Statment of Claim (BSP V MMSF)

BEFORE THE
HON’BLE SOLE ARBITRATOR

Dr. S. N. SINGH

In the matter of:

STEEL AUTHORITY OF INDIA LIMITED
CLAIMANTS
VERSUS
MADURAI MULTI FACILITIES SERVICES PVT LTD
RESPONDENTS
STATEMENT OF CLAIM

Yashveer Singh Yadav
Advocate
MIG-1-533, HUDCO,
BHILAI, Dist.- Durg (Chhattisgarh)
M: +91 98271-88590
Email- yashveer.hnlu@gmail.com
COUNSEL FOR CLAIMANTS
STEEL AUTHORITY OF INDIA LIMITED
1
Filed on : 18.03.2023
TABLE OF CONTENTS
Sl. No. Description of Document Date Annexure Page No.
1 Statement of Defence and Verifi- 07.01.2022 1-22

cation

Bhilai
Dt. 01.03.2023 Counsel for Respondent
2
I. INTRODUCTION
2. This Statement of Claim is submitted on behalf of Steel Authority of
India Limited, Bhilai Steel Plant (Claimants) in accordance with the
Arbitration Agreement, which entered into force on dated November
4, 2022. See Exhibit 1 (attached hereto). The Respondent, Madurai
Multifacilities Services Pvt. Ltd. (MMSPL) has consented to resolve
its dispute with the Claimants via arbitration.
III. THE PARTIES TO THE ARBITRATION AND RELATED ENTI-

TIES
4. The Claimant in the above-referenced arbitration (the “Arbitration”)
is a unit of Steel Authority of India Limited (SAIL), a Government
Company within the meaning of the Companies Act 2013 and also
has the status of the the State under Article 12 of the Constitution.
The Claimant is Eleven times winner of Prime Minister's Trophy for
Best Integrated Steel Plant in the country and is a part of SAIL, In-
dia's largest producer & supplier of world class rails for Indian Rail-
ways and other Steel goods.
5. Claimant is an integrated steel plant meaning thereby that it con-
sists of manufacturing facilities so as to enable conversion of raw
material into finished steel by steel making process. Hirri Mines is a
captive dolomite mines of Respondent. Hirri Dolomite Mine, is lo-
cated 135 km North-East of Bhilai, in the Bilaspur District of Chhat-
tisgarh and operating since 1959. The mine was developed for an
initial capacity of 0.31 MTPA of ROM, and has been developed sub-
sequently to 2.0 MTPA to meet the increased requirement of Bhilai
Steel Plant.
3
6. That the dolomite supplied by the Hirri mines is one of the most
critical raw material in sinter making process and other important
activities. The main uses of dolomite in iron and steel industry are
(i) as a fluxing material (ii) for protection of refractory lining, and
(iii) as a refractory raw material. Dolomite in iron and steel industry
is normally used in three forms. These are (i) raw dolomite which is
also the natural form of dolomite, (ii) calcined dolomite, and (iii) sin-
tered dolomite. When dolomite is used as a fluxing material then it
is used as either raw dolomite or calcined dolomite. When dolomite
is used for the protection of refractories, it is used in calcined form
and when dolomite is being used as a refractory raw material, it is
used in the form of sintered dolomite.
7. In absence of the dolomite, not only the Claimant’s cost of produc-
tion increases but also it shall hamper the production and productiv-
ity. Hence in case of non-receipt of supplies from the Hirri Mines the
Dolomite is procured from other sources of supplies at a cost higher
than the cost of production from the captive hirri mines hence the
mining operation of Hirri Mines is critical for production purposes
and also for cost saving. Therefore in absence of supplies, the
Claimant incurs extra expenditure and cash outflow apart from other
amount being spent as administrative expenses in the process.
Hence the contract executed in relation to mining activities have
provision of Liquidated damages on non-fulfillment of monthly tar-
gets, which is based on the genuine estimate of loss suffered by the
Claimant.
8. The Respondent is a partnership firm registered under the relevant
provisions of the Partnership Act 1932. Respondent is engaged in
4
the business of contractor-ship with Government, PSUs and Non-
Government Establishments.
III. GENERAL NATURE OF THE CLAIM

4. The Claimants bring this action to remedy the Respondent’s contin-
uing wrongful conduct, which has continued unabated since failure
of installation of C & S setup by 22/12/2015 and notwithstanding re-
peated representations and promises by the Respondent that it
would meet its obligation.
5. Claimant’s claim are directed towards continuing acts and facts as
well as other acts and facts that took place since the issue of the
Letter of Acceptance dated 21/09/2015. The Respondent’s conduct
has been continuing intentional, wrongful, willful and reckless ac-
tions and omissions have caused catastrophic loses to the
Claimants.
IV. THE BASIS FOR THE ARBITRATION, PRE-ARBITRATION NE-

GOTIATION AND CONSULATATION, THE APPOINTMENT OF
THE TRIBUNAL, THE APPLICABLE LAW.
5. That both the Claimant and the Respondent have signed Arbitration
Agreement dated 04/11/2022 in furtherance of which this State-
ment of Claim is being submitted.
6. That before Proceeding with the Arbitration, there were two concili-
ation meeting were held in this regard respectively on 11.11.2019
and 16.01.2020.
5
V. RELEVANT FACTS & PRAYER
6. That the Claimant company floated tender through Tender No.
CCNW/PR/-130007613/Mines/OT-379/2070 (Annexure A-2) for
the work of “Breaking, Crushing, Transportation & Loading of
Dolomite at Hirri Mines by Mechanised Means”. The cope of work in-
cluded Breaking of oversized boulders, loading by excavators, un-
loading, crushing and screening to obtain final product, loading and
transportation of dolomites, loading into railway wagons.
7. The contractor had to procure and install a Crushing and screening
unit of a reputed brand and all other equipments were to be of par-
ticular SP/RMP grade. Contractor had to maintain a diesel generator
at the site in order to meet repair jobs during power failures. As per
the tender the contractor also had to install a new road weigh
bridge of reputed make. The contractor also had an obligation to
maintain equipments in good and safe working orders, safety mea-
sures were to be taken up and guidelines from DGMS, Ministry of
Environment and Forest, CSEB were to be followed strictly. Medical
safety and health hazards of the employees were to be kept main-
tained.
8. That the Respondent firm succeeded in bidding the lowest bid in the
tendering process for the contract of “Breaking, Crushing, Trans-
portation & Loading of Dolomite at Hirri Mines by Mechanised
Means.” vide LOA letter No. -CCNW/PR-1130007613/Mines/OT-
379/LOA/4430 dated 21/09/2015 (Annexure A-3).
9. That as per the Letter of Acceptance (Annexure A-3) the contract
period was for a total period of 36 months beginning from
23/09/2015, including a period of 3 months for the construction and
6
installation of C & S Plant and 33 months for the actual production
and dispatch of dolomite.
10.That as per the Purchase Order (Award Letter) CCNW/PO-
4270004313/PR-1130007613/4679 dated 15/10/2015 issued in
favour of the Respondent the award value of the Contract was Rs.
28,54,89,600/- (Rupees Twenty Eight Crores Fifty Four Lakhs Eighty
Nine Thousand and Six Hundred Only) and the Award Letter (An-
nexure A-4) also reiterated that the contract period was for a total
period of 36 months from 23/09/2015 including construction and in-
stallation of Crushing and Screening Plant. That a sum of Rs.
35,00,000/- (Rupees Thirty Five Lakhs Only) deposited by the Re-
spondent was kept as security deposit and the same was to be re-
covered @5 % on each bill. The schedule of Work and Rate is men-
tioned below:
S. Job Code/ Accounting Unit Qty. RATE Amount (Rs.)
No. (Rs.)
1 4005020018 1(A) 1 1,80,000.000 22.520 40,53,600.00

Breaking of Over size dolomite (+800mm) at desig-
nated stock pile (located within 500 meters) and
loading of (-800mm) feed size into tippers and un-
loading into crusher hopper to perform the follow-
ing operation: (A) Screening & separation of 0-6
mm reject/waste before crushing and stacked sepa-
rately and loading the same from crusher site into
tipper, transporting to dump yard within 1.0 km in-
cluding unloading and levelling etc.
2 4005020018 1(B) 1 28,20,000.000 88.150 24,85,83,000.00

ing operation: (B) Crushing & screening of ROM
dolomite to obtain SP/SMS/RMP grade of various
sizes, stacking separately, loading into tippers,
transporting and unloading at Dadhapara railway
siding.
7
S. Job Code/ Accounting Unit Qty. RATE Amount (Rs.)
No. (Rs.)
3 4005020018 1(C) 1 28,20,000.000 11.650 3,28,53,000.000

ing operation: (C) Loading into railway wagons by
mechanised means at Dadhapara siding.
Total Value 28,54,89,600
11.
12.That the Respondent firm failed to install the C & S unit within 3
months i.e. 22/12/2015 and due to non-commencement of the work
by the Respondent, penalty was imposed upon them for late com-
missioning of the contractual obligation as per the SPTC of the NIT
and PO No. - CCNW/PO-4270004884/PR-1130010150/1805, dated
20/05/2016.
13.That the Respondent after delayed commencement of work could
not meet up with the required efficiency and the pace of the work
was below par rate as prescribed in the contract.
14.That the Claimant company issued several reminders and intima-
tions informing the Respondent against their slow pace of work and
them not meeting the desired results as per the terms of the con-
tract. That the Respondent as per the schedule provided by the op-
erating authority had to meet total production of 55,000 MT, against
which the Respondent till 24/06/2016 produced a total 22,400 MT
only.
15.The letter/notices issued by the Claimant are as follows:
1. DGM (CCNW)/2015-2016/Hirri/4270004313/2300 dated
28/06/2016.
8
2. क्रमांक॰ खदान/हि॰ख॰/ख॰प्र॰/2016/674; दिनांक 28/06/2016.
5. क्रमांक॰ खदान/हि॰ख॰/ख॰प्र॰/2016/838; दिनांक 23/06/2016
6. क्रमांक॰ खदान/हि॰ख॰/ख॰प्र॰/2016/839; दिनांक 22/06/2016 pertaining to
submission of fitness certificates of the vehicles operating for
work within a week.
9. क्रमांक॰ खदान/हि॰ख॰/ख॰प्र॰/2016/612; दिनांक 20/06/2016 concerning sub-
mission of Labour License which as per the contract was to be
submitted within 15 days of the Award Letter i.e. 21/09/2015.
10.क्रमांक॰ खदान/हि॰ख॰/ख॰प्र॰/2016/ दिनांक 10/06/2016; क्रमांक॰
खदान/हि॰ख॰/ख॰प्र॰/2016/580 दिनांक 09/06/2016; क्रमांक॰
खदान/हि॰ख॰/ख॰प्र॰/2016/565 दिनांक 06/06/2016 giving information re-
garding non-installation of Weigh Bridge, Pay Loader, 30 tonne
Shovel, Water Tanker, Scoop Body Dump Truck and also non-
submission of lease agreements of the equipment and other re-
lated documents to the Claimant.
11.क्रमांक॰ खदान/हि॰ख॰/ख॰प्र॰/2016/542 दिनांक 31/05/2016 informing non-
commencement of work and recurring losses being borne by the
Claimant.
12.क्रमांक॰ खदान/हि॰ख॰/ख॰प्र॰/2016/381 दिनांक 07/04/2016; क्रमांक॰
खदान/हि॰ख॰/ख॰प्र॰/2016/331 दिनांक 25/03/2016 requesting Respondent
9
to submit Layout plan of the Crushing Plant and documents of
the Crusher Machine.
13.Notice- OMQ/HM/MM/2016/258 dated 08/03/2016 and
27/02/2016 informing no progress in installation and commis-
sioning of crushing plant.
14.Notice- OMQ/HM/MM/2016/266 dated 11/03/2016 pertaining to
submission of crushing plant documents.
15.Notice- OMQ/HM/MM/2016/265 dated 11/03/2016 directing com-
pletion of civil works contract.
16.Notice- OMQ/HM/MM/2016/171 dated 13/02/2016 informing
slow pace of work and directing submission of Time Schedule
Plan for installation and commissioning of crushing unit.
17.Notice- OMQ/HM/MM/2016/128 dated 05/02/2016 informing de-
lay in commissioning of Crushing Plant.
18.Notice- OMQ/HM/MM/2016/95 dated 29/01/2016 informing delay
in commissioning of Crushing Plant.
19.Notice- OMQ/HM/MM/2015/22 dated 07/12/2015 informing slow
work pace and reminding commissioning of the crushing plant to
be completed by 23/12/2015.
20.Notice- OMQ/HM/MM/2015/1304 dated 17/10/2015 advising to
expedite the construction and installation of the crushing and
screening plant.
16.That when the DGM (Hirri Mines) as per the SPTC and the NIT rules
imposed penalties for non-performance, then the Claimant started
the actual production of the work from 09/06/2016.
17.That the Mines Manager of the Hirri Mines submitted Plan for the
month of July 2016 on 01/07/2016 to the Respondent directing
10
them to complete the work as per the plan. That the Repondent
replied with a letter dated 14/07/2016 requesting the Claimant to
not impose any penalties for failing to meet the June months target.
18.That the Claimant informed the Respondent through a letter dated
27/07/2016 that due to many failures on their part in meeting the
desired outputs, the Claimant conducted a meeting of its officials on
22/06/2016 and it was held in the meeting to proceed against them
as per the Risk and Cost Clause of the NIT.
19.That on 29/12/2016 the Mines Manager of the Claimant company is-
sued 3 notices (खदान/हि.ख./ख.प्र/एम.एम.एफ़.एस./2016/1886),
(खदान/हि.ख./ख.प्र/एम.एम.एफ़.एस./2016/1887),
(खदान/हि.ख./ख.प्र/एम.एम.एफ़.एस./2016/1888) pertaining to non-payment of
dues of the vehicles employed in the work for transportation, supply
of below par/sub-standard quality of the finished product and non-
employment of any supervisor on the work site due to which the
supply and the working of the Claimant company was being ef-
fected.
20.That despite several notices being served to the Respondent firm,
the Respondent were still reckless in following the terms of the con-
tract and again a series of letters for continuing default were issued
to the Respondent firm.
1. खदान/हि.ख./ख.प्र./एम.एम.एफ़.एस./2017/08; dated 03/01/2017
2. खदान/हि.ख./ख.प्र./एम.एम.एफ़.एस./2017/32; dated 06/01/2017 was issued
informing delay in commencement of work, Non-submission of
requisite documents of the transporting vehicles as per the NIT,
Non-appointment of any supervisor, Continuous decline in pro-
duction and Delay in payment of wages and charges.
11
3. खदान/हि.ख./ख.प्र./एम.एम.एफ़.एस./2017/37; date 07/01/2017 issued for
non-payment of statutory dues (Service Taxes, CPF etc.).
10.खदान/हि.ख./ख.प्र./एम.एम.एफ़.एस./2017/220; dated 13/02/2017
12
21.That on 15/03/2017, a Risk Purchase Notice (Risk & Cost Notice)
was issued by the Claimant to the Respondent and a period of 14
days time was granted to the Respondent to improve performance
and to speed up the pace of the contract, failing which the Claimant
were going to initiate punitive actions which included cancellation of
the Award letter and termination of contract, value of increment dif-
ference for the unexecuted work to be recoverable, debarring from
participating in future tenders for a period of one year and other ac-
tions Cl. -21 of the Special Terms and conditions.
22.That through a reply dated 29/03/2017, the Respondent assured
that they have taken remedial actions to improve the production
and performance which will bring the production to 65,000-70,000
tonnes from April 2017.
23.That on 12/04/2017 a meeting was called in the Office of GM (Mines
and Rawghat) for increasing the production capacity of the plant
and the Respondent was represented by the Mr. Ramesh Patil and
Mr. Patil assured that they would be taking all the relevant steps to
increase the production capacity. It was also directed to the Re-
spondent to increase the production capacity to at least 1,00,000
tonne in the month of April 2017 and May 2017. To employee su-
pervisors in all the requisite sites and areas. To build an appropriate
plan and implement the same.
24.That again a letter was sent to the Respondent on 30/05/2017 in-
forming them about the continuous low production of the dolomites
as a result of which the Claimants were constrained to purchase the
dolomites to meet their demands from outside vendors.
13
25.That the Respondent were not executing the contract as per the
work schedule given by the Operating Authority. Inspite of the let-
ters/reminders/notices the Respondent neither speed up the work
pace and gave any satisfactory reply nor did they show any interest
and steps to execute the job as per the work schedule. That the
mobilisation of the work was extremely poor, there were violations
of statutory laws and several other failures on the part of the Re-
spondent.
26.That despite repeated failures on the part of the Respondent and
ample opportunities and reminders which appear to have fallen on
the deaf ears of the Respondent, the Claimant management pro-
posed on 25/04/2018 to take prompt actions as per the Risk and
Cost Clause. That the aforesaid actions were to be taken as per Rule
24 (Labour Clause), Rule 18 (Termination of Contract) and Rule 21
(Risk and Cost Clause) of the NIT and it was also proposed, that the
contract awarded to the Respondent be revoked and a new tender
to be floated for supply of dolomite.
27.That till 07/07/2018, the Respondent only completed part of the
contract awarded to them. That even after a period of 2 years and 9
months (33 months) when the total contract was for a period of 36
months, the Respondent had done only around 38.27 % of the work
till 03/07/2018 whereas it should have been 93.05 % by then.
Item Awarded Quantity Executed Quan- Balance Quantity % Balance
No. tity (Till June
2018)
1 (A) 1,80,000.00 15,254.70 1,64,745.30 91.53%

1 (B) 28,20,000.00 10,91,289.91 17,28,710.09 61.30%
1 (C) 28,20,000.00 10,91,289.91 17,28,710.09 61.30%
Percentage of work done by the Respondent.
14
28.That on 11/07/2018 a Pre- Emptory notice (Urgent) for anticipated
breach of contract (Risk & Cost Notice) was issued by the Claimant
to the Respondent and again a period of 15 days time was granted
to the Respondent to rectify their actions and to still follow the spirit
of the contract failing which the Claimant were going to initiate
punitive actions which included cancellation of the Award letter and
termination of contract, value of increment difference for the unexe-
cuted work to be recoverable, debarring from participating in future
tenders for a period of one year and other actions Cl. -21 of the
Special Terms and conditions.
29.Due to non-fulfilment and continuous failure on the part of the Re-
spondent, the Organisation & Methods Department of the Claimant
company issued a Banning order after due representation by the au-
thorised representative during the personal appearance before the
standing committee on 03/11/2018 and the committee found the
Respondent guilty of submission of fabricated documents. It was ul-
timately decided to call-off the business dealings with the Respon-
dent firm for a period of 3 years w.e.f. 19/11/2018. That the esti-
mated unexecuted value of the work not performed by the Respon-
dent was Rs. 17,62,35,331/-
30.That in reality there was no capital investment done by the Respon-
dent M/s MMFS on its own in this contract. The Claimant has not
been using the Plants & Machineries of M/s MMFS and it is kept in
idle condition since Dec. 2018.
31.That to the utter shock of the Claimant, the Director General of GST
Intelligence (DGGSTI) Bilaspur issued a summon to the Claimant in
August 2018 with respect to default in payment of Service Tax and
15
GST by M/s Mudrai Multifaciltiies Services, Pune (Respondent). That
the said summon was issued as the Claimant availed Service Tax &
GST credit on the invoices raised buy the Respondent and the Re-
spondent defaulted and contravened the provisions of the GST Law.
32.That due to contravention of the GST laws by the Respondent, the
Claimant had to reverse the GST credit availed by them from July
2017 till March 2018, amounting to Rs. 95,91,715/- and interest of
sum of Rs. 16,19,162/- till December 2018, a Total sum of Rs.
1,12,10,977/- (One Crore Twelve Lakhs Ten thousand and Nine
Hundred Seventy Seven Only) on 20/12/2018 was reversed by the
Claimant to the GST Authorities.
33.That as on 05/02/2019 after deducting from the pending bills and
adjustment of the security deposit and GST reversed, a total sum of
Rs. 74,29,793/- (Seventy Four Lakhs Twenty Nine Thousand Seven
Hundred Ninety Three Only) was payable by the Respondent to the
Claimant.
AMOUNT WITH BSP RECOVERIES
Recoveries on account of:

(i) Salary paid by BSP to
contractor’s employee.
(ii) PF payment made by BSP
(iii) Bonus payment paid by
BSP
(iv) Labour wages escalation
paid
Payment Due Rs. 1,96,63,503/- (v) Administration charges Rs. 2,68,44,270/-
(vi) Penalty
(vii) Misc. & Deductions
(viii) Rent & Electricity
dues
(ix) Bill of Gyan Singh
GST Reversal as per notice of Rs. 1,12,10,876/-
GST Dept. & Interest thereof-
Payment to GST Department.
SD with BSP Rs. 1,09,61,850/-
16
Extra Expenditure on account Rs. 2,53,45,508.71/-
of Risk & Cost action against
award letter under reference.
Total Amount with Rs. 3,06,25,353/- Total Recoveries Rs. 6,34,00,654.71/-

BSP
34.That, as on 12/04/2019, the Claimant sent a notice to the Respon-

dent for recovery of the total sum as mentioned below in the table
and the same was payable by the Respondent to the Claimant
within a period of 15 days from the date of receipt.
Net Recovery Amount was Rs. 3,27,75,301.71/- (Rs.
6,34,00,654.71-Rs. 3,06,25,353).
35.That a letter dated 13/12/2018 was issued to the Respondent stat-
ing recoveries of Bonus payment to 138 contract labourers and EL
Encashment payment and on 20/12/2018 a letter was issued to the
Respondent informing Bonus Payment to the labour for the year
2018-19 to be Rs. 11,93,577/- .
36.That through a letter bearing Ref No. MMFS/BSP/2020-21/001, the
Respondent agreed and gave No-Objection from their end to deduct
and pay the PF dues from their Outstanding sum and deposit the
same with PF department.
37.That for the execution of the remaining work, the NIT approved for
re-issuing tender CCNW/PR-1130001613/RPN/Mines/OT-962/2644
dated 21/07/2018.
38.That on 06/08/2019, the new tender was awarded to M/s Nanesh
Projects vide PO 4270007731 being the lowest bidder out of the 3
offerees.
AMOUNT WITH BSP RECOVERIES
17
Recoveries on account of:
(i) Salary paid by BSP to
contractor’s employee.
(ii) PF payment made by BSP
(iii) Bonus payment paid by
BSP
(iv) Labour wages escalation
paid
Payment Due Rs. 1,96,63,503/- (v) Administration charges Rs. 2,68,44,270/-
(vi) Penalty
(vii) Misc. & Deductions
(viii) Rent & Electricity
dues
(ix) Bill of Gyan Singh
GST Reversal as per notice of Rs. 1,12,10,876/-
GST Dept. & Interest thereof-
Payment to GST Department.
SD with BSP Rs. 1,09,61,850/-
Extra Expenditure on account Rs. 2,53,45,508.71/-

of Risk & Cost action against
award letter under reference.
Payment due in account of Rs. 25,92,738/-

“Departmental Payment of PF
Contribution in F/O Contrac-
tor Workers” (inclusive of ad-
ministrative charges @ 5%)
Old Bonus payment (for the Rs. 11,93,577.00/-

period 01.04.2018 to
22.12.20218), paid on
08.02.2020 as per approval
No. CEO/3/197, dated
29.01.2020
Total Amount with Rs. 3,06,25,353/- Total Recoveries Rs. 6,71,86,969.71

BSP /-
39.That the total outstanding liabilities payable by the Respondent is

The Net Recovery Amount works out to Rs. 3,65,61,616.71
(67186969.71– 30625353.00)
40.The Claimant’s claim are directed towards continuing acts and facts
as well as other acts and facts that took place since the issue of the
Letter of Acceptance dated 21/09/2015. The Respondent’s conduct
has been continuing intentional, wrongful, wilful and reckless ac-
18
tions and omissions have caused catastrophic loses to the
Claimants.
41.The Claimant is entitled to claim a sum of Rs. 3,65,61,616.71 /-
(Rupees Three crore Sixty Five Lakhs Sixty One Thousand Six
Hundred Sixteen and Seventy One Paise only).
42.The Claimant is further entitled to claim Interim interest and further
interest on the awarded sum and accordingly claims the same @
18% p.a. on the said sum.
43.The Claimant is entitled to get cost of and incidental to this pro-
ceeding and accordingly claims the same.
44.The Claimant reserves its right to amend and/or alter the instant
Statement of Claim and/or to submit additional Statement of Claim
and also craves leave to refer to true copies of further and addi-
tional documents at the time of hearing, if necessary.
The Claimant therefore Claims:
A. Award directing the Respondent to pay the
sum of Rs. Rs. 3,65,61,616.71 /- as de-
scribed in paragraph 44 of the instant
Statement of Claim;
B. To pass necessary directions in favour of
the Claimant against the Respondent so
that the right of the Claimant in terms of
the Statement of Claim is secured;
C. Interim interest and further interest on the
awarded sum @ 18% p.a. or at any other
rates as the Learned Arbitrator may deem
fit and proper;
19
D. To direct the Respondent to indemnify the
Claimant for all the losses and damages
suffered by the Claimant with necessary in-
terest and penalties as may be applicable
until commencement of the arbitration pro-
ceedings;
E. Cost of and incidental to this present arbi-
tration proceeding;
F. Such further order/orders, direction/direc-
tions may be passed as the Learned Arbi-
trator may deem fit and proper.
And for this act of kindness, the Claimant as in duty bound shall
ever pray.
VERIFICATION
20

Statment of Claim (BSP V MMSF)

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BEFORE THE

HON’BLE SOLE ARBITRATOR

MADURAI MULTI FACILITIES SERVICES PVT LTD

Sl. No. Description of Document Date Annexure Page No.

1 Statement of Defence and Verifi- 07.01.2022 1-22

III. THE PARTIES TO THE ARBITRATION AND RELATED ENTI-

III. GENERAL NATURE OF THE CLAIM

IV. THE BASIS FOR THE ARBITRATION, PRE-ARBITRATION NE-

1 4005020018 1(A) 1 1,80,000.000 22.520 40,53,600.00

2 4005020018 1(B) 1 28,20,000.000 88.150 24,85,83,000.00

3 4005020018 1(C) 1 28,20,000.000 11.650 3,28,53,000.000

Total Value 28,54,89,600

1 (A) 1,80,000.00 15,254.70 1,64,745.30 91.53%

Recoveries on account of:

Total Amount with Rs. 3,06,25,353/- Total Recoveries Rs. 6,34,00,654.71/-

34.That, as on 12/04/2019, the Claimant sent a notice to the Respon-

Extra Expenditure on account Rs. 2,53,45,508.71/-

Payment due in account of Rs. 25,92,738/-

Old Bonus payment (for the Rs. 11,93,577.00/-

Total Amount with Rs. 3,06,25,353/- Total Recoveries Rs. 6,71,86,969.71

39.That the total outstanding liabilities payable by the Respondent is

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