9911796707
TMI Blog2010 (12) TMI 1277X X X X Extracts X X X X X X X X Extracts X X X X ..... ( 2. ) On 25.1.1990, the Company submitted a proposal for term loan to the then Industrial Credit and Investment Corporation of India Ltd., later known as ICICI Bank (for short 'ICICI'), for starting a manufacturing unit. The sanction was granted for the financial assistance with pari -passu charge in favour of the consortium of Banks including ICICI, IDBI and IFCI. The financial facilities amounting to ₹ 9,25,66,743/ - were granted inclusive of Rupee Term Loan and Foreign Currency Loan etc.. As per the agreements, the amount was payable in installments, the last of them being payable in 1998. The loan share of ICICI was 38.28% amounting to ₹ 3.55 Crores; IDBI's loan share was 34.45% amounting to ₹ 3.28 Crores and that of IFCI was 26.27% amounting to ₹ 2.43 Crores. The Company submitted an application for registration of the Company as a sick company with Board for Industrial and Financial Reconstruction (for short BIFR) constituted under the Sick Industries (Special Provisions) Act, 1985 (for short 'the SICA') on 28.10.1994. Such application was declined on 6.12.1994 for the reason that the 5 years have not elapsed from the commenceme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Company after returning a finding that the net worth of the Company has turned positive and the Company has ceased to be a sick industrial company. It recorded that the company has discharged its major financial obligations. However, the non -fulfilled obligations under the approved package would continue to remain in operation. ( 5. ) It is pleaded by ICICI in its petition for winding up of the Company that the BIFR has granted certain concessions and reliefs to the Company. But in spite of the reliefs and concessions, the Company has failed and neglected to pay outstanding dues of the Petitioner amounting to ₹ 3,29,92,998.08 as on 30.4.2004. The Petitioner is further entitled to interest from May, 2004 till the amount is liquidated. The statement of claims in respect of the five loan accounts were detailed in Annexure P.3. It is pleaded that the Petitioner has served a statutory notice dated 30.4.2004. In reply dated 17.5.2004, the Company asserted that the notice is bad and invalid and has been issued with suppressed facts and bias. The Company denies liability of the payment of the alleged sum of ₹ 3,29,92,998.08. ( 6. ) M /s Kotak Mahindra Bank Limited filed CA N ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . ( 8. ) The record of the case has a written statement dated 27.7.2005, though there is no order permitting the said written statement to be taken on record nor there is any indication that on which date such written statement was filed. But along with the said written statement, the Company has appended its 14th, 15th and 16th Annual Reports for the years 2001 -02, 2002 -03, 2003 -04. In the Balance Sheets for the year ending on 31.3.2002 (14th Annual Report Annexure R.3), the secured loan as per Schedule -C, is said to be ₹ 9,22,00,300/ -. Such was the position as on 31.3.2001 as well. In the Balance Sheet for the year ending 31.3.2003 (15th Annual Report Annexure R.4), the secured loan as per Schedule -C is stated to be ₹ 8,72,00,000/ -. The 16th Annual Report, Annexure R.5 is for the year ending 31.3.2004, the secured loan as per Schedule -C of such report is ₹ 8,02,01,700/ -. Though in the written statement, the Company has denied that it is indebted to the Petitioner in the sum of ₹ 2,38,46,263/ - towards the principal amount and ₹ 91,46,735.08 towards interest, but the Company has not attached any document or the statement of accounts that pay ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... RFAESI Act. ( 10. ) An appeal bearing Company Appeal No. 41 of 2009 filed by the Alchemist aggrieved against the order passed on 21st August, 2009 was dismissed by the Division Bench on 16.2.2010. In the Special Leave to Appeal, the matter was remitted to the Company Court for deciding the said claim of the Company as per the directions contained therein. However, on 28.7.2010, the Company withdrew its aforementioned application with liberty to continue with the writ petition against the action initiated by the Alchemist under the SARFAESI Act. M/s Alchemist filed an affidavit, which was assigned CA No. 530 of 2009, wherein it opted out of the winding up proceedings and intended to realize its security outside winding up instead of relinquishing its security and proving its debt. The Company in its reply to the CA No. 530 of 2009 dated 14.10.2009 stated in para (C): C. It is not in dispute that Respondent No. 1 -Company CCHL has already paid a sum of about ₹ 12.80 crore to the original lenders (ICICI, IFCI, IDBI) against loan of about ₹ 9.25 crore. This amount of ₹ 12.80 crore include payment of about ₹ 11.01 crore paid by CCHL after the liability was f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the said Guidelines dated 3.9.2005 applicable to Financial Institutions also). The OTS application was submitted by the Company to IDBI on 8.3.2006 and to IFCI on 9.3.2006, well before the deadline of31.3.2006 (with ICICI Ltd., the Company took up the matter separately in Winding -Up proceedings in Punjab & Haryana High Court). As per the language of the said OTS guidelines and as per the mandate of Section 21 & 35A of the Banking Regulation Act and as per the judgments of the Courts, the said OTS guidelines are mandatory and are binding up n the Banks and Financial Institutions. The IDBI replied vide their letter dated 21.4.2006, classifying the Company's loan account as doubtful NPA in its books of accounts as on 1.4.1993 and demanding ₹ 396 lakhs as full and final payment of their dues. The IFCI replied vide letter dated 23.3.2006, classifying the Company's account as doubtful NPA as on 31.3.1995 and demanded ₹ 465.66 lakhs as full and final payment of their dues. The Company replied to IDBI's and IFCI's letters vide letter dated 21.5.2006 and 22.5.2006 respectively, wherein the Company raised grievance that the amount demanded by IDBI and IFCI in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s in the DRT, Delhi. With these observations, the suit was disposed off on 17.5.2008. It came to light during Inter -Pleader suit proceedings that the KMBL had filed Recovery Suit in the DRT, Delhi on 23.1.2007 for recovery of ₹ 4,72,06,961/ -, but the same was not intimated to the Company prior to filing of inter -pleader suit. The said DRT suit is still pending. Vide letter dated 24.2.2007, the IDBI issued default notice and demanded a sum of ₹ 7,80,26,765/ -. Same was protested by the Company by its legal counsel's communication dated 5.4.2007. In the meanwhile, vide letters dated 14.5.2007 and 4.6.2007, the IFCI recalled their loan and invoked the personal guarantee for a sum of ₹ 84,49,38,818/ -. Same was protested by the Company on 18.6.2007. Vide letter dated 20.3.2008, the IFCI assigned the debt to Dhir & Dhir Asset Reconstruction Securitization Company Ltd. The same was objected by the Company. The Division Bench of Punjab & Haryana High Court, before whom the order of Single Judge (Company Court) admitting the winding up petition was challenged on 7.4.2008, dismissed the appeal of the Company vide order dated 1.8.2008 on the ground of delay. On ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nnexure P.24 is the reply submitted by the Company to the show cause notice, whereas Annexure R.9 dated 12.1.2009 and 6.2.2009 are the reasons communicated to the Company in terms of Section 13(3A) of the SARFAESI Act. ( 13. ) It is inter -alia, pleaded that 250 workers and staff are employed in its Rewari Factory and the company is one of the major suppliers of automotive springs to the leading automobile manufacturers of India including Maruti Suzuki India Ltd. It is pleaded that the Banking Regulations Act, 1949 empowers the RBI to determine the policy and lay down guidelines to be followed by the Banking Companies. The directions issued by the RBI have statutory force. SARFAESI Act, also gives powers to the RBI and no Company can carry its business of securitization and assets without obtaining a licence from the RBI. It is pleaded by the Petitioner -Company that the loan amount disbursed by Consortium of Banks with ICICI being lead institution was ₹ 9,25,66,743/ -. It is also pleaded that the Company made several payments to the Financial Institutions, but due to market forces and reasons beyond the Company's control, it defaulted in making payments. The Company mad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Provisioning pertaining to Advances" dated July 17, 2004. ( 15. ) The stand of the Company is that the Company's loan account ought to have been categorized as Non Performance Assets (for short 'NPA') prior to 1.4.1993. The Company has also pointed out that on 19.6.2006 in the joint meeting of the Company with the Officers of the IFCI, IDBI and Kotak Mahindra Bank, the financial institutions were of the view that they would accept the One Time Settlement on the condition that the Company shows its willingness to deposit 100% principal amount, as per the balance sheet of the Company for the year 2004 -05. The company was to submit an acceptable proposal to the creditors to be received by them by 4.7.2006. The minutes of the meeting were sent to the Petitioner by IDBI on 23rd June 2006, but the Petitioner disputed such minutes primarily on the ground of insertion of clause regarding requisite details of the various payments made by the Petitioner. The company allegedly submitted One Time Settlement application on 1.7.2006 and calculation of ₹ 2.62 lacs as per RBI's guidelines and requested the financial institutions to settle the alleged dues accordingly. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is ₹ 20.18 crores aggregating ₹ 35.34 crores as on 30.6.2010. It is pointed out that RBI's guidelines for One Time Settlement are not applicable to the Company as such guidelines were applicable only to Small Medium Enterprises (SME), whereas as per the Balance Sheet of the Company for the year 2004 -05, the investment in the plant and machinery of the Company was more than ₹ 16 crore and the outstanding dues were more than ₹ 10 crore. The Company has not availed loan facility as SME and that RBI guidelines are not applicable to willful defaulters. No One Time Settlement proposal was ever made by the Company as per the RBI guidelines and by raising various contentions, the Company offered only ₹ 2.62 lacs to all the lenders put together. The said affidavit is accompanied by the calculations sheet of interest reflecting the interest chargeable and the amount received from the company from time to time. The Alchemist has filed another counter affidavit, wherein reliance has been placed upon an order passed by the Hon'ble Supreme Court in United Bank of India v. Satyawati Tondon and Ors. : (2010) 8 SCC 110 and Transcore v. Union of India : (2008) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 10 filed by Guarantor (Coventry Springs Co.. Ltd.) of the Company before AAIFR Seeking setting aside of order dated 3.12.2009 passed by BIFR Dismissed on 3.6.2009 8. WP (C) No. 4938/2010 by Guarantor (Coventry Springs & Engineering Co. Ltd.) of the Company Seeking setting aside of orders dated 3.12.2009 passed by BIFR and 3.6.2010. Dismissed on 27.7.2009. ( 17. ) It is also pointed out that as per the proposal filed by the Company before BIFR under Section 17(2) of the SICA, the dues of the Company towards the three financial institutions were ₹ 35.65 crores as on 31.3.1999. The detail of exposure as on 31.3.1999 is stated to be as under: Name of the Institution Principal Simple Interest Other charges Total ICICI 35.5 44.0 42.3 121.8 IDBI 32.8 47.7 54.7 135.2 IFCI 24.3 34.1 41.1 99.5 Total 92.6 125.8 138.1 356.5 It is also pleaded that even if the dues of IDBI and IFCI are calculated as per the settlement arrangement filed by the Company under Section 17(2) of the SICA before BIFR, the amount works out to be ₹ 35.31 crores as on 31.6.2010 and that the Company has not made any repayment since the year 2006. It is also pointed out that th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aid amount is the principal sum advanced and 20% of the interest amount. It may be noticed that amount of over Nine Crores Rupees was advanced to the Company in the year 1990 -92, whereas the settlement arrived was in the year 1999 with 20% interest for the entire period. As against the said amount, the Company has paid a sum of ₹ 11,01,88,705/ - between November, 1997 to October, 2005. As per the financial institutions, the amount due and payable by the Company as on 31.3.2004 is ₹ 35.34 crores in terms of settlement submitted before BIFR by the Company. ( 19. ) Firstly , it is required to be examined "Whether, the Company is liable to be wound up for its inability to discharge its admitted liabilities or that the defence of the Company that the amount claimed to be due and payable is disputed is bona -fide or not". ( 20. ) Shri R.C. Setia, learned Senior Counsel, appearing for the Company has vehemently argued that the amount claimed by the ICICI in the petition for winding up is bona -fide disputed, in as much as in the communication Annexure P.27/B, the ICICI Bank has communicated the receipt of various amount, the total of which comes to ₹ 5,43,87 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mination of the amount due by invoking the jurisdiction of the DRT. Therefore, till such time, the amount is adjudicated upon and determined to be payable by the Company, the process of winding up is not available to the Petitioner. It is contended that the winding up proceedings are not the proceedings for recovery of the amount due, therefore, the process of winding up cannot be used to arm -twist the Company to succumb to the pressure of the financial institutions to make the payment of the amount, which is yet to be determined. It is also argued that the Company has filed CA No. 732 of 2009 to which the Bank has not even filed reply. In the said application, the Company has sought a direction to the Bank to produce the statement of accounts. Thus, it is contended that having failed to communicate even statement of account reflecting the payments made by the Company in the books of account of the financial institutions, the process of winding up is untenable. ( 22. ) On the other hand, the learned Counsel for the financial institutions has vehemently argued that the Company cannot be permitted to raise an argument that the amount is bona -fide disputed after the petition was or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and fix a date for hearing thereof without pre admission notice. After admission, the petition is to be advertised in terms of Rule 99. An advertisement of petition in form 48 calls upon any creditor or contributory or other persons desirous of supporting or opposing the making of an order on the said petition. Rules 96, 99 and Form 48 of the Companies (Court) Rules, read as under: 96. Upon the filing of the petition, it shall be posted before the Judge in Chambers for admission of the petition and fixing a date for hearing thereof and for directions as to the advertisements to be published and the persons, if any, upon whom copies of the petition are to be served. The Judge may, if he thinks fit, direct notice to be given to the company before giving directions as to the advertisement of the petition. xx xx xx Advertisement of petition. 99. Subject to any directions of the Court, the petition shall be advertised within the time and in the manner provided by Rule 24 of these Rules. The advertisement shall be in Form No. 48." xx xx xx Form 48 Advertisement of petition Notice is hereby given that a petition for the winding -up of the above -named company by the H ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... thousand per annum. Therefore, the payment of approximately Rs. One Crore Fifty thousand up till 24.4.1993 i.e. almost for a period of three years, is in fact part payment of interest amount only. It cannot be said that the Company had paid any part of the principal amount up to 24.4.1993. ( 26. ) THE Company's Rehabilitation Package under Section 17(2) of the SICA Act was accepted by BIFR on 24.12.1999. As per the calculations submitted by the Company, it was to pay the principal amount i.e. ₹ 9.26 crores and the interest of ₹ 2.52 crores as on 31.3.1999, total amounting to ₹ 11.78 crores. Such amount was to carry interest @ 15% from 1.4.1999. Admittedly, the Company has not paid ₹ 11.78 crores up to March, 2002. An amount of ₹ 11.01 Crores was paid after the package submitted by the Company was accepted. The amount paid is not in terms of the settlement arrived at before the BIFR. The Company has come out with a plea that a sum of ₹ 2,62,126/ - is payable. The said amount is arrived at by taking into consideration only the payments made without taking into consideration any interest payable on the amount advanced. The Company has easily ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Satyawati Tondon : (2010) 8 SCC 110, the Court held that with a view to give impetus to the industrial development of the country, the Central and State Governments encouraged the banks and other financial institutions to formulate liberal policies for grant of loans and other financial facilities to those who wanted to set up new industrial units or expand the existing units. Many hundred thousand took advantage of easy financing by the banks and other financial institutions but a large number of them did not repay the amount of loan, etc. Not only this, they instituted frivolous cases and succeeded in persuading the civil courts to pass orders of injunction against the steps taken by banks and financial institutions to recover their dues. Due to lack of adequate infrastructure and non -availability of manpower, the regular courts could not accomplish the task of expeditiously adjudicating the cases instituted by banks and other financial institutions for recovery of their dues. As a result, several hundred crores of public money got blocked in unproductive ventures. Thus the purpose of the SARFAESI Act is to empower Banks and the financial Institutes to recover their dues expedit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt petition by the creditors and all the contributors. The Bombay High Court in the case of S.P. Capital Financing Ltd. V. Bagade (India) Engineering Ltd., 2002 (10) Comp Cas 657, rejected the application of one of the creditors who had filed a winding up petition holding that the prayer made by such creditors is not acceptable. It has been observed that Section 447 of the Act in its plain language provides that as soon as the order of winding up is passed the nature of the winding up petition undergoes transformation from an individual petition to a petition on behalf of all the creditors and all the contributors. Therefore, the Petitioner was not permitted to withdraw the petition without the consent of all the creditors or contributories. Therefore, it is not surprising that the learned Company Judge did not feel the necessity of passing any order on the application filed by the Appellant. The argument that the proper stamp duty has not been affixed on the assignment deed of debt by ICICI Bank in favour of Kotak Mahindra, is again not tenable. The assignment has been registered by the competent authority. The registration of document is prima -facie a proof of affixation of pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rity under the SARFAESI Act. Since the Company has failed to pay huge amount of the money to the financial institutions, such act of the Company is against the public interests. Supreme Court in Transcore (Supra) held that there is one more reason for enacting the SARFAESI Act, 2002. The Parliament enacted the DRT Act as the civil courts failed to expeditiously decide suits filed by the banks/Financial Institutions. However, DRT did not provide for assignment of debts to securitization companies. The secured assets also could not be liquidated in time. In order to empower banks/ Financial Institutions to liquidate the assets and the secured interest, the SARFAESI Act was enacted in 2002. The enactment of such Act is, therefore, not in derogation of the DRT Act. The SARFAESI Act removes the fetters which were in existence on the rights of the secured creditOrs. The argument raised by the counsel for the workmen and Shri Setia that the Company is employing 250 persons and is contributing to the State Exchequer, is again not tenable. It is not in dispute that the interests of the workmen has to be kept in view, but it is the Company which has to ensure the payment of wages to the wo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the company. The Balance Sheets of the Company also reflects large sum of money as due and payable to the secured creditors. Therefore, it would be just and equitable to order winding up of the Company, which has failed to discharge its admitted liabilities. Accordingly, the Company is ordered to be wound up. The Official Liquidator attached to this Court is appointed as Liquidator of the Company, who shall take over all the assets and liabilities, actionable claims of the Company and act in accordance with law. CP No. 129 of 2004 and other applications stand disposed of accordingly. Coming the writ petition filed by the company, the same was filed on 6.7.2010 challenging the notice dated 12.12.2008 under Section 13(2) and notice under Section 13(4) of the SARFAESI Act. Before filing of the petition, the financial institutions have communicated the reasons declining objections filed by the Company. A notice under Section 13(4) of the SARFAESI Act was issued on 17.8.2009 and published in newspapers on 19.8.2009. Once, a notice under Section 13(4) of the SARFAESI Act has been issued, the remedy of the Company is before the DRT alone, as has been held in Mardia Chemicals and reitera ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ken under Sub -section (4) of Section 13 and before the date of sale/auction of the property it would be open for the borrower to file an appeal (petition) under Section 17 of the Act before the Debts Recovery Tribunal. 3. That the Tribunal in exercise of its ancillary powers shall have jurisdiction to pass any stay/interim order subject to the condition as it may deem fit and proper to impose. 4. In view of the discussion already held in this behalf, we find that the requirement of deposit of 75% of the amount claimed before entertaining an appeal (petition) under Section 17 of the Act is an oppressive, onerous and arbitrary condition against all the canons of reasonableness. Such a condition is invalid and it is liable to be struck down. Reiterating the said judgment in Transcore's case (supra), the Court held to the following effect: On reading Section 13(2) it is clear that the said Sub -section proceeds on the basis that the borrower is already under a liability and further that, his account in the books of the bank or FI is classified as substandard, doubtful or a loss. The NPA Act comes into force only when both these conditions are satisfied. Section 13(2) proceed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... judgments aforesaid, the remedy of the Company is to approach DRT in terms of Section 17 of the SARFAESI Act. ( 36. ) The Company has filed miscellaneous application in a petition for winding up for restraining the financial institutions from proceedings under the SARFAESI Act. The said application has been withdrawn. However, it may be noticed that the petition for winding up was filed by the ICICI Bank, whereas the proceedings under the SARFAESI Act, are being taken by the assignee of IFCI and IDBI Banks. Both of the said secured creditors were not parties to the petition for winding up when the said application was filed nor has winding up order been passed by this Court on that date. Therefore, in a petition for winding up, such application was not maintainable and has been rightly withdrawn on 28.7.2010. It may be noticed that such application was filed after notice under Section 13(4) of the SARFASI Act was published. Instead of invoking the jurisdiction of the DRT, the Company invoked the jurisdiction of the Company Court through a miscellaneous application, in which the secured creditors were not even party. Apart from the said application, the numerous litigations initia ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ignee against the borrower. Therefore, the amount of assignment cannot be claimed to be an amount on the basis of which the Company can claim to settle the account of the secured creditOrs. ( 38. ) The IFCI has claimed ₹ 133,77,25,581/ - as the amount due in terms of the agreements executed by the Company, whereas the claim of the IDBI is ₹ 10,76,34,691 as per settlement produced by the Company before BIFR as on 15.9.2008. It is the stand of M/S Alchemist in short affidavit, that the amount payable to IFCI is ₹ 15.16 Crores and to IDBI ₹ 20.18 Crores as on 30.6.2010 as per the settlement package produced by the Company before BIFR. Though IFCI has claimed amount on the basis of original agreement entered upon by the Company with the secured creditors, but the said claim of the secured creditor cannot be said to be unjustified for the reason that the Company has failed to honour the Rehabilitation Package submitted before the BIFR. The argument raised by Shri Setia that the Company has a right to avail One Time Settlement is again not tenable. The argument is that the financial institutions were bound to declare the assets of the Company as Non Performing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... terest and/or instalment of principal remain overdue for a period of more than 180 days in respect of a Term Loan, ii) the account remains 'out of order' as indicated at paragraph 2.2 below, in respect of an Overdraft/Cash Credit (OD/CC), iii) the bill remains overdue for a period of more than 180 days in the case of bills purchased and discounted, iv) interest and/or instalment of principal remains overdue for two harvest seasons but for a period not exceeding two half years in the case of an advance granted for agricultural purposes, and v) any amount to be received remains overdue for a period of more than 180 days in respect of other accounts. 2.1.3 With a view to moving towards international best practices and to ensure greater transparency, the '90 days' overdue' norm for identification of NP As has been adopted, from the year ending March 31, 2004. Accordingly, with effect from March 31, 2004, a non -performing asset (NPA) shall be a loan or an advance where; i) interest and/ or instalment of principal remain overdue for a period of more than 90 days in respect of a term loan, ii) the account remains 'out of order' as indicated at para ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ct from 31.3.2001; 90 days with effect from 31.3.2004 and 30 days with effect from 30.9.2004. Therefore, in the year 1993, the period from which the Company claims that its assets should have been declared as Non Performing Assets, the default period was four quarters and not 30 days. Therefore, the argument that the assets of the Company should have been declared as Non Performing Assets in December, 1993 is not borne out from the circular issued by the RBI relied upon by the Company. ( 40. ) A perusal of the circular dated 3.9.2005 issued by the RBI appended with the writ petition as Annexure P.5 shows that such circular is in respect of Non Performing Assets below ₹ 10 crores. It contemplates as under: Guidelines on One -Time Settlement Scheme for SME Accounts Please refer to Paragraph No. 8 of our circular RPCD. PLNFS.BC. No. 31/06.02.31/2005 -06 dated August 19, 2005 and accordingly, a one -time settlement scheme for recovery of NP As below ₹ 10 crore is proposed hereunder which is required to be implemented by all public sector banks. These guidelines will provide a simplified, non -discretionary and non -discriminatory mechanism for one -time settlement of c ..... X X X X Extracts X X X X X X X X Extracts X X X X
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