(COMMERCIAL, Ct pis 1 E, COURT: DELHI CS Comm. No. 206 of 2024 In the matter of: ‘Mis LabourNet Services India Pvt Ltd. Plaintife ‘Versus ‘Mis Mls SGTB Electro Pvt Lid. Defendant INDEX ‘SR. [PARTICULARS PAGE NO. NO. 1. [Replication on behalf of the plaintiff to the written datement filed on behalf of the defendant |! ¢6 alongwithstatement of truth 2.) Affidavit of Admission & Denial on behalf of defendant |W 1g 3 hoof of Sewer 14 NEW DELHI FILED BY :- DATE: 21.11.2024 (Saumitra Singhal Advocate C-245, 1* Floor, Defence Colony, ‘New Delhi — 110024 9818341523 saumnitra,singhal@gmail.comIN_THE COURT OF SHRI_PITAMBER DUTT, DISTRICT JUDGE (COMMERCIAL COURT), DISTRICT: EAST. KARKARDOOMA COURTS, ELH Is CS Comm. No. 206 of 2024 In the matter oft M/s LabourNet Services India Pvt Ltd. Plaintiff Versus ‘Mis M/s SGTB Electro Pvt Ltd. Defendant REPLICATION ON BEHALF OF THE PLAINTIFF TO THE WRITTEN STATEMENT FILED BY THE DEFENDANT 1, That the contents of para 1 are wrong and denied. It is denied that Mr. Arun Pandey is the Authorized Representative of the defendant as alleged. It is also denied that he is well conversant with the facts of the matter and it is further denied that he is competent to institute and file the written statement on behalf of the defendant or that he is authorized to sign and verify the pleadings as alleged. It is also submitted that the written statement has been stated to be filed by Mr. Arun Pandey as an Authorized Representative of the defendant authorized vide Board Resolution dated 07.09.2024, however, no such resolution has been placed on record by the defendant and hence it is submitted that the written statement has not been filed as per the provisions of law and the same is liable to be rejected. 2, That the Plaintiff, through the preserit replication, refutes and denies all allegations, submissions, and contentions made by the Defendant in the written statement unless specifically admitted hereinafter. The Plaintiff reiterates and reaffirms all the ‘averments, submissions, and contentions made in the plaint, as if fully set forth herein and states that the same should be read as part and parcel of this replication. The Plaintiff denies the assertions made by the Defendant in the written statement, which are OQO inconsistent with the facts, admissions, and evidence presented by the Plaintiff. It is submitted that the Defendant is making baseless claims in an attempt to evade its lawful liabilities arising out of its breach of the agreement.It is also submitted that of suit has been correctly filed and the claim is based on va supported by relevant documents and evidence and the suit is liable to be decreed in favour of the plaintiff by the Hon’ble Court. and enforceable transactions and is 3. That in response to para 3, the plaintiff reiterates that the claims made in the plaint are based on documented and verifiable transactions and the defendant's blanket denial does not refute the specific and detailed claims made by the plaintiff, and as such, should not be accepted by the Hon'ble Court as a valid defence. PARAWISE REPLY TO PRELIMINARY OBJECTIONS: 4. That the contents of Paragraph No. 4 of the written statement are are denied as false, frivolous, and baseless. It is specifically denied that the suit has been filed without any cause of action, The plaintiff has provided detailed facts establishing the existence of a valid agreement, the performance of obligations, and the defendant's failure to honour its commitments, which constitute a valid cause of action. It is further denied that the plaintiff has resorted to "clever drafting” to create an illusion of a cause of action. The plaintiff's claims are based on documented facts, including the agreement, invoices, cheque issued by the defendant, and subsequent dishonour, all of which are annexed as evidence.The plaintiff has acted in good faith and followed all legal procedures to recover the outstanding dues. The detailed narrative in the plaint merely reflects the sequence of events leading to the present suit and does not, in any manner, constitute fabrication or manipulation.The dishonour of the cheque due to a signature mismatch and the defendant's failure to clear dues, despite repeated communications and mediation attempts, clearly establish a continuing cause of action.It is respectfully submitted that all facts, communications, and legal steps have been presented transparently, supported by documents, which are annexed to the plaint.The defendant's claim that the suit is liable to bbe dismissed is denied. The plaintif has a legitimate cause of action, which is Me8 substantiated by the dishonour of the cheque and the defendant's repeated failure to pay the outstanding dues. 5. That the contents of paragraph 5 are denied as incorrect and misleading. It is denied that the plaintiff raised invoices for services provided retrospectively without a valid basis. The plaintiff submits that the agreement dated 01.06.2023 was executed to formalize the relationship between the parties and explicitly covered the services already provided under mutual understanding and consent, as evidenced by prior communications and acknowledgments by the defendant.The assertion that the agreement does not mention its applicability 10 prior services is denied. It is submitted that the defendant was aware of and accepted the services provided by the plaintiff before the formal execution of the agreement. The retrospective nature of the services billed under the invoices is implicit in the conduct of the parties and the subsequent issuance of a cheque by the defendant, acknowledging the outstanding liability.The plaintiff denies the assertion that the agreement is inapplicable to services rendered before 01.06.2023, The services provided were a continuation of the professional relationship between the parties, later formalized by the agreement. The invoices are legitimate, and the defendant's own actions, including partial payments and acknowledgment of dues, establish the plaintiffs cause of action.It is denied that the suit is liable to be dismissed. The plaintiff reiterates that the services provided, the issuance of invoices, and the subsequent agreement were all part of a coherent and mutually understood commercial relationship. The defendant's attempt to evade liability by disputing the applicability of the agreement to prior services is an afterthought and tacks merit-The plaintiff maintains that the agreement dated 01.06.2023, coupled with the parties' prior conduct and communications, substantiates the claims raised in the plaint. ‘The suit has been filed based on enforceable rights, and the defendant's attempts to dispute liability are baseless and intended to delay justice. 6. That the contents of the paragraph 6 are admitted to the extent that Clause 16 of the agreement mentions that the courts at Bangalore shall have jurisdiction. However, the plaintiff submits that the invocation of jurisdiction at Bangalore does not exclude the Jurisdiction of this Hon'ble Court, as the cause of action arose within its territorial =4 ion. It is denied that the objection raised by the plaintiff has no merit. The services in question were provided at Delhi, and the defendant is situated within the jon of this Hon'ble Court. Under Section 20(a) of the Code of Civil Procedure, 1908, the plaintiff is entitled to institute the suit where the cause of action wholly or juris jurisdi partly arose or where the defendant resides, carries on business, or personally works for gain.The plaintiff denies that the jurisdiction clsuse in the agreement exclusively ousts the jurisdiction of this Hon'ble Court. It is submitted that the jurisdiction of this Hon'ble Court is attracted under Section 20 CPC, as the material events and transactions, including the provision of services and partial payments, occurred within its territorial limits. The defendant has its principal office within the jurisdiction of this Hon'ble Court, further substantiating the plaintiff's choice of forum-The plaintiff reiterates that this Hon'ble Court has jurisdiction to adjudicate the present dispute, given the location of service delivery and the defendant's business operations within Delhi. The defendant's objection to jurisdiction is baseless, as the jurisdiction clause does not amount fo an exclusive jurisdiction clause under the law. 7. That in response to Paragraph No. 7 of the written statement, the plaintiff notes the defendant's admission that the defendant agreed to avail services of the plaintiff for the supply of staff in accordance with the agreement dated 01.06.2023. However, the allegation that 8.33% of the value was for any “specialized consultancy services" is baseless and contrary to the terms of the agreement. The plaintiff strictly adhered to the scope of services outlined in the agreement.The plaintiff denies the claim that charges were payable only if candidates were referred by a third-party vendor or if the plaintiff coordinated interviews. The defendant's interpretation of the agreement is self-serving and erroneous. The charges were for providing manpower services as per the agreed terms, which were duly fulfilled by the plaintif:The allegation that the plaintiff failed to disclose any recruitment of staff is false and malicious, Detailed records of manpower supplied to the defendant were shared in accordance with the terms of the agreement.The plaintiff denies that it failed to comply with the provisions of the Contract Labour (Regulation and Abolition) Act, ESI Act, Payment of Wages Act, Minimum Wages Act, or Payment of Bonus Act. All statutory requirements were complied with, and the defendant has been duly informed. The defendant has provided A5 substantiate its claim of non-compliance.tt is denied that the plaintiff failed to submit proof of compliance to the defendant. All necessary documentation and invoices were provided, and the defendant has willfully ignored them to avoid its payment obligations.The allegation that the plaintiff contravened the terms of the agreement is baseless. The plaintiff adhered to all obligations under the agreement dated 01.06.2023, On the contrary, it is the defendant who breached the terms by failing to make payment for the manpower services provided.The defendant has admitted that manpower services were provided for a month and invoices were raised as per the terms of the agreement. However, the claim of payment through a dishonored cheque further demonstrates the defendant's breach of contractual obligations. The defendant's vague allegations of non- compliance without identifying specific instances or provisions violated by the plaintiff are baseless and defamatory. The pleintiff has complied with all terms of the agreement and statutory requirements.The allegation that the plaintiff is fabricating a story is false and defamatory. The plaintif?’s claims are supported by documentary evidence, including the agreement, invoices, and communications with the defendant,The defendant's repeated references to the agreement and baseless allegations are a mere attempt to evade payment obligations. The plaintiff reiterates that it has fully complied with the terms of the agreement, supplied manpower as agreed, and raised invoices accordingly. The defendant is liable to make payment for the services availed and cannot use unfounded allegations to escape its liability. 8 That the contents of para 8 are wrong and denied. The plaintiff categorically denies the baseless allegation that it has not approached the Hon’ble Court with clean hands. The plaintiff has presented all material facts and supporting documents to the Hon’ble Court transparently and in good faith. 9. That the contents of paragraph No. 9 of the written statement are wrong, false and are vehemently denied. The plaintiff denies that the allegations levelled against the defendant are a "web of imagination.” The claims made in the suit are supported by documentary evidence, including the agreement dated 01.06.2023, invoices, and communications exchanged between the parties. The defendant's attempt to discredit the plaintiff's te claims is frivolous.10, That the contents of para 10 are wrong and denied. The plaintiff denies the unfounded assertion that the suit has been filed with false, frivolous, and misconceived allegations. The suit is based on a valid agreement and arises from the defendant’s non- payment for services duly provided by the plaintiff. The allegations by the defendant are a desperate attempt to evade legal and financial responsibility.The plaintiff strongly denies the accusation of concealment of material facts. All relevant facts, agreements, and supporting documents have been disclosed to the Hon’ble Court. It is, in fact, the defendant who is attempting to mislead the Court by making baseless and contradictory statements. The defendant’s allegations lack merit and are intended to distract from the real issue, which is the defendant's failure to make payments for the manpower services provided under the agreement dated 01.06.2023. The plaintiff has approached the Hon’ble Court with a clear and legitimate claim, supported by evidence, and is entitled to the relief sought. 11, ‘That the contents of para 11 are partially incorrect as stated by the defendant and hence denied, It is denied that any security cheque was issued by the defendant to the plaintiff. The cheque in question was not issued as a security cheque but in discharge of the defendant's liability and towards the payment of the invoice raised by the plaintiff for manpower services provided in accordance with the agreement dated 01.06.2023.The plaintiff denies the claim that the defendant made several follow-ups with the plaintiff for compliance with the agreement dated 01.06.2023. The plaintiff fully adhered to the terms and conditions of the agreement and provided the services as stipulated. The defendant's claim of non-compliance is fabricated and unsubstantiated.{t is specifically denied that the cheque dated 30.06.2023 was issued as a security cheque, The cheque was issued by the defendant in acknowledgment of its liability for the services availed from the plaintiff under the agreement. The issuance of the cheque was a clear indication of the defendant's acceptance of the invoice and the corresponding payment obligation-The plaintiff reiterates that it has fulfilled all its obligations under the agreement dated 01.06.2023, The defendant's attempt to label the cheque as a "security cheque” and to alfege rion-compliance is a deliberate misrepresentation of facts aimed at evading payment.4 12, That the contents of para 12 are wrong and denied, It is denied that the defendant issued a post-dated security cheque of INR 13,78,900. The cheque in question was issued by the defendant in discharge of its liability arising from the invoice raised by the plaintiff for the manpower services provided in accordance with the agreement dated 01.06.2023.The allegation that the plaintiff deposited the cheque with ill intentions is baseless and denied. The cheque was deposited as part of the standard business process for recovering payment for services rendered. The defendant's claim is a mistepresentation of facts aimed at avoiding its payment obligations.It is denied that the cheque amount does not correspond with the invoice amount, The cheque was issued by the defendant in acknowledgment of its liability for the invoice raised by the plaintiff. If there is any discrepancy, the same is an afterthought of the defendant to evade liability:The defendant’s claim of non-liability is completely baseless and devoid of metit, The services were provided by the plaintiff, an invoice was duly raised, and payment was made by the defendant through the cheque in question. However, the defendant stopped the payment intentionally, which clearly demonstrates malafide intent.The plaintiff submits that the defendant’s narrative is a fabricated attempt to justify its wrongful act of dishonoring the cheque issued in good faith. The’ defendant's allegations hold no ground and are contradicted by the very fact that services were availed, and the invoice was raised in accordance with the terms of the agreement.The plaintiff reiterates that the defendant issued the cheque to discharge its liability, and the subsequent dishonoring of the cheque is'a deliberate breach of trust. The defendant's allegations regarding the cheque being a "security cheque" or the mismatch of amounts are baseless and intended to cover up its wrongfull conduct. The defendant is liable to make payment to the plaintiff without further delay. 13, That the contents of para para 13 are wrong and denied. The plaintiff denies that the suit is liable to be dismissed. The plaintiff has approached this Hon’ble Court with a valid cause of action arising out of the defendant's failure to honor its obligations under the agreement dated 01.06,2023 and the invoice raised in accordance with it-The allegation that the invoice dated 12.06.2023 is a misleading document is denied in its entirety. The invoice was raised strictly as per the terms of the agreement and reflects the8 charges for services provided by the plaintiff. The defendant's objections are an afterthought and hold no merit-The defendant’s baseless challenges to payment ‘components, including PF, GST, and service charges, are denied,It is denied that the plainti¢f fated to comply with statutory requirements. All necessary deposits and filings related to PF and GST have been duly complied with, as per applicable Iaws.TThe service charge was part of the agreed terms under the agreement dated 01.06.2023. The defendant’s objection is frivolous and aimed at evading liability.It is noteworthy that the defendant has admitted to making a payment of Rs. 1,00,000/- to the plaintiff for compliance related to the same services now being disputed. This admission confirms that the defendant availed of the services provided by the plaintiff and is liable for the balance payment in terms of the invoice raised. the defendant's objection to the interest rate is baseless. The plaintiff is entitled to interest at 12% per annum on the outstanding amount in line with standard commercial practices and as per the agreement terms.The plaintiff submits that the defendant's defense is a mere concoction of contradictory statements and unfounded allegations. On one hand, the defendant disputes the services and invoice, and on the other hand, admits payment towards the same. Such contradictory stances demonstrate the lack of credibility in the defendant’s case.The plaintiff reiterates that the suit is maintainable, the invoice is valid and compliant with alt statutory requirements, and the defendant's written statement is devoid of any merit. The plaintiff is entitled to the outstanding amount along with interest, and the defense raised by the defendant should be rejected as baseless. 14. That in response to para 14, the plaintiff denies the defendant's claim that the prayer for the cost of the suit is not maintainable. The plaintiff is entitled to claim costs of the suit in accordance with the provisions of law, including Section 35 of the Code of Civil Procedure, 1908.The plaintiff has been compelled to initiate the present suit due to the defendant's failure to discharge its contractual and legal obligations, causing unnecessary expenditure of time and resources. It is submitted that the defendant's baseless contentions and non-compliance with the agreement terms have led to the present proceedings, making the prayer for costs justifiable and maintainable,4 15. That the contents of para 15 are wrong and denied. The plaintiff strongly denies the defendant's baseless and malicious allegation that false and frivolous documents have, been filed in the present suit. The plaintiff has submitted all documents in good faith and in compliance with the procedural and evidentiary requirements of the Hon'ble Court.It is further submitted that the defendant has not substantiated its claim of falsity with any cogent evidence or specific details. Vague and unsubstantiated allegations made to divert attention from the real issues cannot be considered credible.The defendant’s assertion of being entitled to take legal action against the plaintiff is untenable and without merit. It appears to be a tactic to intimidate and harass the plaintiff rather than addressing the merits of the case. The plaintiff reserves the right to seek appropriate remedies against such baseless and defamatory allegations by the defendant.The plaintiff maintains that all documents filed are genuine and relevant to the present case. The defendant's allegations are frivolous, lacking evidence or legal basis, and should be rejected outright by the Hon'ble Court. PARAWISE REPLY ON MERITS: 1. In seply to the contents of para 1, the contents of corresponding paras 1 of the plaint are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff It is reiterated that the primary business of the Plaintiff is supplying manpower to other business concerns and providing workforce solutions, which could encompass a range of services including recruitment, staffing, and possibly even training of personnel. 2. In reply to the contents of para 2, the contents of corresponding paras 2 of the plaint are reiterated as true and correct and same are not being reproduced for sake of brevity. 3. Inreply to the contents of para 3, the contents of corresponding paraof the plaint are reiterated as true and correct and sam; ing reproduced for sake of brevity. Py ge 3jo 4. That the contents of paragraph 4 of the written statement are erroneous, misconceived, and hence, denied. It is denied that the plaintiff approached the defendant for getting any business as alleged. It is also denied that the plaintiff violated the terms and conditions of the agreement as alleged. 5. That the contents of para 5 are wrong and denied and the contents of corresponding para 5 of the plaint are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff, Furthermore, itis reiterated that the plaintiff supplied the required manpower and submitted the invoice which was not paid by the defendant. It is reiterated that plaintiff fulfilled its end of the agreement by providing the necessary workforce, adhering to the specified requirements and timelines given by the defendant and accordingly the plaintiff raised an invoice corresponding to the supplied manpower, detailing the services rendered and the payment due. 6. _ Inreply to the contents of para 6, the contents of para 6 of the plaint and reply to para 13 of the reply to preliminary objections herein above are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plainti 7. In reply to the contents of para 7, the contents of para 11 & 12 of the reply to preliminary objections herein above and corresponding para of the plaint are reiterated as ‘rue and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff. It is reiterated that suit amount js still outstanding and payable by the defendant to the plaintiff and the payment of which was delayed by the defendant on one pretext or the other. 8, In reply to the contents of para 8, the contents of para 11 to 13 of the reply to preliminary objections herein above and para 8 of the plaint are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incofrect, false, wrong and denied unless admityed-pesi se 3" 9. In reply to the contents of para 9, the contents of para 11 to 13 of the reply to preliminary objections herein above and corresponding para of the plaint are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff. 10. In reply to the contents of para 10, the contents of corresponding para of the plaint are reiterated as true and: correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff. 11. In reply to the contents of para 11, the contents of para 11 of the plaint are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff. 12. _ In reply to the contents of para 12, the contents para 12 of the plaint are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff, It is reiferated that the defendant failed to clear the outstanding amount due and payable by the defendant to the plaintiff. 13, In reply to the contents of para 13, the contents of para 13 of the plaint and para 11 & 12 of the reply to preliminary objections are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff. 14. In reply to the contents of para 14, the contents of corresponding para of the plaint are reiterated. 15, That in reply to para 15 of the reply to reply on merits herein above and para 15,yo therewith is deemed to be incorrect, false, wrong and denied uniess admitted specifically by the plaintiff. It is reiterated that the plaintiff is entitled to recover the suit amount from the defendant and it is also reiterated that the defendant is also liable to make the payment of the outstanding amount to the plaintiff aiong with interest. 16. In reply to the contents of para 16, the contents of parawise reply to prefiminary objections and para 16 of the plaint are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff. It is reiterated that defendant is liable to make the payment of the suit amount alongwith interest to the plaintiff. 17. In reply to the contents of para 17, the contents of parawise reply to preliminary objections and para 17 of the plaint are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff, 18, In reply to the contents of para 18, the contents of parawise reply to preliminary objection and corresponding para of the plaint are reiterated as true and correct, anything, contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff. 18. In reply to the contents of para 19, the contents of parawise reply to preliminary objection and corresponding pare of the plaint are reiterated as true and correct, anything contrary therefor tSent therewith is deemed to be incorrect, false, wrong and denied unk “mitted speditically by the plaintiff. \ fs 20. In repij-to the contents of para 20, the contents of parawise reply to preliminary objection and corresponding para of the plaint are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff. It is reiterated that every cause of action arose in favour of the plaintiff and against the defendant and it is also reiterated that the suit of the plaintiff is liable tobe| 21. - In reply to the contents of para 21, the contents of para 6 of the parawise reply to preliminary objection and corresponding para of the plaint are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff. 22. . In reply to the contents of para 22, the contents of the parawise reply to preliminary objection and corresponding para of the plaint are reiterated as ttue and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, false, wrong and denied unless admitted specifically by the plaintiff. 23. Inreply to the contents of para 23, the contents of para 6 of the parawise reply to preliminary objection and corresponding para of the plaint are reiterated as true and correct, anything contrary thereto or inconsistent therewith is deemed to be incorrect, ‘false, wrong and denied unless admitted specifically by the plaintiff. The prayer clause of the written statement filed by the defendant is wrong and hence ‘denied. It is also submitted that the written statement filed by the defendant is liable to be rejected being false and frivolous. tis, therefore, most respectfully prayed that the written statement filed by the defendant ‘may please be rejected and the relief as prayed for by the plait iff in the present suit may st the a please be granted along with the cost in favour of the plaintiff and, Place: Delhi Dated: 21.11.2024 ‘Through: Saumitra Singhal, Advocfte Counsel for the plaintiffVerified at Delhi on this 21%day of November, 2024 that the contents of paras 1 to 19 of the parawise reply on merits are true and correct to the best of my knowledge and belief and are based on record maintained by the plaintiff which I believe to be true and that of para 1 to 15 of the tejoinder/parawise reply to preliminary objections and paras 20 to 23 aihich I believe to be oe of the parawise reply on merits are based on legal advice true. Last para is humble prayer to this Hon’ble Court.= IN_THE COURT OF SHRI_PITAMBER DUTT, DISTRICT JUDGE (COMMERCIAL, Di ‘ KARKARDOO! OURTS, DELHI CS Comm. No. 206 of 2024 In the matter of M/s LabourNet Services India Pvt Ltd. Plaintiff Versus M/s M/s SGTB Electro Pvt Ltd. Defendant STATEMENT OF TRUTH 1, Monika Phogaat W/o Mr. Naveen Saroha, aged about 36 years R/o H. No. 260, Ward No. 02, Mehrauli, New Delhi 110030, presently at New Delhi, do hereby solemnly affirm and declare as under:~ 1. That the deponent is the AR of the plaintiff in the present matter. The deponent is fully conversant with the facts of the case and as such is competent to swear this affidavit, 2. Lam sufficiently conversant with the facts of the case and have also examined all relevant documents and records in relation thereto. I say that the statement made in paras 1 to 19 of the parawise reply on merits are 1e and correct to the best of my knowledge and belief and are based on recordte 4. say that the above-mentioned pleading comprises of a total of 13 pages, each of which has been duly signed by me. 5. The deponent says that she is aware that for any false statement or concealment, she shall be liable for action taken against her under the law for the time being in force. Place: Delhi Date: 20.11.2024 ost eee VERIFICATIO ec as 25 NOV 2024 ee eh 1, Monika Phogat, do hereby declare that the statements made above are true to my knowledge. Verified at Delhi on this 21“day of November, 2024 \1 ony IN \URT_OF PITA! DISTRICT. (COMMER YUR" Dis! : KAI YOR" DELHI CS Comm. No. 206 of 2024 In tter of ‘Mis LabourNet Services India Pvt Ltd. Plaintift Versus M/s M/s SGTB Electro Pvt Lid. Defendant AVY & ON QF DEFENDANT I, Monika Phogaat,W/o Mr. Naveen Sarcha, aged about 36 years R/o H, No. 260, Ward ‘No. 02, Mehrauli, New Delhi 110030, presently at New Delhi, do hereby solemnly affirm and declare as under: 1. That | am the Senior Manager H.R. and authorized Representative of the plaintiff in the present matter and as such I am well conversant with the facts and circumstances of the present matter and am competent to swear this affidavit, 2. — That the documents filed by the defendant alongwith its written statement are admitted and denied by the Deponent as under:~ Particulars | Correctness of) Existence | Execution | Tesuance | Custody ‘Contents of | of of ot Receipt | of Documents | Documents | Document | of Document Document Denied for | Denied for | Defendant [NA Defendant want of| want of, knowledge _| knowledge\8 2. [Memorandum | Denied for | Denied for | Defendant | NA Defendant | of association | want of| want of, of the | knowledge | knowledge defendant 3. |Articles of {Denied for | Denied for | Defendant [NA Defendant association of | want of| want of the defendant | knowledge | knowledge 4 [Email dated | Admit ‘Admit | Admit | Both Both 31.05.2023 3. | Email dated | Admit ‘Admit [Admit | Both Both 29.05.2023 Email dated | Admit ‘Admit [Admit | Both Both 02.06.2023 [Email dated [Admit ‘Admit | Admit | Both Both 15.06.2023, » i Email dated | Admit ‘Admit ‘Admit Both Both 02.06.2023 | Q) Deponent || wn Pon 1 adentty tm an has signed in MY 25 NOV 2024 Verified at New Delhi on this 21"day of November, 2024, that the contents of the present Affidavit of Admission & Denial are true and correct to my knowledge and no part of it is false. Nothing material has been concealed from this Hon’ble Court.