BEFORE THE LEARNED SOLE ARBITRATOR

MR. SHANAY SHAH

Inthe matter of Arbitration Between:

Subhash Nagar Dnyandeep CHS LTD .. Claimant

Versus

G.A Builders Pvt Ltd. .. Respondents

INDEX
Sr no. | Particulars Page no.

. Application in reply on behalf of the 1-6

Claimant for inspection and photocopies of

document
2. Exhibit A 7-13
Compilation of Documents

3. Exhibit B 14-20

Copy of letter dated 18th January, 2023

addressed by the Advocates for the
Respondent to the Advocates for the
Claimant
Exhibit C 21

Copy of mail dated 18 January. 2023 by

Advocates for Claimant to Advocates for
Respondent
 BEFORE THE LEARNED SOLE ARBITRATOR

MR. SHANAY SHAH

Inthe matter of Arbitration Between;
Subhash Nagar Dnyandeep CHSLTD Claimant

Versus

G.A Builders
Pvt Ltd. Respondents

APPLICATION IN REPLY ON BEHALF OF THE CLAIMANT FOR

INSPECTIONAND PHOTOCOPIES OF DOCUMENT
1. This Present
reply is filed by the Claimant in reply to the Respondents
application for inspection and photocopies of minutes of meetings of
General body as well Managing Committee
maintained by the Claimant
Society.

2. The Claimant states and submits

that the Respondents deposition in their
application filed for inspection and photocopies of documents, dated 9th
March. is irrelevant and ambiguous. The aforementioned application is
unconvincing and fails to provide facts to
support their claim, rendering
it
unpersuasive. We deny the claim and contention made by the respondent
in the application as they are untrue,
unsubstantiated and baseless.

3. The Claimant states that

complete inspection of the documents relied by
the Claimant society in the above
captioned matter has been granted by the
Advocate for Claimant on 17th January 2023 to Ms.
Viloma Shah and Mr.
Harshad Vyas at the Bar Association. 3trd Floor of the
Hon'ble Bombay
High Court at 5.25 p.m. Hereto marked and annexed as Exhibit "A". On
 18th January 2023, Advocate for the claimant received a letter from

Advocate for Respondent requesting legible copies of the documents,

hereto marked and annexed as Exhibit "B", which was further provided to
the respondents vide mail dated 18th January 2023. Hereto marked and
annexed as Exhibit "C" and also hardcopies of the same was provided to
the Advocate for Respondent on 19th January 2023.

4. The Claimant states that Para No. 2,3,4,5,7 of the application filed by the
Respondent for inspection and photocopies of the document are a matter of
fact on record.

5. In response to Para No. 6, The Claimant states that Advocate for the
Claimant Society were in receipt ofletter dated 18h January 2023 addressed
by the Advocates for Respondent, calling upon to provide clear legible
copies of the illegible pages in the Compilation of document. Furthermore
it is pertinent to note that the Advocate for the claimant furnished clear
legible scanned copies ofthe same through email dated 18th January 2023
and also produced legible hardcopies of the same in the Arbitration meeting
held on 19gth January 2023. Additionally, the Advocate for the Claimant
affirmed in good faith with Advocate for Respondent, if
needed any they
additional copies, to which advocate for respondent raised no objection and
were satisfied with the same. As a result, complete inspection was granted.

6. In response to Para No.8, Claimant states that the

arbitration proceedings
are being conducted
jointly for four societies, Subhash Nagar Kiran Samrat
CHS Ltd.. Subhash Nagar Surangi CHS Ltd. Subhash
Nagar
Three Star
CHS Ltd. and Subhash Nagar Dnyandeep CHS Ltd. During the course of
arbitration meeting held on 20th January 2023 and whilst the document of
the claimant was being marked, it was
put across by the Advocate for
Claimant to the Arbitral Tribunal that Subhash Nagar Kiran Samrat CHSL
[Case I] and Subhash Nagar Surangi CHSL {Case IV] maintains minutes of
meetings in the form of files. Thereafier, the Tribunal directed the claimant
 to grant inspection of the files of Subhash Nagar Kiran Samrat CHSL
Casel] and Subhash Nagar Surangi CHSL [Case IVJto confirm that
minutes of meetings are being maintained by the Claimant Societies in the
form of file and are Authentic. Further taking upon the instructions of the
Learned Sole Arbitrator, Advocate for the claimant provided inspection of
the minute file of aforementioned societies at a mutual convenient date i.e
9th February 2023

7. The content of Para No.9 is incorrect. The Claimant states that

inspection
of minute book of the captioned society has already been granted on 17h
January 2023 for a sufficient amount of time, therefore question of
providing inspection again for the second time does not arise. Further it is
accurate that inspection of the minute file of Subhash
Nagar Kiran Samrat
CHSL [Case I] and Subhash Nagar
Surangi CHSL [Case IV] was granted
by Advocate for Claimant on 9h February 2023 with a specific purpose
of
confirming the authenticity of minutes of the meetings that are being
maintained by the claimant society in the form of file.
Also, photocopies of
documents that are directly relied upon by Claimant
Society have already
been provided in the compilation of documents.

8. In Response to Para No
10, The advocates for Respondent in their letter
dated 27th February 2023 falsely recorded that
inspection of the minute
book has not been granted. Whereas, an effective
inspection of minute files
was
provided by Advocate for Claimant on 17h january 2023 for a
sufficient time of more than two hours. Further it is
pertinent to note that
inspection of minute file was granted on 9 February 2023 whereas
letter
stating that incomplete inspection was provided and
requesting for
photocopies was sent on 27th February 2023 addressed to Advocate
for
Claimant, which is an afterthought, with an intention to
buy time and delay
the arbitration proceeding.
 Claimant by its letter
No.11 is incorrect. Advocate For
9. The of Para
contents
Claimant states that
true facts on record. The
dated 4m March 2023 placed
the
the facts and wrongly twisting
Respondent is incorrectly interpreting
Claimant was
it was accurately recorded that Advocate for
matter as
the minute files
directed by provide only inspection of
Arbitral Tribunal to
CHSL
Subhash Nagar Kiran Samrat
maintained by claimant society (i)
CHSL [Case 4] with a specific
[Case I ] and (ii) Subhash Nagar Surangi
of minutes of the meetings that
are
purpose of confirming the authenticity
in the form of file.
being maintained by the claimant society

Para No 12, raised by the

10.The Claimant denies the discrepancies in
of the documents relied
respondents calling into question the gaminess
have misinterpreted the fact that
upon by the claimant society. Respondents
files/books
in the arbitration meeting, it agreed, inspection of minute
was

ought to be granted for all four societies in view of the discrepancies found

and that the claimant resolutions were marked in evidence

by respondents
on the assurance that inspection would be provided. Whereas the actual fact
the
is there was no discrepancies with regards to the minutes file. During
the
course meeting held on 20h January 2023 and whilst
of arbitration
document of the claimant was being marked,
it was put across by the

Advocate for Claimant to the Arbitral Tribunal that

Subhash Nagar Kiran
Samrat CHSL [Case I] and Subhash Nagar Surangi CHSL [Case IV]
the Tribunal
maintains minutes of meetings in the form of files. Thereafter,
directed the claimant to grant inspection of the files of the aforementioned
societies to confirm that minutes of meetings are being maintained by the
Claimant Societies in the form of file and are Authentic. Further taking

upon the instruction of Arbitral tribunal, advocate for the claimant

completely acted and performed what was by granting the
directed
2023.
inspection of minute file of aforementioned societies on 9th February
It is pertinent to note that inspection of minute book of the captioned

society, i.e Subhash Nagar Three-star CHS Ltd has already been granted on
17th January 2023 for a sufficient amount of time, therefore question of

providing inspection again does not arise.

11.The contents of Para No.13 is incorect. The Claimant states that inspection

of the minute book is complete as originals were compared photocopy

to

ofcompilation of document by the advocates for respondent on 17h January

2023. The Claimant states that photocopies of documents that are directly
relevant and material to the proceedings relied upon by Claimant Society
have already been provided in the compilation of documents. Further,
Advocate for the Claimant Society were in receipt of letter dated 18h
January 2023 addressed by the Advocates for Respondent, calling upon to
provide clear legible copies of the illegible pages in the Compilation of
document. It is pertinent to note that the Advocate for the claimant
furnished clear legible scanned copies of the same through email dated 18th
January 2023 and also produced legible hardcopies of the same in the
Arbitration meeting held on 19th January 2023. Additionally, the Advocate
for the Claimant affirmed in good faith with Advocate for Respondent, if
they needed any additional copies, to which advocate for respondent raised
no objection and were satisfied with the same. As a result, complete
inspection and photocopies were granted and the Respondents rights to
have copies of the documents to be inspected remains unaffected.

12.In response to Para No 14, The claimant states that complete Inspection of
minute book that is relevant and material to the proceedings as well as for
cross examination has been provided as directed by the Arbitral Tribunal,
so the question of Respondents impossibility to conduct cross examination
of the witness doesn't arise.
6
13. Accordingly, the Claimant prays as under:
Order directing the
(a) That this Hon'ble tribunal be pleased to pass an

Respondent to proceed with the cross examination of the witness.

(b) Reject the Respondents request to provide inspection again of the

minute book maintained by Claimant and photocopies of the documents
that are are not relied upon by the Claimant in the captioned matter

(c)Reject the respondents request that the evidence ofthe Claimant and its
witnesses in respect of society/managing committee resolutions be
Struck off /lgnored and also to reject the request to strike off the
resolution of the claimant Society from the record of these proceedings.

(d) Dismiss the application filed by Respondent.

(e) For costs; and

()For further and otherreliefs as this Hon'ble arbitral tribunal may deem
fit and proper.

Solemnly affirmed at Mumbai

Dated this day of March 2023

Adv. Ria Jain

Advocate For Claimant

 ExHIB17 "A"
7

COMPILATION OF DOCUMENTS

DATE PARTICULARS REMARKS

SR.
NO.
1. 2d January 2023 Abstract of the resolution Original
passed by the Managing
Committee
December| Development Agreement Certified Copy
2009
9th December| Power of Attorney Certified Copy
2009
4. 17th April 2010 Offer letter issued by Photocopy Copy.
Mhada Respondent had requested
Claimant to provide legible
copy of the same.
However, the same has
been
provided

SA 28th May 2009 Leave and License Certified Copy shown.

agreement of Dinesh S. Respondent had requested
Chaplot Claimant to provide a
photocopy of the certified
copy. However, the same
has been provided

5B 2nd April 2010 Leave and License Original

agreement of Dinesh S.
Chaplot
5C |1st July 2012 Leave and License Original
agreement of Dinesh S.
Chaplot
SD 26th June 2013 Leave and License Original
agreement of Dinesh S.
Chaplot
 I July 2014 Leave and License Original
agreement of Dinesh S.
Chaplot

SF 29th March 2012 |Leave and License Certified copy.

agreement of Pramod S. Respondent had requested
Shelar Claimant to provide copy
of the certified copy.
However, the same has
beenprovided.
SG 25th March 2013 Leave and License Original
agreement of Pramod S.
Shelar

5H s February 2014 Leave and License of Certified Copy shown

Pramod S. Shelar along with receipt.
Respondent had
requested Claimant to
provide copy of the
certified copy. However,
the same has been
provided
6A 30th April 2010 Leave and License Photocopy
agreement of Pramod S. Page 378 original
Shelar handwritten shown

6B 14th March 2009 Leave and License

PhotocopPy
agreement of Pramod S.
Shelar

6C 14th July 2009 Leave and License of Arun Certified copy

D. Mugdum

6D 1st August 2009 Leave and License

Photocopy shown
agreement of Umesh G.
Respondent had
Kini requested Claimant to
provide legible copy of the
document. However, the
same has been provided
7A. Bank Statement of Pramod Original Passbooks
S. Shelar shown
First Passbook - Pages

419 to 426
Second Passbook - Pages

427 to 441
Third Passbook - Pages

443 to 462

7B. Bank Statement of Umesh Original Passbook

Kini Shown Pages 463 to 468
Respondent had requested
Claimant to provide copies
of original passbook pages
463 to 468 as the same
could not even be
inspected. However, the
same has been provided

Second Original
Passbook Shown- Pages
469 to 490
Respondent had requested
Claimant to provide copies
of original passbook pages
469 to 490 as the same
could not even be
inspected.
Respondent had also
requested for first page of
the bank statement.
However, the same has
been provided
7C Bank Statement of Vinod S. Original Shown Pages
-

Chaplot 491 to 504

Respondent had
requested legible copy of
the same as the same could
not even be inspected.
However, the same has
been provided.
 8. 13th February Letter addressed by four Photocopy
2018 societies including the
claimant to the Respondent

9 5th March 2018 Letter addressed by four office copy along with
societies including the original
claimant to the Respondent acknowledgment shown

10. 28th April 2018 Letter addressed by four office copy along with
societies including the original
claimant to the Respondent acknowledgment shown

11. 24th October 2020 Minutes of the Special Original Agenda shown
General Body meeting of along with photocopy of
the Claimant Society the Minutes.
Respondent had requested
Claimant to provide a copy
of the Agenda. However,
the same has been
provided
12. 30th October Public Notice Original extract from
2020
the Navshakti and the
Free Press Journal
newspapers shown.
Respondent had
requested Claimant to
provide copy of the same.
However, the same has
13. 28th October
been provided
Termination notice
2020 addressed by the
Photocopy
Advocates for the
Claimant to the
Respondent
 Original extract from
14.6th November Tender notice
the Navshakti and Free
2020
Press Journal
newspapers shown
Respondent had requested
Claimant to provide copy
of the Free Press Journal
newspaper. However, the
same has been provided.
December Minutes of the meeting of Original Shown
15. 19h
the Special General Body Respondent had
2020
meeting of the Claimant requested Claimant to

provide a copy of the

original document.
However, the same has
been provided.

16. 6 January 2021 No Objection issued by Original

Deputy Registrar Mhada
office Copy along with
17. 23rd March 2021 Complainant made by the
Claimant to the senior original
Inspector of Police, acknowledgment shown
Chembur Police Station
the Printout
18. 18th June 2021 Order passed by
Hon'ble Bombay High
Court
19. 18th August 2021 Offer letter issued by Original
Mhada shown with
receipt
20. 23rd December Solid waste Management Original
2021 permission

21. 13th April 2021 IOA issued by Mhada Original.

Respondent had
requested Claimant to
provide a copy of the
original document.
However, the same has
been provided.
12
22. 5th May 2021 Notice addressed by Original
Advocates for the
Respondent to the Claimant
23. 31st May 2021 Letter addressed by the Office copy
advocate for the claimant to shown.
the Advocates for the Respondent
Respondent had requested
Claimant to
provide a
copy of the
R.P.A.D
receipts
affixed to the
letter.
However, the
same has
been
provided.
24. 31st January 2022 Form of Declaration of the Original
Claimant

25. 1st February 2022 Minutes of the newly Original

elected managing Respondent had
Committee ofthe Claimant requested Claimant to
provide legible copy of the
same. However, the same
has been provided.

26. 1* February 2022 Minutes of the Special Original

general body meeting of the|
Claimant

27. 10th February Order passed by the Printout

2022 Hon'ble Bombay High
Court
28. 17th May 2022 Order passed by the Printout
Hon'ble Bombay
Court
High
 of the
29 13th May 2022 Commencement Certificate | Photocopy shown
first page
Respondent had
requested Claimant too

provide a copy ofthe

second page of the
Commencement
Certificate. However, the
same has been provided.

30. 15th June 2022 Excavation permission PhotocopPY

Respondent had
requested Claimant to
provide legible
photocopy of the
permission. However,
the same has been
provided.

31. RERA Certificate Printout

 AVP PARTNERS
Advocates & Solicitors

BY EMAIL/R.P.A.D
AVP/67/2023
18th January 2023

To,
Ms. Ria Jain
Advocate for the Claimant
803, Lilum CHSL, Building No.16,
Vasant Oasis, Marol Makwana Road,
Andheri East, Mumbai - 400059

Dear Madam,

Re: Before The Ld. Sole Arbitrator,

Mr. Shanay Shah
Inthe matter of arbitration between:
Subhash Nagar Chembur Dnyandeep Co-operative
Housing Society Limited .. Claimant

Versus
G.A. Builders Pvt. Ltd. . Respondent

We are concerned for our client, G.A. Builders Pvt. Ltd. the Respondent in the captioned
matter.

Viloma Shah and Mr. Harshad

Pursuant to the date and time fixed for inspection, our Ms.
Court on
Vyas attended the Bar Association at the 3rd floor of the Hon'ble Bombay High
13th January 2023 at 4.10 p.m. Inspection of the documents was granted by you alongwith
Ms. Madhumita Sureshbabu and Ms. Katyani Pandey.

At the outset, referred to the compilation of the documents served upon us in the
we
above matter on 5th January 2023 and enquired with you if any further documents were
to be referred to and relied upon by your client apart from those contained in the
of the documents were
compilation of Documents. You informed us that the compilation
the only documents referred to and relied upon by your client in the above matter and
that your client will not be referring to and/or relying upon any other or further

documents.

their affidavits of evidence in

We further enquired whether your client had filed all
accordance with the directions ofthe Arbitration Tribunal dated 1s* December 2022 or if
client. You clarified that
the evidence of any other witness remained to be lead by your
Thomas George K in the
you/ your client would only be leading the
evidence of Mr.
other witnesses on behalf of the Claimant.
captioned matter and that there were no
19th January 2023, before
We further request Mr. Thomas George K to remain present
on

the Ld. Sole Arbitrator for marking of the documents.

301. 3rdAoorJehangjirBulding,13,MahatmaGandhikoad.Fort,Mumbai 40001.S:022:2261398|/2267 2513

 AVP PARTNERS
15 Advocates & Solicitors

Kindly note, our observations with respect to the inspection of the documents is as

follows:

COMPILATION OF DOCUMENTS
REMARKS
SR. DATE PARTICULARS
NO.
2nd January 2023 Abstract of the resolutionOriginal
passed by the Managing
Committee
2. 3rd December Development Agreement Certified Copy
2009
3. 9th December Power of Attorney Certified Copy
2009
4. 17th April 2010 Offer letter issued by | Photocopy
Mhada Copy not legible.
Respondent had
requested Claimant to
provide legible copy of
the same. However, the
same has not been
provided
5A 28th May 2009 Leave and License Certified Copy shown.
agreement of Dinesh S. | Respondent had
Chaplot requested Claimant to

provide a photocopyof
the certified copy.
However, the same has
not been provided
5B 2nd April 2010 Leave and License Original
agreement of Dinesh S.
Chaplot
5C 1st July 2012 Leave and License| Original
agreement of Dinesh S.

Chaplot
5D 26th June 2013 Leave and License Original
agreement of Dinesh S.

Chaplot
5E 1st July 2014 Leave and License Original
agreement of Dinesh S.
Chaplot
SF 29th March 2012 Leave and License Certified copy.
| Respondent had
agreement of Pramod S.
Shelar
requested Claimant to
provide copy of the
 AVP PARTNERS 16
Advocates & Solicitors

certified copy. However,

the same has not been
provided

5G 25th March 2013 Leave and License Original

agreement of Pramod S.
Shelar
Certified Copy shown
5H 1st February 2014 Leave and License of
Pramod S. Shelar along with receipt.
Respondent had
requested Claimant to
provide copy of the
certified copy. However,
the same has not been

provided
6A 30th April 2010 Leave and License | Photocopy
agreement of Pramod S. | Page 378 original
Shelar handwritten shown

6B 14th March 2009 Leave and License Photocopy

agreement of Pramod S.
Shelar
14th July 2009 L Leave and License of Arun | Certified copy
6C
D. Mugdum
6D 1s August 2009 Leave License Photocopy shown
and
agreement of Umesh G. | Respondent had
Kini requested Claimant to
provide legible copy of
the document. However,
the same has not been
provided
7A. Bank Statement of Pramod Original Passbooks
S. Shelar shown
First Passbook Pages
419 to 426
Second Passbook - Pages

427 to 441
Third Passbook Pages
443 to 462
Bank Statement of Umesh | Original Passbook
7B.
Kini Shown Pages 463 to
468
Respondent had
requested Claimant to
provide copies of original
passbook pages 463 to

301 3rdfor JehangjrBuilding,133,MahatmaGandhiRoad.Fort.NMumbai40001.2:022:22673988/20672513

 AVP PARTNERS
7 Advocates & Solicitors

468 as the same could not

even be inspected.
However, the same has
not been provided

Second Original
Passbook Shown - Pages

469 to 490
Respondent had
requested Claimant to

provide copies of original

passbook pages 469 to

490 as the same could not

even be inspected.
Respondent had also
requested for first page of
the bank statement.

However, the same has

not been provided.
Bank Statement of Vinod S. | Original Shown - Pages
7C
491 to 504
Chaplot
Respondent had
requested legible copy of
the same as the same
could not even be
inspected. However, the
same has not been
provided.
8. 13th February | Letter addressed by four Photocopy
2018 societies including the
claimant to the Respondent
9. 5th March 2018 Letter addressed by four Office copy along with
societies including the original
claimant to the Respondent acknowledgment shown
10. 28th April 2018 Letter addressed by four Office copy alongwith
societies including the original
claimant to the Respondent acknowledgment shown
1. 24h October2020 Minutes of the Special Original Agenda shown
General Body meeting of | alongwith photocopy of
the Claimant Society the Minutes.
Respondent had
requested Claimant to
provide a copy of the
Agenda. However, the

301.3rd foor JebangirBuilding,133,MahatmaGandhiRoad.Fort,MumbaiH0001.:022:2673988/22672513

 AVP PARTNERS 8
Advocates & Solicitors

has not been

same
provided
extract from the
12. 30th October 2020 Public Notice Original
Navshakti and the Free

Press Journal newspapers

shown.
Respondent had
requested Claimant to

provide copy of the same.

However, the same has
not been provided

13. 28th October 2020Termination notice Photocopy

addressed by the Advocates
for the Claimant to the
Respondent
Original extract from the
14 6th November Tender notice
Navshakti and Free Press
2020
Journal newspapers
shown
Respondent had
requested Claimant to

provide copy of the Free

Press Journal newspaper.
However, the same has
not been provided.

15. 19th December Minutes of the meeting of Original Shown

the Special General Body Respondent had
2020
Claimant requested Claimant to
meeting of the
provide a copy of the
Original document.
However, the same has
not been provided.

16. 6th January 2021 No Objection issued by Original

Deputy Registrar Mhada
23rd March 2021 Complainant made by the Office Copy alongwith
17.
Claimant to the senior original
Inspector of Police, acknowledgmentshown
Chembur Police Station

Order passed by the Printout

18. 18th June 2021
Hon'ble Bombay High
Court
19. 18th August 2021 Offer leter issued by | Original shown
Mhada alongwith original
receipt

301, JrdfloorJehangir Building,133.Mahatma GandhiRoad,Fort.JMumbai 40001.:02-2267.3988/2267 2513

 AVP PARTNERS
Advocates & Solicitors

Respondent had
requested Claimant to
provide a copy of the
original document.
However, the same has
not been provided.
20. 23rd December | Solid waste Management Original
2021 permission
21. 13th April 2021 1OA issued by Mhada Original
Respondent had
requested Claimant to
provide a copy of the
original document.
However, the same has
not been provided.
22. 5th May 2021 Notice addressed by Original
Advocates for the
Respondent to the Claimant
23. 31st May 2021 Letter addressed by the | Office shown
copy
advocate for the claimant to without acknowledgment
the Advocates for the
Respondent had
Respondent requested Claimant to
provide a copy of the
R.P.A.D receipts affixed
to the letter. However,
the same has not been
provided.
24. 24h January 2022 Form of Declaration of the Original
Claimant
25. 31S January 2022 Minutes of the newly Original
elected managing| Respondent had
Committee of the Claimant requested Claimant to
provide legible copy of
the same. However, the
same has not been
provided.
26. 1s February 2022 Minutes of the Special Original
general body meeting ofthe
Claimant

27. 1s February 2022 Order passed by the Printout

Hon'ble Bombay High
Court

301. Jrd foor Jehangir Building,133,Mahatma Gandhi Ruad. Furt. Mumbai H001.:0:22673988 /267:513
 AVP PARTNERS X 20
Advocates & Solicitors

28. 10th February Order passed by the Printout

2022 Hon'ble Bombay High
Court
29 17th May 2022 Commencement Certificate Photocopy shown of the
first page
Respondent had
requested Claimant to

provide a copy of the

second page of the

Commencement
Certificate. However,the
same has not been
provided.
30. 13th May 2022 Excavation permission Photocopy
Respondent had
requested Claimant to

provide legible
of the
photocopy
permission. However,
the same has not been

provided.
RERA Certificate Printout
31. 15th June 2022
Statement of rent due Not provided
32 Statement of Liquidation of Not provided
33
damage due
Statement of additional Not provided
34 losses/ reimbursement of
incurred
expenses and cost
Not Provided
35.
Statement of Compensation
for severe inconvenience

and hardship

here call upon you to provide

clear legible copies of the illegible
In view ofthe above, we remains incomplete.
have to inform you that the inspection
pages and we

Yours truly.
For M/s. AVP Partners

Partner
Encl: As above
Ltd
Cc.: G.A. Builders Pvt.

Mumbai40001. :02-12673988/2267 2513

301. 3rdMoor JehangirBuilding 13.MahatmaGandhi Road.Fort.
b435fi2arn
 BEFORE THE LEARNED SOLE

ARBITRATOR

In the matter of Arbitration Between:

Subhash Nagar Dnyandeep Co-operative
Housing Society Limited ...Claimant

Versus

G.A Builder Pvt.Ltd. ...Respondent

APPLICATION IN REPLY ON BEHALF OF

THE CLAIMANT FOR INSPECTION
AND PHOTOCOPIES OF DOCUMENTS

Dated this 27th day of march 2023

Adv.Ria Jain
702, Tulsi Meadows,
Near Uttam Society,
Chembur, Mumbai-400071.
Registered No:MAH/2025/2021
Mobile:9833153311
advocateriajain@gmail.com