REJOINDER REPLY CUM LEGAL NOTICE

 

BY SPEED POST WITH ACKNOWLEDGEMENT DUE AND BY EMAIL

 

Date: 29^th day of June, 2026

To,

Shri Shashank Tripathi,

Advocate

High Court, Lucknow

Chamber:

D-405, High Court Building, Lucknow,

& D-1/365, Sector-F, Jankipuram, Lucknow,

Contact: 6386160931

Email: shashank.tripathi1507@gmail.com

 

REJOINDER REPLY CUM LEGAL NOTICE

Subject: Rejoinder Reply to your Email dated 01.06.2026 and Reply-Cum-Legal Notice dated 01.06.2026 issued in response to our Legal Demand Notice dated 21.05.2026.

Ref.: Memoranda of Understanding dated 01.06.2022, Addendum dated 01.09.2022, and Addendum dated 01.01.2024.

 

My Client: M/s. Sustainable Green Initiative Private Limited, a Company duly incorporated under the provisions of the Companies Act, 2013, bearing CIN No. U02000WB2022PTC253934 and having its registered office at P-41, Princep Street, 2nd Floor, Room No. 213, Kolkata – 700072, West Bengal. (“SGIPL”)

 

Your Client: M/s. Navchetna Agro Center Producer Company Limited, House No. 233, Bitthalapur Sikhar, Mirzapur – 231306, Uttar Pradesh, Phone No.: 919956603894, Email: navchetnafpo@gmail.com (“Navchetna”)

 

Dear Sir/s, Madam/s,

 

Under instructions and on behalf of my client, M/s. Sustainable Green Initiative Private Limited (hereinafter referred to as "SGIPL"), I hereby issue the present Rejoinder Reply to your email dated 01.06.2026 and the Reply-Cum-Legal Notice dated 01.06.2026 purportedly issued on behalf of Navchetna Agro Center Producer Company Limited.

 

At the outset, all statements, allegations, insinuations, assertions, interpretations, claims, counterclaims, denials, contentions, averments and allegations contained in your Reply-Cum-Legal Notice are specifically denied and disputed save and except those which are expressly admitted herein. Nothing contained in this Rejoinder shall be construed as an admission of any allegation, fact, contention or legal proposition advanced by you.

 

It is further stated that your Reply-Cum-Legal Notice is materially misleading, self-serving, evasive and deliberately designed to divert attention away from the fundamental issues raised in Legal Demand Notice dated 21.05.2026, namely the catastrophic failure of plantation survival, non-performance of contractual obligations, suppression of records, reporting deficiencies, financial irregularities, non-compliance with agreed Standard Operating Procedures, non-payment of labour-related dues despite reimbursement, and failure to account for substantial sums entrusted to you for execution of the project.

 

At the very outset, it is noteworthy that throughout your Reply you have conspicuously avoided addressing the central issue giving rise to the present dispute, namely the admitted and undeniable failure of the plantation project to achieve the contractually stipulated survival benchmarks. Instead of furnishing verifiable records demonstrating achievement of the agreed survival percentages, you have attempted to shift responsibility upon SGIPL by advancing vague allegations regarding supervision, funding structures, field conditions, plant quality and project scale, none of which either legally or factually absolves Navchetna of its independent contractual obligations.

 

Your Reply contains an inherent contradiction. On the one hand, you repeatedly claim that Navchetna was merely a small grassroots organization lacking resources, technical capability and commercial sophistication. On the other hand, you simultaneously admit having undertaken one of the largest plantation implementation projects in the region involving crores of rupees, lakhs of plantations, thousands of farmers, multiple districts, extensive manpower deployment and continuous field operations over a period of nearly four years. Having voluntarily represented yourselves as competent and capable and having accepted substantial funds and contractual responsibilities, you are now estopped from pleading your own alleged incapacity or inadequacy as a defence.

 

Your repeated attempt to characterize yourselves as a mere "field implementation partner" does not assist your case. The very essence of your contractual engagement was field implementation, plantation execution, maintenance, monitoring, labour management, reporting, statutory compliance, survival management and related operational activities. The obligations relating to plantation survival, pit preparation, watering, maintenance, gap filling, protection, farmer coordination, reporting and documentation were entrusted exclusively to Navchetna. Consequently, describing yourselves as an implementation partner merely reinforces, rather than diminishes, your responsibility for the failures documented in our Legal Demand Notice.

 

Your allegations that SGIPL exercised supervision, monitoring, audit, inspection and approval rights are wholly misconceived and legally untenable. Such rights were incorporated into the contractual framework precisely because Navchetna was entrusted with field execution responsibilities. A right of inspection does not convert the inspecting party into the executing agency. An audit right does not transfer operational liability. A monitoring function does not make SGIPL responsible for failures committed by Navchetna in carrying out field activities. Acceptance of reports and reimbursement claims submitted by Navchetna cannot validate work which was later discovered to be incomplete, deficient, inaccurately reported or unsupported by records.

 

Further, your contention that SGIPL approved every payment and therefore cannot question project execution is rejected. Every payment released by SGIPL was based upon representations, certifications, MIS reports, utilisation statements, plantation records, reimbursement claims, photographs, geo-tagging records and other information furnished by Navchetna. Any approval obtained on the basis of inaccurate, incomplete, misleading or suppressed information is legally ineffective and cannot constitute a waiver of SGIPL's rights once the true facts subsequently emerged through audits, inspections, reconciliations and field verification.

 

That the contemporaneous documentary record unequivocally establishes that SGIPL did not remain passive or acquiescent in the face of Navchetna's contractual defaults, but acted promptly, diligently and in good faith immediately upon detecting irregularities and performance deficiencies. The record demonstrates that as soon as discrepancies relating to project implementation, labour payments and field performance came to the notice of SGIPL, appropriate contractual measures were initiated. In particular, by e-mail dated 12.11.2025, followed by the corresponding ledger entry dated 14.11.2025, it was expressly recorded that although an amount of Rs.5,11,621/- stood sanctioned for reimbursement, SGIPL deliberately released only Rs.4,42,192/-, while withholding a sum of Rs.69,429/-. The said withholding was neither arbitrary nor unilateral, but was specifically occasioned by Navchetna's admitted and unexplained failure to disburse wages and other dues payable to its own employees, labourers and field personnel, despite having sought reimbursement from SGIPL for the very same purpose. The contemporaneous withholding of this amount constitutes a clear and independent instance of financial irregularity and dishonest retention of labour reimbursement, thereby demonstrating that SGIPL had already begun identifying and addressing instances of contractual breach long before the present dispute crystallised.

 

That the aforesaid action was not an isolated occurrence but formed part of a continuous course of contractual enforcement undertaken by SGIPL in response to Navchetna's deteriorating performance. As further evidence of its bona fide conduct, SGIPL thereafter issued the detailed Show Cause Notice dated 30.01.2026, specifically recording serious deficiencies including substantial plantation survival shortfalls, failure to comply with contractual performance benchmarks, inaccurate and incomplete reporting, deficiencies in monitoring and documentation, and other material breaches affecting project implementation. When Navchetna failed to satisfactorily explain or rectify these defaults, SGIPL was constrained to issue its communication dated 07.02.2026, whereby suspension of further operations and the proposed termination of the contractual arrangement were communicated. These contemporaneous documents conclusively demonstrate that SGIPL consistently invoked contractual remedies, repeatedly called upon Navchetna to account for its defaults, and afforded adequate opportunity to cure the breaches before taking any adverse action. The suggestion that SGIPL remained silent, accepted deficient performance, or sought to raise objections only after the passage of time is therefore demonstrably false and stands completely belied by the documentary record.

 

That the documented withholding of Rs.69,429/- assumes particular legal significance, inasmuch as it evidences that funds specifically reimbursed for labour-related expenditure were not utilised for the purpose for which they had been entrusted. Navchetna's failure to make payment to its own workforce despite claiming reimbursement constitutes not merely a contractual default but raises serious questions regarding diversion, misapplication and dishonest retention of project funds entrusted for a designated purpose. Such conduct fundamentally undermined the relationship of trust between the parties and independently justified SGIPL's decision to intensify scrutiny of Navchetna's financial and operational conduct. The said contemporaneous withholding therefore constitutes cogent evidence that SGIPL had already detected financial irregularities during the subsistence of the project and had acted immediately in accordance with the contractual framework.

 

Equally untenable is the question rhetorically posed by Navchetna as to why SGIPL continued to approve bills and release payments if, according to SGIPL, plantation survival and implementation standards were allegedly failing. The answer lies squarely in the contractual mechanism governing the project. Every approval, reimbursement and payment released by SGIPL was based entirely upon the progress reports, utilisation statements, survival certifications, MIS data, plantation records, geo-tagged photographs, reimbursement claims and other representations repeatedly submitted and certified by Navchetna itself. SGIPL, as the project owner, was necessarily entitled to rely upon the accuracy, completeness and truthfulness of the field information furnished by its designated implementation partner. The subsequent discovery, through audits, reconciliations, field inspections and independent verification exercises, that the actual ground realities materially differed from the figures and representations furnished by Navchetna, completely destroys any suggestion that earlier approvals amounted to acceptance or waiver of the underlying defaults.

 

In other words, SGIPL approved payments only to the extent that Navchetna represented, certified and warranted that the corresponding plantation activities, maintenance obligations, survival benchmarks and utilisation of funds had been duly achieved. The approvals were therefore conditional upon the truthfulness and accuracy of Navchetna's own disclosures and cannot, in law or in equity, operate as an estoppel against SGIPL once it became apparent that the true field position had been concealed through inaccurate, incomplete, misleading or suppressed reporting. A party guilty of concealing material facts cannot subsequently rely upon approvals obtained through its own misrepresentations to defeat the rights of the other contracting party. Accordingly, the continued release of payments during project implementation cannot be construed as acceptance of deficient performance; rather, it demonstrates that SGIPL acted throughout in good faith upon the representations made by Navchetna, the falsity of which became evident only upon subsequent verification and reconciliation. Such concealment vitiates every approval procured on the basis of inaccurate reporting and preserves SGIPL's full contractual and legal rights to recover losses, demand restitution, seek rendition of accounts and hold Navchetna accountable for its breaches.

 

Your allegation that the plantation project failed due to poor-quality saplings supplied by SGIPL is false, baseless and unsupported by any contemporaneous record whatsoever. Significantly, despite operating the project continuously for several years, you have failed to produce a single contemporaneous email, letter, notice, inspection report, rejection memo, quality complaint, WhatsApp communication or other written record showing that Navchetna ever rejected, protested against, segregated or refused to plant the saplings allegedly supplied in defective condition.

 

A prudent and competent implementation agency genuinely believing that saplings were incapable of meeting the contractually mandated survival benchmark would have immediately refused acceptance, demanded replacement, recorded objections in writing and suspended plantation activities. Instead, Navchetna accepted the saplings, transported them, planted them, submitted reimbursement claims in respect thereof, certified plantation progress, reported implementation status and continued project execution for years without raising any formal quality objection. The allegation regarding sapling quality has surfaced for the first time only after issuance of the Legal Demand Notice and is therefore an obvious afterthought devised solely to evade liability.

 

That the explanation now sought to be advanced by Navchetna attributing the catastrophic plantation failure solely or substantially to the alleged quality of the saplings supplied by SGIPL is wholly untenable, scientifically unsustainable, factually unsupported and contrary to the contemporaneous record. Even assuming, arguendo and without admitting, that a limited number of saplings may have exhibited natural variations in quality, such circumstance could never, either in agronomic practice or in ordinary commercial experience, account for an overall plantation mortality of approximately 85% across multiple project sites, districts and plantation cycles. Such an extraordinarily high mortality rate is neither consistent with isolated deficiencies in planting material nor capable of being explained by sapling quality alone. On the contrary, it is a classic indicator of systemic failures in field implementation, post-plantation maintenance, monitoring, protection and survival management, all of which indisputably fell within the exclusive contractual responsibilities assumed by Navchetna under the Memoranda of Understanding and the agreed Standard Operating Procedures (SOPs). The sheer magnitude of the mortality itself constitutes compelling circumstantial evidence that the plantations were not maintained in accordance with the prescribed technical standards and contractual obligations.

 

The material available with SGIPL demonstrates that the principal causes of the massive plantation failure lay in Navchetna's own executional lapses and persistent non-compliance with the prescribed plantation methodology. Among the most significant defaults was Navchetna's failure to ensure that plantation pits were excavated strictly in accordance with the mandatory technical specifications requiring a minimum pit size of 30 cm × 30 cm × 45 cm. The prescribed pit dimensions were not merely procedural guidelines but constituted essential agronomic requirements intended to facilitate proper root establishment, adequate soil aeration, moisture retention and nutrient availability. Any substantial deviation from these specifications inevitably compromises root development, restricts water infiltration and materially reduces the survival prospects of newly planted saplings. The failure to comply with these mandatory standards therefore directly contributed to plantation mortality and represents a serious breach of the contractual obligations undertaken by Navchetna.

 

Equally significant was Navchetna's failure to provide adequate post-plantation care and maintenance, without which no plantation project of this scale could reasonably be expected to achieve the contractually stipulated survival percentages. The available records indicate serious deficiencies in watering schedules, irrigation support, moisture management and routine maintenance, particularly during critical periods immediately following plantation and during adverse climatic conditions. Proper watering and timely irrigation are indispensable for the establishment and survival of young saplings, especially during the vulnerable initial growth stages. The absence of adequate watering, delayed irrigation or complete neglect of post-plantation maintenance inevitably accelerates plant stress, root failure and mortality, irrespective of the inherent quality of the saplings supplied. These obligations formed part of Navchetna's core implementation responsibilities and could not, either contractually or technically, be shifted upon SGIPL.

 

Further, the records disclose equally serious deficiencies in the application of manure, vermicompost and other prescribed soil-conditioning measures necessary to support healthy plantation growth. The project guidelines contemplated the application of appropriate quantities of manure and vermicompost to improve soil fertility, moisture retention and nutrient availability. However, Navchetna has failed to produce any credible records demonstrating that such agronomic inputs were applied consistently, adequately or in accordance with the approved implementation protocols. In the absence of proper nutrient management, even healthy saplings are rendered susceptible to stress, disease and premature mortality. The cumulative effect of inadequate pit preparation, deficient soil conditioning and lack of proper post-plantation maintenance inevitably results in widespread plantation failure, precisely as reflected in the actual field outcomes.

 

The failure of Navchetna to ensure physical protection of the plantations constitutes yet another independent and substantial cause of the extraordinarily high mortality rate. SGIPL had, at considerable expense, supplied fencing materials specifically for the purpose of protecting the plantations from grazing animals, human interference and other foreseeable risks. The supply of fencing material was intended to facilitate effective protection of vulnerable plantations and formed an integral component of the project's survival strategy. However, despite the availability of such materials, it is an admitted position that more than 80% of the fencing material remained unutilised, with the inevitable consequence that large numbers of plantations were left exposed to preventable damage. The non-installation of fencing not only defeated the very purpose for which the material had been supplied but also resulted in substantial wastage of project resources and significantly increased plantation vulnerability. The admitted non-utilisation of the fencing material therefore constitutes a clear indicator of gross negligence, failure of supervision and complete disregard of elementary plantation management practices on the part of Navchetna.

 

Significantly, despite now seeking to deny responsibility for these failures, Navchetna has failed to produce a single contemporaneous record capable of demonstrating that the fencing materials supplied by SGIPL were actually deployed, installed or utilised in accordance with the project requirements. No inventory registers, stock movement records, material issue slips, site-wise consumption statements, installation certificates, geo-tagged photographs, fencing completion reports, site-specific fencing maps, inspection records, protection registers, maintenance logs or other documentary evidence have been produced to establish the receipt, distribution or utilisation of the fencing materials supplied under the project. Likewise, no documentary material has been furnished showing the locations where fencing was erected, the quantity of material consumed at individual plantation sites, the dates of installation or the personnel responsible for such work. The complete absence of such basic implementation records renders Navchetna's present assertions entirely devoid of evidentiary value and gives rise to a strong and legitimate adverse inference that the fencing materials were either never utilised in the intended manner or were grossly underutilised despite reimbursement and supply by SGIPL.

 

Viewed cumulatively, the overwhelming mortality of approximately 85% is therefore neither accidental nor attributable to any isolated factor but is the direct and inevitable consequence of a series of systemic implementation failures exclusively attributable to Navchetna. The failure to excavate pits to the prescribed dimensions, the lack of adequate watering and irrigation, deficient application of manure and vermicompost, neglect of routine maintenance, failure to install protective fencing despite the availability of materials supplied by SGIPL, and the complete absence of reliable implementation records together establish a continuing pattern of deficient execution, inadequate supervision and material breach of contractual obligations. These failures, individually and collectively, completely undermine Navchetna's attempt to attribute the catastrophic plantation losses to alleged deficiencies in sapling quality. In the absence of credible contemporaneous documentary evidence demonstrating proper execution of its own contractual responsibilities, Navchetna cannot escape liability by advancing speculative and belated allegations unsupported by technical data, field records or independent verification. On the contrary, the contemporaneous facts unmistakably establish that the unprecedented mortality was the natural and foreseeable consequence of Navchetna's own acts, omissions and failures in executing and maintaining the plantation project in accordance with the agreed contractual standards.

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Likewise, your allegations concerning inadequate funding and unrealistic rates are equally untenable. The financial arrangements, management fees, reimbursement structures and rate schedules were mutually negotiated and expressly accepted by Navchetna under the MOU and subsequent Addendums. If the agreed rates were genuinely commercially unviable, Navchetna was free to reject the engagement, seek revision of rates, invoke contractual remedies or terminate the arrangement. Having accepted the contractual terms, continuously performed thereunder for nearly four years and received substantial payments aggregating approximately Rs.13.71 Crores, Navchetna cannot now approbate and reprobate by claiming that the very terms voluntarily accepted were unrealistic.

 

Your attempt to attribute the project failures to difficult terrain, labour shortages, monsoon conditions, transportation challenges and field realities is equally misconceived. Such conditions were neither unforeseen nor extraordinary. They constituted the very circumstances within which Navchetna represented itself to possess expertise and operational competence. Ordinary field difficulties cannot be retrospectively converted into force majeure events, nor can they excuse the admitted failure to maintain records, furnish reports, ensure survival, comply with SOPs, make statutory payments or account for entrusted funds.

 

Most significantly, your Reply completely fails to answer the fundamental question: if the project was implemented properly, where are the surviving plantations? Despite extensive narrative allegations against SGIPL, you have failed to furnish any credible data demonstrating achievement of the contractually mandated survival percentages. You have not furnished authenticated survival audits, plantation inventories, geo-tagged verification records, independent assessments, survival certificates, farmer-wise survival data or any other credible material capable of rebutting the plantation mortality and survival shortfall identified by SGIPL.

 

The counterclaim of Rs.20,00,00,000/- raised by Navchetna is wholly speculative, unsubstantiated and legally unsustainable. No ledger account, audited statement, damage assessment report, expert valuation, financial computation, causal analysis or documentary evidence has been furnished in support thereof. The same appears to have been raised solely as a pressure tactic and is accordingly rejected in toto.

 

SGIPL reiterates that its claims remain subject to ongoing reconciliation, audit, forensic verification and production of records, and reserves the right to enhance, modify or supplement its claims based upon further evidence that may emerge.

 

Accordingly, all allegations contained in your Reply-Cum-Legal Notice are denied. The demands contained in our Legal Demand Notice dated 21.05.2026 are hereby reiterated and reaffirmed in their entirety.

 

PARA-WISE REBUTTAL OF MATERIAL ALLEGATIONS RAISED IN THE REPLY-CUM-LEGAL NOTICE DATED 01.06.2026;

 

1.   In reply to the contention that Navchetna was engaged merely as a "ground implementation partner" and was paid inadequate amounts compared to the scale of the project, it is submitted that the allegation is misleading and irrelevant. Navchetna voluntarily entered into the contractual arrangement with full knowledge of the project scope, commercial structure, payment mechanism and responsibilities. The adequacy or inadequacy of compensation cannot be questioned retrospectively after receipt of substantial payments and continued participation over several years.

 

2. The allegation that the project value exceeded Rs.100 Crores and that Navchetna received only approximately Rs.13 Crores is wholly irrelevant. The overall value of the programme has no bearing upon the contractual entitlements of Navchetna. Navchetna was entitled only to payments expressly agreed under the MOU, Addendums and approved project budgets.

 

3. The allegation that every bill, voucher, attendance record and plantation record was verified and approved by SGIPL does not absolve Navchetna of liability. Verification was undertaken on the basis of information, records and representations furnished by Navchetna. Discovery of inaccuracies, suppression, discrepancies or misrepresentations subsequently entitles SGIPL to challenge such records notwithstanding prior provisional acceptance.

 

4. The allegations concerning the involvement of SGIPL's directors, managers, consultants and technical teams are denied insofar as they seek to transfer operational responsibility to SGIPL. Supervision does not displace execution. Monitoring does not replace implementation. Inspection does not transfer contractual liability.

 

5. The allegation that final land identification and approval were undertaken by SGIPL is admitted only to the extent that SGIPL exercised project oversight. However, identification of land parcels does not absolve Navchetna of its independent obligations regarding plantation, maintenance, survival management, protection and reporting.

 

6. The allegations relating to KML verification, mapping, geo-tagging and technical approvals are similarly misconceived. Technical review processes existed to evaluate project progress. They did not convert SGIPL into the executing agency nor did they dilute Navchetna's contractual obligations.

 

7. The admission that Navchetna was responsible for farmer mobilization, labour deployment, tribal engagement, local coordination and field implementation directly supports SGIPL's case. These responsibilities constituted the very core of the implementation arrangement and any failure therein remains attributable to Navchetna.

 

8. The allegations concerning goodwill among farmers and local communities are denied for want of proof. Even assuming such goodwill existed, the same cannot excuse contractual defaults, reporting deficiencies or survival failures.

 

9. The allegation that SGIPL exploited Navchetna's goodwill and network is false, baseless and unsupported. The relationship between the parties was governed by written contractual arrangements voluntarily entered into for mutual commercial benefit.

 

10. The allegation that plantation targets were not achieved because of inadequate budgets is denied. Navchetna accepted the agreed budgets, continued performance thereunder and repeatedly sought reimbursement under the same framework without protest. The plea now raised is an afterthought.

 

11. The allegation concerning pit-digging rates is denied. The rates were mutually discussed, negotiated and accepted. No contemporaneous notice alleging impossibility of performance due to pit-digging rates has been produced.

 

12. The allegation regarding rocky terrain and difficult field conditions is denied as a defence. Such conditions were known and foreseeable at the time of engagement and formed part of the very circumstances in which Navchetna represented itself to possess local expertise.

 

13. The allegation concerning manure quantities is denied for want of proof. No contemporaneous complaint, agronomic assessment, technical report or expert recommendation supporting such allegation has been furnished. In any event, the manure in question was procured and supplied by Navchetna itself, the entire cost whereof was duly paid and/or reimbursed by SGIPL. Having itself arranged, sourced and applied the manure against payment made by SGIPL, Navchetna cannot now be heard to raise any grievance as to, or take refuge under, either the quality or the quantity of such manure; any deficiency in either respect is attributable solely to Navchetna's own procurement and field execution and cannot, in fact or in law, be cast upon SGIPL.

 

14. The allegations regarding dissatisfaction among farmers are vague, generalized and unsupported by farmer-wise records, affidavits, declarations or contemporaneous complaints.

 

15. The allegations that saplings supplied by SGIPL were inferior, weak, under-aged or unsuitable are specifically denied. No contemporaneous rejection reports, inspection notes, supplier complaints, quality objections or replacement requests have been produced.

 

16. The allegation that farmers repeatedly objected to sapling quality is denied for want of proof. Not a single farmer statement, complaint register, written representation or documentary record has been furnished.

 

17. The allegation that SGIPL pressured Navchetna to continue plantation activities despite awareness of alleged deficiencies is denied. Navchetna was at all material times responsible for carrying out its contractual obligations in a professional and lawful manner.

 

18. The allegation regarding fencing responsibilities is misleading. The scope of work evolved through project requirements and communications between the parties. Any additional activities undertaken by Navchetna were accepted and performed by it without raising any legally sustainable objection.

 

19. The allegation that SGIPL subsequently engaged other vendors is irrelevant. SGIPL was entitled to adopt such measures as were necessary to mitigate losses and address implementation deficiencies.

 

20. The allegation that Navchetna acted bona fide throughout the project period is denied insofar as it conflicts with the documentary evidence concerning reporting discrepancies, survival failures, labour-payment irregularities and record deficiencies.

 

21. The allegation that SGIPL was fully aware of all ground realities is denied. SGIPL's knowledge was dependent upon information supplied by Navchetna. Concealment, inaccurate reporting and incomplete disclosures materially impaired SGIPL's ability to ascertain the true state of affairs.

 

22. The allegation that the Legal Demand Notice was issued after four years merely to shift responsibility is false and misleading. The notice was issued after extensive review, reconciliation, audit and discovery of serious deficiencies which required formal legal action.

 

23. The denial of fraud, intentional misconduct, misappropriation and related allegations is noted. However, such denial cannot substitute for production of records, reconciliation of accounts and explanation of documented discrepancies.

 

24. The allegation that shortcomings resulted from collective project-level issues is denied. The contractual framework clearly allocated responsibilities between the parties and Navchetna cannot avoid liability by invoking vague references to systemic challenges.

 

25. The reservation of rights claimed by Navchetna to produce records in future is noted. However, the fact remains that such records have not been produced despite repeated requests and opportunities.

 

26. The threats of legal proceedings, reputational claims and compensation demands are rejected in their entirety as baseless, unsupported and legally unsustainable.

 

27. The assertion that SGIPL's legal notice is defamatory is specifically denied. The notice constitutes a bona fide legal communication issued in exercise of lawful rights and is protected by principles of qualified privilege.

 

28.                The allegation that Navchetna is entitled to compensation of Rs.20,00,00,000/- (Rupees Twenty Crores only) is emphatically denied, disputed and rejected in toto as being wholly baseless, speculative, legally untenable and entirely unsupported by any contemporaneous or admissible evidence. The purported counterclaim is not founded upon any contractual provision, statutory entitlement, established legal principle or cogent factual foundation. Rather, it consists of vague, generalized and inflated assertions unsupported by audited financial statements, books of accounts, damage assessments, expert reports, independent valuations, causal analyses, documentary proof or any legally admissible material capable of establishing either the existence or quantum of the alleged loss. The figure of Rs.20 Crores has been arbitrarily asserted without disclosing the methodology of computation, the factual basis for such quantification, or any contemporaneous records demonstrating that such loss was actually suffered. It is therefore evident that the counterclaim has been advanced merely as a pressure tactic, intended to intimidate SGIPL, divert attention from Navchetna's own contractual defaults, create an artificial bargaining position and obstruct SGIPL's legitimate claims for recovery, reconciliation of accounts and enforcement of contractual obligations.

 

29.                Without prejudice to the aforesaid, even assuming the allegations contained in the Reply-Cum-Legal Notice to be correct for the sake of argument alone, the entire counterclaim remains legally unsustainable under the settled principles governing the assessment of contractual damages embodied in Section 73 of the Indian Contract Act, 1872. It is a well-established principle of law that damages recoverable for breach of contract are confined only to such losses as naturally arise in the usual course of events from the alleged breach, or such losses as were within the reasonable contemplation of both contracting parties at the time the contract was entered into. Remote, indirect, consequential, speculative, contingent or hypothetical losses are expressly excluded from the scope of recoverable damages. The burden lies squarely upon the party claiming compensation not merely to allege loss, but to establish by credible and contemporaneous evidence the fact of such loss, the quantum thereof, the direct causal nexus between the alleged breach and the claimed damage, and that such loss was not too remote or self-induced. Navchetna has failed to satisfy any of these essential legal requirements.

 

30.                The principal component of the alleged claim, namely the purported reputational loss and business injury allegedly aggregating to approximately Rs.20 Crores, is entirely conjectural, hypothetical and incapable of legal enforcement. No evidence has been produced to demonstrate the existence of any actual diminution in business, cancellation of contracts, loss of customers, reduction of revenue, withdrawal of investors, termination of commercial relationships or any measurable financial consequence directly attributable to any act or omission on the part of SGIPL. No independent valuation, forensic financial assessment, auditor's certificate, expert opinion, business impact analysis or other objective material has been furnished in support of the alleged reputational damage. Mere assertions of reputational injury, unsupported by demonstrable financial consequences and contemporaneous documentary evidence, do not constitute legally recoverable damages under the law of contract. Such claims are inherently speculative, incapable of objective quantification and clearly fall within the category of remote and indirect losses excluded by Section 73 of the Indian Contract Act. Consequently, the alleged reputational component of the counterclaim is liable to be rejected outright.

 

31.                Equally untenable is Navchetna's attempt to attribute its alleged loan liability of approximately Rs.2 Crores to SGIPL. The borrowing of monies from banks, financial institutions or other lending agencies constituted an independent commercial and financial decision taken exclusively by Navchetna in the course of managing its own business affairs. SGIPL was neither a borrower, guarantor nor co-obligor in respect of such financial facilities, nor did it exercise any control over Navchetna's internal financial management, borrowing policies or debt structure. Any liability arising under such loan arrangements flows exclusively from contractual relationships voluntarily entered into between Navchetna and its lenders, entirely independent of the contractual arrangements between the parties herein. Consequently, any interest burden, repayment obligation, default consequences or financial exposure arising out of such borrowings is solely attributable to Navchetna's own commercial decisions and cannot, either factually or legally, be shifted upon SGIPL. The law does not permit a contracting party to convert its self-assumed financial liabilities into contractual damages against another party in the absence of a direct contractual obligation or legally established causal connection.

 

32.                The allegations concerning unpaid salaries, wages and labour-related liabilities are equally devoid of merit and, in fact, reinforce SGIPL's own case regarding financial irregularities committed by Navchetna. The contemporaneous records maintained by SGIPL clearly establish that reimbursement amounts specifically earmarked for payment of employees, labourers and field personnel had already been released to Navchetna for the designated purpose. Indeed, the documentary record further demonstrates that an amount of Rs.69,429/- was consciously withheld by SGIPL only after it came to light that Navchetna had failed to disburse wages to its own workforce despite having claimed and received reimbursement for such expenditure. The alleged non-payment of salaries therefore did not arise because of any omission on the part of SGIPL but resulted directly from Navchetna's own failure to utilise reimbursed project funds for the purposes for which they had been entrusted. Having retained or failed to appropriately apply labour reimbursements received from SGIPL, Navchetna cannot now seek to convert the consequences of its own financial misconduct into a claim for damages against SGIPL. Such a contention is contrary to both law and equity and offends the settled principle that no person can be permitted to derive an advantage from his own wrong.

 

33.                Furthermore, Navchetna has failed to establish the indispensable element of proximate causation required for maintaining any claim for contractual damages. The alleged reputational injury, financial liabilities, borrowing obligations and employee-related dues do not arise naturally or directly from any alleged act or omission of SGIPL. Rather, each of these alleged heads of loss originates from Navchetna's own independent commercial decisions, internal financial management, contractual commitments with third parties, implementation failures and admitted operational deficiencies. The chain of causation is therefore broken by Navchetna's own intervening acts and omissions, rendering the alleged losses too remote, indirect and legally irrecoverable. In the absence of a direct and immediate causal nexus between the alleged conduct of SGIPL and the losses claimed by Navchetna, no enforceable right to compensation can arise.

 

34.                The counterclaim is equally liable to fail for want of mitigation. Even assuming that Navchetna had suffered any genuine financial difficulty, it was under a continuing legal obligation to take reasonable steps to mitigate its alleged losses. No material has been produced to show that Navchetna sought to minimise its alleged financial exposure, restructure its operations, reduce avoidable expenditure, recover outstanding dues, renegotiate financial obligations or otherwise take commercially reasonable steps to limit the consequences of the alleged events. Instead, Navchetna has sought to accumulate and exaggerate alleged losses while simultaneously withholding material records and resisting reconciliation of accounts. Such conduct disentitles it from claiming damages which could reasonably have been avoided by the exercise of ordinary prudence.

 

35.                Accordingly, the entire counterclaim of Rs.20,00,00,000/- is liable to be rejected as speculative, unsupported, remote, legally untenable and contrary to the settled principles governing contractual damages. The alleged reputational loss is hypothetical and incapable of proof; the alleged loan liabilities arise exclusively from Navchetna's own borrowing decisions; the alleged unpaid salaries and labour dues are the direct consequence of Navchetna's own failure to utilise reimbursed funds for their intended purpose; and none of the alleged heads of damage is attributable, either in fact or in law, to any act or omission of SGIPL. Far from establishing any actionable claim, the allegations contained in the Reply-Cum-Legal Notice further underscore Navchetna's own financial mismanagement, contractual breaches and failure to account for project funds entrusted to it. The purported counterclaim therefore deserves to be dismissed in its entirety with all attendant legal consequences, while SGIPL's rights to recover its own losses, seek rendition of accounts, restitution, indemnification and all other remedies available in law and equity remain expressly reserved.

 

36. Save as expressly admitted herein, each and every statement, allegation, contention, submission, averment and claim contained in the Reply-Cum-Legal Notice dated 01.06.2026 is denied and disputed as if specifically traversed herein.

 

37. The contents of SGIPL's Legal Demand Notice dated 21.05.2026 are reiterated, reaffirmed and incorporated herein by reference.

 

38.                Without prejudice to the foregoing submissions, SGIPL states that the conduct of Navchetna throughout the subsistence of the project creates a complete legal bar against many of the defences now sought to be raised for the first time in the Reply-Cum-Legal Notice.

 

39.                The doctrine of approbation and reprobation is well settled. A party cannot simultaneously accept benefits under a transaction and thereafter challenge the very basis of the transaction when liabilities arise.

 

40.                Navchetna admittedly accepted engagement under the project, accepted project responsibilities, accepted reimbursements, accepted management fees, accepted implementation assignments, accepted operational authority and continuously participated in project execution for several years.

 

41.                Having voluntarily accepted the benefits of the contractual arrangement, Navchetna cannot now selectively disown the obligations arising therefrom.

 

42.                Throughout the implementation period, Navchetna repeatedly submitted reports, certifications, utilisation statements, reimbursement claims, progress updates and representations portraying implementation progress and compliance.

 

43.                At no point during the substantial duration of the project did Navchetna issue any formal notice alleging fundamental impossibility of performance, frustration of contract, impossibility arising from project design, inability to perform due to sapling quality or any other circumstance now alleged.

 

44.                Had the allegations presently advanced been genuine, they would necessarily have found reflection in contemporaneous correspondence exchanged during the implementation period.

 

45.                The absence of such contemporaneous records is highly significant and renders the present allegations inherently unreliable.

 

46.                A party genuinely believing that project success was impossible due to defective inputs, inadequate budgets or fundamentally flawed assumptions would ordinarily record objections immediately and seek corrective action.

 

47.                Instead, Navchetna continued to undertake plantation activities, submit implementation records and seek reimbursement without raising any such fundamental objections.

 

48.                The conduct of Navchetna therefore constitutes acquiescence in the project framework and acceptance of the contractual arrangements under which the parties operated.

 

49.                Navchetna is consequently estopped from alleging that the project structure itself rendered performance impossible.

 

50.                Equally, Navchetna is estopped from challenging the rates, budgets and reimbursement mechanisms voluntarily accepted and acted upon throughout the project duration.

 

51.                The doctrine of waiver equally applies. Any objection which could and ought to have been raised contemporaneously but was not raised is deemed to have been waived.

 

52.                The present allegations concerning pit-digging rates, plantation budgets, sapling quality, manure allocation, operational methodology and project design have surfaced only after legal liability has been asserted against Navchetna.

 

53.                Such belated allegations are incapable of displacing years of conduct evidencing acceptance of the project framework.

 

54.                Commercial contracts allocate risks between contracting parties.

 

55.                Under the MOU and related arrangements, SGIPL undertook responsibilities relating to project conceptualisation, funding mobilisation, stakeholder engagement and project oversight.

 

56.                Navchetna undertook responsibilities relating to field implementation, farmer engagement, labour deployment, plantation execution, maintenance, monitoring support, documentation and local operational management.

 

57.                The allocation of responsibilities was neither accidental nor incidental but formed the foundation of the contractual relationship.

 

58.                Navchetna cannot now seek to transfer implementation risks to SGIPL merely because implementation outcomes have proven unsatisfactory.

 

59.                A contractor cannot escape liability by asserting that the project owner monitored performance.

 

60.                A field implementation partner cannot avoid responsibility by asserting that project oversight existed.

 

61.                Such a proposition would destroy the very distinction between project ownership and project execution.

 

62.                The contractual framework must therefore be interpreted in a manner which preserves the responsibilities voluntarily assumed by each party.

 

63.                Any contrary interpretation would render the implementation obligations undertaken by Navchetna meaningless and commercially absurd.

 

64.                The burden of proving the allegations advanced in the Reply-Cum-Legal Notice rests squarely upon Navchetna.

 

65.                Mere assertions, suspicions, assumptions and generalized allegations cannot substitute documentary evidence.

 

66.                Allegations relating to poor sapling quality must be supported by contemporaneous records.

 

67.                Allegations relating to inadequate budgets must be supported by contemporaneous objections and financial analyses.

 

68.                Allegations relating to farmer dissatisfaction must be supported by farmer-wise records and complaints.

 

69.                Allegations relating to project impossibility must be supported by technical assessments and contemporaneous correspondence.

 

70.                Allegations relating to damages of Rs.20 Crores must be supported by audited computations and legally admissible evidence.

 

71.                To date, no such evidence has been furnished.

 

72.                The burden likewise rests upon Navchetna to explain the discrepancies between reported implementation figures and actual field outcomes.

 

73.                The burden further rests upon Navchetna to explain the non-production of labour records, PF records, ESIC records, salary registers, utilisation statements and supporting vouchers.

 

74.                Until such burden is discharged, the allegations contained in the Reply remain unsupported assertions devoid of evidentiary value.

 

75.                SGIPL further states that no party is entitled to retain benefits arising from contractual performance while simultaneously disclaiming accountability for the obligations attached thereto.

 

76.                Any reimbursement received for designated project purposes necessarily carried corresponding obligations concerning utilisation, accounting, transparency and record maintenance.

 

77.                Where funds have been entrusted for specific purposes, the recipient bears a continuing obligation to account for such funds.

 

78.                Failure to account gives rise to an independent cause of action for recovery, restitution and rendition of accounts.

 

79.                To the extent project funds, labour reimbursements or operational allocations have not been properly accounted for, Navchetna remains liable to restore, refund and reconcile the same.

 

80.                SGIPL expressly reserves its right to seek rendition of accounts, tracing of funds, forensic examination of transactions and recovery of all amounts found due upon reconciliation.

 

81.                The allegation that SGIPL has acted maliciously, coercively or with any ulterior motive is denied.

 

82.                Throughout the project duration, SGIPL extended repeated opportunities to Navchetna to rectify deficiencies, improve performance, furnish records and address implementation concerns.

 

83.                The Legal Demand Notice dated 21.05.2026 was not issued precipitously but only after extensive review, reconciliation, discussions and examination of project records.

 

84.                The notice was issued in good faith, for protection of legitimate commercial interests and for securing accountability concerning substantial project funds and project outcomes.

 

85.                The issuance of such notice constitutes a lawful exercise of contractual and legal rights and cannot be characterised as defamation, coercion or harassment.

 

86.                The allegations to the contrary are rejected in their entirety.

 

87.                Accordingly, SGIPL reiterates that the Reply-Cum-Legal Notice dated 01.06.2026 is devoid of merit, unsupported by contemporaneous evidence, contrary to the contractual record and liable to be rejected in toto.

 

88.                SGIPL states that the gravamen of the present dispute is not merely plantation execution but the systematic failure of Navchetna to discharge the obligations entrusted to it under the project framework and the subsequent attempts to conceal, minimize and mischaracterize the consequences of such failure.

 

89.                The project was conceived and implemented as a long-term agroforestry and carbon-sequestration initiative, the success of which depended not merely upon plantation activity but upon the actual survival, maintenance, growth and sustainability of the plantations.

 

90.                Mere plantation of saplings was never the contractual objective. The objective was the creation of viable, surviving and measurable plantations capable of generating ecological, environmental, commercial and carbon-related outcomes.

 

91.                Consequently, survival percentages constituted one of the most fundamental performance indicators under the project.

 

92.                The obligations relating to maintenance, monitoring, protection, replacement, gap-filling, watering support, farmer engagement, survival management and field supervision were inseparably linked with the implementation responsibilities undertaken by Navchetna.

 

93.                The material available with SGIPL demonstrates that the actual survival outcomes were substantially below the levels represented during project implementation.

 

94.                The discrepancy between reported implementation figures and actual field outcomes raises serious concerns regarding the accuracy of records, certifications and progress reports submitted by Navchetna.

 

95.                Despite repeated opportunities, Navchetna has failed to furnish authenticated survival reports capable of demonstrating compliance with the expected survival benchmarks.

 

96.                The failure to produce such records gives rise to a strong and legitimate inference that the actual survival figures were known to be significantly lower than the figures reflected in project reporting.

 

97.                The obligation to maintain accurate records was not a mere procedural requirement but formed an essential component of the trust reposed in Navchetna.

 

98.                Project owners, investors, stakeholders, environmental partners and funding institutions necessarily relied upon implementation records supplied by field partners such as Navchetna.

 

99.                Any inaccuracy, suppression, exaggeration or concealment within such records has consequences extending far beyond the immediate contractual relationship.

 

100.             The failure to disclose actual survival conditions in a timely manner prevented SGIPL from undertaking corrective measures, deploying alternative strategies and mitigating losses at an earlier stage.

 

101.             Had the true extent of plantation mortality and implementation deficiencies been disclosed promptly and accurately, remedial interventions could have been undertaken before irreversible losses occurred.

 

102.             Navchetna's conduct therefore directly contributed not only to project failure but also to the escalation of losses suffered by SGIPL.

 

103.             Throughout the course of implementation, Navchetna remained under a continuing duty to disclose all material facts affecting project performance.

 

104.             Such duty included disclosure of plantation mortality, farmer dissatisfaction, labour shortages, survival concerns, maintenance deficiencies, logistical failures, operational difficulties and other matters materially affecting project outcomes.

 

105.             A contracting party entrusted with field implementation cannot remain silent regarding material deficiencies and thereafter seek to rely upon those very deficiencies as a defence.

 

106.             The Reply-Cum-Legal Notice repeatedly refers to alleged problems relating to sapling quality, manure availability, labour shortages, transportation constraints and field conditions.

 

107.             Significantly, however, Navchetna has failed to produce contemporaneous documentary evidence establishing that such matters were disclosed with the seriousness now sought to be attributed to them.

 

108.             The absence of such contemporaneous disclosures strongly suggests that the present allegations have been reconstructed after the emergence of legal disputes.

 

109.             A party cannot remain silent during implementation, continue receiving reimbursements and thereafter rely upon previously undisclosed grievances to avoid liability.

 

110.             Such conduct is contrary to the principles of good faith, transparency and fair dealing which govern commercial relationships.

 

111.             The losses suffered by SGIPL extend beyond the direct financial disbursements made under the project.

 

112.             SGIPL has incurred substantial costs towards project planning, technical support, project management, stakeholder engagement, compliance activities, monitoring mechanisms, technology deployment, audits, verification exercises and remedial interventions.

 

113.             SGIPL has further incurred losses arising from project underperformance, reduced survival outcomes, reputational exposure, stakeholder concerns, investor scrutiny and the necessity of undertaking corrective measures.

 

114.             To the extent such losses arose directly or indirectly from the acts, omissions, misrepresentations, reporting deficiencies or implementation failures attributable to Navchetna, SGIPL reserves its right to seek complete compensation and indemnification.

 

115.             The quantification presently reflected in the Legal Demand Notice is based upon information presently available and remains subject to revision upon production of records and completion of reconciliation exercises.

 

116.             SGIPL expressly reserves its right to enhance, modify, amend or supplement its claims upon discovery of additional facts and documents.

 

117.             Navchetna is under a continuing obligation to render true, correct and complete accounts concerning all project-related receipts, reimbursements, expenditures and financial transactions.

 

118.             Such obligation survives termination of the commercial relationship and remains enforceable until full reconciliation is completed.

 

119.             The mere denial of liability does not extinguish the duty to account.

 

120.             Until complete accounts are rendered and supporting documents are produced, SGIPL shall remain entitled to seek detailed scrutiny of all project-related transactions.

 

121.             Any deficiency, inconsistency or discrepancy discovered upon such scrutiny shall constitute an independent ground for recovery and appropriate legal proceedings.

 

122.             In the circumstances, SGIPL reiterates that the conduct of Navchetna demonstrates substantial breaches of contractual obligations, failure of transparency, suppression of material facts, failure to account for entrusted resources and failure to achieve the survival outcomes which formed the very foundation of the project.

 

123.             Accordingly, Navchetna remains liable to account for its conduct, reconcile the project records, compensate SGIPL for losses suffered and answer the serious discrepancies identified in the Legal Demand Notice and reiterated in the present Rejoinder.

 

SGIPL further calls upon Navchetna to immediately preserve and refrain from destroying, altering, manipulating or suppressing any books of accounts, vouchers, invoices, payroll records, PF records, ESIC records, plantation registers, geo-tagging records, MIS records, photographs, correspondence, bank statements, GPS data, attendance registers and all other project-related records, failing which appropriate adverse inference shall be sought before the competent forum.

 

SGIPL reiterates and reaffirms each and every allegation, contention, claim, demand and reservation contained in the Legal Demand Notice dated 21.05.2026.

 

SGIPL further reiterates its claim for recovery of losses presently quantified at approximately Rs.13,20,00,000/- (Rupees Thirteen Crores Twenty Lakhs only), together with interest, costs, damages and such additional amounts as may be determined upon reconciliation, forensic audit and production of records.

 

It is pertinent to say that the total programme scope entrusted to Navchetna comprised approximately 42 lakh plantation interventions and approximately 25 lakh replantation interventions, aggregating to approximately 67 lakh interventions. The estimated surviving saplings presently stand at approximately 10 lakh, and the estimated failed / non-surviving saplings are therefore approximately 57 lakh, representing approximately 85% failure of the entrusted scope. Any reference, in prior without-prejudice discussions, to a reduced shortfall (including the conservative figure of approximately 35 lakh adopted for the interim computation below) was made solely for settlement purposes and does not dilute the actual field-verification and mortality assessment presently available with SGIPL.

 

For clarity of reconciliation: aggregate deployment towards management fees and the plantation / project accounts stands at approximately Rs. 13,71,89,494/-; aggregate programme deployment at the SGI Group level (inclusive of associated entities) is approximately Rs. 14.30 Crore; and the present interim claim is Rs. 13.20 Crore. The aforesaid figures exclude the independent economic value and cost of the saplings supplied separately by SGIPL, the entire expenditure for which was incurred directly and independently by SGIPL over and above the aforesaid amounts. The interim computation is set out below and is conservative, provisional and subject to enhancement upon forensic audit.

 

Sl.	Head of Claim	Basis / Computation	Amount (Rs.)
A	Saplings cost	Cost of replacement saplings for approx. 35 lakh failed saplings, conservatively at Rs. 12 per sapling (35,00,000 × Rs. 12).	4,20,00,000/-
B	Restitution / recovery of misutilised payments (alternative head, not in addition)	Out of total payments of Rs. 13,71,89,494/-, the amount attributable to failed / dead saplings on a conservative, proportionate basis (approx. 85% mortality). Claimed in the alternative to Heads A and C, not in addition.	11,66,11,070/-
C	Replantation, gap-filling, maintenance and corrective plantation cost	Gap-filling, corrective plantation, post-plantation maintenance, watering, monitoring, transportation, labour and initial care for approx. 35 lakh saplings, conservatively at Rs. 20 per sapling (35,00,000 × Rs. 20).	7,00,00,000/-
D	Forensic audit, expert valuation, supervision, quality control and remediation costs	Forensic audit, technical / environmental valuation, independent field verification, survival assessment, quality control, supervisory deployment and incidental remediation.	2,00,00,000/-
E	INTERIM TOTAL (A + C + D; Head B claimed in the alternative, not in addition)	Exclusive of interest, legal costs and further / consequential damages; subject to enhancement.	13,20,00,000/-

 

Accordingly, SGIPL's interim quantified claim is Rs. 13,20,00,000/- (Rupees Thirteen Crore Twenty Lakh only), together with interest at 18% per annum from the respective dates of breach and payment until full realisation, Head B being claimed strictly in the alternative to Heads A and C and not in addition thereto. The counterclaim of Navchetna for Rs. 20 crore is rejected as false, remote, speculative and barred under Section 73 of the Indian Contract Act, 1872. SGIPL reserves its right to claim additional damages towards reputational loss, stakeholder disruption, costs, statutory exposure, environmental damage and consequential losses.

 

Hence,

 

Navchetna is called upon to;

 

a. Withdraw all false, misleading and defamatory allegations made against SGIPL;

b. Cease and desist from circulating unverified allegations amongst SGIPL's investors, partners, stakeholders and associated organizations;

c. Preserve all project-related records;

d. Produce the records demanded herein;

e. Reconcile all project-related accounts;

f. Cooperate with audit and verification processes;

g. Remedy the breaches and defaults identified by SGIPL.

 

In the event of failure to comply with the aforesaid demands within seven (7) days from receipt of this Rejoinder, SGIPL shall proceed to take such arbitral, civil, criminal, regulatory and other legal actions as may be advised, entirely at the risk as to costs and consequences of Navchetna.

 

The Reply-Cum-Legal Notice dated 01.06.2026 and the email communication dated 01.06.2026 are hereby denied, disputed and rejected in toto as being false, misleading, evasive, unsupported by contemporaneous records and legally untenable.

 

All rights and remedies available to SGIPL in law and equity, whether civil, criminal, arbitral, contractual or statutory, are hereby expressly reserved.

 

You are therefore advised to treat this matter as MOST URGENT.

 

Thanking you,

 

Yours faithfully,

 

 

Ashok Kumar Singh

Advocate

High Court Calcutta

 

Copy to;

 

1.   Mr. Mukesh Kumar Pandey, Chief Executive Officer, Navchetna Agro Center Producer Company Limited, House No. 233,  Bitthalapur Sikhar, Mirzapur – 231306, Uttar Pradesh, Email: mukesh.sikhar@gmail.com

 

2.   M/s. Navchetna Agro Center Producer Company Limited, House No. 233, Bitthalapur Sikhar, Mirzapur – 231306, Uttar Pradesh, Phone No.: 919956603894, Email: navchetnafpo@gmail.com

 

3.   Umesh Chandra Pandey, Director (DIN: 08321860), M/s. Navchetna Agro Center Producer Company Limited, House No. 233, Bitthalapur Sikhar, Mirzapur – 231306, Uttar Pradesh, Phone No.: 919956603894, Email: navchetnafpo@gmail.com

 

4.   Rajni Kant Pandey, Director (DIN: 08321873), M/s. Navchetna Agro Center Producer Company Limited, House No. 233, Bitthalapur Sikhar, Mirzapur – 231306, Uttar Pradesh, Phone No.: 919956603894, Email: navchetnafpo@gmail.com

 

5.   Akhilesh Kumar Tripathi, Director (DIN: 08344648), M/s. Navchetna Agro Center Producer Company Limited, House No. 233, Bitthalapur Sikhar, Mirzapur – 231306, Uttar Pradesh, Phone No.: 919956603894, Email: navchetnafpo@gmail.com

 

6.   Tushar Pandey, Director (DIN: 08891335), M/s. Navchetna Agro Center Producer Company Limited, House No. 233, Bitthalapur Sikhar, Mirzapur – 231306, Uttar Pradesh, Phone No.: 919956603894, Email: navchetnafpo@gmail.com

 

7.   Anju Shukla, Director (DIN: 09168700), M/s. Navchetna Agro Center Producer Company Limited, House No. 233, Bitthalapur Sikhar, Mirzapur – 231306, Uttar Pradesh, Phone No.: 919956603894, Email: navchetnafpo@gmail.com

 

8.   Vishal Kumar Pandey, Director (DIN: 10320794), M/s. Navchetna Agro Center Producer Company Limited, House No. 233, Bitthalapur Sikhar, Mirzapur – 231306, Uttar Pradesh, Phone No.: 919956603894, Email: navchetnafpo@gmail.com

 

9.   M/s. Samunnati Financial Intermediation & Services Private Limited, Baid Hi Tech Park, 8th Floor, No 129 B, East Coast Road, Thiruvanmiyur , Chennai, Tamil Nadu, India – 600041, Email ID: secretarial@samunnati.com

 

10.                M/s. Nabkisan Finance Limited, 3RD FLOOR, NANARD REGIONAL OFFICE BUILDING,NO.48 MAHATMA GANDHI ROAD, NUNGAMBAKKAM, , CHENNAI 600034, Tamil Nadu, India – 600034, Email ID: finance@nabkisan.org

 

11.                HDFC Bank Limited, HDFC BANK HOUSESENAPATI BAPAT MARG LOWER PAREL W , MUMBAI, Maharashtra, India – 400013, Email ID: santosh.haldankar@hdfcbank.com

 

12.                Umesh Chandra Pandey, Village Bitthalpur, Sikhar, Chunar, Mirzapur – 231306, Uttar Pradesh.

 

13.                Ranji Kant Pandey, Sikhar, Mirzapur Sadar – 231306, Uttar Pradesh.

 

14.                Akhilesh Kumar Tripathi, Village – Goraiya, Post Office – Sikhar, Mirzapur – 231306, Uttar Pradesh.

 

15.                Tushar Pandey, Village – Sikhar, Mirzapur – 231306, Uttar Pradesh.

 

16.                Anju Shukla, House No. B38/113-3, Tulsipur, Mahmoorganj, Post Office – Mahmoorganj, Chhitupur, Varanasi – 221010, Uttar Pradesh.

 

17.                Vishal Kumar Pandey, Village – Sikhar, Mirzapur Sadar – 231306, Uttar Pradesh.

{for information and necessary action} only.