White and Case

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N

THE

SIJPREME

CCURT

OF

INDIA

SPECIAL

LEAVE

PETITION

(uncler

Article

t 36

of

the

Constitution

of

India)

Special

Leave

Petition

(Civil)

No'17150-17154

ot2012

IN

THE

MATTER

OF:

The

Bar

Council

of

lndia

21,

Rouse

Avenue

lnstitutional

Area

New

Delhi

-

I

l0

002

-Vs-

Petitioncr

I{esPondcnts

\/

\46*

1//

0M

A.K.

Balaji

7l

107

,

Mel

Batcha

Pet

Harur,'Tamil

Nadu

-

636

903

And

39

others

COLTNTER

AFFIDAVIT

FILED

ON

BEFI"ALF

OF

RESPo;;;NI

No

14'

wHlrE

&

cAsE

LLP'

I,

Nandan

Nelivigi,

son

of

Shivaraj

Nerivigi,

agcd

abcut

4l

years'

with

ofhce

at

II55

Avenue

of

the

Americas'

New

York'

NY

10036'

do

hereby

solemnly

attlrm

and

sincercly

state

as

follows:

l.

I

am

one

of

the

Partners

of

this

Respondent

and

theretbre'

I

am

acquaintedwiththefactsanddulyauthorizedtoaifirmthiscounter

affidavit.IhavereadthespecialLeavePetitionfiledbythcPetitioner

hereinandherebydenytheavennentscontainedtherein(excepttothc

extent expressly

admitted) on the

basis

of

my

knowledge'

intbrmation

and

legal

advice

l:.

:t.:

),1*

L

ffiaa

JoHN

&

oSTUlio

ltr

xotri-rii&'3rto

ct

xar

voa

O.lrneO

l:r

Oudl.

CountY

corilEii

Fro

rn tlr.vo(carn3t

C{,rrrns.on

EryoaJa't/.



3v{

PRELIMINARY

OBJEC

|IONS

:

2.

The

Petition

is

liable

to

be

dismissed

in

limine

for

reasons

set

out

in

this

counter

affidavit

and

to

be

urged

at the

time

of

merking

written

and

oral

submissions.

The

Petition

does

not

present

any

substantial

question

of

law

or

lact.

This

Respondent

does

not

have

a law

oflice

in

lndia

and

it does

not

give

lndian

law

advice

to

its

clients

as

alleged

by

the

Petitioner

in

the

Petition.

The

Petitioner

does

not

have

locus

standi

to

file

this

Special

Leave

Petition.

There

is

no

contradiction

in

the

ruiings

of

the

Bombay

High

court

and

the

Madras

High

Court

as

inconectly

alleged

in

the Petition'

Therefore,

there

is

no

Bermane.issue

for

consideration

by

the

Hon',ble

Supreme

Court.

REPLY

TO

THE

SY]TJOPSIS:

3.Thestatementsinthesynopsisareincorrectandmisleading.ln

particular,

the

Petitioner

has

averred

that

the

issues

that

arose

in

the

case

betbre

the

Madras

High

court

were

the

same

as

the

issues

bclbrc

the

Bombay

Fligh

court

in

Lawyers

collective

vs.

BelI

council

of

lndia'

2010

(ll2)BombayLawReport32(theLawyers'collectivecase)']'his

averment

is

lactually

inconect

and

is,

therefore,

misleading

and

dcnied'

4.

ln

the

Lawyers' Collective

case,

the

Bombay

High

Court

was

required

to

adjudicate

on

the

validity

of

licenses

issued

by

the Rescrv'c

Bank

of

India

to

a

t-ew

foreign

law

t-irms

under

Section

29

of

the

Foreign

Exchange

Regulation

Act,l9l3.lt

was

contended

that

the

Advocates

Act,

JOHII

c.

osrLlNO

Ut

li.'i-Hfotsdl$ Ycrr

qr.{.Gr-.CarD

r,rrglcathd'thrYcl.fut

Cgqnnqoo,qprr

l*t,**5

i.

M

6

;fa*rw



::

.

lvol

lAdrocares

Acr)

onll

deals

$ith thc

Practicc

ol'lndian

law

in

court

and

that

it

does

not

deal

with

or

regulate

the

practice

of lndian

law

outside

court.

On this

basis,

it

was

further

contended

that

tbreign

lawyers

arc

entitled

to

provide

transactional

and

advisory

services

in relation

to

mattcrs

governed

by

Indian

law.

This

contention

was

rejected

by

the

Bombay

High

court

which

held

that

the

practice

of

law,

under

the Advocates

Act,

covers

both

litigation

and

transactional

i advisory

practice.

The

issue

of

whether

advice

conceming

fbreign

law

is

regulated

by

the

Advocates

Act

was

not

raised

betbre

the

Bombay

High

Court.

5.

In

distinct

contrast, A.K.Balaji,

the Petitioner betbre

the

Madras

High

court,

contended

that

the

Aclvocates

Act

governs

the

practicc

of

all

laws,

whether

Indian

or

tbreign,

within

the

territory

of lndia.

ln

responsc,

this

Respondent

submined

that

it does

not

have

offices

in

India

and

that

its

lawyers

do

not

practice

lndian

law.

Further,

it

was

contended

that

the

Advocates

Act

does

not

deal

rvith or

regulate

the

practice

of

tbreign

law

and

that,

in

particular,

the

Advocates

Act

does

not

prohibit lbreign

lawycrs

from

providing

services

in lndia

in relation

to

non-Indian

law'

Because

this

issue

was neither

raised

by

any

of

the

parties

nor

adjudicated

by

the

Bombay

High

court

in the

Lawyers'

Collective

case,

this

issue

was

res

integra

and

was

required

to

be

decided

by

the

Madras

High

court.

6.

In

the

impugned

judgment,

the

Madras

High

court

acceptcd

tltc

submission

of

A.K.Balaji

that

the

practice

of law

covers

both

litigation,

and

non-litigation,

practice.

In

reaching

this

conclusion,

the Madras

l{igh

Court

\,1-

(

o&tt

'..,'ir'J

ltuEoS'"u

Ju'$

i

JIJ'''''

*#'#f*.l #ifrqtts

C'crnmbsron

Er;:rrc$

Jarr'

''



)-,

ot\t'/

referred

to,

and

relied

upcn,

rhe

decision

of

the

Bombay

High

court

in

&e

Lawyers,

collective

case.

In

addition,

the

Madras

High

court

accepted

the

contention

of

this

Respondent

and

the

other

foreign

law

firms

ttrat

the

Advocates

Act

does

not

dear

with,

regulate

or

prohibit

the

practice

of

tbreign law. For

these reasons,

it

is

incorrect

to

state

that

the

judgrnents of

the

Madras

High

Courl

and

the

Bombay

High

Court

are

contradictory'

T,Withoutprejudice,thisRespondentisalsoadviscdbycounselto

statethattheMadrasl{ighCourtisnotboundtotbllowthejudgmentofthe

Bombay

High

Court.

REPLY

TO

THE

NARRA

ION

OF

DATES

AND

EVENTS:

8.FortheSamereasons,thenarrationofdatesirndeventsisalso

incorrect

and

misleading.

In

addition,

in

this

connection

this

Respondcnt

is

advised

by

counsel

to

state

that

Section

4l

of

the

Advocates

Act

dcals

with

the

practice

of

Indian

law

by

persons

who

are

not

citizens

of

lndia'

Therefore,

the

Bar

council

of India

is

authorized

to

permit

non-citizens

with

foreign

legal

qualifications

to

practice

lndian

law

if

reciprocity

requirements

are

fu1fi

lled.

g,Asregardstheexerciseofdisciplinaryauthorityoverlbreign

lawyers,

this

Respondent

submits

that

all

its

lawyers are subjcct

to

the

disciplinary

control

of

specihc

supervisory

bodies

in the

relevant

home

jurisdiction.

Moreover,

the

Bar

Council

of

India

is

not

entitled

to

exercise

suchdisciplinarycontrolunlessthelawsoprovides.Atthisjuncture,this

*..#Effi&.s,,"

.-

"?#fl?..*

o""ff

f;rlii

s,'

n

-...,uti,"s,o;,

l)rlt'

ir't'

r'

il

'-

)er

6\a



- aru-

Respondent

is

advised

by

counsel

to snte

that

the

Adv

Act

and

the

Bar

council

of

India

Rules

(the

BCI

Rules)

do

not

emPower

the

exercise

of

disciplinary

control

by

the

Bar

Council

of

lndia

over

foreign

lawyers

practicing

foreign

law

in India.

10.

The

narration

of

tacts

in

relation

to

the

contents

of

the

allidavit

tlled

byA.K.BalajiandthecounterattldavirstrledbyeachoftheRespondentsis

incomplete.

ln

particular,

the

Petitioner

herein

has

not

adverted

to

the

avermentsinthecounteraffidavitof'thisRespondentinresponseto

A.K.Balaji,s

affidavit.

This

Respondent

requests

leave

to

treat

the

contents

of

its

counrer

aflidavit

in

the Madras

High Courl

as

an integral part

of

this

counter

affidavit

so

as

to

avoid

repetition

of the

contents

thereof'

A

copy

ot

the

counter

affidavit

filecl

before

the

lvladras

High

Court

is annexed

hersto

as

"Atrnexure

Rl".

I l.

In

addition,

this

Respondent

is

advised

to

submit

that

none

of

the

provisions

of

the

Advocates

Act

or

the

BCI

Rules

refer

to,

or

deal

with,

the

practice

of

tbreign

law

or

international

law

within

the

territory

of lndia'

On

a literal

interpretation,

the

Advocates

Act

cannot

be

interpreted

as

a

statute

that

deals

with the

practice

of

foreign

law

or international

law

in

lndia'

Furthermore,

it

is

submitted

that

this

Respondent

is

not

liable

to

be

restrained

from

practicing foreign

law

or

international

law within

the

territory

of

India.

Any

such

restriction

would

be

without

statutory

mandate

'

ocates

.rotiN

G

O.STLING

lll

notarv-nlilc-stu

of

xow

vorr

*^?#j'+*:',ill.frE's

Corunusrot

ErPrral

Jatl-

u'

zu

t;

)$c

oftrt



i:,::'

11'.'

.,,|.

12.

Moreover,

to

attempt

to

regulate

under

thc

Advocatcs

Act

thc

provision

of

aclvice

on

matters

of

tbreign

law

by

fbreign

lawyers

while

in

India

would

be

unreasonable

for

a

number

of

reasons

including,

inter

alia'

thc

[ollowing:

a.

In

the

event

that

there

are

cases

initiated

against

or

by

lndian

companies,

Government

agencies,

Public

Sector

Undertaliings

or

individuals

before

courts

in the

United

States

of

Arnerica

(USd US)

or

US

regulatory

authorities,

it

would

become

necessary

to

engage

US attorneys

and

seek

the

advice

of

such

attorneys.

At

such

instances,

it

may

become

necessary

for

such

attomeys

to t)y in

and

fly

out

of

lndia

to

meet

clicnts,

discuss

the

case,

peruse

documents

and

clarity-

their

doubts

if any

for

ablc

representation.

Such

visits

may

also

be

necessary

when

the

attorney

concerned

needs

to

elicit

intbrmation

concerning

the

case

from

more

than

one

of the

employees

of

a

client

and

peruse

all

documents

penaining

to

the

case

so

as

to

identity

relevant

documents.

In

the

event

such

attorneys

are

not

permitted into

India

in order

to

ably

rcpresent

their

clients

on matters

of

US

law,

whether

before

US

coufls,

US

adminisUative

aBencies

or

otherwise,

their

Indian

clients

and/or

their

employecs

would

have

to

schedule

meetings

out

of

lndia

and

ship

or carry

all

documents

pertaining

to

the

case,

whether

relevant

or

irrelevant.

This

would

substantially

increa;e

the

costs

of all

those

availing

themse

lves

of the

services

of

tbreign

lawycrs

-- whether

the

Indian

Government,

public sector

undertakings,

othcr

lndian

companies

or

individuals.

1i,

i.a.):,),

;,

i;

**ffil$ffix'*

tffis

&A

(

dut



))

b.

According

to

Census

data,

lndia

exported

$36

billion

in

goo<is

to

the

US

itr

201

I

(https ://www.census.

gov/ lbre

i

gn

-

trade/statistics/product/enduse/imports/c5330'html).Thema}iersofthose

products

need

to

understand

U'S'

law

on

labeling

and

regulation

of

the

products,aswellasobtainadviceonthelawgoverningcontractswithU.S.

buyers

and

distributors.

Similariy,

Indian

makers

of

export

goods

need

to

understand

the

laws

of

thc

many

countries

other

than

the

United

Statcs

into

which

lndian

goods

are

sold.

Such

an

entity,

e'g',

an

lndian

pharmaccutical

finn,

might

wish

to

have

lawyers

from

numerous

countries

travel

to

lndia

to

discuss

regulatory

and

labeling

issues

that

bear

on

the

products

they

exporl.

It

would

be

inefficient

to

force

the

management

of

the

company

to

visit

lawyers

in

each

country

in

which

the

Indirur

source

products

are

sold'

c.

Many

international

commercial

contracts

contain

an

arbitration

clause

and

a

governing

law

clause.

It

is both

legally

permissiblc

and

plausible

that

in

a

contract

befween

an

lndian

company

and

a

lbreign

company,

the

governing

law

is

fbreign

law

whereas

the

seat

of

arbiuation

is

India

(an

lndian

client

may

negotiate

such

a clause

in

order

to reduce

costs)'

ln

such

a

situation,

it

will

be

necessary

to

engage

the

services

of

lawyers

qualitied

in the

governing

law.

However,

such

services

are

required

to

bc

rendered

in

India.

In

all

likelihood,

the

services

of

foreign

lawyers

(non-

citizens)

who

are

not

enrolled

as

advocates

under

the

Advocates

Act

will

bc

required.

lf the

interpretation

canvassed

by

the

Petitioner

herein

is

to

bc

accepted,

it

would

be

illegal

tbr

clients

to

engage

the

services

of

ftrreign

lawyers

for

such

arbitration

proceedings

held

in

India,

which

would

tbrce

the

clients

to choose

a

location

outside

India

as

the

seat

of arbitration'

As

a

JollN

c'

osTuxc

ltr

tr"t

V

rulq

St.t"

o,Jrt*

Vo,r

Oualfrd

rn

Orianr

County

ffiiI

P"c

@q:



f"1..

?{1

result, the burden

and

costs

'on

Indian

clients

of

participating

in such

arbitration

proceedings

would

increase

signiticantly.

Moreover,

such

a

position

would be

contrary

to the

policy

of

the

Indian Coverntncnt

in

actively

promoting

India

as

a

destination

for

international

commercial

arbitration. Indeed,

it

would

be contrary

to

the legislative

mandate

of

thc

Arbitration and Conciliation

Act, 1996, and

the interpretation

thereof

by

this

Hon'ble Court and the

High Courts.

d. Foreign

lawyers

/

law

lirms

have

been

engagcd by

public

sector

undertakings

to

provide

advice

in

relation to disinvestments

and

public

issue

of

shares.

By way

of

illustration,

reference

may

be

made to

the

disinvestrnent

process

initiated

by

the Department

of

Disinvestment,

Ministry of

Finance, Government

of India. l'he

Department

ol'

Disinvestment

in

its

'Hand

Book

on

Disinvestment

tfuough

Public

Ofterings', mandated the appointment of inrernational legal advisors in

respect

of

the

scope

of

work

set

out

in

Annexure

II

thereto.

Likewise,

the

prospectuses

issued

by NTPC Ltd. and Coal lndia

Ltd., in

connection

with

their tbllow-on

public

issue

and

initial

public

issue respectively,

contain

the

names of their international

legal counsel.

In

connection

with

such

engagements, lbreign

lawyers have

been invited

by the

Government

or

public

sector

undertakings,

as

the

case

may be, to attend meetings

in India

to

provide

advice on foreign

or international law. No

reiaxation has bcen

granted

by the Petitioner

herein in this regard by exercising

powers

undcr

Section 47(2) of

the Advocates Act.

JOHN C. OSTUI'aO

UI

l'dri-pla.r.-

srai

dixr

vqrl

,{o.olo8sfigEE

,

qlllfldmQo.rBCounty

Cortificat

Fhd

in

lJer

Yqt

Qiunrv

Cofirrlrrpn

Errplrrr

Jarr.

Znl(

Mcffit



Rules

which

prohibits

the

t1y-in

fly-out

this

question

of

law

has

been

prepared

of

the

impugned

judgment'

il

,/

practice

of

lbreign

law'

'l-hcrctbre'

on

the

basis

of

a misundcrstanding

v)

ln

reply

to

paragraph

2(E):

the

statement

that

every

stratsglc

investment

coming

to

India,

as

an

investment

decision,

should

be

vicwed

in

a

holistic

manner

is

contained

in

paragraph

5g

of

the

impugned

judgment

rvhich

refers

to

the

observations

of

this

Hon'ble

court

in

vodalbne

lnternarional

B.v.

vs.

Union

of

lndia,

(20'12)

6

SCC

613.

A

question

of

law

does

not

arise

tbr

consideration

on

the

basis

of this

observation.

vi)

In

reply

to

paragraph

2

F:

this

question

should

be

considered

in

the

context

of

the

fact

that

intemational

commercial

arbitrations

often

involve

fbreign

law.

REPLY

TO

TI]E

GROLINDS:

15.

on

advice

fiom

counsel,

this

Respondent

sets

out

below

its

response

to

the

grounds ofaPPeal:

i)InreplytoParagraph5(I)ofthePetition:asstatedearlier,thereisno

contradiction

in

the

impugned

judgment

of

the

Madras

High

court

wherein

the

judgment

of

the Bombay

High court

was

referred

to

and

relicd

upon

with regard

to

the

practice

of

lndian

law

to

conclude

that

lbreign

lawyers

cannot

practice

Indian

law

in court

or

outside

court

without

complying

with

the

requirements

of

the

Advocates

Act

and

the

BCI

Rules'

On

thc

other

r11

t:,;:

|

'l

(

:'i

,*doil8

3,i1"'Sf#'*

sffiffi#lffiff*8

$r{"

r

Oil',



--

.

hand, in relation to the

practice

of

foreign law, the

Madras High Court held

that there is no

bar either

in the

Advocates

Act

or

the BCI

Rules

which

prohibits

the

fly-in fly-out

practice

of

foreign

law. Therefore, this

ground

of

challenge

of

the

impugned

judgment

is liable to be rejected.

ii)

In

reply to

paragraph

5(ll) of

the

Petition: tire Madras Higlr

Court

has

refened

to and relied upon

the

judgment

of the

Division Bench of the

Hon'ble

Bombay l{igh

Court in

the. Lawyers'

Collective

case.

l'he

impugned

judgment

also takes into consideration

the

plcadings

and oral

submissions

on

this issue and records,

in

paragraph

58

of the

irnpugned

judgment,

that "the tbreign law firms, who

are the

private

respondents in

this

writ

petition,

have accepted

the legal

position

ttlat

the

term

practicc

would include

both Iitigation as well as non-litigation

work, which

is bettcr

known

as

chamber

practice.

Therelbre, rendering

advice

to

a client

would

also be

encompassed

in the term

practice."

In

addition, the

impugned

judgment

records, in

paragraph

60,

that

"the

private

respondents herein,

namely

the foreign

law

firms, have

accepted

that there is

express

prohibition

tbr

a

lbreign lawyer

or a foreign law

hrm

to

practice

Indian

law."

Besides,

the Lawyers'

Collective

judgrnent

does not

deal

with or

record findings

on

the issue

arising in

the

present

Petition:

whether

tbreign

lawyers

can render legal advice,

in

India,

on foreign

law

on a

fly

in

-

tly

out

basis.

Funher,

and without

prejudice, the judgrnent

in

Lawyers'

Collective

was

not binding

on

the Madras

High Court.

Therefbre,

this

ground

ofappeal

is

untenable.

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vi)

In

reply

to

paragraph

s(VlI)

of

the

Petition:

the

provision

of

reciprocity

under

the

Advocates

Act

pertains

to

the

practice

of the

lnditun

law

and

not

with

respect

to

the

practice

of

foreign

law

by

a

tbreign

lawyer

onaflyin_flyoutbasis.TheHon,bleHighCourtallerconsideringanrl

appreciating

the

relevant provisions

of

the

Advocates

Act'

especially

Sections2(a),17(l),24(l),and47(l)'rightlyheldthat"ifalawyerfrom

a

foreign

law

firm

visits

India

to

advise

his

clients

on

matters

relating

to

the

law

which

is

applicable

to

their

country'

for

which

PurPose

he

flies

in

and

fliesoutoflndia,therecouldnotbeabarforsuchservicesrenderedby

such

foreign

law

firm/

tbreign

lawyer"'

I6.

In

view

of

the

tbregoing,

the

order

sought

to

be

impugned,

includingtheoperativeportion'is,inanyevent'justandfair'ltiswell

settled

that

the

Hon'ble

Supreme

Court

will

not

interfere

with

a

judgment

of

a

High

court

if

it

is

just

and

fair.

Therefore,

the

impugned

judgrnent of

the

Hon'ble

Madras

High

Court

calls

for

no

interf'erence'

REPLY

TO

THE

GROLNDS

FOR

INTERIM

RELIEF:

|T.Inreplytoparagraphs6(I)and(lI)ofthePetition,thisRespondent

reiterates

that

it

does

not

practice

lndian

law

and

does

not

have

oftices

in

India

as

recorded

by

the

High

court

in

the

impugned

judgrnent'

Theretbre,

the

Petitioner

has

not

made

out

a prima

tacie

case

for

interim orders'

There

has

been

no

starutory

or

judicial prohibition

of

the

Practice

of

foreign

law'

inlndia,tilldate,includingduringthependencyofthePetitionbefbrethc

Madras

High

Court.

JoHN

a

osTut{G

lu

)totrv

hbac.

Strto

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lrcr

Yon

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\rn\

18.Aninterimstayoftheimpugnedjudgmentislikelytobe

misinterpreted

by

the

Petitioner

as

an

order

restraining

the

practice

of

lbreign

law

in

India.

Any

such

prohibition

restraining

this

Respondent

from

rendering

legal advice on foreign law

to

its clients

would

cause

irreparqble

hardship

to

this

Respondent

and

its

clients,

both

Indian

and

fbreign'

As

already

stated,

it

would

increase

transaction

costs

substantially

for

Indian

clients

who

will be

constrained

to

travel

outside

lndia

to

obtain

advice

on

non-lndian

law

and,

in

any

event,

is

likely

to

impair

materially

the

provision

of

advice

to,

and

representation

ol

lndia

based

clientS

on

mattcrs

of U.S. law.

19.

This

Respondent

states,

on

information

and

beliet,

that

the

Government

of

India,

various

State

Covernments

utd

other

state

authorities

also

rely

upon

the

services

of

foreign

law

firms

and

lawycrs

tbr

legal

advice

in relation

to

larvs

other than

lndian law. This

includes

advice

in

the

area

of

project finance,

foreign

investments,

accessing

international

markets,

in

international

dispute

resolution,

intemational

trade

etc'

The

interim

ordsrs'

if

granted,

would

prejudicially

atfect

these

activities

and

thcreby

compromise

India's

strategic

interests

and

be

against

public

interest

in

general.

20.

Hence,

tbr all

of

the

above

reasons,

the

balance

of

convenience

ls

ln

favour

of

this

Respondent,

and

it

is

prayed that

this

Hon'ble

Court

may

be

pleased to

reject

the

interim

relief

sought

by the

Petitioner'

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JOHN

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21.

I

say

that

no

new

facts

or

grounds

which

have

not

been

plcaded

before

the

courts

below

have

been

pleaded

in

the

present

counter

Affidavit.

PRAYER

It

is therefore

prayed

that

this

Hon'ble

Court

may

be

pleased

to

dismiss

the

special

leave

petition

filed

by

the

Petitioner

herein

and

to

pass

such

fuither

orders

as

deemed

fit

in

the

interest

ofjustice'

DEPONENT

VEzuFICATION:

I,

the

deponent

above

named

do hereby

veriff

that

the

contents

of the

above

aftidavit

are

true

to

my

knowledge;

the

submissions

made

are

based

on

advice

received

and

believed

to

be conect;

no

part of

it is false

and

nothing

material has

been

concealed

theretiom'

Verified

by

me at

New

York,

New

York

on this

l5th

day

of February,20l3.

3n

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DEPONEN'I-

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