BEFORE THE SENIOR CIVIL JUDGE ,TIS HAZARI

COURT,DELHI

ORIGINAL JURISDICTION

ARB. P. NO. OF 2005

IN THE MATTER OF:

M/s Sahil Brothers

Through Proprietor,
Manju Dhingra,
1496, Street No.7,
Ramganj Mandi,
Moga. ... Applicant

Versus

M/s Reliance Engineering,

Associates Pvt. Ltd.
SCF 61-62, Phase II,
Mohali-160 055,
(Punjab). … Respondent

1. Provisions under which Section 11 (6) of the

Application is filed Arbitration and Conciliation
Act, 1996

2. Name of the Applicant with M/s Sahil Brothers

address Through Proprietor, Manju
Dhingra,1496, Street No.7,
Ramganj Mandi, Moga.

3. Name of the other party to M/s Reliance Engineering,

Arbitration Agreement with Associates Pvt. Ltd. SCF
complete address 61-62, Phase II, Mohali-160
055, (Punjab).

4. Names and addresses of the

Arbitrator, if any, already Not Applicable
appointed by parties

5. Names and addresses of the To be appointed by the

person or institution, if any, to Hon’ble Court
whom any function has been
entrusted or the parties of the
Arbitration Agreement under
the appointment procedure
 agreed upon by them

6. Qualification required, if any

of the Arbitrator by the Not Applicable
agreement of the parties

7. STATEMENT OF FACTS:

1. That the Applicant, herein M/s Sahil Brothers have

their registered office at 1496, Street No.7, Ramganj Mandi,

Moga and are engaged in construction work.

2. That the Respondent herein M/s Reliance Engineering

Associates Pvt. Ltd., have their registered office at SCF 61-62,

Phase II, Mohali-160 055, (Punjab) and are also engaged in

construction work.

3. That the Applicant herein was granted Work

Order/Agreement No.13500695 by Respondent for laying

optical fiber cable on sangur-sunam route. The Applicant

started work on the said project on 5.12.2001 and completed

on 21.12.2001. The above referred agreement is in the

possession of the Respondent.

4. That the Applicant, after undertaking the work under

the said Work Order/Agreement submitted various bills

towards the payment for undertaking the work under the

aforesaid Work Order/Agreement No.13500695.

5. That however Respondent while making payments of

said bills made a illegal deduction of Rs.1,36,125 on account

of material recovery. However no detail was given on what

basis deductions were made.

6. Further more payment of Rs.42,620 i.e. security refund

and amount of Rs.4402/ was also deducted as T.D.S. amount

without giving any reasons for deduction.

7. That because of unjust deductions made by Respondent

a legal notice dated 8.8.2003 was sent to Respondent

through Petitioner’s Counsel calling upon Respondents to pay

the aforesaid illegally deducted amount .The true copy of the

legal notice dated 8.8.2003 is annexed herewith as Annexure-

A.

8. It was further stated in the legal notice that the

Respondent have tempered badly with the photocopies of the

I.T.P’s enabling them to make illegal deductions. The

Applicant also made it clear to the Respondent that they are

in possession of the photocopies of the original I.T.Ps and

also the photocopies of the tampered I.T.P.s’.

9. The Applicant further specified in the notice that by this

notice he is calling upon Respondent to make full payment of

the amounts referred to above alongwith interest @ 12% per

annum from the date they were due to Applicant till the date

of payment which amounts have been retained by

Respondent illegally and without any justification, within one

month of the receipt of this notice, failing which Applicant

shall be constrained to take appropriate action against

Respondent as is available under the law.

10. The said notice was replied by Respondent on

27.8.2003, wherein they admitted that Applicant have

submitted bills for payment towards the execution of the

Work Order\Agreement No.13500695. The Respondent

further said that the deduction of Rs.1,36,125/- has not been

made on account of the material recovery but the same has

been deducted for extra payment made by Respondent to

Applicant for Soil Exca, on Trenching work in previous Bill

.and since the payment of Rs.1,36,125/- was already made

for Soil Excavation in trenching under service code 3043223,

however, on the basis of joint inspection by Applicant and

respondent it was revealed that the payment was to be made

for hard Soil under service code 3036175, which comes to

Rs.2,09,632.50p and the same was paid by respondent and

the amount of Rs.1,36,125/- which was already paid by

Respondent for the same was deducted by Respondent.

Therefore, the claim of Applicant is without any basis as the

amount has not been deducted on account of material

recovery. The true copy of the reply dated 27.8.2003 to the

legal notice dated 8.8.2003 is annexed herewith as Annexure-

B.

11. However no steps were taken by the Respondent to

remit the payment even after the legal notice and repeated

telephonic requests made by the applicant.

12. Again on 1.7.2004 another legal notice was sent by

Applicant to the Respondent stating therein that as the

Applicant have already served a legal notice through Sh.

Puneet Kansal, Advocate on 8.8.2003 which was duly

acknowledged by Respondent company and Reply was filed,

the Applicant is compelled to invoke the arbitration clause of

the Work Order\ Agreement No. 13500695.

13. It is now relevant to quote here the Arbitration clause of

the Work Order/Agreement:-

“Arbitration
If any disputes or differences arise between the
Owner and the Contractor in relation to or out of
this Contract, the same shall be referred to the
arbitration of two arbitrators, one each to be
appointed by the Owner and the Contractor. The
provisions of the Indian Arbitration Act, 1940 shall
apply for such arbitration. The decision so given
shall be final and binding upon the parties
hereto”.
14. It was further submitted by the Applicant in the legal

notice dated 1.7.2004 that though the Respondent have

admitted in their reply dated 27.8.2003 that they have

deducted Rs.1,36,125/- and TDS amount, on account of

extra payment, made to Applicant. Whereas at the time of

deduction of the amount Respondents have mentioned that

the same amount has been deducted on account of material

recovery. This clearly shows their malafide attitude.

15. In these circumstances now there is a dispute whether

the deducted amount is on account of material recovery or on

account of extra payment. It was further stated in the notice

that the Applicant do not admit any extra payment as alleged

by Respondent in their reply.

16. It was also stated in the Legal Notice dated 1.7.2004

that in these circumstances now there is no other alternative

but only to get adjudicated the matter through arbitration as

per the agreement. Similarly Respondent admitted in his

reply that he have deducted the TDS, but as per law the

amount of TDS is not deductible as per the provision of

Income Tax Act. So there is again controversy between the

company and Applicant, whether the TDS is deductible or

not. Again this matter is to be adjudicated through

arbitration.
17. It was further stated by the Applicant in their legal

notice that as now the dispute has arisen as per Work

Order/Agreement therefore the dispute of this effect can be

adjudicated through arbitration only as per Work

Order/Agreement entered between the parties.

18. That as per the Work Order/Agreement there is a clause

of arbitration i.e. “if any dispute or difference arise between

the owner and the contractor in relation to or out of this

contract, the same shall be referred to the arbitration of two

arbitrator, one each to be appointed by the owner and the

contractor and the provisions of the arbitration Act shall

apply for such arbitration. The decision of the Arbitrator

shall be final and binding upon the parties.” So in light of

this arbitration clause, now there is a dispute regarding the

amount deducted by the company and this dispute is to be

adjudicated through arbitration. Therefore as the present

dispute is regarding the amount deducted by the Respondent

Company with regard to bills raised by Applicant under Work

Order/Agreement No.13500695 and this dispute is to be

adjudicated through arbitration. So the Respondent must

suggest the name of the arbitrator so that Applicant also can

suggest the name of their arbitrator and also refer all the

documents to the arbitrator for the adjudication.

19. The Legal notice dated 1.7.2004 clearly stated that

Respondent should mention the name of the arbitrator and

to refer the matter to arbitrator as per the clause of the

agreement and also supply the certified copy of the agreement

within one month from the date of receipt of this notice,

failing which Applicant shall be constrained and compelled to

knock the door of Court of law for the appointment of the

arbitrator under the provisions of Arbitration and conciliation

Act 1996 and in that event, the Respondent Company will be

held responsible for all types of costs and damages incurred

by Applicant. The true copy of the Legal Notice dated

1.7.2004 is annexed herewith as Annexure-C.

20. The Legal Notice dated 1.7.2004 was replied by the

Respondent on 6.9.2004 wherein the Respondent again

repudiated the Respondents claim and refused to appoint an

Arbitrator. True Copy of the reply dated 6.9.2004 is annexed

herewith as Annexure-D.

21. That till today even after the lapse of considerable time

the respondents have failed to take any step towards

forwarding the name of arbitrator and issuing the certified

copy of work agreement/order.

20. That because of this irresponsible/illegal attitude of the

Respondent, Applicant herein is constrained to file the

present petition before this Hon’ble Court.

21. That the Applicant is always ready and willing to refer

the present dispute to the Arbitration as per the terms of the

Work Order/Agreement. The Applicant is seeking the

assistance of this Hon’ble Court for appointment of an

arbitrator primarily due to the non-cooperative and

unreasonable attitude and conduct of the Respondent

Company.

22. That the Applicant has no other efficacious alternate

remedy except to approach this Hon’ble Court by way of the

present Petition to redress their grievances as Respondent

have failed to comply with the terms of Work

Order/Agreement.

23. That the Applicant has not filed any other or similar

Petition earlier before this Hon’ble Court or any other court

praying the same relief as in the present Petition.

25. The Applicant also submits that this Hon’ble Court has

all the necessary territorial jurisdiction to entertain the

present Petition. It is irrelevant to state that the parties had

mutually decided to subject all differences and/or disputes

arising between them to the court in New Delhi as per clauses

of the Work Order/Agreement].

8. Valuation of the subject Rs.2,52,100/- with interest

matter @ 18% Per Annum
[Rupees two lacs and fifty
two thousand and one
hundred only] as on 15th
November, 2001 Plus
interest @ Eighteen Percent
Per Annum

Court fees paid as per the

rules of Hon’ble Delhi High
Court in accordance with
provisions of the
Arbitration and Conciliation
Act., 1996.

9. Relief or remedy sought Recovery of Rs.2,009,632

with interest @ 18% per
annum.

PRAYER

It is, therefore, most respectfully prayed that this Hon’ble Court be

graciously pleased to :

[a] allow the present Petition after issuing notice to the

Respondent Company;

[b] appoint a sole arbitrator under Clauses of Work Order

\Agreement No.135000695 according to which any dispute

between the parties with regard to Work Order\Agreement

shall be settled by the Arbitration.

[c] to direct Respondent to supply the certified copy of the Work

Order/Agreement and pay all the cost and damages incurred

by Applicant because of Respondents irresponsible attitude.

[d] Pass any other or such further order/s as may be deemed fit

and proper in the facts and circumstances of the present

case.

AND FOR WHICH ACT OF KINDNESS YOUR HUMBLE APPLICANT

WOULD IN GRATITUDE EVER PRAY

Drawn By: APPLICANT

[Namrata Chopra] THROUGH

Advocate
Namrata Chopra/Uday Kumar
INDIAN LAW ASSOCIATES
ADVOCATES FOR THE APPLICANT
16, TODARMAL ROAD,
NEAR BENGALI MARKET
NEW DELHI – 110001
September , 2004

VERIFICATION:

I, Manju Dhingra, the abovenamed Applicant, verify that the

contents of para 1 to of the Petition are true and correct to the

best of my knowledge and belief and contents of para to are legal

averments based on the information received and are believed to

be true.

Verified at Moga, Punjab on this th day of September, 2004.

APPLICANT
 BEFORE THE SENIOR CIVIL JUDGE ,TIS HAZARI

COURT,DELHI

ORIGINAL JURISDICTION

ARB. P. NO. OF 2005

MEMO OF PARTIES

IN THE MATTER OF:

M/s Sahil Brothers

Through Proprietor,
Manju Dhingra,
1496, Street No.7,
Ramganj Mandi,
Moga. ... Applicant

Versus

M/s Reliance Engineering,

Associates Pvt. Ltd.
SCF 61-62, Phase II,
Mohali-160 055,
(Punjab). … Defendant

FILED BY:

Namrata Chopra/Uday Kumar

INDIAN LAW ASSOCIATES
ADVOCATES FOR THE APPLICANT
16, TODARMAL ROAD,
NEAR BENGALI MARKET
NEW DELHI - 110001

April , 2005
 BEFORE THE SENIOR CIVIL JUDGE ,TIS HAZARI COURT,
DELHI

ORIGINAL JURISDICTION

ARB. P. NO. OF 2005

IN THE MATTER OF:

M/s Sahil Brothers

Through Proprietor,
Manju Dhingra,
1496, Street No.7,
Ramganj Mandi,
Moga. ... Applicant

Versus

M/s Reliance Engineering,

Associates Pvt. Ltd.
SCF 61-62, Phase II,
Mohali-160 055,
(Punjab). … Respondent

1. Provisions under which Section 11 (6) of the

Applicant is filed Arbitration and Conciliation
Act, 1996

2. Name of the Applicant with M/s Sahil Brothers

address Through Proprietor, Manju
Dhingra,1496, Street No.7,
Ramganj Mandi, Moga.

3. Name of the other party to M/s Reliance Engineering,

Arbitration Agreement with Associates Pvt. Ltd. SCF
complete address 61-62, Phase II, Mohali-160
055, (Punjab).

4. Names and addresses of the

Arbitrator, if any, already Not Applicable
appointed by parties

5. Names and addresses of the To be appointed by the

person or institution, if any, to Hon’ble Delhi High Court
whom any function has been
entrusted or the parties of the
Arbitration Agreement under
the appointment procedure
agreed upon by them
6. Qualification required, if any
of the Arbitrator by the Not Applicable
agreement of the parties

7. STATEMENT OF FACTS:

1. That the Applicant, herein M/s Sahil Brothers have

their registered office at 1496, Street No.7, Ramganj Mandi,

Moga and are engaged in construction work.

2. That the Respondent herein M/s Reliance Engineering

Associates Pvt. Ltd., have their registered office at SCF 61-62,

Phase II, Mohali-160 055, (Punjab) are also engaged in

construction work.

3. That the Applicant, herein was granted by Respondents

Work Order/Agreement No.RXPN/W/39, on 14.5.2001 on

basis of certain terms and conditions for trenching and duct

laying at Amritsar to Zira route . The Work Order/Agreement

along with terms and conditions is annexed herewith as

Annexure-A.

4. That the Applicant, after undertaking the work under

the said Work Order/Agreement submitted their first and

final bill dated 15.11.2001 of Rs. 16,78,878 for the work

undertaken. The said bill dated 15.11.2001 was measured as

recorded and the joint measurement record in this regard was

signed by engineer in Chief of Respondent organization. The

true copy of the bill dated 15.11.2001 is annexed herewith as

Annexure-B.

5. That however while making the payment on the basis of

the bill submitted by the Applicant ,a deduction of

Rs.2,52,100/- in that bill was made by Respondents, against

Item No. 18 without any legal justification.

6. That because of unjust deductions made by

respondents on 29.7.2003 a legal notice was sent on behalf of

Applicant to Respondent calling upon them to make the

payments regarding the illegally deducted amount against

item 18. The true copy of the legal notice dated 29.7.2003 is

annexed herewith as Annexure-C.

7. The notice further specified that as per the clause 18 of

Annexure ‘C’ , the general condition of contract envisage

reference of any dispute or difference arisen between the

owner or contractor in relation to the said contract being

referred to the Arbitration of two Arbitrators and the

Applicant shall be constrained to take legal steps as may be

available to Applicant including the arbitration if the

Respondent fails to make the payment of a sum of

Rs.2,52,100 against item No.18 of the first and final bill to

any client without any delay alongwith interest @ 12% per

annum within 30 days of the receipt of the legal notice.

8. The said notice, was replied by Respondents on

27.8.2003 ,wherein they submitted that the rates of item

No.1 are inclusive of work done for item No.18 also and no

separate charges were payable for the work done under item

No.18 as per clause 3.2 of Section IV of Annexure “C” which

incorporates general condition of the contract. The true copy

of the reply of legal notice dated 27.08.2003 is annexed

herewith as Annexure-D.

The clause 3.2 of Section IV of Annexure “C” is reproduced as

under

“During Monsoon and other period, it shall be

responsibility of contractor to keep construction
work site free from water at its own cost”

9. Furthermore it was also stated in the reply that since

the deductions of amount of Rs.2,52,100/- has been made

by Respondent in terms of the clause 3.2 of Section IV of

Annexure “C” therefore, no dispute arises between

Respondent and Applicant and therefore they are not

required to be referred to the Arbitrators for its arbitration.

10. Again on 1.7.2004, another legal notice was sent by

Applicant to the Respondent stating therein that as the

Applicant have already served a legal notice through Sh.

Puneet Kansal, Advocate on 29.7.2003 which was duly

acknowledged by Respondent company and Reply was filed,

the Applicant is compelled to invoke the arbitration clause of

the agreement/work order No. RXPN/W/39. The true copy of

the Legal Notice dated 1.7.2004 is annexed herewith as

Annexure-E.

11. It is now relevant to quote here the Clause 18 of

Section III of the contract of work agreement:-

“Arbitration
If any disputes or differences arise between the Owner
and the Contractor in relation to or out of this Contract,
the same shall be referred to the arbitration of two
arbitrators, one each to be appointed by the Owner and
the Contractor. The provisions of the Indian Arbitration
Act, 1940 shall apply for such arbitration. The decision
so given shall be final and binding upon the parties
hereto”.

12. It was further stated in notice that as in reply to Legal Notice

dated 29.7.2003 Respondent admitted that they have deducted Rs.

2,52,100/- against Item. No. 18, but it was alleged that the same is

liable to be deducted as per clause 3.2 of Section of IV of the

agreement. As per which the Respondents mentioned that during

Monsoon and other period it shall be the responsibility of the

contractor to keep the construction work site free from water at its

own costs.

13. The Applicant in their second Legal notice dated 1.7.04

clarified that the clause 3.2 of Section IV of Agreement is not

applicable in present case as all the work was completed

before Monsoon. Moreover the amount cannot be deducted

as our client did the Job work after digging out the earth

where the water already stand i.e. 3 ponds and other water
areas. Whereas the Applicant is entitled to get the amount for

digging the earth under the standing water.

14. It was further stated by the Applicant in their legal

notice that as now the dispute has arisen as per the terms

and conditions of the Work Order/Agreement therefore the

dispute of this effect can be adjudicated through arbitration

as per clauses of Work Order/Agreement entered between

the parties.

15. That as per the terms and conditions of the Work

Order/Agreement there is a clause of arbitration i.e. “if any

dispute or difference arise between the owner and the

contractor in relation to or out of this contract, the same shall

be referred to the arbitration of two arbitrator, one each to be

appointed by the owner and the contractor and the provisions

of the arbitration Act shall apply for such arbitration. The

decision of the Arbitrator shall be final and binding upon the

parties.” So in light of this arbitration clause, now there is a

dispute regarding the amount deducted by the company and

this dispute is to be adjudicated through arbitration.

Therefore as the present dispute is regarding the amount

deducted by the Respondent Company with regard to bills

raised by Applicant under work order/agreement and this

dispute is to be adjudicated through arbitration. So the

Respondent must suggest the name of the arbitrator so that

Applicant also can suggest the name of their arbitrator and

also refer all the documents to the arbitrator for the

adjudication.

16. The Legal notice dated 1.7.2004 clearly stated that

Respondent should mention the name of the arbitrator and

to refer the matter to arbitrator as per the clause of the

agreement and also supply the certified copy of the agreement

within one month from the date of receipt of this notice,

failing which Applicant shall be constrained and compelled to

knock the door of Court of law for the appointment of the

arbitrator under the provisions of Arbitration and conciliation

Act 1996 and in that event, the Respondent Company will be

held responsible for all types of costs and damages incurred

by Applicant.

17. That till today even after the lapse of considerable time

also the respondent failed to take any step towards

forwarding the name of arbitrator and issuing the certified

copy of Work Agreement/Order.

18. That because of this irresponsible/illegal attitude of the

Respondent, Applicant herein is constrained to file the present

petition before this Hon’ble Court.

19. That the Applicant is always ready and willing to refer

the present dispute to the Arbitration as per the terms of the

Agreement. The Applicant is seeking the assistance of this

Hon’ble Court for appointment of an arbitrator primarily due

to the non-cooperative and unreasonable attitude and

conduct of the Respondent Company.

20. The Applicant submits that in the light of the facts and

circumstances of the present case, the following disputes

arise for being referred to arbitration proceedings:

(a) that the Applicant and Respondent entered into a Work

Order/Agreement dated 14.5.2001 on certain terms and
conditions.

(b) that after completion of work when Applicant submitted

their final bill Respondent deducted Rs2,52,100/-
without any justification

(c) that Respondent subsequently failed to comply with

clause 18 of Work Order/Agreement i.e. appointment of
arbitrator even after two legal notices sent on behalf of
Applicant.

21. That the Respondent had not acted in consonance

with terms and conditions specified in Clause 18 of Work
Order\Agreement dated 14th May, 2001.

22. That the Applicant has no other efficacious alternate

remedy except to approach this Hon’ble Court by way of the
present Petition to redress their grievances.

23. That the Applicant has not filed any other or similar
Petition earlier before this Hon’ble Court or any other court
praying the same relief as in the present Petition.
24. The Applicant also submits that this Hon’ble Court has
all the necessary territorial jurisdiction to entertain the
present Petition. It is irrelevant to state that the parties had
mutually decided to subject all differences and/or disputes
arising between them to the court in New Delhi [Clause 19 of
the Work Order/Agreement].

8. Valuation of the subject Rs.2,52,100/- with interest

matter @ 18% Per Annum
[Rupees two lacs and fifty
two thousand and one
hundred only] as on 15th
November, 2001 Plus
interest @ Eighteen Percent
Per Annum

Court fees paid as per the

rules of Hon’ble Delhi High
Court in accordance with
provisions of the
Arbitration and Conciliation
Act., 1996.

9. Relief or remedy sought Recovery of Rs.2,52,100/-

with interest @ 18% Per
Annum

PRAYER

It is, therefore, most respectfully prayed that this Hon’ble Court be

graciously pleased to :

[a] allow the present Petition after issuing notice to the

Respondent Company;

[b] appoint a sole arbitrator under Clause 18 of Annexure ‘C’ of

terms and conditions on which the Work
Order/Agreement No.RXPN/W/39 dated 14th May, 2001 is
based, which states that any dispute between the parties
with regard to Work Order shall be settled by the Arbitration;
[c] to direct Respondent to supply the certified copy of the Work

Order\ Agreement and pay all the cost and damages

incurred by Applicant because of Respondents irresponsible

attitude.

[d] Pass any other or such further order/s as may be deemed fit

and proper in the facts and circumstances of the present

case.

AND FOR WHICH ACT OF KINDNESS YOUR HUMBLE APPLICANT

WOULD IN GRATITUDE EVER PRAY

Drawn By: APPLICANT

[Namrata Chopra] THROUGH

Advocate
Namrata Chopra/Uday Kumar
INDIAN LAW ASSOCIATES
ADVOCATES FOR THE APPLICANT
16, TODARMAL ROAD,
NEAR BENGALI MARKET
NEW DELHI – 110001
September , 2004

VERIFICATION:

I, Manju Dhingra, the abovenamed Applicant, verify that the

contents of para 1 to of the Petition are true and correct to the

best of my knowledge and belief and contents of para to are legal

averments based on the information received and are believed to

be true.

Verified at Moga, Punjab on this th day of September, 2004.

APPLICANT
 BEFORE THE SENIOR CIVIL JUDGE ,TIS HAZARI
COURT,DELHI
ORIGINAL JURISDICTION
ARB. P. NO. OF 2005

IN THE MATTER OF:

M/s Sahil Brothers ... Applicant

Versus
M/s Reliance Engineering,
Associates Pvt. Ltd. … Defendant
INDEX

S. PARTICULARS PAGE NO.

NO.
1 Memo of Parties A

2. Arbitration Petition No. of 2005 1 – 10

3. ANNEXURE-A
The Work Order/Agreement along with 11 – 47
terms and conditions dated 14.5.2001.

4. ANNEXURE-B 48 – 59
The true copy of the bill dated 15.11.2001.

5. ANNEXURE-C
The true copy of the legal notice dated 60 – 61
29.7.2003.

6. ANNEXURE-D 62 – 64
The true copy of the reply dated 27.8.2003.

7. ANNEXURE-E 65 – 67
The true copy of the Legal Notice dated
1.7.2004.

8. Vakalatnama B

FILED BY:

Namrata Chopra/Uday Kumar

INDIAN LAW ASSOCIATES
ADVOCATES FOR THE APPLICANT
16, TODARMAL ROAD,
NEAR BENGALI MARKET
NEW DELHI - 110001
April 29th, 2005
 BEFORE THE DISTRICT JUDGE ,TIS HAZARI COURT,DELHI

ORIGINAL JURISDICTION

ARB. P. NO. OF 2005

MEMO OF PARTIES

IN THE MATTER OF:

M/s Sahil Brothers

Through Proprietor,
Manju Dhingra,
1496, Street No.7,
Ramganj Mandi,
Moga. ... Applicant

Versus

M/s Reliance Engineering,

Associates Pvt. Ltd.
SCF 61-62, Phase II,
Mohali-160 055,
(Punjab). … Defendant

FILED BY:

Namrata Chopra/Uday Kumar

INDIAN LAW ASSOCIATES
ADVOCATES FOR THE APPLICANT
16, TODARMAL ROAD,
NEAR BENGALI MARKET
NEW DELHI - 110001

April , 2005
 BEFORE THE SENIOR CIVIL JUDGE ,TIS HAZARI
COURT,DELHI
ORIGINAL JURISDICTION
ARB. P. NO. OF 2005

IN THE MATTER OF:

M/s Sahil Brothers ... Applicant

Versus

M/s Reliance Engineering,

Associates Pvt. Ltd. … Defendant
INDEX

S. PARTICULARS PAGE NO.

NO.
1 Memo of Parties A

2 Arbitration Petition No. of 2005 1 – 11

3 ANNEXURE-A
The true copy of the legal notice dated 12 – 14
8.8.2003

4 ANNEXURE-B
The true copy of the reply dated 27.8.2003 15 – 17
to the legal notice dated 8.8.2003.

5 ANNEXURE-C
The true copy of the Legal Notice dated 18 – 20
1.7.2004

6 ANNEXURE-D
True Copy of the reply dated 16.9.2004. 21 – 23

7 Vakalatnama B

FILED BY:

Namrata Chopra/Uday Kumar

INDIAN LAW ASSOCIATES
ADVOCATES FOR THE APPLICANT
16, TODARMAL ROAD,
NEAR BENGALI MARKET
NEW DELHI - 110001
April 29th, 2005