AGARWAL LAW ASSOCIATES Advocates Supreme Court EC Agrawala | Mahesh Agarwal | Rishi Agrawala | Shally Bhasin by Gpostos MD 17, 2016 Mr, Suren Uppal Advocate: 26 Sector 49 NOIDA 201301 Dear Sir, This is with reference to your letter dated 2 March, 2016 addressed to our clients Mr Shashi Ruia, Mr Ravi Ruia, Mr Prashant Rua and Mr Anshuman Ruia and the management of Essar India Ltd and under their instructions, we address. you the following notice: 1. At the outset our clients deny each and every allegation, statement and assertion made by your clients in the caution notice. The allegations are completely false and incorrect. Obviously these false and incorrect allegations have been made with a malafide objective of pressurizing our clients and / or causing loss and damage and are extortionist in nature, 2, Tho allegations in the letter are principally based on the assumptions as stated in your letter that our client informed you in the very first month of operations in the year 2001 that BPL is a subsidiary of Essar Group and further that Hutchison was under the control of and management of our clients and could therefore direct these companies to act as per their instructions, Both these assumptions are patently and factually Incorrect, The question therofore of our clients in any manner being a party to or being involved in any manner whatsoever in the various actions attributed \\ organ tice, 9, Bab on, Gergal Market, New Dts "10008 | Phone +91 11 47200006, 23721400 | Fax ~91 1142200000 ‘orale Practice Oftcr 34 Babar Lane, Bangali Markat New Del: 110001 | Phono +91 14 23854330. 23738122 [fax «01.11 23360586 ‘Chamber 48, Layers Chamber, Supreme Cout of indo. New Doth -*1000' | Phones: +81 11 23382318, 25389629 Fmat: maleaglawin| Fan. +09 14 66172033AGARWAL LAW ASSOCIATES by you to them in the notice therefore could not and does not arise. Everything else therefore you have stated in your fetter is obviously contrived, concocted and false. With regard to the professional services rendered by your client the same would be as per the employment agreement and any other allegations of any other services as alleged is therefore out of the question. The allegations are completely denied. It therefore follows that any question of our clients contacting you for the purpose of interception, tapping and recording or for conducting any surveillance by using telecom and IT infrastructure of the company or otherwise, does not arise. With regard to allegations relating to Mr Shishir Aganwal-The allegations that our alients informed your client that Mr. Shishir Agrawal would facilitate the aforementioned operations by providing logistical support is also wrong and completely denied. Our clients have verified with Mr. Shishir Agrawal who has denied that he had any meeting with your client in 2015 and the same is also a concocted story. It is more than evident that your clients have made deliberately, malicious, scandalous and patently false allegations against our clients for motivated and malafide reasons which we suspect could be al the behest of certain third parties interested in causing damage to our clients’ name and reputation. Under the circumstances, we call upon you to unconditionally withdraw the notice. Our clients reserve the right and liberty to seek appropriate legal action against your client for making false, malicious and \\,AGARWAL LAW ASSOCIATES scandalous allegations. Needless to say that if your clients initiate or ‘commence any action as alleged by you in your caution notice, the same would be strongly defended by our clients at the risk and cost of your dlient. Yours faithfully, For AgarwahLaw Associates yw MAHESH AX L