0% found this document useful (0 votes)
229 views24 pages

Section 33 Arb Act, 1996

Nagarjuna Agro Chemicals Private Limited has filed a claim against the National Federation of Farmers’ Procurement Processing and Retailing Cooperatives of India Limited and others for unpaid dues amounting to ₹5,82,25,163 related to various purchase orders. The respondents argue that they acted merely as facilitators and that the ultimate liability for payment lies with the government departments that issued the purchase orders. The document outlines the legal proceedings and various correspondences related to this arbitration case.

Uploaded by

Shrey Kumar
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
0% found this document useful (0 votes)
229 views24 pages

Section 33 Arb Act, 1996

Nagarjuna Agro Chemicals Private Limited has filed a claim against the National Federation of Farmers’ Procurement Processing and Retailing Cooperatives of India Limited and others for unpaid dues amounting to ₹5,82,25,163 related to various purchase orders. The respondents argue that they acted merely as facilitators and that the ultimate liability for payment lies with the government departments that issued the purchase orders. The document outlines the legal proceedings and various correspondences related to this arbitration case.

Uploaded by

Shrey Kumar
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

BEFORE THE MICRO AND SMALL ENTERPRISES

FACILITATION COUNCIL, RANGA REDDY REGION.


APPLICATION NO. _______/2025
IN
CASE NO. 506/MSEFC/2023

IN THE MATTER OF:

NAGARJUNA AGRO CHEMICALS PRIVATE LIMITED


… CLAIMANT

VERSUS

NATIONAL FEDERATION OF FARMERS’ PROCUREMENT


PROCESSING AND RETAILING COOPERATIVES OF
INDIA LIMITED AND ORS. … RESPONDENT

INDEX

S. No. Particulars Page Nos.


01. Memo of Parties
Application on behalf of the Respondent
No. 01 and 02 under Section 33(1) of the
02.
Arbitration and Conciliation Act 1996,
along with supporting Affidavit.
03. Copy of Arbitral Award dated 17.02.2024.
Copy of Application Form dated
12.02.2016 submitted by Nagarjuna
Agrochemicals Private Limited and
04. Affidavit sworn by Shri Mukund
Maheshwari, Managing Director of
Nagarjuna Agro Chemicals Private
Limited, Hyderabad.
UDYAM Registration Certificate No.
UDYAM – TS – 02 – 0038972 dated
05.
28.09.2021 of Nagarjuna Agro Chemicals
Private Limited.
Letter No. 1135 dated 27.12.2023, by the
Secretary, Department of Agriculture,
06.
Animal Husbandry and Cooperative under
the Government of Jharkhand to the Joint
Secretary, Ministry of Agriculture and
Farmers Welfare, Government of India;
seeking reallotment of funds, to clear the
dues of Nagarjuna Agro Chemicals Private
Limited.
Letter No. 5355 dated 25.10.2023 from the
Directorate of Agriculture, Jharkhand to
07.
the Chairman, MSEFC, Ranga Reddy
Region.
Application on behalf of the Respondent
No. 01 and 02 under Section 05 of the
08.
Limitation Act, 1963 for Condonation of
Delay, along with supporting Affidavit.
Correspondence by NACOF Ltd. to
Government Department to clear the dues
09. and credit payment of Nagarjuna Agro
Chemicals Private Limited; in terms of the
Arbitral Award dated 17.02.2024.
Letter No.
NACOF/NAG/Accounting/2024-25/097
dated 19.02.2025 issued by NACOF Ltd.
10. to Nagarjuna Agro Chemicals Private
Limited along with Demand Draft No.
084953 dated 18.02.2025 for
₹5,47,09,650/-.
11. Vakalatnama along with Board Resolution.

RESPONDENT NOS. 01 AND 02

THROUGH
COUNSEL
(MANAV KUMAR | SHREY KUMAR)
Flat No. 101, Lahari Homes, Street No. 01,
Tarnaka, Secunderabad, Telengana – 500 017
+91 98184 93330 | kumarshrey12@[Link]
+91 99710 73298 | manavkumar102@[Link]
Place: Telangana.
Date: 25.04.2025
BEFORE THE MICRO AND SMALL ENTERPRISES
FACILITATION COUNCIL, RANGA REDDY REGION.
APPLICATION NO. _______/2025
IN
CASE NO. 506/MSEFC/2023

IN THE MATTER OF:

NAGARJUNA AGRO CHEMICALS PRIVATE LIMITED


… CLAIMANT

VERSUS

NATIONAL FEDERATION OF FARMERS’ PROCUREMENT


PROCESSING AND RETAILING COOPERATIVES OF
INDIA LIMITED AND ORS. … RESPONDENT

MEMO OF PARTIES

Nagarjuna Agro Chemicals Private


Limited
… Claimant
versus

Chairperson, National Federation


of Farmers’ Procurement
Processing and Retailing
Cooperatives of India Limited
(NACOF Ltd.) … Respondent No. 01

Branch Mangar, National


Federation of Farmers’
Procurement Processing and
Retailing Cooperatives of India
Limited (NACOF Ltd.)

Both through; 101 – 116, 01st Floor,


Devika Tower, Nehru Place, New
Delhi – 110 019 … Respondent No. 02

Principal Secretary, Department of


Agriculture, Animal Husbandry
Government of Jharkhand, Ranchi
Nepal House, Doranda, Ranchi,
Jharkhand – 834 002. … Respondent No. 03

Director, Department of
Agriculture, Animal Husbandry
Krishi Bhawan, 03rd Floor, Kanke
Road, Ranchi – 834 008 … Respondent No. 04

RESPONDENT NOS. 01 AND 02

THROUGH

COUNSEL
(MANAV KUMAR | SHREY KUMAR)
Flat No. 101, Lahari Homes, Street No. 01,
Tarnaka, Secunderabad, Telengana – 500 017
+91 98184 93330 | kumarshrey12@[Link]
+91 99710 73298 | manavkumar102@[Link]
Place: Telangana.
Date: 25.04.2025
BEFORE THE MICRO AND SMALL ENTERPRISES
FACILITATION COUNCIL, RANGA REDDY REGION.
APPLICATION NO. _______/2025
IN
CASE NO. 506/MSEFC/2023

IN THE MATTER OF:

NAGARJUNA AGRO CHEMICALS PRIVATE LIMITED


… CLAIMANT

VERSUS

NATIONAL FEDERATION OF FARMERS’ PROCUREMENT


PROCESSING AND RETAILING COOPERATIVES OF
INDIA LIMITED AND ORS. … RESPONDENT

APPLICATION ON BEHALF OF THE RESPONDENT NO.


01 AND 02 UNDER SECTION 33(1) OF THE
ARBITRATION AND CONCILIATION ACT 1996.

MOST RESPECTFULLY SHOWETH

1. That the Claimant, Nagarjuna Agro Chemicals Private


Limited, had filed a Claim before this Ld. Council under
Application No. UDYAM – TS – 02 – 0038972/S/00002,
for payment of principal amount of ₹5,82,25,163/-, against
Purchase Order No. NACOF/BUS/REG/6/2016 dated
29.02.2016 issued by the Respondent Nos. 01 and 02, for
and on behalf of Respondent Nos. 03 and 04; as the
‘Buyer’ under Section 2(d) of the Micro, Small and
Medium Enterprises Development Act, 2006 (hereinafter
referred to as Act, 2006).

2. It is submitted that the Respondent Nos. 01 and 02;


collectively for convenience; referred to as NACOF Ltd. or
National Federation of Farmers’ Procurement Processing
and Retailing Cooperatives of India Limited is an apex
organization established under the Multi-State Cooperative
Societies Act, 2002 by the Joint Secretary and Central
Registrar, Cooperative Societies in the Ministry of
Agriculture, Government of India. The objective of
NACOF Ltd. inter alia is to organize and develop, the
cooperative societies engaged in Procurement, Processing,
Retailing, Construction, Mining and akin related activities,
by way of mutual cooperation with other industry players.
NACOF Ltd., on account of its massive infrastructure and
PAN India network, often acts as a facilitator for work
between various private parties and government
department/ entities.

3. It is furthermore submitted that the Claimant herein


applied to be registered as an authorized Supplier of
NACOF Ltd. vide its Application Form and Affidavit
dated 12.02.2016, for the supply of; Soil Testing
Laboratories with the description; ‘Mridaparikshak –
MiniLab: A Soil Testing Kit – 4 Models’ and Light Traps
with the description; ‘NCIPM Light Traps – 9 Models’,
(hereinafter jointly referred to as ‘goods’) all across India
to various Government Departments/ PSUs/ Cooperative
Organizations etc. The registration of the Claimant was
confirmed by NACOF Ltd. vide Letter No.
NACOF/BUS/REG/6/2016 dated 29.02.2016.

4. That thereafter 25 nos. Purchase Orders were raised by the


officers of Respondent Nos. 03 and 04, specifically; by the
Department of Agriculture, Animal Husbandry and
Cooperative under the Government of Jharkhand, for the
supply of Upgraded Model of Mridaparikshak (Mini Lab).
The details of these Purchase Orders are tabulated below:
District
S. Letter
Agriculture Date Quantity
No. No.
Officer
01. Pakur 366 15.04.2017 30
02. Ranchi 486 06.04.2017 90
03. Deoghar 208 31.03.2017 50
04. Godda 173 31.03.2017 25
East Singhbhum
05. 148 31.03.2017 55
Jamshedpur
Camp
06. Jamtara Ranchi | 03.04.2017 30
01
07. Dumka 423 31.03.2017 50
08. Dhanbad 265 03.04.2017 40
Camp
Office
09. Bokaro 03.04.2017 45
Ranchi |
01
10. Giridih 350 31.03.2017 65
Camp
11. Koderma Ranchi | 03.04.2017 30
01
Seraikela
12. 177 03.04.2017 45
Kharsawan
13. Ramgarh 919 03.04.2017 30
14. Hazaribagh 918 03.04.2017 80
15. Latehar 220 31.03.2017 45
16. Lohardaga 188 31.03.2017 35
17. Gumla 269 (B) 31.03.2017 60
18. Khunti 342 31.03.2017 30
19. Garhwa Camp (1) 03.04.2017 100
20. Palamau Camp (3) 31.03.2017 105
21. Chatra 325 31.03.2017 60
22. West Singhbhum 474 31.03.2017 90
23. Simdega 330 (2) 31.03.2017 19
24. Simdega 330 31.03.2017 31
25. Sahibganj 257 08.04.2017 45

5. By virtue of the Application Form and Registration Letter,


the Claimant was directed to supply the aforementioned
quantity goods to the government departments. It goes
without saying that the individual Orders had been placed
by 24 District Agriculture Officers in Jharkhand and the
only reason of having 25 Purchase Orders is that, the
District Agriculture Officer, Simdega placed a
Supplementary Order (No. 330 (2)) with the main
Purchase Order (No. 330).

6. That on completion of delivery, Payment Invoices were


raised by the Claimant, to the tune of ₹11,18,00,000/-, to
NACOF Ltd; since the Purchase Order was issued to the
Claimant by NACOF Ltd. only. At this juncture, it is
pertinent to note herein; as also has been admitted by the
parties; that NACOF Ltd. was merely a facilitator of work
and the Purchase Orders was in actuality effected by the
Respondent Nos. 03 and 04; as ‘Buyer’ under Section 2(d)
of the Act, 2006. Thus, any and all relief of a ‘Supplier’,
under Section 2(n) thereof, of the Claimant would lie with
the Respondent Nos. 03 and 04 only and not against the
Respondent Nos. 01 and 02. That at Page No. 08 of the
Award, the submissions of the Claimant being;
“Respondents no 1 and 2 are the Nodal agency for the
supply of material to respondents no 3&4 govt of
Jharkhand for 24 districts which is the End receiver of
supplied material” further made it evident that ultimate
liability for payment laid upon the Respondent Nos. 03 and
04.

7. Be that as it may, it is once again reiterated that although


no direct liability arose against the Respondent Nos. 01
and 02, in terms of Section 18 or Chapter V of the Act,
2006, NACOF Ltd. by virtue of “Clause No. (E): Terms
of Payment on”, of the Application Form, was instead
duty bound to immediately transfer payment, as and
when it received/ realised the same, from the
Government Department, without any delay; under the
back – to – back payment basis. It can thus fairly be
concluded that the liability of NACOF Ltd. would only
arise, after the payment (of the Claimant) is received by it,
for further disbursement.

8. Without prejudice, it is further submitted that NACOF Ltd.


is in no way trying to evade any liability of payment and is
simply only requiring a clarification and interpretation of
the directions of this Ld. Council; to effectuate and fulfil
the Award dated 17.02.2024.

9. Coming back to the facts of the matter, it is submitted that


out of the total due amount of ₹11,18,00,000/-, the
Respondent Nos. 03 and 04, only disbursed ₹5,35,74,837/-
to the Claimant, leaving a balance due of ₹5,82,25,163/-.
The subject claim (Application No. UDYAM – TS – 02 –
0038972/S/00002), was filed; post which the parties
proceeded for arbitration.

10. The first correction, clarification and/or interpretation of


the Respondent Nos. 01 and 02 is with regard to the Rule
of Kompetenz – Kompetenz; on the applicability of the
subject Arbitral Proceedings Case No. 506/MSEFC/2023.
It is submitted that admittedly the subject transactions
and/or the cause of actions arose in 2016 – 17; when the
Claimant got registered as an authorised Supplier with
NACOF Ltd. and when the Purchase Orders were issued.
However, at that time, the Claimant was not an (Small)
Enterprise registered under Section 8 of the Act, 2006 and
only got registered with MSME on 28.09.2021, having
Udyam Registration No. UDYAM – TS – 02 – 0038972;
and thus, could not have availed the relief under Section 18
or Chapter V thereof. Reliance is placed on the judgments
of Silpi Industries v. Kerala State Road Transport
Corporation 2021 INSC 314 and Gujarat State Civil
Supplies Corporation Limited v. Mahakali Foods
Private Limited 2022 SCC Online SC 1492, both passed
by the Hon’ble Supreme Court of India.
11. The second correction, clarification and/or interpretation of
the Respondent Nos. 01 and 02 arise with regard to the
extent of liability of the Respondents to make payment. It
is submitted that the Respondent Nos. 03 and 04, in the
Arbitral Proceedings; as also has been recorded in the
Award dated 17.02.2024; conceited their complete
responsibility for payment, being the ‘Buyer’ under
Section 2(d) of the Act, 2006. The Respondent Nos. 03 and
04 furthermore; all the while admitting their liability of
delay and payment; averred that funds were stuck and/or
diverted on account of COVID – 19 Pandemic and some
technical issues with the state treasury. It was further
submitted by them; as recorded in Page No. 09 of the
Award that; “the state is in the process of receiving of
revalidated central share from GOI. The state shall
process the pending liability of NACOF as soon as the
budget is received by state from GOI.” The said
submission was not objected by either of the parties
(Claimant and Respondent Nos. 01 and, 02), which
confirmed the acceptance of chain of liability of Nagarjuna
Agro from NACOF Ltd. to the Department of Agriculture,
Animal Husbandry and Cooperative under the Government
of Jharkhand. A Letter No. 5355 dated 25.10.2023 from
the Directorate of Agriculture, Jharkhand was also issued
to the Chairman, MSEFC, Ranga Reddy Region, with
similar submissions.

12. The Respondent Nos. 01 and 02, by way of the present


Application under Section 33(1)(b) of the Arbitration and
Conciliation Act 1996, are thus merely seeking a
correction and/or interpretation of the Arbitral Award
dated 17.02.2024, with regard to the findings of this Ld.
Council on ‘Issue No. 03: Is the respondents have joint
and several liability to pay to the claimant?’; in view of
the various submissions of the parties. It is once again
reiterated that NACOF Ltd. is in no way trying to evade its
liability of payment; however, is only seeking a
clarification on the interpretation of this Ld. Council’s
observation at Page No. 12 of the Award as; “Issue No. 3.
It is evident by the material on the record submitted by
both the respondents that NACOF would be able to pay the
claimant only after the realization of the said amount from
the Department of Agriculture govt of Jharkhand”. That
from the said observation, a prudent inference can be
drawn that although the Respondents have a joint and
several liability for payment; the specific liability of
NACOF Ltd. can only arise, after payment has been
received by it from the Department of Agriculture, Animal
Husbandry and Cooperative under the Government of
Jharkhand.

13. This said interpretation is relevant, at this stage, to enable


the parties (The Claimant and NACOF Ltd.), to eventually
join hands for the execution of the Arbitral Award dated
17.02.2024. It is once again averred that the Respondent
Nos. 01 and 02, do not seek an alternative prayer; as in
their Statement of Defence or otherwise and is only
seeking a clarification on the interpretation of the Arbitral
Award dated 17.02.2024.
14. The subject Application has now been preferred as the
Respondent Nos. 03 and 04 have till date only paid the
balance principal amount of ₹5,47,09,650/- to the
Respondent Nos. 01 and 02; to eventually transfer the
same to the Claimant vide Demand Draft No. 084953
dated 18.02.2025, with further intimation vide Letter
No. NACOF/NAG/Accounting/2024-25/097 dated
19.02.2025.

15. That the Respondent Nos. 01 and 02 reserve their right to


adopt, add, alter, or amend any of the averments at a
subsequent stage, if needed.

16. The Respondent Nos. 01 and 02 have not filed any other
similar Application either in this Ld. Council or before any
other Ld. Judicial/ Quasi Judicial Authority.

17. That the Annexures in the present Application are true


copies of their respective originals.

18. That the present Application is filed bonafide and in the


interest of justice.

19. That in view of the Judgment titled; North Delhi Municipal


Corporation v. M/s. S.A. Builders Limited 2024 INSC 988,
passed by the Hon’ble Supreme Court of India; it is
submitted that this Ld. Council, in regard to clarifications
under Section 33 of the Arbitration and Conciliation Act
1996, has not become functus officio and thus, has the
jurisdiction to entertain and adjudicate the present
Application.

PRAYER
20. In the above circumstances, it is, therefore, most
respectfully prayed that the Ld. Council in the interest of
justice, fair play and equity be pleased to:

a. Correct, Clarify and/or Interpret on the Applicability


of the claim and contract under the Arbitral Award
dated 17.02.2024; having transacted prior to the
registration of the Claimant as a Small Enterprise
under the Micro, Small and Medium Enterprises
Development Act, 2006; AND

b. Correct, Clarify and/or Interpret on the extent of


liability of the Respondent Nos. 01 and 02, to make
payment to the Claimant; only after release and
reimbursement of funds, to them, by the Respondent
Nos. 03 and 04; being the actual ‘Buyer’ under
Section 2(d) of the Micro, Small and Medium
Enterprises Development Act, 2006 and in view of
the “Clause No. (E): Terms of Payment on”, of the
Application Form dated 12.02.2016, which stipulated
transfer of payment, as and when it is received from
the Government Department; under “back – to – back
payment basis”.
c. Make the aforesaid correction and pass an additional
award under Section 33(4) of the Arbitration and
Conciliation Act 1996.

d. Pass any other order that the Ld. Council may deem
fit and proper in the facts and circumstances of the
present case.

RESPONDENT NOS. 01 AND 02

THROUGH

COUNSEL
(MANAV KUMAR | SHREY KUMAR)
Flat No. 101, Lahari Homes, Street No. 01,
Tarnaka, Secunderabad, Telengana – 500 017
+91 98184 93330 | kumarshrey12@[Link]
+91 99710 73298 | manavkumar102@[Link]
Place: Telangana.
Date: 25.04.2025
BEFORE THE MICRO AND SMALL ENTERPRISES
FACILITATION COUNCIL, RANGA REDDY REGION.
APPLICATION NO. _______/2025
IN
CASE NO. 506/MSEFC/2023

IN THE MATTER OF:

NAGARJUNA AGRO CHEMICALS PRIVATE LIMITED


… CLAIMANT

VERSUS

NATIONAL FEDERATION OF FARMERS’ PROCUREMENT


PROCESSING AND RETAILING COOPERATIVES OF
INDIA LIMITED AND ORS. … RESPONDENT

AFFIDAVIT

I, Sh. Vipan Kumar Kohli s/o Late Sh. Ganga Bishan, working as
Executive Director (Bus.), with National Federation of Farmers’
Procurement Processing and Retailing Cooperatives of India
Limited, having its registered office at, 101 – 116, 01st Floor,
Devika Tower, Nehru Place, New Delhi – 110 019, do hereby
solemnly affirm and state as under:

1. That I am the Authorised Representative of the


Respondent Nos. 01 and 02 and am conversant with the
facts and circumstances of the present case and as such am
competent to swear this affidavit.

2. That the statements made in the accompanying Application


herein are true to my knowledge and based on information
received and believed to be true.
DEPONENT
VERIFICATION
Verified at Delhi on this _____ day of April 2025 that the
contents of the above affidavit are true and correct, no part
of it is false and nothing material has been concealed
therefrom.

DEPONENT
BEFORE THE MICRO AND SMALL ENTERPRISES
FACILITATION COUNCIL, RANGA REDDY REGION.
APPLICATION NO. _______/2025
IN
CASE NO. 506/MSEFC/2023

IN THE MATTER OF:

NAGARJUNA AGRO CHEMICALS PRIVATE LIMITED


… CLAIMANT

VERSUS

NATIONAL FEDERATION OF FARMERS’ PROCUREMENT


PROCESSING AND RETAILING COOPERATIVES OF
INDIA LIMITED AND ORS. … RESPONDENT

APPLICATION ON BEHALF OF THE RESPONDENT NO.


01 AND 02 UNDER SECTION 05 OF THE LIMITATION
ACT, 1963 FOR CONDONATION OF DELAY.

MOST RESPECTFULLY SHOWETH

1. An Application seeking Correction, Clarification and/or


Interpretation of the Arbitral Award dated 17.02.2024 has
been filed by the Respondent No. 01 and 02 under Section
33(1) of the Arbitration and Conciliation Act, 1996; which
is being relied hereupon, in support of this present
Application for Condonation of Delay; however, the
contents thereof are not being repeated for the sake of
brevity.

2. It is submitted that the Arbitration Proceeding Case No.


506/MSEFC/2023, was filed by the Claimant against the
Respondents, for release of balance payment of
₹5,82,25,163/-, against supply of Upgraded Model of
Mridaparikshak (Mini Lab), to various (24) District
Agriculture Officers under the Department of Agriculture,
Animal Husbandry and Cooperative, Government of
Jharkhand. The Purchase Orders were placed by the
Department on NACOF Ltd., to grant the contract to the
Claimant; as its authorised Supplier. It is writ large that the
parties were aware of this chain of transaction; with the
Claimant being the ‘Supplier’ under Section 2(n) of the
Act, 2006, the Government Department being the ‘Buyer’
under Section 2(d) of the Act, 2006 and NACOF Ltd. as
simply the facilitator of the Contract. The abovesaid fact is
pertinent because, payments would be released by the
Govt. Department to NACOF Ltd., who would then
disburse the same, to the Claimant.

3. That however, despite several requests and/or reminders;


post passing of the Arbitral Award dated 17.02.204, the
Government Department has till date only transferred the
balance principal amount of ₹5,82,25,163/- and is yet to
credit the interest thereof; in terms of Section 16 of the
Act, 2006; to NACOF Ltd., to eventually transfer to the
Claimant.

4. Thus, the subject Application under Section 33(1) of the


Arbitration and Conciliation Act, 1996, has now become
warranted, to enable the Respondent Nos. 01 and 02 to
exert quasi judicial and administrative control over the
Respondent Nos. 03 and 04 and aid and, assist the
Claimant, towards release of payment, if granted under
law.
5. That there exists a limitation period of 30 days from the
date of Arbitral Award i.e., 17.02.2024, to file the subject
Application under Section 33(1) of the Arbitration and
Conciliation Act, 1996 or another period of time, as
agreed for between the parties. The present Application is
bonafide and in the interest of justice, fair play and equity,
of both the Claimant and, the Respondent Nos. 01 and 02
and thus ought to be allowed.

6. That despite the same and as a matter of abundant caution,


the present Application is being filed under Section 05 of
the Limitation Act, 1963 for condonation of delay of 408
days (from 18.03.2024 i.e., 30 days from Arbitral Award
till 30.04.2025) in filing the Application under Section
33(1) of the Arbitration and Conciliation Act, 1996.
PRAYER
7. In the above circumstances, it is, therefore, most
respectfully prayed that the Ld. Council in the interest of
justice, fair play and equity be pleased to:

a. Condone the delay of 408 days in filing of the


Application under Section 33(1) of the Arbitration
and Conciliation Act, 1996; from the Arbitral Award
dated 17.02.2024; AND;

b. Pass such further order or orders which this Hon’ble


Court may deem fit and proper.
RESPONDENT NOS. 01 AND 02

THROUGH

COUNSEL
(MANAV KUMAR | SHREY KUMAR)
Flat No. 101, Lahari Homes, Street No. 01,
Tarnaka, Secunderabad, Telengana – 500 017
+91 98184 93330 | kumarshrey12@[Link]
+91 99710 73298 | manavkumar102@[Link]
Place: Telangana.
Date: 25.04.2025
BEFORE THE MICRO AND SMALL ENTERPRISES
FACILITATION COUNCIL, RANGA REDDY REGION.
APPLICATION NO. _______/2025
IN
CASE NO. 506/MSEFC/2023

IN THE MATTER OF:

NAGARJUNA AGRO CHEMICALS PRIVATE LIMITED


… CLAIMANT

VERSUS

NATIONAL FEDERATION OF FARMERS’ PROCUREMENT


PROCESSING AND RETAILING COOPERATIVES OF
INDIA LIMITED AND ORS. … RESPONDENT

AFFIDAVIT

I, Sh. Vipan Kumar Kohli s/o Late Sh. Ganga Bishan, working as
Executive Director (Bus.), with National Federation of Farmers’
Procurement Processing and Retailing Cooperatives of India
Limited, having its registered office at, 101 – 116, 1st Floor,
Devika Tower, Nehru Place, New Delhi – 110 019, do hereby
solemnly affirm and state as under:

1. That I am the Authorised Representative of the


Respondent Nos. 01 and 02 and am conversant with the
facts and circumstances of the present case and as such am
competent to swear this affidavit.

2. That the statements made in the accompanying Application


herein are true to my knowledge and based on information
received and believed to be true.
DEPONENT
VERIFICATION
Verified at Delhi on this _____ day of April 2025 that the
contents of the above affidavit are true and correct, no part
of it is false and nothing material has been concealed
therefrom.

DEPONENT
BEFORE THE MICRO AND SMALL ENTERPRISES FACILITATION COUNCIL, RANGA REDDY REGION.
APPLICATION NO. _______/2025
IN
CASE NO. 506/MSEFC/2023
IN THE MATTER OF:

NAGARJUNA AGRO CHEMICALS PRIVATE LIMITED … CLAIMANT


VERSUS

NATIONAL FEDERATION OF FARMERS’ PROCUREMENT PROCESSING AND RETAILING COOPERATIVES OF INDIA LIMITED AND
ORS. … RESPONDENT
VAKALATNAMA

Know all to whom these Present shall come that I, Sh. Vipan Kumar Kohli s/o Late Sh. Ganga Bishan, working as Executive Director (Bus.), with
National Federation of Farmers’ Procurement Processing and Retailing Cooperatives of India Limited, having its registered office at, 101 – 116, 1st
Floor, Devika Tower, Nehru Place, New Delhi – 110 019, for the above named Respondent Nos. 01 and 02 do hereby appoint:

ADV. MANAV KUMAR | ADV. SHREY KUMAR


Office: Flat No. 101, Lahari Homes, Street No. 01, Tarnaka, Secunderabad, Telengana – 500 017
MOB: +91 98184 93330, +91 99710 73298 | E – Mail: kumarshrey12@[Link], manavkumar102@[Link]

(herein after called the advocate/s) to be my / our Advocate in the above – noted case authorize him:

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-objection or petitions for executions 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 subjects to
payment of fees for each stage.

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 of disputes that may arise
touching or in any manner relating to the said case.

To take execution proceedings on paying separate fee.

To deposit, draw and receive money, cheques, cash and grant receipts hereof 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 on 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 fit to do so and to sign the power of attorney on our
behalf.

And I/we undersigned to 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 purpose.

And I/we undertake that I/We or my/our duly authorized agent would appear in court on all hearings and
will inform the Advocate 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 for himself.

And I/we 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 settle 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 and if
the case prolongs for more than 3 years the original fee shall be paid again by me/us.

IN WITNESS WHERE OF I/We do hereunto set my/our hand to these presents the contents of which have been understood by me/us on
this 25th day of April, 2025. Accepted subject to the terms of the fees.

Advocate Client Client

I Identify the Signature/Thumb Impression of Below Mentioned Person,


Signed in My Presence. The Client.

You might also like