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tN
THE
'uPREME
couRT
oF
INDIA
3
oRDER
XVI
RULE
4(1XA)
CIVI
L
APPELLATE
J
U
RlSDICTIOhI
SPECI.AL
LE,AVE
PETITICN
(under
Article
136
of
the Constiiution of
lndia)
rwlrH
PRAYER
FOR
INTERIM
RELiEFI
LN
THE
MATTEF
OF:
spEclAL
LEAVE
PETITIQ-II
{cJVlL\
NO.
Ul10-54
Cr
?s1?
(Arising
out
of the
impugned
judgment
and
final
order
dated
21.O2.2Ol2passedbytheHon'bieHighCourtof;udicatureat
Madras
in
WP
No.
561
4 2012)
BETWEEN
The
Bar
Council
of
lndia,
21,
Rouse
Avenue,
lnstitutional
Area,
New
Dethi
-
1
10
002'
ffiryN
Appe,anU
Respondent
No.
7
l'r.r,yl1;t,}'=
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J;{n'itav
)
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O.*.
Balaji
N'
-,,f''
{fr
rr;ffi.1
7t107,
Mel
Batcha
Pet,
'.:'
Harur,
Tamil
Nadu
636
903
ResPondent
No'1/
Petitioner
'
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40
others.
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'I
couNTER
AFFIDAVIT
FILED
oN
BEHALF
o ')
RESPONDENT
NO.22
l,
Christopher
John
Humphrey
Parsons'
son
of
John
Douglas
Parsons,
aged
about
50
years
having
an
office
at
HerbertSmithFreehillsLLP,ExchangeHouse'Primrose
Street,
London
.EC2A
zEG,
now
having
come
down
to
Jodhpur,
Rajasthan,
do
hereby
solemnly
affirm
and
sincerelY
state
as
follows:
I
am
a
member
and
partner
in
the
22nd
Respondent
Firm
(hereinafter
"Answering
Respondent")'
I
am
authorized io
filethisaffidavitonbehalfoftheAnsweringRespondent.l
amwellacquaintedwiththefactsandcircumstancesof
the
case.l
crave
leave
to
refer
to
my
counter
affidavit
filed
beforetheHighCourtatMadrasdatedls.0s.20l0aspart
and
parcel of
this
affidavit'
At
the
outset,
I
state
that
the
above
special
Leave
petition
fited
against
the
impugned
judgment and
order
dated
21.02.2012
passed
by
the
Hon'ble
High
Court
of
Judicature
at
Madras ("the High
Court
at
Madras")
in
WP
No'561
4
of
2010
is
misconceived,
not
maintainable
in
law
or
on
the
facts
and
should
be
dismissed
with
exemplary
costs.
I
submit
that
none
of
the
questions
of
law
raised
by
the
Appellant
arise
out
of
the
impugned
judgment
and
order
or are of
such nature that
warrant
any
interference
1.
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by
this
Hon'ble
Court
in
judgment
and
order.
an
appeal
against
the
imPugned
I deny
each
and
every
allegation
mentioned
in
the
Special
Leave
Petition
so
far
as
they
relate
to
the
Answering
Respondent
save those
that are
expressly
admitted
herein.
I submit
that
the
Answering
Respondent
is
a
limited
liability
partnership
registered
in
England
and
wales
and
is
regulated
by
the
solicitors
Regulation
Authority.
lts
registered
office
is
atExchange
House,
Primrose
street,
London EC2A
zEG. Herbert
smith
LLP
WaSregisteredintheyear2005.onloctober2012
Herbert
smith
LLP
merged
with
Freehills,
the
3othRespondent
Firm.
On
the
same
day
Herbert
Smith
LLP's
registered
narne
was
changed
to
Herbert
Smith
Freehiils
LLP,The
merged
firm, its
subsidiaries
and
the
36thRespondent
has
an
international
legal
practice
with
over2,sO0lawyersinofficesspanningAsia'Australia'
Europe,
the
Middle
East
and
the
us.
submit
that
the
AnsweringRespondenthasgroupofficesworldwidebut
not
in
lndia.
lt
does
not
have
an
office
in
lndia nor
a
liaison
office
and
neither
does
it
give
advice
on
lndian
law
to
its
clients.
The
Answering
Respondent
does
not
seek
tooperateanofficeinlndiabyusinghotelroomsor
private
premises
either.
Therefore,
in
the
present
situation,
the
Answering
Respondent
being
dragged
to
J.
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the
Apex
Court
to
answer
on
matt""
n"u6'
raised
before
the
High
court
at
Madras
is
highly
misconceived
and
prejudiciat
to
the
interests
of
the
Answering
Respondent'
I
submit
that
the
Answering
Respondent
does
not
have
an
interestinanylndianlawfirm,whetherbypartnership,
shareholding
or
affiliation'
lt
does
not
have
alliance-type
relationship
with
any
lndian
law
firm'
The
Answering
Respondent
does
not
carry
on
the
practice
of
law
in
lndia
in
contravention
of
lndian
regulations'
The
Answering
Respondent
instructs
and
works
with
a
number
of
lndian
lawfirmstoprovideeffectiveassistancetoclients'The
Answering
Respondent
does
not
represent
parties
in
the
lndian
courts,
nor
does
it
advise
on
lndian
law'
The
Answering
Respondent
acts
on
matters
for
clients
whose
business
spans
across
borders
and
jurisdictions
and
which
depends
on
lawyers
who
understand
the
nature
of
their
business'
With
regard
to
business
in
lndia'
work
done
by
the
Answering
Respondent
is
either
in
connectionwithinvestmentoutsidelndiabylndianbased
companiesorbusinessorganizations'orinconnection
with
investment
into
lndia
by
companies
and
other
business
organizations
babed
outside
lndia
or
lndian
based
companies
on
matters
of
law
other
than
lndian
law'
This
includes
representing
clients
who
wish
to
buy
interests
in
business
organizations
and/or companies
or
4.
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setting
up
joint
ventures
or
lending
money
to
lndian
companies
where
the
governing
law
of
the
transaction
is
English
law
or
the
law
of
one
of
the
other
jurisdictions
in
which
we
practice
law
(by
way
of
example
France'
Spain'
Hong Kong
and
Singapore)'
ln
short'
the
Answering
Respondent
acts
on
international
transactions
where
it
gives
advice,
from
an
international
perspective'
to
clients
on
English
law
or
one
of
thg
other
laws
mentioned
above.Staff
from
the
Answering
Respondent's
various
offices may
visit
lndia
to
promote
the
firm
and
to
visit
clients
and
business
contacts'
This
may
inctude
giving
talks
and
attending
conferences
held
in
lndia'
I
submit
that
these
instances
can
in
no
way
be
construed
as
legal
practiceirrlrrdia.lrrallmattersoftlrekindi.eferredto
above
which involve lndian law'
we
work
alongside
lndian
law
firms
who
provide
lndian
law
advice;
in
the
majority
of
:'a-t
rr:'r'*
matters
not
involving
lndian
law'
we
also
work
alongside
.r,
,'il''):
lndian
law
firms'
Therefore
the
Answering
Respondent
ts
lui
-L
'r
the
activities
that
are
described
,,
,'".,i
futly
entitled
to
engage
ll
above.
I submit
that none of the Answering Respondent's
activities
amount
to
the
practice
of
law
in
lndia
and
therefore
cannot
be
subject
to
the
regulatory
control
of
the
lndian
authorities'
ThesubmissionsoftheAppel|antbeforetheHighCourtat
Madras
are
recorded
in
para
26
of
the
impugned
J
5.
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judgment.l
further
submit
that
none
of
the
questions
of
law
raised
before
this
Hon'ble
Court
were
canvassed
by
the
Appellant
before
theHigh
Court
at
Madras'
I
submit
that
the
contentions
of
the
Appellant
before
the
High
CourtatMadrasasfoundfromitscounter.affidavitinWP
5614
of
2010
can
be
summarized
as:
i.
The
issue
in
the
Writ
Petition
has
been
settted
by
the
judgment
and
order
of
the
High
Court
of
Judicature
at
Bombay
("the
High
Court
at
Bombay")
inWPNo'l526oflgg5inthematterofLawyers
CollectivevsBarCounciloflndiawhereitwasheld
that
the
Advocates
Act'
1961
not
only
governed
practice
in
titigious
matters
but
also
practice
in
non-
titigious
matters
within
lndia'
Only
persons
who
are
citizens
of
lndia
and
thus
eligible
to
enroll
under
Section
24
of
the
Advocates
Act,
1g61
are
a[owed
to
practice.
The
Bar
council
of
lndia
has
the
power
to
provide
for
a
relaxation
of
such
conditions'
The
practice
of
foreign
law
within
the
territory
of
lndia
will
also
be
suQject
to
regulation
by
the
Bar
Council
of
lndia'
Such
practice
could
even
be
by
practitioners
registered
or
recognized
within
their
domestic
j
urisdictions'
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None
of the
aforesaid
points
have
been
called
into
question
under the
impugned
judgment.
Therefore
the
Appellant
cannot
be
aggrieved
by
any of
the
findings
or
observations
made
by
the
High
Court
at
Madras.
The
impugned
judgment does
not state that
the
practice of
law
does
not
include
practice
on
the
non-litigious
side'
On
the
other
hand,
in
paragraph
63(i)
the
High
Court
at
Madras
affirms
that
foreign
law
firms
br
foreign
lawyers cannot
practice
the
profession
of
law
either on
the
litigious
side
or
the
non-l.itigious
side
unless
they
fulfill
the
requirement of
the
Advocates
Act,1961
or
the
Bar Council
of
lndia
Rules.
Fufther,
the
impugned
judgment
does
not
state
that
non-
citizens
who
othenryise
have
not obtained
relaxation
from
the Bar
Councii
of
lndia are
ailowed
io
practice
law
within
lndia.
The
High
court
at
Madras
specifically
states
in
para44
of
the
impugned
judgment
that it
does
not
differ
from
the
view
taken
in
the
Lawyers
Collective
case.
However
the
High
court
at
Madras
rightly
points
out that
the
primary
question
that
arose
before
the
High
Coud
at
Bombay
was
whether
foreign
law
firms
could
open
liaison
offices
in lndia
and
render
legal
assistance
to
another
person
in
litigious
and
non-litigious
matters.
I
submit
that
at
paragraph 45
the
High
court
at
Madras
in
its
impugned
judgment
rightly
points
out
that
the
question
in
this case
is
A/)
whether
foreign
law
firms
or
foreign
tawyers,
without
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iiiil
,p
establishing
any
liaison
office
in
lndia
and
who
visit
lndia
for the
purpose
of
offering
legal advice
to
their
clients
in
lndia
on
foreign
law,
are
prohibited
under
the
provisions
of
the
Advocates
Act,
1961.
The
High Court
at
Madras
t,
further
rightly points
out
that
this
question
was
neither
raised
nor
answered
in lhe
Lawyers
Collecfive
case'
8.
_
The third
point
raised
by
the
Appellant
that
even
the
,practice'
of
foreign
law
within
lndia
would
be
governed
by
the.
Bar
Council
of
lndia
was
not
argued
by
the
Appellant
before
the
High
court
at Madras.
ln
any
event,
the
term
'practice'
envisages
some
level
of
permanency
of
establishment
or
operations
in
lndia.
Only
the
Petitioner
before
the
High
court
at
Madras
(who
is
the
First
Respondent
in
the
present
appeal)
contended
that
even
a
temporary
visit
to
lndia by
a
foreign
law
firm
or a
foreign
lawyer
for
and
on
behalf
of
his
client
to
advise
a
client
on
i,
matters
of
foreign
law
is
also
not
permitteci
under
the
Advocates
Act,
1961.
Such
contention
was
rejected
and
the
High
court
at
Madrasdecided
that
there
is
no
bar
either
in
the
Act
or
the Rules
preventing foreign
law
firms
or
foreign
lawyers
from
visiting
lndia
for
a
temporary
period
on
a
'fly
in
and
fly
out'
basiq,
for the
purpose
of
giving
legal
advice
to
their
clients
in
lndia
regarding
foreign
law
or
their
own
system
of
law
and/or
on
diverse
nh
international
legal
issues.
The
First
Respondent
has
not
u**;
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l r
:ia,
i
.
,t,,
t::::
e
filed
an
appeal'
The
Appellant
who
was
the
7th
RespondentbeforetheHighCourtatMadrasnever
raised
such
contention
before
the
High
Court'
g,TheHighCourtatMadrastookonrecordthesubmissions
made
by
the
Respondent
law
firms
in
para
47
'
I
submit
that
such
visits
on
a
temporary
or
transient
basis
do
not
amount
to
practice
of
law
within
lndia.
The
term
.practice,
notonlyconnotespermanencyofestablishmentbutalso
connotes
practice on
a
systematic
and
day
in
day
out
basis
which
is
absent
as
far
as
the
Answering
Respondent
is
concerned'
Atpara
51'
the
High
Court
at
Madras
found
as
fotlows,
"such
activities
cannot
at
atl
be
consideredaspractisinglawintndia.lthasnotbeen
controvertedthatinEngland,foreignlawyersarefreeto
adviceontheirownsystemoflaworonEnglishLawor
any
other
sysfem
of
law
without
any
nationality
requirement
or
need
to be
quatified
in
England'"Fudher'
theHighCourtatMadrasalsoinparaS2reasonedthatin
international
commercial
arbitration
between
lndian
and
foreignpartiesarisingoutofinternationalcontractsthat
may
be
subject
to
foreign
law,
it
would
be
inappropriate
to
state
that
such
foreign
parlies
cannot
be
represented
or
advised
by
their
own
lawyers
merely
because
the
venue
of
such
arbitration
is
in
lndia.
th"
reasons
are
cogently
l
A
lt
explained
in
paragraphs
52
to
57
of
the
impugned
fila .
S'mr'"i
O'6-.loJ.)3
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70140074329_t
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judgment.l
submit
that
the
High
Coutt
5t
tvt.Oras
rightly
found
in
para
57
as
follows,
"Therefore,
to
advocate
a
proposition
that
foreign
lawyers
or
foreign
law
firms
cannot
come
into
tndia
to
advice
their
clienfs
on
foreign
law
would be a
far
fetched
and dangerous proposition
and
in
our
opinion,
would
be
to
take
a
step
backward'
when
tndiaisbecomingapreferredseafforarbitrationin
lnternational
commercial
Arbitratibns."on
the
said
basis,
the
High
Court
at
Madras
in
the
impugned
judgment
acceptedthecontentiononbehalfoftheRespondentlaw
firms
and
also
pointed
out
at
para
60
that
such
an
argument
would
be
counter-productive
to
the
aim
of
the
lndianGovernmenttomakelndiaahubofinternational
arbitration
and
would
also
result
in
a
"manifestly
absurd
situatianwhereinonlylndiancitizenswithlndianlaw
degree
who
are
enrolled
as
an
advocate
under
the
Advocates
Acf
could
practice
foreign
law""'
I
respectfully
submit
that
the
findings
in
paragraph
63(ii)
and
(iii) are
well
founded
in
law
and
the
contention
taken
by
the
Appellant
is
not
only
inconsistent
with
its
own
earlier
position
but
is
also
unsuppcrted
by
the
provisions
of
the
Advocates
Act,
1961
or
the
Bar
Council
of
lndia
Rules.Accordingly,thereisnothingincorrectinanyof
the
findings
in
the
impugned
judgment
which
deserves
*r^r,fuu;ffii-;*n"*'ce
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this
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12.
11.
Without
prejudice
to
the
above
contentio'i
''t"ff"'"
are
no
direct
allegations
against
the
Answering
Respondent
in
the
Special
Leave
Petition'
I
respond
parawise
only
to
the
questions
of
law
raised
before
this
Hon'ble
High Court'
With
respect
to
paragraph2(A)
of
the
Special
Leave
Petition,
I
submit
that
the
Appellant's
question
is
very
different
from
the
finding
made
by
the
itigh
Court
at
Madras
in
paragraph
63(i)
of
the
impugned
judgment'
Paragraph
63(i)
states
that
foreign
law
firms
or
foreign
lawyers
cannot
practice
the
profession
of
lawin
lndia
eitheronthetitigationornon-litigationside'unlessthey
fulfil
the
requirements
of
the
Advocates
Act'
1961
and
the
Bar
Council
of
lndia
Rules'However'
aopearing
before
an
Arbitrat
Tribunal
in
respect
of
a
dispute
arising
under
foreignlawshouldnotbeconsideredas,practicing,the
profession
of
law
in
lndia'
Therefore'
the
High
Court
at
Madrasclarifiedwhatconstitutespracticingtheprofession
of
law.
lt
is
in
this
regard
that
the
High
Court
at
Madras'
in
its
finding
in
paragraph
63(iii)
stated:
"foreign
lawyers
cannot
be
debarred
to
come
to
lndia
and
conduct
arbitration
proceedings
in
respect
of
disputes
arising
out
of
a
contract
retating
to
international
commercial
A
arbitration"
'
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t{5>
7
13.
With
respect
to
paragraph
2(B)
of the
Special
Leave
Petition,
the issue
in
dispute
is whether
it would breach
the
provisions
of
the
Advocates
Act,
1961
if advice
is
given
on a
matter
of
foreign law
on
a fly
in
and
fly out
basis
by
a
foreign lawyer
or
foreign
firm.
However,
the
High
Court at
Madras
found
in
paragraph
63(ii)
that
providing
legal
advice
to
clients
in
lndia
regarding
foreign
law'on
a fly in
and
fly out
basis
would not
breach
any of
the
provisions
of
the
Advocates
Act,
1961. The
High
Court
at
Madras
held that
giving
such
advice
on
temporary
visits on
a
"fly
in
and
fly
out
basis"
does
not
constitute
"practicing"
the
profession
of
law
which is
the
prohibition
imposed
by
section
29
of the
Advocates
Act,
1961.
14. With
respect
to
paragraph
2(C)
of
the Special
Leave
Petition,
the
question raised
is whether
a
person
not
enrolled
as an
advocate
under
the
Advocates
Act,
'
196'1can
be
allowed
to
"carry
on
legal
profession".
I
Paragraph
63(i)
confirms
that
a
person
not
enrolled
as
an
"Advocate"
in
lndia
cannot
practice
the
profession of law
in
lndia
whether on
the
litigation
or
non-litigation
side.
Thereforq,
I am
advised
that
this cannot
form
a
ground
for
appeal
before
this
Hon'ble Court.
1S.
paragraph
2(D) of
the Special
Leavb
Petition,
involves the
word
'practice'.
nl interoretation
of
the
xo",rffit5l,ilo,o,,,-,
't1
8/9/2019 Herbert Smith
13/15
'Practice'contemplates
a
continuous
,
systematic
activity
as
opposed
to
a
fleeting
visit
or
a
transitory
presence
for
giving
advice
on
matters
of
foreign
law
or
conduct
of
arbitration
governed
by
foreign
law'
I
submit
'
,n",
the
High
court
at
Madras
was iustified in finding
that
there
is
no
bar
either
in
the
Act
or
the
Rules
for
foreign
law
firms
or
foreign
lawyersto
visit
lndia
for
a
temporary
periodonaflyinandflyout'basis'forthepurposeof
giving
tega'l
advice
to
clients
in
lndia
regarding
foreign
law or
their own
system
of
law and
on
diverse
international
issues'
There
is
nothing
inconsistent
between
the
findings
made
by
the
High
Court
at
Madras
in
paragraph
63(i)
and
63(ii)
of
the
impugned
judgment'
16.
With
respect
to
paragraph
2(E)
of
the
Special
Leave
Petition,
t
submit
that
there
is
nothing
erroneous
about
the
findings
of
the
High
Court
at
Madras
that
law
must
be
interpreted
keeping
in
mind
the
international
nature
of
business
that
is
conducted'
17.
With
respect
to
paragraph
2F)
of
the
Special
leave
Petition,lsubmitthatthefindingmadeinparaEraph63(iii)
with
the
High
of
the
impugned
judgment
is
consistent
'
CourtatMadras,interpretationthatthepracticeoflawis
differentfromtheconductofspecificarbitralproceedings,
relating
to
lnternationat Commerciat
Arbitration'
^^Therefore,thecontentionthatevenatemporaryor
4lh,tir"
ii
u
13
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)W
and
.-:,
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,::',.
.
8/9/2019 Herbert Smith
14/15
,a1il
transient
presence
of
foreign
lawyers
or
foreign
law
firms
in
lndia
would
amount
to
'practicing'
law
in
lndia
is
unfounded
and
without
basis.
consequently
there
is
no
error
which
warrants
the
interference
by
this
Hon',ble
court
on
any
of
the findings made by
the
High
court
at
Madras
in
the
imPugned
judgment'
18.
Therefore,
I submit
that
thereis
no
regulatory
jurisdiction
of
the
Appellant
that
could
be
extended
to
foreign
lawyers
who
visit
lndia
temporarily
or
on a
fly
in
fiy
out
basis
to
advise
clients
on
foreign
law
or
to
conduct
lnternational
commercial
Arbitration.
I
believe
that
each
of
these
Respondentlawfirmsaresubjecttoregulatory
supervisionintheirownhomecountry'Nothingcontained
inanyfindingoftheimpugnedjudgmentgivesrisetoa
view
that
the
foreign
law
firms
are
allowed
to
practice
in
lnclia
even
if they
do
not
satisfy
the
eligibility
of
section
24
of the
Advocates
Act,
1961
'
1g.
I submit
that
none
of
the
grounds
raised
in
paragraph
5
of
thisappealarevalidandthereisnoerrorinanyofthe
findingsoftheHighCourtatMadrasinparagraph63or
elsewhere
in
the
impugned
judgment.
I
further
submit
that
thestandtakenbytheAppellantresultsinanabsurd
situation
where
lndian
lawyers
would
be
required
to
give
advice
on
matters of
foreign
law
ind
conduct
lnternational
.,ilfr,,,,ir.,.
commerciar
Arbitrations
within
rndia
even
though
they
)\,ry'\4
,rl'r'd
o[$
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8/9/2019 Herbert Smith
15/15
r:;
"\
24.
21.
22.
would
not
bequalifiecl
to
practice foreign
law.
such
an
interpretation
may
even
breach
the
regulations
of
other
foreign
jurisdictions
as
it
nnay
amount
to
practice
of
foreign
law
by
lndian
lawyers
without
meeting
the
eligibility
criteria for the same.
,
As
there
are
no
specific
allegations
against
the
Answering
Respondent
in
the
special
Leave
Petition,
I seek
the
riberty
to
file an
additional
affidavii
at
a
later
stage,
if the
Answeiing
Respondent
feels
the
need
to
respond
to
any
allegations
that
are
made.
The
Appellant
has
not
made
out
any
case
for
the
grant or
continuation
of
any
of
the
interim
relief.
The
allegations
contained
in
paragraph
6
of
the
appeal
are
denied
as
unjustified and
without
basis.
ln
view
of
the
above,
it
is
therefore
humbly
prayed
that
this
Hon',ble
court
may
be
pleased
to dismiss
the
special
Leave
Petition
with
exemplary
costs
and
thus
render
justice.
i
J+r-*u
Solemnly
affirmed
at
Jodhpur,
lndia
I
t'^..
*-Yrui#p
u^
.- b?-
,]''{
tn''
the
B
dav
of
February
2013
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and
signed
his
name
in
my
presence
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