SETTLEMENT AGREEMENT

This Settlement Agreement (the “Agreement”) states the terms and

conditions that govern the contractual agreement between Dr. R.K.
Anand (“Party I”), and M/s DLF Commercial Developers Limited
(“Party II”), parties to the Arbitration Petition bearing no. Arb. No. 670
of 2020 (“Arbitration Petition”), pending for adjudication before the
Hon’ble High Court of Delhi, New Delhi, who agrees to be bound by
this Agreement.

WHEREAS, the Hon’ble High Court of Delhi vide order, dated

27.11.2020, directed the parties to amicably resolve the dispute and
referred the Arbitration Petition to Delhi High Court Mediation and
Conciliation Centre for settlement.

WHEREAS, the Party I and the Party II agree to settle the matter
through Mediation and avoid any further litigation.

NOW, THEREFORE, in consideration of the mutual covenants and

promises made by the parties hereto, the Party I and the Party II
(individually, each a “Party” and collectively, the “Parties”) covenant
and agree as follows:
1. DISMISSAL / WITHDRAWAL OF PENDING LITIGATION.

The Party I agrees to withdraw the abovementioned Arbitration

Petition, on the next date of hearing after the date of this
settlement, pending for adjudication before the Hon’ble High Court
of Delhi or effect dismissal of any claims existing or pending in any
jurisdiction relating to the Arbitration Petition.

2. RELEASE OF PAST, CUURENT & FUTURE CLAIMS

i. The Parties hereby irrevocably releases and forever discharges
each other from any past, current & future claims in relation
to the Arbitration Petition.
ii. The Parties hereby irrevocably and forever waives all rights
against each other, which may have accrued to them under
the law with respect to the Arbitration Petition.
iii. The Parties agree and acknowledge that A GENERAL
RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE
PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN ITS/HIS
FAVOR AT THE TIME OF EXECUTING THE RELEASE,
 WHICH IF KNOWN BY HIM MAY HAVE MATERIALLY
AFFECTED ITS/HIS DECISION TO SETTLE.

3. SETTLEMENT TERMS.
i. Party II hereby agrees to pay the amount calculated in the
Exhibit A, attached with this agreement, to the Party I.
ii. Party II hereby also agrees to provide peaceful and vacant
possession, as it was taken at the time of signing of Lease
Deed dated 14.07.2011, of the Retail/Commercial Space
bearing No. MS0-308, having an approximate super area of
340.49 sq. mtrs. (hereinafter, referred to as “demised
premises”) within 30 days from signing of this settlement
agreement.
iii. Party II hereby also agrees that the Interest Free
Refundable Security Deposit of Rs. 5,49,750.00 (Rupees
Five Lakh Forty Nine Thousand Seven Hundred Fifty Only)
shall not be refunded by the Party I.
iv. Party II hereby agrees to handover the peaceful possession
of the demised premises as per the mutually agreed
specification mentioned in the Exhibit B, attached with
this agreement.
v. Party II hereby also agrees that if Party II will fail to deliver
the peaceful possession of the demised premises to the
Party I, on or before 30 days from the signing of this
settlement agreement, then Party II will be liable pay
monthly rent as per the lease deed, dated 14.07.2011, of
the demised premises.

4. TIME IS OF THE ESSENCE. The Parties agree and acknowledge

that time is of the essence with regard to the Settlement payments.

5. NO MODIFICATION UNLESS IN WRITING. No modification of this

Agreement shall be valid unless in writing and agreed upon by
both Parties.

6. CONFIDENTIALITY. The Parties hereby agree and acknowledge to

maintain the full secrecy and confidentiality pertaining to the
settlement terms of this Agreement.

7. FULL INTEGRATION. This Settlement Agreement supersedes any

prior agreements, understandings, or negotiations, whether written
or oral, to the extent of any conflicting provisions.
8. FURTHER ASSURANCES. The Parties shall make any further
assurances as may be necessary to implement and carry out the
intent of this Agreement.

9. BREACH. The Party I acknowledge and agree that any breach of

this present agreement would result in irreparable harm to the
Party II. Accordingly, the Party I agree that if there is any breach by
the Party I in any terms of the present agreement, the Party II shall
be entitled to injunctive relief along with damages in accordance
with law.

10.NO ADMISSION OF LIABILITY. This Agreement is not, and shall

not be construed as, an admission of liability, fault, or wrongdoing
of any kind by any Party.

11. NO “PREVAILING PARTY.” Except as otherwise provided in this

Agreement, the Parties, and each of them, agree to bear their own
attorneys’ fees and costs, and no Party shall be deemed to be a
“prevailing party.”

12.INTERPRETATION. The language and terms of this Agreement are

to be understood in their ordinary sense (except where otherwise
defined) and are not to be interpreted in a technical manner so as
to unfairly deprive any Party of substantive rights.

13.SEVERABILITY OF TERMS. If any provision of this Agreement is

held to be invalid or unenforceable by a court of competent
jurisdiction, that determination shall not invalidate or render
unenforceable any other provision of this Agreement.

14.BINDING NATURE. The above terms and conditions are reciprocal

in nature, constitute one inseparable and composite set of terms
and shall be mutually binding upon all the both parties, their
group of companies, affiliates, associates, successors in interest
and title and anyone acting for and on their behalf.

15.AUTHORITY TO ENTER AGREEMENT. Each Party warrants that

the person signing this Agreement is authorized and empowered to
sign this Agreement on its/his/her behalf, and to bind such Party
to the terms of this Agreement.

16.EFFECTIVE DATE. This Agreement shall be deemed fully executed

and effective when it has been signed by all of the Parties.
17.VENUE. This Settlement Agreement and the interpretation of the
terms herein shall be governed by and construed in accordance
with the laws of the Republic of India. The Parties irrevocably
submit to the exclusive jurisdiction of the courts located in New
Delhi, India.

IN WITNESS WHEREOF, each of the Parties has executed this

Settlement Agreement, both Parties by its duly authorized person, as
of the day and year set forth below.

[Party I NAME]

_________________________________ ______________

DATE

[Party II, NAME]

_________________________________ ______________

DATE