Tag: #LegalView

Delhi High Court Orders Immediate GST Refund: Upholding Taxpayer Rights and Rule of Law

Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 07.09.2026

Delhi High Court Orders Immediate GST Refund: Upholding Taxpayer Rights and Rule of Law

This Short Article has been prepared & written by Advocate Madhumita Jha. The views expressed are based on her interpretation of the law. She can be reached at her email id jhamadhumita27@gmail.com .

The Delhi High Court recently delivered a significant judgment in the case of Brij Mohan Mangla vs. Union of India & Ors., addressing the issue of delayed GST refunds and the obligations of tax authorities to comply with appellate orders. This article provides a comprehensive overview of the case, its background, the legal proceedings, and the implications for taxpayers and authorities under the GST regime.

Background of the Case

Brij Mohan Mangla, a manufacturer of liquid printing inks, was registered under the Central Goods and Services Tax Act, 2017 (GST Act). During the period from May 2019 to December 2019, he accumulated an input tax credit (ITC) of ₹74,02,337 due to an inverted duty structure, which occurs when the tax rate on inputs is higher than the tax rate on outputs. Unable to utilize the ITC fully, Mangla filed six separate refund applications for the relevant period.

Timeline of Refund Applications

Date of Filing	Period	Amount (INR)
09.12.2020	May 2019	8,89,402
23.12.2020	June 2019	7,39,443
07.01.2021	July 2019	10,62,596
07.01.2021	August 2019	11,12,574
22.01.2021	September 2019	9,72,486
16.03.2021	Oct–Dec 2019	26,25,836
Total		74,02,337

Initial Rejection and Appeals

The refund claims were not processed. Instead, the authorities issued show cause notices, citing two main reasons for rejection:

Non-existence at Registered Premises: Physical verification allegedly found the business non-existent at the declared address.
Cancellation of GST Registration: The GSTIN was cancelled with effect from 19.02.2021.

Mangla responded, clarifying that he had shifted his business premises after the relevant period. Despite this, the refund applications were rejected on the grounds that he was not a “registered person” at the time of application, as required under Section 54(3) of the GST Act.

Mangla appealed these decisions. The Appellate Authority ruled in his favor, confirming that he was indeed a registered person during the relevant period and entitled to the refund. The Authority also directed restoration of his GST registration.

Continued Non-Compliance by Authorities

Despite the appellate orders, the authorities did not process the refunds. Instead, they issued deficiency memos and repeated the same objections already settled by the Appellate Authority. The authorities argued that they intended to appeal the appellate orders and thus withheld the refunds.

High Court’s Judgment

The Delhi High Court found the authorities’ conduct unacceptable, emphasizing the following points:

Obligation to Implement Appellate Orders: Authorities cannot ignore or withhold implementation of appellate orders merely because they intend to file an appeal, unless a stay is obtained.
Rule of Law: Allowing authorities to disregard appellate decisions undermines the rule of law.
Direction to Disburse Refunds: The Court directed the authorities to process and disburse the refunds, including applicable interest, without further delay.
Right to Appeal Preserved: The authorities retain the right to challenge the appellate orders, but must comply with them unless and until they are set aside.

Implications and Takeaways

For Taxpayers: This judgment reinforces the rights of taxpayers to timely refunds and the enforceability of appellate decisions.
For Authorities: Tax authorities must comply with appellate orders unless a stay is granted by a higher forum. Delays or non-compliance can be challenged in court.
For the GST Regime: The case highlights the importance of procedural fairness and the need for efficient dispute resolution mechanisms under GST.

Conclusion

The Brij Mohan Mangla case sets a precedent for the prompt implementation of appellate orders in GST matters. It serves as a reminder that administrative authorities are bound by the rule of law and must respect judicial and quasi-judicial decisions, ensuring justice for taxpayers.

Connected Matter

Bombay High Court Orders Refund of Pre-Deposit for Dropped GST Demand Despite Pending Appeal

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Delhi High Court

Disclaimer

Handy Download:

“Handy Order for Download”Download

Write to us at office@aadrikaalaw.com

Tel: +91-11-4999 2707

www.aadrikaalaw.com

September 7, 2026

Arbitration Awards and the Importance of Reasoned Decisions: Necessity for Clarity in Arbitration Decisions
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 07.09.2026

Arbitration Awards and the Importance of Reasoned Decisions: Necessity for Clarity in Arbitration Decisions

This Short Article has been prepared & written by Arbitrator Shobhit Mallik. The views expressed are based on his interpretation of the law. He can be reached at his email id shobhit.Ica23@gmail.com .

The Supreme Court of India’s decision in the case of Dyna Technologies Pvt. Ltd. v. Crompton Greaves Ltd. serves as a significant precedent on the necessity for reasoned arbitral awards and the boundaries of judicial intervention in arbitration. This article explores the background, legal issues, and implications of the judgment, providing valuable insights for businesses, legal professionals, and arbitrators.

Background of the Dispute
- Parties Involved:
  - Appellant: Dyna Technologies Pvt. Ltd.
  - Respondent: Crompton Greaves Ltd. (CGL)
- Contractual Context:
  - Dyna Technologies was contracted by CGL for construction works related to an aquaculture unit for DCM Shriram Aqua Foods Limited.
  - The contract included provisions for compensation in case of idle equipment and manpower due to delays not attributable to the contractor, as well as clauses allowing CGL to terminate the contract under certain conditions without compensation.
- Dispute Origin:
  - CGL instructed Dyna Technologies to stop work prematurely in January 1995.
  - Dyna Technologies claimed compensation for losses due to idle machinery, unproductive use of resources, loss of profit, interest, and costs, totaling over Rs. 53 lakhs after deductions.
Arbitration and Legal Proceedings
1. Arbitral Tribunal:
  - Dyna Technologies’ claims were referred to a three-member Arbitral Tribunal.
  - The Tribunal awarded compensation for losses due to unproductive use of machinery (Claim No. 2), but did not provide detailed reasoning for its decision.
2. High Court Proceedings:
  - The award was challenged under Section 34 of the Arbitration and Conciliation Act, 1996.
  - The Single Judge upheld the award, emphasizing limited grounds for judicial interference.
  - On appeal, the Division Bench set aside the award for Claim No. 2, citing lack of sufficient reasoning and the contract’s exclusion of such compensation.
Supreme Court’s Analysis

Key Legal Issues
- Requirement of Reasoned Awards:
  - Section 31(3) of the Arbitration Act mandates that arbitral awards must state the reasons upon which they are based, unless parties agree otherwise.
  - The Court clarified that reasons must be proper, intelligible, and adequate, though not as elaborate as a court judgment.
- Judicial Intervention under Section 34:
  - The Court reiterated that arbitral awards should not be set aside lightly; intervention is warranted only for perversity or violation of statutory grounds.
  - Courts should distinguish between inadequate and unintelligible reasoning—only the latter justifies setting aside an award.
- Remand to Tribunal:
  - Section 34(4) allows courts to remit awards back to the tribunal to cure defects in reasoning, but the Supreme Court noted that after 25 years of litigation, further remand would not serve justice.
Findings
- The Tribunal’s award was found to be confusing, with mixed factual narration and arguments, lacking clear legal reasoning.
- The Supreme Court held that the award was unintelligible and could not be sustained in its existing form.
- To bring finality to the prolonged dispute, the Court directed CGL to pay Rs. 30 lakhs to Dyna Technologies in full and final settlement of Claim No. 2.
Implications and Lessons

For Arbitrators
1. Clarity and Reasoning:
  - Awards must clearly state the basis for decisions, especially when dealing with complex contractual disputes.
2. Form vs. Substance:
  - While awards need not be as detailed as court judgments, they must be intelligible and adequately reasoned.
For Parties
1. Contractual Clauses:
  - Parties should carefully draft and review compensation and termination clauses to avoid ambiguity and future disputes.
2. Arbitration as a Remedy:
  - Arbitration is intended to be a speedy and final dispute resolution mechanism; unclear awards can undermine this purpose.
For Courts
1. Limited Intervention:
  - Courts should respect the autonomy of arbitral tribunals and intervene only on statutory grounds.
2. Remand vs. Finality:
  - Remanding awards for clarification is appropriate, but not when it would prolong already lengthy litigation.
Conclusion

The Dyna Technologies v. Crompton Greaves case underscores the critical importance of reasoned arbitral awards and the need for clarity in both contractual drafting and arbitral decision-making. It also highlights the judiciary’s role in balancing the finality of arbitration with the need for fairness and transparency. This judgment serves as a cautionary tale for all stakeholders in the arbitration process, emphasizing that clarity and reasoning are essential to uphold the integrity and efficiency of alternative dispute resolution.

Connected Matter

Bombay High Court’s Analysis of Arbitral Award Challenge under Section 34 of the Arbitration and Conciliation Act, 1996 in a Cotton Supply Dispute

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Supreme Court

Disclaimer

Handy Download:

“Handy Order for Download”Download

Write to us at office@aadrikaalaw.com

Tel: +91-11-4999 2707

www.aadrikaalaw.com
Share this:
X
Facebook
Like this:
Like Loading…
September 7, 2026
High Court of Karnataka Affirms Conviction Under Section 138 of the Negotiable Instruments Act
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 07.09.2026

High Court of Karnataka Affirms Conviction Under Section 138 of the Negotiable Instruments Act

This Short Article has been prepared & written by Advocate G Sridharamurthy. The views expressed are based on his interpretation of the law. He can be reached at his email id sriadv3@gmail.com .

This article provides a comprehensive overview of a significant judgment delivered by the High Court of Karnataka in Criminal Revision Petition No. 1313 of 2017, involving a dispute under Section 138 of the Negotiable Instruments Act, 1881 (N.I. Act). The case highlights key legal principles, procedural aspects, and the importance of evidence in cheque dishonor cases.

Background of the Case
1. Parties Involved:
  - Petitioner: V K Lakshmidevi (mother-in-law of the complainant)
  - Respondent: Smt. Jayalakshmi (widow of the petitioner’s son)
2. Nature of Dispute:
  - The dispute arose after the death of the complainant’s husband, leading to a partition suit over family property. A compromise was reached, allotting a share to the complainant.
  - The petitioner (mother-in-law) continued to occupy the property beyond the agreed period, leading to further negotiations and financial transactions between the parties.
Sequence of Events
1. Compromise and Continued Occupation:
  - Despite a compromise, the petitioner did not vacate the property allotted to the complainant.
  - The complainant allowed further stay on the petitioner’s request, but the petitioner failed to vacate even after the extended period.
2. Financial Transaction:
  - The petitioner and her son requested the complainant to purchase the property for Rs. 23,00,000.
  - The complainant paid the amount in cash, expecting vacant possession and execution of a sale deed, which did not materialize.
3. Issuance and Dishonor of Cheques:
  - On persistent demand, the petitioner issued a post-dated cheque for Rs. 10,00,000, and her son issued another for Rs. 13,00,000.
  - Both cheques were dishonored due to insufficient funds.
  - Legal notice was served, but the petitioner did not comply, leading to a private complaint under Section 138 of the N.I. Act.
Legal Proceedings and Findings
1. Trial and Appellate Court Decisions:
  - The trial court convicted the petitioner under Section 138 of the N.I. Act, sentencing her to pay a fine of Rs. 10,05,000.
  - The appellate court confirmed the conviction and sentence.
2. Arguments in Revision Petition:
  - The petitioner argued procedural lapses, lack of notice, and insufficient evidence of payment.
  - The respondent countered that ample opportunity was given for cross-examination, which the petitioner did not utilize.
3. High Court’s Analysis:
  - The court emphasized the presumption in favor of the complainant under the N.I. Act when a cheque is dishonored, unless rebutted by effective cross-examination or defense evidence.
  - The petitioner failed to cross-examine the complainant or provide substantive rebuttal evidence.
  - The court found that the notice was duly served, and the petitioner’s conduct did not warrant interference in revision.
Key Legal Takeaways
1. Presumption under Section 138:
  - Once a cheque is dishonored, the law presumes liability unless the accused rebuts it with credible evidence.
2. Importance of Cross-Examination:
  - Failure to cross-examine the complainant or present defense evidence can lead to adverse inference and uphold conviction.
3. Limited Scope of Revision:
  - The High Court reiterated that revision jurisdiction is limited to examining the legality and correctness of lower court orders, not to reappreciate evidence unless there is a gross miscarriage of justice.
Conclusion

The High Court of Karnataka dismissed the revision petition, upholding the conviction and sentence under Section 138 of the N.I. Act. This judgment underscores the importance of procedural diligence, timely defense, and the evidentiary burden in cheque dishonor cases. It serves as a crucial reference for legal practitioners and individuals involved in negotiable instrument disputes.

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Karnataka High Court

Disclaimer

Handy Download:

“Handy Order for Download”Download

Write to us at office@aadrikaalaw.com

Tel: +91-11-4999 2707

www.aadrikaalaw.com
Share this:
X
Facebook
Like this:
Like Loading…
September 7, 2026
Gujarat High Court on RERA Jurisdiction, Completed Projects, and Scope of Adjudicating Officer’s Powers
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 05.09.2026

Gujarat High Court on RERA Jurisdiction, Completed Projects, and Scope of Adjudicating Officer’s Powers

This Short Article has been prepared & written by Advocate Narendra Singh. The views expressed are based on his interpretation of the law. He can be reached at his email id amitnaren@outlook.com .

A recent judgment by the Gujarat High Court in the case of Hiren Sureshbhai Patel vs. State of Gujarat has clarified crucial aspects of the Real Estate (Regulation & Development) Act, 2016 (RERA), particularly regarding the jurisdiction of RERA authorities and the rights of homebuyers and promoters. This article provides a detailed analysis of the case, its background, legal arguments, and the implications for real estate stakeholders.

Background of the Case
- Project: Landmark Harmony, a residential complex of 120 flats developed by Landmark Probuild Pvt. Ltd. in Gandhinagar, Gujarat.
- Parties:
  - Petitioner: Hiren Sureshbhai Patel, Director of Landmark Probuild Pvt. Ltd.
  - Respondent No. 3: Shyamsundar Ghasitasingh Karhana (homebuyer)
- Dispute:
  - An agreement to sell (Banakhat) was entered in 2014 between the company and the respondent and his wife.
  - The respondent failed to pay the full consideration amount.
  - Initially, a consumer complaint was filed and later withdrawn; subsequently, a complaint was filed before the RERA Adjudicating Officer seeking compensation for non-delivery of the flat.
Key Legal Issues Raised
1. Jurisdiction of RERA Authorities:
  - Whether the RERA Adjudicating Officer had the authority to order possession of the flat and compensation, especially when the project had received a completion certificate before RERA came into force.
2. Proper Parties to the Complaint:
  - The complaint before RERA was filed only against the Director, not the company or the co-signatory (wife), raising issues of mis-joinder and non-joinder of necessary parties.
3. Scope of Relief under RERA:
  - Whether the Adjudicating Officer could grant relief beyond compensation, such as ordering possession, under Section 71 of the Act.
Court’s Analysis and Findings

1. Applicability of RERA to Completed Projects
- Completion Certificate Pre-RERA:
  - The project received its completion certificate on 27.09.2016, before RERA’s commencement on 01.05.2017.
  - Section 3(2)(b) of RERA exempts such projects from registration and the Act’s rigors.
  - The Court cited the Bombay High Court’s Neelkamal Realtors and Supreme Court’s New Tech Promoters decisions, confirming that RERA does not apply to projects completed before its enforcement.
2. Jurisdiction and Powers of the Adjudicating Officer
- Limited to Compensation:
  - Section 71 of RERA restricts the Adjudicating Officer’s powers to adjudging compensation for violations under Sections 12, 14, 18, and 19.
  - Reliefs like possession or specific performance must be sought before the Regulatory Authority, not the Adjudicating Officer.
  - The complaint format (Form-B) and rules reinforce this separation of powers.
3. Defective Complaint Due to Mis-joinder/Non-joinder
- Necessary Parties Not Included:
  - The original agreement involved both the respondent and his wife as buyers and the company as seller.
  - The RERA complaint was filed only against the Director, omitting the company and the wife, making the complaint defective.
4. Change in Relief Sought
- Consumer Forum vs. RERA:
  - The respondent initially sought withdrawal and refund before the Consumer Forum, but later sought compensation and possession before RERA.
  - The Court held that the scope of relief cannot be expanded in this manner, especially when the Adjudicating Officer lacks jurisdiction for possession orders.
Final Judgment
- The High Court quashed the RERA Adjudicating Officer’s order, holding it was beyond jurisdiction and based on a defective complaint.
- The petition by the Director was allowed, and the impugned order was set aside.
Key Takeaways for Real Estate Stakeholders
1. RERA’s Applicability:
  - Projects with completion certificates before 01.05.2017 are not subject to RERA’s registration or its dispute resolution mechanisms.
2. Jurisdictional Clarity:
  - The Adjudicating Officer under RERA can only award compensation, not order possession or specific performance.
  - Reliefs like possession must be sought before the Regulatory Authority, following the correct procedure and forms.
3. Proper Party Inclusion:
  - Complaints must include all necessary parties as per the original agreement to avoid dismissal on technical grounds.
4. Consistency in Relief Sought:
  - Applicants cannot change the nature of relief sought across different forums without following due process.
Conclusion

This judgment reinforces the importance of understanding the scope and limitations of RERA, both for homebuyers and developers. It highlights the need for precise legal strategy, correct party inclusion, and adherence to procedural requirements when seeking remedies in real estate disputes. The decision also provides clarity on the non-applicability of RERA to completed projects and the distinct roles of the Adjudicating Officer and Regulatory Authority.

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Gujarat High Court

Disclaimer

Handy Download:

“Handy Order for Download”Download

Write to us at office@aadrikaalaw.com

Tel: +91-11-4999 2707

www.aadrikaalaw.com
Share this:
X
Facebook
Like this:
Like Loading…
September 5, 2026
Bombay High Court on Rejection of Suit for Joint Ownership of Common Amenities
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 05.09.2026

Bombay High Court on Rejection of Suit for Joint Ownership of Common Amenities

This Short Article has been prepared & written by Advocate Madhumita Jha. The views expressed are based on her interpretation of the law. She can be reached at her email id jhamadhumita27@gmail.com .

A recent judgment by the Bombay High Court has brought clarity to the rights of cooperative housing societies regarding common amenities and conveyance of property in large residential layouts. The case, involving Laxmi Charitable Trust and several cooperative societies, revolved around the ownership and use of recreation grounds and internal roads within a multi-plot layout in Andheri, Mumbai.

Background of the Dispute

The plaintiffs, three cooperative housing societies, filed a suit seeking joint ownership and conveyance of common amenities—specifically, recreation grounds (RG) and internal access roads—under the Maharashtra Ownership Flats Act (MOFA) and its Rules. The societies had already secured deemed conveyance of their respective plots (A, B, and C) but claimed further rights over RGs and roads situated on plots D, E, and F, which were owned by educational trusts.

The defendants, including Laxmi Charitable Trust and Mathuradas Vissanji Female Education Trust, challenged the suit, arguing that:
- The trusts acquired ownership of plots D and E before MOFA came into force.
- The trusts were not promoters under MOFA and had no statutory obligation to convey land to the societies.
- The suit was based on non-existent legal provisions and lacked a valid cause of action.
Key Legal Issues
1. Cause of Action: Did the societies have a legal basis to claim joint ownership and conveyance of common amenities on plots not owned by them?
2. Applicability of MOFA: Could MOFA obligations be enforced against trusts that acquired property before the Act’s commencement and were not promoters?
3. Validity of Cited Rules: The plaintiffs relied on sub-rules (2) and (3) of Rule 9 of the MOF Rules, which, as the Court found, do not exist.
4. Interpretation of Layout Conditions: Did the sanctioned layout and municipal conditions mandate joint ownership or only maintenance of RGs?
Court’s Analysis and Findings

1. Ownership and Timing
- The trusts acquired plots D and E in 1962 and 1963, before MOFA became applicable in Mumbai (1964).
- The societies admitted in their pleadings that the trusts were the owners of these plots prior to MOFA.
2. No Statutory Obligation for Conveyance
- The trusts were not promoters under MOFA and thus had no statutory duty to convey land or amenities to the societies.
- The plaintiffs’ reliance on non-existent sub-rules of Rule 9 was unfounded; Rule 9 only prescribes the period for conveyance, not the obligation to convey common amenities in the manner claimed.
3. Misinterpretation of Layout and FSI
- The sanctioned layout required maintenance of RGs but did not mandate joint ownership for the entire layout.
- Each society’s building plans and FSI (Floor Space Index) calculations were plot-specific, not based on the entire layout.
- The plaintiffs’ claims that RGs and FSI were shared across all plots were contradicted by the sanctioned plans and municipal records.
4. Vexatious Litigation and Lack of Cause of Action
- The Court found that the suit was based on false premises and clever drafting, creating an illusion of a cause of action where none existed.
- The suit was deemed vexatious and an abuse of the judicial process, as it sought to claim playgrounds used by schools and colleges for the societies’ benefit.
Final Judgment
- The Bombay High Court set aside the City Civil Court’s order and allowed the revision applications filed by the trusts and Wallace Flour Mills Co. Ltd.
- The plaint in L.C. Suit No. 3712 of 2017 was rejected under Order VII Rule 11 of the Code of Civil Procedure for not disclosing a cause of action.
- The suit was dismissed, and all interim applications were disposed of.
Key Takeaways for Housing Societies and Trusts
1. Statutory Rights Must Be Clearly Established: Societies must base their claims on existing statutory provisions and not on imagined or non-existent rules.
2. Ownership and Timing Matter: Rights under MOFA cannot be enforced against parties who acquired property before the Act’s commencement and are not promoters.
3. Layout Conditions Are Binding: Maintenance obligations in sanctioned layouts do not automatically confer ownership rights over common amenities.
4. Courts Will Dismiss Vexatious Suits: The judiciary will not entertain cleverly drafted suits that lack real substance or are contrary to documentary evidence.
Conclusion

This judgment reinforces the importance of clear legal foundations for property claims and the need for societies to carefully examine statutory provisions and documentary evidence before initiating litigation. It also protects educational trusts and similar entities from unwarranted claims over their properties by neighboring societies.

Listen to this on our #YouTube Channel

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Bombay High Court

Disclaimer

Handy Download:

“Handy Order for Download”Download

Write to us at office@aadrikaalaw.com

Tel: +91-11-4999 2707

www.aadrikaalaw.com
Share this:
X
Facebook
Like this:
Like Loading…
September 5, 2026
Judicial Review of Arbitral Awards and the Public Policy Doctrine
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 05.09.2026

Judicial Review of Arbitral Awards and the Public Policy Doctrine

This Short Article has been prepared & written by Arbitrator Shobhit Mallik. The views expressed are based on his interpretation of the law. He can be reached at his email id shobhit.Ica23@gmail.com .

The Supreme Court of India’s decision in Associate Builders vs. Delhi Development Authority is a pivotal judgment in the field of arbitration law. This case addresses the scope of judicial intervention in arbitral awards, the application of public policy, and the standards for setting aside such awards under the Arbitration and Conciliation Act, 1996.

Background of the Dispute
- Parties Involved: Associate Builders (contractor) and Delhi Development Authority (DDA).
- Project: Construction of 168 Middle Income Group and 56 Lower Income Group houses in Trilok Puri, Delhi.
- Contract Value: Rs. 87,66,678/-
- Stipulated Completion: 9 months; Actual Completion: 34 months (25 months delay).
- Claims: The contractor raised 15 claims due to delays, damages, and additional costs, with the dispute referred to arbitration.
Key Claims in Dispute

The Supreme Court focused on the following claims:
1. Hire Charges for Centering and Shuttering (Claims 9 & 10): Due to delays caused by DDA, the contractor incurred extra hire charges.
2. Damages for Tools, Plants, and Scaffolding (Claim 11): Prolonged contract led to additional expenses.
3. Establishment Expenses (Claim 15): Overhead costs due to extended project duration.
4. Damages for Price Escalation (Claims 12 & 13): Compensation for increased costs of materials and labor during the delay.
Arbitration and Court Proceedings
- Arbitrator’s Award: The arbitrator found the delay entirely attributable to DDA and awarded Rs. 23.39 lakhs out of the total claim of Rs. 37.28 lakhs.
- Single Judge (Delhi High Court): Upheld the arbitrator’s award, dismissing DDA’s objections.
- Division Bench (Delhi High Court): Set aside several claims, reduced the awarded amount, and criticized the arbitrator’s use of standard formulas for calculating damages.
Supreme Court’s Analysis

Grounds for Setting Aside Arbitral Awards

The Court clarified that under Section 34 of the Arbitration and Conciliation Act, an arbitral award can only be set aside on limited grounds:
- Incapacity of a party
- Invalid arbitration agreement
- Lack of proper notice or inability to present the case
- Award beyond the scope of arbitration
- Composition or procedure not as per agreement
- Conflict with public policy of India
Public Policy and Patent Illegality

The Court elaborated on what constitutes “public policy of India,” including:
- Fundamental policy of Indian law
- Interest of India
- Justice or morality
- Patent illegality (must go to the root of the matter)
Judicial Approach to Arbitral Awards
- Courts should not act as appellate bodies over arbitral awards.
- Errors of fact or law by the arbitrator are not grounds for setting aside unless they fall within the specific grounds under Section 34.
- The arbitrator is the final judge of evidence and contract interpretation unless the decision is perverse or shocks the conscience of the court.
Application to the Present Case
- The Supreme Court found that the Division Bench exceeded its jurisdiction by re-evaluating evidence and substituting its own reasoning for that of the arbitrator.
- The arbitrator’s use of standard industry formulas (like Hudson’s formula) for calculating damages was within his domain.
- The Division Bench’s approach of “rough and ready justice” was inappropriate under the Arbitration Act.
- The claims were not overlapping, and the arbitrator had properly considered the evidence and contract terms.
Final Judgment and Impact
- Supreme Court Decision: Restored the arbitrator’s award and the Single Judge’s judgment, setting aside the Division Bench’s order.
- Significance:
  - Reinforces the limited scope of judicial intervention in arbitral awards.
  - Clarifies the interpretation of “public policy” and “patent illegality.”
  - Affirms the arbitrator’s authority in assessing evidence and applying industry standards.
Conclusion

The Associate Builders vs. DDA judgment is a cornerstone for arbitration law in India. It strengthens the autonomy of arbitral tribunals, limits court interference, and provides clear guidance on the grounds for setting aside arbitral awards. This decision is essential reading for legal professionals, contractors, and parties involved in construction and commercial arbitration.

Connected Matter

Bombay High Court’s Analysis of Arbitral Award Challenge under Section 34 of the Arbitration and Conciliation Act, 1996 in a Cotton Supply Dispute

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Supreme Court

Disclaimer

Handy Download:

“Handy Order for Download”Download

Write to us at office@aadrikaalaw.com

Tel: +91-11-4999 2707

www.aadrikaalaw.com
Share this:
X
Facebook
Like this:
Like Loading…
September 5, 2026
Karnataka High Court Quashes Cheque Dishonour Proceedings
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 05.09.2026

Karnataka High Court Quashes Cheque Dishonour Proceedings

This Short Article has been prepared & written by Advocate G Sridharamurthy. The views expressed are based on his interpretation of the law. He can be reached at his email id sriadv3@gmail.com .

The Karnataka High Court recently delivered a significant judgment in a series of criminal petitions involving Kavitha Chopra and Dhirendra Chopra, directors of Osia Hyper Retail Limited. The petitions sought to quash proceedings related to cheque dishonour cases initiated by M/s 63Ideas Infolabs Pvt. Ltd. (Ninjacart). This article provides a comprehensive overview of the case background, legal arguments, judicial reasoning, and the implications of the court’s decision.

Case Background
- Parties Involved:
  - Petitioners: Kavitha Chopra and Dhirendra Chopra, directors of Osia Hyper Retail Limited.
  - Respondent: M/s 63Ideas Infolabs Pvt. Ltd. (Ninjacart), a company engaged in wholesale trade of agricultural products.
- Nature of Dispute:
  - Osia Hyper Retail Limited entered into a sale and purchase agreement with Ninjacart for the supply of 37 metric tons of loose tuvar dal gili, valued at ₹50,02,400.
  - Cheques issued by Osia Hyper Retail Limited towards payment were dishonoured due to insufficient funds.
  - After statutory demand notices went unanswered, Ninjacart filed private complaints under Section 138 of the Negotiable Instruments Act (NI Act) and Section 223 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023.
  - Five separate criminal cases were registered, leading to the present petitions seeking quashing of proceedings against the Chopras.
Legal Arguments

Petitioners’ Contentions
1. Role of Directors:
  - Kavitha Chopra was not involved in the day-to-day affairs of the company and was not a signatory to the dishonoured cheques.
  - The complaints lacked specific averments regarding her role or knowledge of the transactions.
  - Dhirendra Chopra, though a signatory in some cases, was not involved in all cheque issuances, and the complaints did not detail his responsibilities.
2. Vicarious Liability:
  - Merely naming someone as a director is insufficient to fasten criminal liability under Section 138 read with Section 141 of the NI Act.
  - The twin requirements under Section 141—being in charge of and responsible for the conduct of the business—were not satisfied.
Respondent’s Contentions
- Both Chopras were authorized representatives and signatories for Osia Hyper Retail Limited.
- The agreement, GST certificate, and board resolutions demonstrated their involvement.
- The grounds raised by the petitioners should be tested during trial, not at the quashing stage.
Judicial Reasoning

Key Legal Principles Cited
- Supreme Court Precedents:
  - Merely being a director does not automatically make one liable under Section 138/141 of the NI Act.
  - Specific averments are required to show how a director was in charge of and responsible for the conduct of the business at the relevant time.
  - Only signatories to the dishonoured cheque or those proven to be managing the company’s affairs can be held vicariously liable.
Application to the Present Case
- The complaints and sworn statements did not specify the roles of the directors, especially Kavitha Chopra, in the company’s daily operations.
- The only evidence was that both were directors and signatories to the agreement, but not all cheques.
- In one case, a cheque was issued from a joint account, but only the signatory can be prosecuted under Section 138.
- The court found that continuing proceedings against Kavitha Chopra, without specific allegations of her involvement, would be an abuse of process.
Court’s Order
1. Petitions by Kavitha Chopra:
  - Allowed. Proceedings against her in the relevant criminal cases were quashed.
2. Petitions by Dhirendra Chopra:
  - Dismissed. Proceedings against him will continue, as he was the Managing Director and signatory in some cases.
Implications and Takeaways
- For Directors:
  - Directors not involved in day-to-day management or not signatories to disputed cheques cannot be held vicariously liable without specific allegations.
- For Complainants:
  - Complaints must clearly state how each accused was responsible for the company’s business at the time of the offence.
- For Legal Practitioners:
  - The judgment reinforces the need for precise pleadings and adherence to statutory requirements in cheque dishonour cases.
Conclusion

The Karnataka High Court’s decision underscores the importance of specific allegations and evidence when seeking to hold company directors criminally liable for cheque dishonour. The ruling provides clarity on the application of vicarious liability under the NI Act and sets a precedent for similar cases involving corporate directors.

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Karnataka High Court

Disclaimer

Handy Download:

“Handy Order for Download”Download

Write to us at office@aadrikaalaw.com

Tel: +91-11-4999 2707

www.aadrikaalaw.com
Share this:
X
Facebook
Like this:
Like Loading…
September 5, 2026
Madras High Court Affirms RERA Non-Applicability to Pre-2017 Completed Projects
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 03.09.2026

Madras High Court Affirms RERA Non-Applicability to Pre-2017 Completed Projects

This Short Article has been prepared & written by Advocate Narendra Singh. The views expressed are based on his interpretation of the law. He can be reached at his email id amitnaren@outlook.com .

A recent judgment by the High Court of Judicature at Madras has brought clarity to the rights of homebuyers and the jurisdiction of regulatory authorities under the Real Estate (Regulation and Development) Act, 2016 (RERA). The case, involving R. Santhi Pitchaiya Nattar and Homefinders Housing Ltd, revolved around refund claims, project completion, and the applicability of RERA to projects completed before the Act came into force.

Background of the Case
- Parties Involved:
  - Appellant: R. Santhi Pitchaiya Nattar
  - Respondent: Homefinders Housing Ltd
- Project in Dispute: Apartments 13A and 16B in the ‘Elegant Palm’ project, Aatchikadu Village, Villupuram District.
- Timeline:
  - Booking and payments made in June 2012.
  - Construction agreement and sale deed executed in June 2012.
  - Dispute arose due to alleged delay in completion and handover.
Key Issues Raised
1. Whether the project was exempt from RERA registration under Rule 2(h)(iii) of the Tamil Nadu RERA Rules, 2017.
2. Whether the appellant was entitled to a refund with interest due to non-completion.
3. Whether a completion certificate from a private architect sufficed in the absence of a certificate from the competent authority.
4. The jurisdiction of RERA and its appellate bodies over unregistered or pre-RERA projects.
Proceedings and Arguments
- Appellant’s Stand:
  - Paid almost the entire sale consideration by 2012.
  - Alleged non-completion and failure to hand over possession.
  - Sought refund with interest from the developer.
- Respondent’s Stand:
  - Claimed project completion in 2014 and communication to the buyer.
  - Argued that the buyer failed to pay the final installment and did not take possession.
  - Asserted exemption from RERA as the project was completed before 01.05.2017.
Orders by Regulatory Authorities
1. TNRERA (Regulatory Authority):
  - Directed the developer to refund the amount paid by the buyer after deducting certain charges.
2. TNREAT (Appellate Tribunal):
  - Set aside the TNRERA order, holding that the project was exempt from RERA registration and outside its jurisdiction.
High Court’s Analysis and Judgment
- The High Court examined the applicability of RERA and the Tamil Nadu RERA Rules, especially Rule 2(h)(iii), which exempts projects completed before 01.05.2017 from registration.
- The Court found that:
  - The project was listed as completed before the cut-off date and notified as such by the authorities.
  - The regulatory authority (TNRERA) lacked jurisdiction over the dispute as the project was not required to be registered under RERA.
  - Aggrieved buyers in such cases must seek remedies through civil courts or consumer forums, not RERA.
- Final Decision: The appeals by the buyer were dismissed, upholding the appellate tribunal’s order.
Implications of the Judgment
1. Jurisdictional Clarity: Projects completed before 01.05.2017 and duly notified are outside RERA’s purview in Tamil Nadu.
2. Remedy for Buyers: Buyers in such projects must approach civil courts or consumer forums for grievances, not RERA.
3. Importance of Timely Communication: Developers must ensure timely completion and proper communication to avoid disputes.
4. Documentation: Both buyers and developers should maintain clear records of payments, agreements, and communications.
Conclusion

This judgment reinforces the boundaries of RERA’s jurisdiction and provides guidance for both homebuyers and developers regarding disputes in pre-RERA projects. It underscores the importance of understanding the legal framework and seeking appropriate forums for redressal.

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Madras High Court

Disclaimer

Handy Download:

“Handy Order for Download”Download

Write to us at office@aadrikaalaw.com

Tel: +91-11-4999 2707

www.aadrikaalaw.com
Share this:
X
Facebook
Like this:
Like Loading…
September 3, 2026
Defining Party Autonomy and Judicial Review in Indian Arbitration
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 03.09.2026

Defining Party Autonomy and Judicial Review in Indian Arbitration

This Short Article has been prepared & written by Arbitrator Shobhit Mallik. The views expressed are based on his interpretation of the law. He can be reached at his email id shobhit.Ica23@gmail.com .

This article explores the Supreme Court of India’s decision in Ssangyong Engineering & Construction Co. Ltd. v. National Highways Authority of India (NHAI), Civil Appeal No. 4779 of 2019, and its far-reaching impact on arbitration law and contract enforcement in India.

Background of the Dispute
1. Project and Contract
  - NHAI invited bids for a four-lane bypass on National Highway 26 in Madhya Pradesh.
  - Ssangyong Engineering & Construction Co. Ltd., a Korean company, won the contract for INR 219 crore.
  - The contract included a price adjustment clause (sub-clause 70.3) for key construction components (cement, steel, plant & machinery, and other materials), based on the Wholesale Price Index (WPI).
2. Change in WPI Series
  - Initially, price adjustments used the WPI (1993-94 = 100, “Old Series”).
  - In 2010, the Ministry of Industrial Development switched to a new WPI series (2004-05 = 100, “New Series”).
  - Both old and new indices were available for calculation, and payments continued accordingly until 2013.
3. Policy Circular and Dispute
  - In 2013, NHAI issued a circular introducing a “linking factor” to connect the old and new WPI series, requiring contractors to accept this adjustment with an undertaking.
  - Ssangyong objected, provided only a conditional undertaking, and initiated dispute resolution.
Arbitration and Court Proceedings
1. Dispute Adjudication and Arbitration
  - The Dispute Adjudication Board (DAB) recommended applying the linking factor, but one member dissented, supporting Ssangyong’s position.
  - The arbitral tribunal (majority) upheld the use of the linking factor and rejected Ssangyong’s claim. The dissenting arbitrator awarded the full claim to Ssangyong.
2. Court Challenges
  - Ssangyong challenged the majority award under Section 34 of the Arbitration and Conciliation Act, 1996, arguing that the award was beyond the scope of arbitration and violated public policy.
  - Both the Single Judge and Division Bench of the Delhi High Court upheld the majority award, citing limited grounds for interference.
Supreme Court’s Analysis and Ruling

Key Legal Issues Addressed
1. Scope of Judicial Review under Section 34
  - The Court clarified that post-2015 amendments, the grounds for setting aside arbitral awards are narrower, focusing on fundamental policy of Indian law and most basic notions of justice or morality.
  - Patent illegality is a ground only for domestic (not international commercial) arbitrations.
2. Application of Unilateral Circulars
  - The Court held that a unilateral circular (like NHAI’s 2013 circular) cannot alter the contract without the other party’s consent.
  - Imposing a new formula via the circular amounted to creating a new contract, breaching fundamental principles of justice.
3. Natural Justice and Due Process
  - The majority arbitrators relied on government guidelines not disclosed to the parties, violating Ssangyong’s right to present its case.
  - This procedural lapse was sufficient to set aside the award under Section 34(2)(a)(iii).
Final Decision
- The Supreme Court set aside the majority arbitral award and the High Court judgments.
- Instead of remanding for fresh arbitration (which would cause delay), the Court invoked Article 142 of the Constitution to enforce the minority award in Ssangyong’s favor.
- Ssangyong was awarded INR 2,01,42,827 plus interest as per the contract.
Impact and Significance
1. Reinforcement of Party Autonomy
  - The judgment affirms that contract terms cannot be unilaterally altered by one party or by administrative circulars.
2. Clarification of Public Policy and Patent Illegality
  - The Court narrowed the scope of “public policy” challenges, aligning Indian law with international standards and reducing judicial interference.
3. Due Process in Arbitration
  - Awards based on undisclosed evidence or guidelines violate natural justice and are liable to be set aside.
4. Speedy Dispute Resolution
  - By enforcing the minority award directly, the Court prioritized efficiency and finality in arbitration.
Conclusion

The Ssangyong Engineering judgment is a milestone in Indian arbitration jurisprudence. It strengthens the sanctity of contracts, limits judicial intervention, and upholds due process, making India a more arbitration-friendly jurisdiction.

Connected Matter

Bombay High Court’s Analysis of Arbitral Award Challenge under Section 34 of the Arbitration and Conciliation Act, 1996 in a Cotton Supply Dispute

Listen to this on our #YouTube Channel

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Supreme Court

Disclaimer

Handy Download:

“Handy Order for Download”Download

Write to us at office@aadrikaalaw.com

Tel: +91-11-4999 2707

www.aadrikaalaw.com
Share this:
X
Facebook
Like this:
Like Loading…
September 3, 2026
Supreme Court Clarifies Railway Compensation: Passenger Rights and No-Fault Liability
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 03.09.2026

Supreme Court Clarifies Railway Compensation: Passenger Rights and No-Fault Liability

This Short Article has been prepared & written by Advocate Madhumita Jha. The views expressed are based on her interpretation of the law. She can be reached at her email id jhamadhumita27@gmail.com .

A recent Supreme Court judgment in the case of Lata v. Union of India has brought significant clarity to the rights of railway passengers and their families regarding compensation for untoward incidents, such as accidental falls from trains. This article provides a detailed analysis of the case, the legal framework, and its broader implications for railway safety and passenger rights in India.

Case Background

The appellant, Lata, filed a claim for compensation after her husband, Chandrakant Thakkar, died from falling off a running train (Train No. 12834 Ahmedabad-Howrah Mail) in November 2015. The Railway Claims Tribunal and the High Court both dismissed her claim, citing the absence of proof that the deceased was a bona fide passenger, as his ticket was not recovered. Lata appealed to the Supreme Court, arguing that her husband was indeed a valid ticket holder and a victim of an untoward incident as defined by law.

Legal Framework

Key Provisions of the Railways Act
- Section 123(c)(2): Defines “untoward incident” to include accidental falling of any passenger from a train.
- Section 124A: Establishes “no-fault liability” for the Railways, making them liable to pay compensation for death or injury resulting from untoward incidents, regardless of negligence, with certain exceptions (e.g., suicide, self-inflicted injury, criminal acts).
- Section 2(29): Defines a “passenger” as someone traveling with a valid ticket or pass.
Burden of Proof

The Supreme Court emphasized that the absence of a ticket on the deceased does not automatically disqualify a claim. The initial burden is on the claimant to establish bona fide travel, which can be done through affidavits and circumstantial evidence. Once this is done, the burden shifts to the Railways to disprove the claim.

Court’s Analysis and Ruling

Liberal Interpretation of Beneficial Legislation

The Court reiterated that welfare statutes like the Railways Act must be interpreted liberally to fulfill their humanitarian purpose. Technicalities should not defeat the objective of providing accessible compensation to victims and their families.

Railway Duties and Passenger Safety

The judgment reviewed various Railway Manuals and statutory duties, highlighting:
- The responsibility of railway staff to ensure passenger safety, prevent overcrowding, and check tickets at multiple points.
- The need for proper record-keeping and enforcement to prevent unauthorized travel and overcrowding, which are frequent causes of accidents.
Overcrowding and Recent Incidents

The Court cited several recent incidents of deaths and injuries due to overcrowding, underlining the persistent risks faced by passengers. Despite guidelines, overcrowding remains a major safety challenge.

Shared Responsibility

While the Railways have a duty to enforce safety protocols, the Court also noted that passengers must act responsibly and avoid risky behaviors, such as traveling on footboards or overcrowded compartments.

Final Decision

The Supreme Court found that the lower courts erred in denying compensation solely due to the missing ticket. The appellant’s affidavit and circumstances established bona fide travel. The Court awarded compensation of Rs. 8,00,000 to the appellant, as per the latest rules, with interest if not paid within four weeks.

Implications and Recommendations
1. For Passengers:
  - Always retain travel documents and avoid risky travel practices.
  - In case of an incident, affidavits and circumstantial evidence can support compensation claims.
2. For Railways:
  - Strengthen enforcement of safety protocols and ticket checks.
  - Address overcrowding through operational improvements and increased capacity.
  - Improve record-keeping to reduce disputes over passenger status.
3. For Policymakers:
  - Consider reforms to further simplify compensation processes.
  - Invest in modernization and manpower to enhance safety and service quality.
Conclusion

This Supreme Court judgment marks a progressive step in protecting the rights of railway passengers and their families. By prioritizing the welfare intent of the law over procedural technicalities, the Court has reinforced the humanitarian objectives of the Railways Act and set a precedent for future compensation claims.

Connected Matter

Delhi High Court Overturns Tribunal Decision: Compensation Ordered for Railway Accident Victim’s Family

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Supreme Court

Disclaimer

Handy Download:

“Handy Order for Download”Download

Write to us at office@aadrikaalaw.com

Tel: +91-11-4999 2707

www.aadrikaalaw.com
Share this:
X
Facebook
Like this:
Like Loading…
September 3, 2026