14/10/2013 To, Sr.C.D.O.

Bandra Terminus, Western Railway, Mumbai Sub:- Contract for internal cleaning with toilet cleaning by high pressure.. for STR PF Trains at Coaching depots BDTS. Ref : Your letter no 137/19/4/(PF) dated 8.10.2012 With reference to your above letter we would like to state as follows. We had been allotted LOA on 30.7..2013 for contract no . As per the tender conditions given in Annexure E we had to deploy 0.45 man power per coach per day. i.e. if there are 201 coaches we had to supply 90 nos man power per day and fixed 12 nos men 6 in 1st shift and 6 in 2nd shift. If there are less coaches we have to deploy manpower accordingly. We had started work on 2.8..2013 all the work was being carried out as per the tender conditions. Labour was being deployed at 0.45 per coach, all the coaches were being cleaned and inspected by your officer in charge. There was no complain till the date we worked ie Suddenly the department demanded they required labor for 8 hours shift i.e. fixed labour. But this not being as per the tender condition we could not comply for the same and go against the tender condition. The department is asking for .. no of labor for 8 hours fixed which is contrary to the tender conditions and illegal and bad in law. We have written several letters to the concerned authorities informing that we are required to deploy 0.45 per coach and not provide fixed labor. The department is forcing us to employ fixed . No of labor for 8 hours which is evident from letter dated 25.09.2013. Which is contrary to the tender. We have even worked for 20 days from 2.8.2013 to 21.8.2013 when we were asked to stop the work by the department for wrong reasons.

We have always been ready to submit performance guarantee provided we are allowed to work as per the tender conditions. As the department is not ready to permit us to work as per the tender conditions we were compelled to stop work and not provide performance guarantee. In our previous letters we had categorically stated that we shall not be held responsible for not submitting the performance guarantee in time. We have to state that your termination is illegal and bad in law. No prior notice as contemplated by GCC rules is given before illegally terminating the contract and therefore also the termination is bad in law. We have invoked the arbitration clause for appointing arbitrator vide our letter dated Thanking You Yours faithfully For P.S. Chandock & Com

Proprietor

14.10.2013 To, General Manager Western Railway, Churchgate Mumbai Sub:- Contract for internal cleaning with toilet cleaning by high pressure.. for STR PF Trains at Coaching depots BDTS. Ref : Tender No M137/19.4(PF) dated 6.03.2013.

Sir, We have received letter dated 08.10.2013 from DRM illegally terminating our Contract / LOA. Disputes and differences have arisen between our self and the Senior CDD, BDDS. In view of the aforesaid we hereby invoke the arbitration clause and have to request you to kindly appoint an arbitration from your panel to redress our grievance. Thanking You Yours faithfully For P.S. Chandock & Com

Proprietor