maxims
- Purposive interpretation
- Joint intent of the parties
Submissions & Arguments
Contentions of Appellants / Petitioners
The petitioners contended that the arbitration clause in Ext. P1 fixing the seat at Haridwar must be harmonised with the High Sea Sale Agreements Ext. P2 which specify Kollam as the seat. They rely on purposive interpretation and joint intent of the parties, as explained in DLF Universal Ltd. and others v. Director, T and C Planning Haryana and others, and on the principle that the seat of arbitration may be determined from other clauses and conduct (Mankastu Impex Pvt. Ltd. v. Airvisual Ltd). They seek appointment of an arbitrator under Section 11(5) of the Arbitration and Conciliation Act, 1996 arguing Kollam as the seat.
Contentions of Respondents
The respondents contend that Ext. P1 fixes Haridwar as the seat and jurisdiction lies there; arbitration should be conducted in Haridwar; they challenge the maintainability before this court and raise objections to the existence of Patanjali entities and jurisdiction; they rely on the seat clause to oppose this court's jurisdiction.
Cited Precedents (2)
| Case Name | Citation | Treatment | Explanation |
|---|---|---|---|
| Mankastu Impex Private Limited v. Airvisual Limited | (2020) 5 SCC 399 | Positive | Cited to support that the seat of arbitration should be determined by joint intent and conduct of the parties, aligning with the court's reasoning that Kollam is the seat. |
| DLF Universal Ltd. and others v. Director, T and C Planning Haryana and others | (2010) 14 SCC 1 | Positive | Cited for purposive interpretation of contracts and joint intent to determine the subject matter and seat of arbitration. |
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Extracted Judgment Text
Exact text extracted from official judgment records.
## **IN THE HIGH COURT OF KERALA AT ERNAKULAM**
## **PRESENT**
## **THE HONOURABLE MR.JUSTICE N.NAGARESH**
**FRIDAY, THE 7[TH] DAY OF OCTOBER 2022 / 15TH ASWINA, 1944**
**AR NO. 69 OF 2022**
## **PETITIONER:**
**M.A.HAKKIM AGED 80 YEARS THE PROPRIETOR, M/S V.M.K EXPORTS, KHAISE BUILDING, BEACH ROAD, KOLLAM, KERALA, PIN - 691004**
**BY ADVS. JOHNSON GOMEZ MOHAMED SHEHARAN VISWANATH JAYAN SANJITH JOHNSON SREEDEVI S. DINOOP P.D. SANJAY JOHNSON JOHN GOMEZ S.BIJU (KIZHAKKANELA)**
## **RESPONDENTS:**
**1 M/S PATANJALI AGRO INDIA PVT. LTD C/O PATANJALI FOOD AND HERBAL PARK, VILLAGE PATHARTHA, LAKSAR ROAD, HARIDWAR, UTTARAKHAND. REPRESENTED BY THE MANAGING DIRECTOR., PIN – 240494**
**2 PATANJALI AGRO PVT LTD, HAVING A REGISTERED OFFICE AT KRIPALU BHAG, KANKHAI, HARIDWAR, UTTARAKHAND. REPRESENTED BY ITS MANAGING DIRECTOR., PIN - 249408**
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**BY ADVS. SRI.RAGHUL SUDHEESH SRI.K.J.GLAXON(K/708/2006) SMT.J.LAKSHMI(K/360/2013) SMT.BINI DAS(K/833/2022)**
**THIS ARBITRATION REQUEST HAVING COME UP FOR ADMISSION ON 07.10.2022, ALONG WITH AR.70/2022, 71/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:**
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## **IN THE HIGH COURT OF KERALA AT ERNAKULAM**
**PRESENT**
**THE HONOURABLE MR.JUSTICE N.NAGARESH**
**FRIDAY, THE 7[TH] DAY OF OCTOBER 2022 / 15TH ASWINA, 1944 AR NO. 70 OF 2022**
**PETITIONER:**
**ABHINANDU VS AGED 37 YEARS PROPRIETOR, M/S ROHINI OVERSEAS TRADING, KP IX/926 B, PALKULANGARA, KALLUMTHAAZHAM PO, KILIKOLLUR, KOLLAM, KERALA, PIN - 691004**
**BY ADVS. JOHNSON GOMEZ MOHAMED SHEHARAN SREEDEVI S. PARSHATHY S.R. S.BIJU (KIZHAKKANELA) SANJITH JOHNSON SANJAY JOHNSON JOHN GOMEZ**
**RESPONDENTS:**
**1 PATANJALI AGRO INDIA , PVT. LTD C/O PATANJALI FOOD AND HERBAL PARK, VILLAGE PATHARTHA, LAKSAR ROAD, HARIDWAR, UTTARAKHAND. REPRESENTED BY MANAGING DIRECTOR., PIN - 249404**
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**2 PATANJALI AGRO PVT. LTD. HAVING A REGISTERED OFFICE AT KRIPALU BHAG, KANKHAI, HARIDWAR, UTTARAKHAND, REPRESENTED BY ITS MANAGING DIRECTOR., PIN - 249408**
**BY ADVS. SRI.RAGHUL SUDHEESH SRI.K.J.GLAXON(K/708/2006) SMT.J.LAKSHMI(K/360/2013) SMT.BINI DAS(K/833/2022)**
**THIS ARBITRATION REQUEST HAVING COME UP FOR ADMISSION ON 07.10.2022, ALONG WITH AR.69/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:**
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## **IN THE HIGH COURT OF KERALA AT ERNAKULAM**
## **PRESENT**
**THE HONOURABLE MR.JUSTICE N.NAGARESH**
**FRIDAY, THE 7[TH] DAY OF OCTOBER 2022 / 15TH ASWINA, 1944 AR NO. 71 OF 2022**
**PETITIONER:**
**MOHAMMED KHAISE AGED 51 YEARS S/O M.A HAKKIM, PROPRIETOR OF M/S RAHUMATH CASHEW CORPORATION, KHAISE BUILDINGS, BEACH ROAD, KOLLAM, PIN - 691001**
**BY ADVS. JOHNSON GOMEZ S.BIJU (KIZHAKKANELA) SANJAY JOHNSON JOHN GOMEZ SREEDEVI S. SANJITH JOHNSON MOHAMED SHEHARAN VISWANATH JAYAN PARSHATHY S.R.**
**RESPONDENTS:**
**1 M/S PATANJALI AGRO INDIA PVT. LTD C/O PATANJALI FOOD AND HERBAL PARK, VILLAGE PATHARTHA, LAKSAR ROAD, HARIDWAR, UTTARAKHAND. REPRESENTED BY MANAGING DIRECTOR., PIN – 240494**
**2 PATANJALI AGRO PVT. LTD. REGISTERED OFFICE AT KRIPALU BHAG, KANKHAI, HARIDWAR, UTTARAKHAND. REPRESENTED BY ITS MANAGING DIRECTOR., PIN - 249408**
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**BY ADVS. SRI.RAGHUL SUDHEESH SRI.K.J.GLAXON(K/708/2006) SMT.J.LAKSHMI(K/360/2013) SMT.BINI DAS(K/833/2022)**
**THIS ARBITRATION REQUEST HAVING COME UP FOR ADMISSION ON 07.10.2022, ALONG WITH AR.69/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:**
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## **IN THE HIGH COURT OF KERALA AT ERNAKULAM**
## **PRESENT**
**THE HONOURABLE MR.JUSTICE N.NAGARESH**
**FRIDAY, THE 7[TH] DAY OF OCTOBER 2022 / 15TH ASWINA, 1944 AR NO. 77 OF 2022**
**PETITIONER:**
**RAHUMATH BEEVI AGED 72 YEARS D/O MOHAMMED HANEEFA, PROPREITOR OF KHAISE INTERNATIONAL, KHAISE BUILDING, BEACH ROAD, KOLLAM, KERALA, PIN – 691001**
**BY ADVS. JOHNSON GOMEZ S.BIJU (KIZHAKKANELA) SANJAY JOHNSON JOHN GOMEZ SREEDEVI S. MOHAMED SHEHARAN SANJITH JOHNSON PARSHATHY S.R. VISWANATH JAYAN**
## **RESPONDENTS:**
- **1 M/S PATANJALI AGRO INDIA PVT. LTD C/O PATANJALI FOOD AND HERBAL PARK, VILLAGE PATHARTHA, LAKSAR ROAD, HARIDWAR, UTTARAKHAND. REPRESENTED BY MANAGING DIRECTOR, PIN - 249404**
- **2 PATANJALI AGRO PVT. LTD. REGISTERED OFFICE AT KRIPALU BHAG, KANKHAI, HARIDWAR, UTTARAKHAND. REPRESENTED BY ITS MANAGING DIRECTOR., PIN - 249408**
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**BY ADVS. SRI.RAGHUL SUDHEESH SRI.K.J.GLAXON(K/708/2006) SMT.J.LAKSHMI(K/360/2013) SMT.BINI DAS(K/833/2022)**
**THIS ARBITRATION REQUEST HAVING COME UP FOR ADMISSION ON 07.10.2022, ALONG WITH AR.69/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:**
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## **CR**
## **N. NAGARESH, J.**
`````````````````````````````````````````````````````````````
A.R. Nos.69, 70, 71 and 77 of 2022
````````````````````````````````````````````````````````````` _Dated this the 7[th] day of October, 2022_
## **O R D E R**
~ ~ ~ ~ ~ ~
The petitioners in these four Arbitration Requests entered into Ext.P1 Sales Contracts with the 1[st] respondent for sale of raw cashew nuts. They later entered into a mutually acceptable High Sea Sale Agreements (Ext.P2) whereunder the respondents sold to the petitioners certain quantity of net weight raw cashew nuts in shell at specified rate. The 1[st] respondent issued invoices to the petitioners for the amount payable. The petitioners took delivery of original shipping documents.
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2. The petitioners state that it was agreed that quality inspection was to be done by RBS Maritime Services. The designated agency took samples from Tuticorin and found that the cashew nuts were of low quality and submitted Annexure-A4 inspection reports. The petitioners therefore issued debit notes. The 1[st] respondent sent e-mail communication stating that the reports of the RBS Maritime Service are null and void as regards quality and admitting liability for short weight.
3. Though the Broker of the 1[st] respondent initially agreed to resolve the issue, later he repudiated the claim. The 1[st] respondent then issued a notice alleging contractual violation and making monetary claims with 12% interest. The petitioners issued Annexure-A7 reply denying the allegations made by the 1[st] respondent. Thereafter, in accordance with the terms contained in Annexure-A2, the petitioners proposed to appoint Sri. E. Francis as the Sole Arbitrator, as per Annexure-A8 notices. The respondents have not responded to Annexure-A8.
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4. Hence, the petitioners have invoked Section 11(5) of the Arbitration and Conciliation Act, 1996 to arbitrate the dispute between the petitioners and the respondents.
5. The 1[st] respondent entered and contested the Arbitration Requests. The 1[st] respondent submitted that there is no entity named Patanjali Agro Pvt. Ltd. and impleading such an entity as 2[nd] respondent is unwarranted. The 1[st] respondent submitted that this Court has no jurisdiction to entertain the Arbitration Requests. The claims of the petitioners are bogus.
6. The 1[st] respondent contended that in view of Clause 4 of Ext.P1 Sales Contract, it is mandatory that when a third party inspection is made, the same be made in the presence of the 1[st] respondent. Therefore, the inspection, if any, made at the instance of the petitioners is not binding on the 1[st] respondent.
7. The 1[st] respondent further argued that as per Clause 10 of Ext.P1 Sales Contracts, the resolution of any disputes between the parties shall be through arbitration and
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the seat of arbitration shall be Haridwar. The Sales Contracts are subject to High Sea Sale Agreements. Only the terms of the Sale Contracts and not the terms of the High Sea Sale Agreements shall be attracted.
8. The 1[st] respondent relied on the judgment of the Apex Court in _**Mankastu Impex Private Limited v. Airvisual Limited** [(2020) 5 SCC 399]_ and contended that the question of seat of arbitration is all about which court would have the supervisory power over the arbitration proceedings. As the seat of arbitration is Haridwar, beyond the territorial limits of Kerala, this Court has no jurisdiction to entertain the Arbitration Requests, contended the 1[st] respondent.
9. Heard.
10. The prime defence raised by the 1[st] respondent against the Arbitration Requests made by the petitioners is that as per Ext.P1 Sales Contracts, the seat of arbitration is Haridwar and hence Arbitration Requests are not maintainable before this Court. The petitioners would submit
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that as per Ext.P2 High Sea Sale Agreements executed by the 1[st] respondent, the seat of arbitration is Kollam, in Kerala and hence the seat of arbitration proceedings should be Kollam. This Court has hence jurisdictional competence to appoint Arbitrator.
11. Contracts are to be interpreted according to their purpose. The purpose of contract is the interest, objectives and values that the contract is designed to actualise. It comprises joint interest of the parties. The Hon’ble Apex Court has held in _**DLF Universal Ltd. and others v. Director, T and C Planning Haryana and others** [(2010) 14 SCC 1]_ that consistent with the character of purposive interpretation, the court is required to determine the ultimate purpose of the contract primarily by the joint intent of the parties. It is not the intent of a single party.
12. In these Arbitration Requests, the 1[st] respondent first issued Ext.P1 Sales Contracts to the petitioners. Clause 10 thereof provided that all disputes arising are to be settled via arbitration under the Indian Arbitration Act and under
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Haridwar jurisdiction only. But, it was made clear in the Sales Contracts that those contracts are contingent upon signing of mutually acceptable High Sea Sales Agreements.
13. Thereafter, the parties entered into Ext.P2 High Sea Sales Agreements. Clause 10 of the High Sea Sales Agreements provided that Arbitration shall be held at Kollam and the proceedings shall be in English language. As the initial Sales Contracts were specifically made contingent upon signing of “mutually acceptable” High Sea Sales Agreements and the subsequently executed and “mutually acceptable” High Sea Sales Agreements specified that arbitration should be held at Kollam, the joint intent of the parties can only be taken as one deciding that the seat of arbitration should be Kollam.
14. The Hon’ble Apex Court in the judgment in _**Mankastu Impex Private Limited v. Airvisual Limited**_
_[(2020) 5 SCC 399]_ has held that the intention of the parties as to the seat of arbitration should be determined from other clauses in the agreement and the conduct of the parties. The
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fact that the initial Sales Contract was made contingent upon mutually acceptable High Sea Sales Agreement to be entered into and the fact that the subsequent High Sea Sales Agreement signed by the parties stipulated that the arbitration should be held at Kollam, would show that joint intention of the parties was to fix the seat of arbitration as Kollam.
15. Other grounds raised by the 1[st] respondent in the counter affidavit relate to factual aspects and conduct of parties, which can be looked into by Arbitrator and does not deserve adjudication in these proceedings. In the facts of the case, the petitioners in the Arbitration Requests are entitled to relief.
16. The Arbitration Requests are therefore ordered as follows:
(i) Mr. Sundaram Govind (Retired District Judge) is appointed as the sole Arbitrator, to arbitrate upon the disputes that have arisen between the applicant and the respondent arising out of Annexure-A1 and Annexure-A2.
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(ii) The learned Arbitrator is at liberty to rule on his own jurisdiction, if the parties raise such a dispute.
(iii) The Registry is directed to communicate a copy of this order to the learned Arbitrator within a period of ten days from today and to obtain a Statement of Disclosure from the learned Arbitrator as provided under Section 11(8) read with Section 12(1) of the Act.
(iv) Once the Disclosure Statement is obtained from the learned Arbitrator, the Registry shall issue the certified copy of this order to the learned Arbitrator, with a copy of the said statement appended to it, retaining the original of the same by this Court.
(v) The fees of the learned Arbitrator shall be governed by the Fourth Schedule of the Act.
(vi) The learned Arbitrator shall decide the manner in which the fees and expenses of the arbitration proceeding has to be paid by the parties.
(vii) The parties will appear before the learned Arbitrator on such date and place as decided by the learned Arbitrator.
(viii) All contentions of the parties are left open to be raised before the learned Arbitrator.
Sd/-
**N. NAGARESH, JUDGE**
aks/03.10.2022
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## **APPENDIX OF AR 69/2022**
## **PETITIONER'S ANNEXURES**
|**Annexure A1**|**TRUE COPY OF THE SALES CONTRACT**|
|---|---|
||**DATED 30.06.2021**|
|**Annexure A2**|**TRUE COPY OF THE HIGH SEAS SALE**|
||**AGREEMENT ENTERED INTO BETWEEN**|
||**PETITIONER AND RESPONDENT NO. 1**|
||**DATED 10/08/2021**|
|**Annexure A3**|**TRUE COPY OF**|
||**INVOICE NO. PAI/1/21-22/005/10.8.2021**|
|**Annexure A4**|**TRUE COPY OF THE RBS REPORT NO.**|
||**RBS/KLM/54729/B&C DATED 02/09/2021**|
|**Annexure A5**|**TRUE COPY OF THE DEBIT NOTE**|
||**DATED 07/9/2021**|
|**Annexure A6**|**TRUE COPY OF THE NOTICE**|
||**DATED 25/10/2021 ISSUED ON BEHALF OF**|
||**THE PETITIONER**|
|**Annexure A7**|**TRUE COPY OF THE REPLY NOTICE**|
||**DATED 13/11/2021**|
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## **APPENDIX OF AR 70/2022**
## **PETITIONER'S ANNEXURES**
|**Annexure A1**|**A TRUE COPY OF THE SALES CONTRACT**|**A TRUE COPY OF THE SALES CONTRACT**||
|---|---|---|---|
||**DATED 25.06.2021**|||
|**Annexure A2**|**A TRUE COPY OF THE HIGH SEAS SALE**|||
||**AGREEMENT**<br>**ENTERED**<br>**INTO**|**BETWEEN**||
||**PETITIONER AND RESPONDENT NO. 1**|||
||**DATED 10/08/2021**|||
|**Annexure A3**|**A TRUE COPY OF**|||
||**INVOICE NO. PAI/1/21-22/001**|||
||**DATED 10.8.2021**|||
|**Annexure A4**|**A TRUE COPY OF THE RBS MARITIME**|||
||**SERVICE**<br>**REPORT**<br>**WITH**||**NO.**|
||**RBS/KLM/54757/B & RBS/KLM/54757/C**|||
||**DATED 08/09/2021**|||
|**Annexure A5**|**A TRUE COPY OF THE DEBIT NOTE**||**NO.**|
||**08/2022 DATED 08/09/2021**|||
|**Annexure A6**|**A TRUE COPY OF THE NOTICE **|**DATED**||
||**26/10/2021 ISSUED BY THE PETITIONER**|||
|**Annexure A7**|**A TRUE COPY OF THE REPLY NOTICE**|||
||**DATED 13/11/2021**|||
|**Annexure A8**|**A TRUE COPY OF THE NOTICE DATED SENT**|||
||**BY THE PETITIONER ON 21.11.2021**|||
|**Annexure A9**|**A TRUE COPY OF THE**|||
||**LETTER**||**NO.**|
||**CPT/2001370922/2001377487/2021**|||
||**DATED 12/01/2022 ISSUED BY THE**|||
||**SENIOR SUPERINTENDENT OF POST**|**OFFICES**||
||**KOLLAM**|||
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## **APPENDIX OF AR 71/2022**
## **PETITIONER'S ANNEXURES**
|**Annexure A1**|**A TRUE COPY OF THE**|**SALES CONTRACT**|
|---|---|---|
||**DATED 24.06.2021**||
|**Annexure A2**|**A TRUE COPY OF THE HIGH SEAS SALE**||
||**AGREEMENT ENTERED INTO BETWEEN**||
||**PETITIONER AND RESPONDENT NO. 1**||
||**DATED 10/08/2021**||
|**Annexure A3**|**A TRUE COPY OF**||
||**INVOICE**|**NO.**<br>**PAI/1/21-**|
||**22/004/10.8.2021**||
|**Annexure A4**|**A TRUE COPY OF THE**||
||**RBS REPORT NO. RBS/TTN/46527/D&E**||
||**DATED 04/09/2021**||
|**Annexure A5**|**A TRUE COPY OF THE**|**DEBIT NOTE**|
||**DATED 07/09/2021**||
|**Annexure A6**|**A TRUE COPY OF THE**|**NOTICE**|
||**DATED 25/10/2021 ISSUED ON BEHALF OF**||
||**THE PETITIONER**||
|**Annexure A7**|**A TRUE COPY OF THE REPLY TO NOTICE**||
||**DATED 13/11/2021 **|**SENT BY THE**|
||**RESPONDENT**||
|**Annexure A8**|**A TRUE COPY OF THE**|**NOTICE**|
||**DATED 21/11/2021 **|**SENT BY THE**|
||**PETITIONER**||
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## **APPENDIX OF AR 77/2022**
## **PETITIONER'S ANNEXURES**
|**Annexure A1**|**A TRUE COPY OF THE SALES CONTRACT**||
|---|---|---|
||**DATED 25.06.2021**||
|**Annexure A2**|**TRUE COPY OF THE HIGH SEAS **|**SALE**|
||**AGREEMENT WITH CERTIFICATE NO. **|**IN-**|
||**UK36325644743847TENTERED INTO BETWEEN**||
||**PETITIONER AND RESPONDENT NO. 1**||
||**DATED 10/08/2021**||
|**Annexure A2(a)**|**TRUE COPY OF THE HIGH SEAS **|**SALE**|
||**AGREEMENTWITH CERTIFICATE NO. **|**IN-**|
||**UK36324730522104TENTERED INTO BETWEEN**||
||**PETITIONER AND RESPONDENT NO. 1**||
||**DATED 10/08/2021**||
|**Annexure A3**|**TRUE**<br>**COPIES**<br>**OF**<br>**INVOICE**|**NO.**|
||**PAI/1/2122/002**||
||**DATED 10.8.2021**||
|**Annexure A3(a)**|**TRUE**<br>**COPIES**<br>**OF**<br>**INVOICE**|**NO.**|
||**PAI/1/2122/003 DATED 10.8.2021**||
|**Annexure A4**|**TRUE COPIES OF THE RBS REPORTS**|**NO.**|
||**RBS/KLM/54720/B&C DATED 01/09/2021**||
|**Annexure A4(a)**|**TRUE COPIES OF THE RBS REPORTS**|**NO.**|
||**RBS/TTN/46510/D&E DATED 31.08.2021**||
|**Annexure A5**|**TRUE COPIES OF THE DEBIT NOTES DATED**||
||**07/09/2021 FOR**||
||**INVOICE NO.'S PAI/1/2122/002**||
|**Annexure A5(a)**|**TRUE COPIES OF THE DEBIT NOTES DATED**||
||**07/09/2021 FOR**||
||**INVOICE NO.'S PAI/1/2122/003**||
|**Annexure A6**|**A TRUE COPY OF THE NOTICE DATED**||
||**25/10/2021 ISSUED ON BEHALF OF **|**THE**|
||**PETITIONER**||
|**Annexure A7**|**A TRUE COPY OF THE REPLY NOTICE DATED**||
||**13/11/2021**||
|**Annexure A8**|**A TRUE COPY OF THE NOTICE DATED**||
||**21/11/2021 SENT BY THE PETITIONER**||