Final Suit With Documents

IN THE HIGH COURT OF DELHI AT NEW DELHI
(CIVIL ORIGINAL JURISDICTION)
CS(OS) NO.______ OF 2021
IN THE MATTER OF:

SREI Infrastructure Finance Ltd. & Ors. ...Plaintiffs
Versus
International Media Corporation & Ors. ...Defendants
COMBINED INDEX
PART –I
S.NO PARTICULARS PG. NO

1. Index to Part I 1
2. Suit Format 2-3
3. Urgent Application 4
4. Notice of Motion 5
5. List of Dates 6-8
6. Memo of Parties 9-12
7. Suit for permanent and mandatory injunction
alongwith affidavits 13-61
8. Certificate of authentication Under Section 65B of the
Indian Evidence Act, 1872 62-64
9. Court Fees and One Time Proses Fee 65-66
PART -II

1. Index to Part II 1-2
2. IA No.____________ of 2021:
Application on behalf of the Plaintiff under Order 39 Rule 3-15
1 & 2 read with Order 26 Rule 9 read with Section 151 of
the Code of Civil Procedure, 1908 along with affidavit.
3. IA No.____________ of 2021:
Application on behalf of the Plaintiff under Order 2 Rule
16-21
2 read with Section 151 of the Code of Civil Procedure,
1908 along with affidavit.
4. IA No.____________ of 2021:
Application under Section 151 of the Code of Civil
Procedure, 1908 on behalf of the plaintiffs for 22-26
exemption from filing original and/or certified copies of
the documents, typed copies of the documents which
are dim, illegible and do not have proper left hand
margin along with affidavit.
5. IA No.____________ of 2021:
Application on behalf of the Plaintiff under Section 149
27-31
read with Section 151 of the Code of Civil Procedure,
1908 for extension of time for filing Court Fees along
with affidavit.
PART -III

1. Index to Part III 1
2. Vakalatnama 2
PART IV
S.N Document Details of Document in Originals or Mode of Line of Pg.

o. Parties to power, photocopies execution/issua custody No.
the possession, or office nce or receipt
documents control and copies
custody of
1. INDEX PART -IV 1-6

2. Document Plaintiff No. Plaintiff No. Photocopy Signed by the Plaintiff
No.1: Board 1 1 Board of the No. 1 7-9
Resolution Director of the
dated Plaintiff
14.12.2020
3. Document Plaintiff No. Plaintiff No. Electronic Registered and Plaintiff

No. 2:Special 2 2 Record signed by No.2 10-
Power of Plaintiff No.2. 13
Attorney of
Plaintiff No. 2
4. Document Plaintiff No. Plaintiff No. Electronic Registered and Plaintiff

No.3:Special 3 3 Record signed by No.3 14-
Power of Plaintiff No. 3 17
Attorney of
Plaintiff No. 3
5. Document Plaintiffs Plaintiffs Electronic Email issued by Plaintiffs

No.4: record employee of 18
Screenshots of Plaintiffs
fraudsbreaking
6. Document Plaintiff and Plaintiffs and Electronic Email issued by Plaintiffs

No.5:Article Defendants Defendants record an employee of and 19-
dated the Plaintiffs Defendants 38
14.12.2020
7. Document Plaintiff and Plaintiff and Electronic Email issued by Plaintiff

No.6:Press Defendants Defendants record an employee of and 39-
Statement the Plaintiff Defendants 53
dated
14.12.2020
8. Document No Plaintiff and Plaintiffs and Electronic Email issued by Plaintiffs

7: Video dated Defendants Defendants record an employee of and 54
14.12.2020 the Plaintiff Defendants
9. Document Plaintiffs & Plaintiffs and Electronic Email issued by Plaintiffs
No. 8 : Defendants Defendants record an employee of and 55-
Transcript of the Plaintiff Defendants 64
the Video
dated
14.12.2020
10. Document Plaintiffs and Plaintiffs and Electronic Email issued by Plaintiffs
No.9:Video Defendants Defendants record an employee of and 65
dated the Plaintiff Defendants
15.12.2020

No. 10: Record an employee of 66
Screenshot of the Plaintiffs
Malya, Nirav
Modi and Lalit
Modi
No. 11: record an employee of 67
Screen the Plaintiff
shot of Lady
Justice

Indian
Currency

Animated
chess

No. 14: Record an employee of 70
Tip of the
Iceberg

No. Record an employee of 71
15:Screenshot the Plaintiffs
of Pictures of
Kanoria
Family
No. 16:List of Record an employee of 72-
URLs the Plaintiffs 73
No.17: Record an employee of 74-
Domain the Plaintiffs 75
information of
scamsbreaking
.com(Who is)
No. 18: record an employee of 76-
Domain the Plaintiffs 77
information of
fraudsbreaking
.com(Who is)
20. Document Defendant Plaintiffs and Electronic Email issued by Plaintiffs

No. No. 1 Defendant record an employee of 78-
19:Privacy No. 1 the Plaintiff 93
Policy of
Defendant No.
1
No. Record an employee of 94-
20:Privacy the Plaintiff 120
Policy of
Warnermedia
No. 21: record an employee of 121-
Australian the Plaintiff 122
Securities and
Investments
Commission
Database
23. Document Plaintiff No. Plaintiff No. Photocopy Email issued by Plaintiff
No. 1 1 an employee of No.1 123-
22:Certificate the Plaintiff No. 125
of 1
Incorporation
dated
04.08.2004
24. Document Plaintiff No. Plaintiff No. Electronic Email issued by Plaintiff
No. 1 1 record an employee of No. 1 126
23:Brochures/ the Plaintiff
Awards &
Accolades of
SIFL
25. Document Plaintiff No. Plaintiff No. Photocopy Email issued by Plaintiff
No. 24:Big 1 1 an employee of No. 1 127
Deals of SIFL the Plaintiff
26. Document Plaintiffs Third Party Electronic Prepared by the Third Party
No. 25: Press record Third Party 128
Statement
issued by Axis
Bank

Screenshot of the Plaintiff No.
Address being 1
Airport
Address
28. Document Plaintiff Plaintiff No. Office copy Prepared by the Plaintiff
No. 27: No.1 1 Plaintiff No. 1 No. 1 130-
Complaint 138
dated
14.12.2020
filed before
DCP, Cyber
Crime Cell,
New Delhi
29. Document Plaintiff Plaintiff No. Office copy Prepared by the Plaintiff
No. 28: No.1 1 Plaintiff No. 1 No. 1 139-
Complaint 171
dated
15.12.2020
filed before
DIG, Cyber
CID West
Bengal Police
30. Document Plaintiff No. Advocates of Office copy Prepared by the Plaintiff
No. 29: Copy 1 the Plaintiffs advocates of the No. 1 172-
of Cease and Plaintiff No. 1 177
Desist Notice
dated
05.01.2021
31. Document Plaintiffs and Defendant Electronic Email issued by Defendant

No. 30: Copy Defendant No. 5 Record Defendant No. 5 No. 5 178
of email of No. 5
Defendant No.
5 dated
13.01.2021

No.31: Copy Defendant No. 5 Record Defendant No. 5 No. 8 179-
of email of No. 8 181
Defendant No.
8 dated
15.01.2021
33. Document Plaintiff Plaintiff Office copy Prepared by the Plaintiff
No. 32: Copy Plaintiff 182-
of email dated 192
29.12.2020

No.33: Copy the No. 1 record Defendant No. 1 No. 1 193-
of emails Defendant 202
dated No. 1
12.01.2021

No.34: Copy the No. 1 record Defendant No. 1 No. 1 203-
of emails Defendant 240
dated No. 1
18.01.2021
36. Document Plaintiff No. Plaintiff No. Electronic Prepared by the Plaintiff
No.35: Master 1 1 record Plaintiff No. 1 No. 1 241-
data of SREI 249
37. Document Third party Third party Electronic Prepared by Third party
No.36: Master record third party 250-
data of BRNL 251
Master data of
SREI
38. Document Defendant Defendant Electronic Prepared by Defendant
No.37: No. 2 No. 2 record Defendant No. 2 No. 2 252-
Inappropriate 254
Content policy
of Google
PLAINTIFF
Through
ARJUN SYAL/MANJIRA DASGUPTA/AKSHITA

SACHDEVA/SHREYAN DAS
SYAL&CO
Advocates for the Plaintiffs
Address – E-34, Greater Kailash Enclave – II,
New Delhi – 110048
Mobile No.: 9439349298
Email Id – syalandcompany@gmail.com
Place: New Delhi
Date: 22.01.2021
001
CS(OS) NO.______ OF 2021
IN THE MATTER OF:

Versus
INDEX PART –I

1. Index to Part I 1
2. Suit Format
2-3
3. Urgent Application
4
4. Notice of Motion
5
5. List of Dates 6-8
6. Memo of Parties 9-12
7. Suit for permanent and mandatory injunction alongwith
affidavits 13-61
8. Affidavits under Order XI Rule 6(3) of the Code of Civil
Procedure, 1908
62-64
9. Court Fees and One Time Proses Fee 65-66
PLAINTIFF
Through

SYAL&CO
Mobile No.: 9439349298
Place: New Delhi

Date: 22.01.2021
002

CS(OS) NO.______ OF 2021
IN THE MATTER OF:

Versus
STATUS INVOKED: Suit for permanent and mandatory injunction
ADVOCATES
Arjun Syal/Manjira Dasgupta/ Akshita Advocates for the Defendants

Sachdeva/ Shreyan Das
Advocates for the Plaintiff
E-34, Greater Kailash Enclave II, New

Delhi-110048
Mobile No.: +91- 9818408503,
9717977915, 9953849298,
7838388837, 9971322560
E-mail: syalandcompany@gmail.com
INTERLOCUTORY APPLICATIONS (IAS)
S.No Year Filed by Provisions of Law Nature of Remarks

Plaintiff/ Relief
Defendant
1. 2021 Plaintiff Under Order 39 Rules 1 & 2 Interim
read with Order 26 Rule 9 read Reliefs
with Section 151 of the CPC
2. 22021 Plaintiff Under Order 2 Rule 2 read with Leave to
Section 151 CPC sue for
reliefs at a
later stage
3. 2021 Plaintiff Under Section 151 of CPC Exemption
003
from filing
original/cer
tified
copies of
documents
4. 2021 Plaintiff Under Section 149 of CPC Extension
of time for
filing court
fees
004
CS(OS) NO.______ OF 2021
IN THE MATTER OF:

Versus
URGENT APPLICATION
To
The Registrar
High Court of Delhi
Sir,
Will you kindly treat the accompanying Suit as an urgent one in
accordance with the High Court Rules and Orders.
The grounds of urgency are mentioned in the accompanying Suit and
Applications.
Thanking You
PLAINTIFF
Through

SYAL&CO
Mobile No.: 9439349298
Place: New Delhi

Date: 22.01.2021
005
CS(OS) NO.______ OF 2021
IN THE MATTER OF:

Versus
NOTICE OF MOTION
Sir,
The enclosed Suit in the aforesaid matter is being filed on behalf of
the Plaintiff and is likely to be listed on 01.02.2021 or any date thereafter.
Please take notice accordingly.
PLAINTIFF
Through

SYAL&CO
Mobile No.: 9439349298
Place: New Delhi

Date: 22.01.2021
006
DATE EVENTS
31.08.2020 The domain name www.scamsbreaking.com
www.fraudsbreaking.com were registered with
PublicDomainRegistry.com. For
www.scamsbreaking.com, the Registrant Contact
Information, Administrative Contact Information and
Technical Contract Information are hidden and only
provides “10 Corporate Drive, Burlington, MA, US”
as the address which are the details of Privacy Protect
LLC. For www.fraudsbreaking.com, the Registrant
Contact Information, Administrative Contact
Information and Technical Contract Information are
International Media Corporation i.e., Defendant No.1
and provides“Australia Square, Level, Plaza, Sydney,
New South Wales, AU as the address with a phone
no. “+61.123456789”, which is an incorrect number.
14.12.2020 The Defendant No. 1 published the malicious,
reckless, derogatory and defamatory Article and
Video in its website i.e scamsbreaking.com and in
various social media platforms of the Defendants No.
2 to 11.
14.12.2020 Plaintiff No. 1 filed a complaint with the Deputy
Commissioner of Police, Cyber Crime Cell,
Government of India, New Delhi and pursuant to the
same action was taken by the concerned authorities
pursuant to which certain links were removed and or
made inactive.
007
15.12.2020 Plaintiff No. 1 filed a complaint dated 15.12.2020 at

DIG Cyber CID West Bengal Police.
Defendant No. 1 published another video on its
YouTube channel titled “Who’s Next | The Biggest
Expose Continues”.
Axis Bank by way of a press release dated 15.12.2020

clarified that Defendant No.1 has published the
Videos and Article without any due diligence and
verification of the end use of the loan amounts. In
fact, Axis Bank further clarified that its outstanding
loan amount to SREI group and SREI entities stood at
about Rs. 1211 crores and not Rs. 44,000 crores as
alleged by Defendant No.1 in the impugned Videos
and the Article.
29.12.2020 The Defendant No. 1 issued a false and malicious
mail to various statutory, administrative and financial
bodies whereby it has made insinuating and
objectionable remarks against the Plaintiffs. The said
emails were issued with the sole intention to defame
and disparage the image, goodwill and credibility of
the Plaintiffs.
05.01.2021 The Plaintiffs also issued a Cease and Desist Notice
dated 05.01.2021 to the Defendants No. 2-11.
12.01.2021 The Defendant No. 1 once again issued a false and
malicious mail to various statutory, administrative and
financial bodies whereby it has made insinuating and
008
objectionable remarks against the Plaintiffs. The said

emails were issued with the sole intention to defame
and disparage the image, goodwill and credibility of
the Plaintiffs.
13.01.2021 Defendant No. 6 by way of an email responded to the
aforesaid Cease and Desist Notice dated 05.01.2021
stating that it is not in a position to take action based
on your defamation concerns at this time.
15.01.2021 Defendant No. 8 by way of an email responded to the
aforesaid Cease and Desist Notice dated 05.01.2021
stating that it shall notify the user of the account
regarding the Cease and Desist Notice and thereafter,
it would also forward a copy of the notice the reported
user within one business day so they can decide
whether to respond to the Plaintiff directly,
voluntarily remove the reported content, or take some
other action.
18.01.2021 The Defendant No. 1 again issued a false and
malicious mail to various statutory, administrative and
financial bodies whereby it has made insinuating and
objectionable remarks against the Plaintiffs.
Hence the present Suit.

009

(ORDINARY ORIGINAL CIVIL JURISDICTION)
C.S. (OS) No.________ OF 2021
IN THE MATTER OF:
SREI Infrastructure Pvt. Ltd. & Ors. ...Plaintiff
Versus
International Media Corporation & Ors. ..Defendants
MEMO OF PARTIES
1. SREI Infrastructure Finance Ltd. Plaintiff No. 1

Through its authorized representative
Mr. Shiv Shankar Chowdhury
having office at D-II, Southern Park,
5th Floor, Saket Place, Saket, New Delhi-110017
Email: corporate@srei.com
2. HemantKanoria Plaintiff No. 2

S/o Mr.Hari Prasad Kanoria
86C, Topsia Road (South)
Kolkata 700046
Through Special Power of Attorney Holder
5th Floor, Saket Place, Saket, New Delhi-
110017
Email: shiv.chowdhury@srei.com
3. Sunil Kanoria Plaintiff No. 3

S/o Mr.Hari Prasad Kanoria
86C, Topsia Road (South)
010
Kolkata 700046
Through Special Power of Attorney Holder
5th Floor, Saket Place, Saket, New Delhi-
110017
Email: shiv.chowdhury@srei.com
-Versus-
1. International Media Corporation Defendant No. 1

Scamsbreaking.com Through Mr. Shiv Raman
Head (Asia Pacific) Chief Officer Legal
Compliances 10 Arrivals Court, Level 8, The
Nigel Love Building Mascot Sydney -2020
Email: head.asiapacific@scamsbreaking.com
2. Google INC Defendant No. 2

1600, Ampitheatre Parkway,
Mountain View, CA 94043
USA
Email: support-in@google.com
3. Google India Pvt. Ltd. Defendant No. 3
Through Director
No 3, RMZ Infinity - Tower E,
Old Madras Road, 4th & 5th Floors,
Bangalore-560016, Karnataka
Email: APAC-CorpOrg.CS@google.com
4. Youtube LLC Defendant No.4

Email: legal@support.youtube.com
5. Facebook Inc/Facebook, Ireland, Defendant No. 5
Menlo Park, California, USA
Also at
Dublin, Ireland
Email:
011
case++aazttr66zn2ode@support.facebook.com
6. Facebook India Online Services Pvt. Ltd. Defendant No. 6

Unit Nos. 1203 and 1204, Level 12,
Building No.20, RahejaMindspace,
Cyberabad, Madhapur,
Hitech City, Hyderabad-500081,Telengana
Email: mailresponses@fb.com
7. Instagram Defendant No. 7

Building No.20, RahejaMindspace,
Hitech City, Hyderabad-500081,
Telengana
Email: support@instagram.com
8. Twitter International Company Defendant No. 8

One Cumberland Place
Fenian Street
Dublin 2
D02 AX07
Ireland
Email: support@twitter.com
9. Twitter Communications India Pvt. Ltd Defendant No. 9

C-20, G Block, Near MCA BandraKurla
Complex,
Bandra (E) Mumbai-400051, Maharashtra
Email: support@twitter.com
10. Linkedin Defendant No.10

1000 W Maude
Sunnyvale, CA 94085, US
Email: sks2@linkedin.com
012
11. Linkedin Technology Information Pvt. Ltd. Defendant No. 11

16A/20, WEA Main Ajmal Khan Road,
Karol Bagh New Delhi-110005
Email: sks2@linkedin.com
12. Ashok Kumar Defendant No. 12
PLAINTIFF
Through

SYAL&CO
Mobile No.:
9717977915/9971322560
Place: New Delhi

Date: 22nd January, 2021
013
C.S. (OS) No.________ OF 2021
IN THE MATTER OF:
M/s SREI Infrastructure Finance Ltd. & Ors. ...Plaintiffs
Versus
International Media Corporation &Ors. ...Defendants
SUIT FOR PERMANENT AND MANDATORY INJUNCTION
MOST RESPECTFULLY SHOWETH:
1. That the present suit is being filed through Mr. Shiv Shankar
Chowdhury who is the authorized signatory of the Plaintiff No. 1 and
the Special power of Attorney Holder of Plaintiff No. 2 and 3. Mr.
Shiv Shankar Chowdhury has also been duly authorized by Plaintiff
No. 1 to file the present suit by way of Board Resolution dated
14.02.2020. Further, Mr. Shiv Shankar Chowdhury has been duly
authorized by Plaintiff No. 2 and 3 by way of Special Power of
Attorneys dated 19.01.2021. Further, Mr. Shiv Shankar Chowdhury is
well conversant with the facts and circumstances of the present case
and is duly competent to file, sign, depose and conduct the present
suit on behalf of the Plaintiffs.

014
2. The Plaintiffs are constrained to approach this Hon‟ble Court by way
of the present suit against the malicious, reckless, malafide and
vindictive reporting of an alleged scam on a sham and bogus website
created by the Defendant No.1 namely
“www.scamsbreaking.com”andwww.fraudsbreaking.comwith the
sole intention of carrying out a smear campaign against the Plaintiffs
by uploading/sharing/dissemination of the
videos/URLs/Weblinks/article on the basis of false and misleading
facts/documents/information to the world at large whose genuineness
and veracity are highly questionable.
3. The Plaintiffs are aggrieved by an article concerning the Plaintiffs on
the website of Defendant No.1 titled as “Again Blindly Shell Crores
Of Public Money Without Any Due Verifications In Yet Another Huge
Scam Commissioned By Kolkata’s Kanoria Brothers.” dated
14.12.2020 being part of an exclusive expose series titled “20 Most
Heinous Scamster Families in India” (“Article”). The said Article
also contains a 27.12-minute-long Video titled “Biggest Expose of
the Year 2020 is Here” descriptively narrating the contents of the
article (“Video”). The Article also contains pictures of Plaintiffs.
4. It is pertinent to state that the imagery used throughout the Video
creates a false and exaggerated narrative against the Plaintiffs to

015
allege commission of certain crimes. For example, the video shows
exchange of brief cases in a covert manner; shows pictures of
fugitives like Mr.Nirav Modi and Mr. Vijay Mallya alongside
pictures of the Plaintiff No. 2 and Plaintiff No. 3 to create a narrative
that the Plaintiff No. 2 and Plaintiff No.3 are comparable with the
likes of Mr.Nirav Modi and Mr. Vijay Mallya; pictures of the Lady
Justice to insinuate that law is blind towards to the Plaintiffs; pictures
of burning Indian currency to suggest that public money is being
burnt at the behest of the Plaintiffs; animated images of two persons
playing chess to portray that the Plaintiffs are playing games with the
law, lending institutions, government authorities and the Indian
economy; shows pictures of an ice berg to allege that the content of
the Video only depicts a small fraction of alleged scams of the
Plaintiffs and there is much more to be unearthed; the Video
repeatedly shows pictures of the Kanoria family. Further, the
voiceover of the Video is by a male person with an Indian accent.
5. The contents of the Article and the Video are highly defamatory and
malicious. The Article and the Video deliberately tries to malign the
reputation of the Plaintiffs as also violate the fundamental rights of
the Plaintiffs guaranteed under the Constitution of India. The said
Video has been uploaded on various digital platforms belonging to
Defendant No. 2 to 11. The URLs/links of the said video is available

016
on numerous websites accessible through Google and other YouTube
Channels.
6. It is stated that upon basic preliminary enquiries/ investigation
conducted by the Plaintiffs on google to find out about the Defendant
No. 1‟s past journalistic endeavours as it claims to be a media,
publishing and broadcasting company based in Australia, the
existence of Defendant No.1 and its website is highly suspected for
the following reasons:
a. There is a similar website namely
www.fraudsbreaking.com. The getup of the website is
similar to the website www.scamsbreaking.com. Articles
relating to the Plaintiffs available on
“www.fraudsbreaking.com” are the same ones available on
“www.scamsbreaking.com”.
b. The address as mentioned on the Defendant No. 1‟s website
is not a real address. It appears that the address of the
Defendant No. 1 is that of “Regus Express-Sydney
International Airport”;
c. The domain name www.scamsbreaking.com was registered
with PublicDomainRegistry.com only on 31.08.2020. The

017
Registrant Contact Information, Administrative Contact
Information and Technical Contract Information are hidden
and only provides “10 Corporate Drive, Burlington, MA, US”
as the address which are the details of Privacy Protect LLC(
services availed to keep the information hidden);
d. The domain name www.fraudsbreaking.com was registered
with PublicDomainRegistry.com also on 31.08.2020. The
Registrant Contact Information, Administrative Contact
Information and Technical Contract Information are
International Media Corporation i.e., Defendant No.1 and
provides“Australia Square, Level, Plaza, Sydney, New South
Wales, AU as the address with a phone no.
“+61.123456789”, which is an incorrect number.;
e. The „privacy policy‟ of the Defendant No. 1 has been
plagiarized from a certain “warnermediagroup” to the extent
that the email addresses and the websites of the
“warnermediagroup” are still mentioned in the privacy policy
on the Defendant No.1‟s website;
f. ASIC (Australian Securities and Investments Commission)
portal does not contain the name of any entity registered by

018
the name of “International Media Corporation” i.e., the
Defendant No.1.
g. The news links available on the website of the Defendant No.
1 are only hyperlinks of other media houses and not original
news content created by the Defendant No. 1;
From the abovementioned, it is evident that the Defendant No. 1
has absolutely no journalistic credentials and is a sham and bogus
entity which has been created with the sole purpose of running the
present defamatory campaign against the Plaintiffs.
7. It is stated that the Article and the Video are not in the pursuit of
genuine and meaningful investigative journalism and the contents of
the Article and Video are even otherwise an abuse of freedom of
speech, which is a right not available to Defendant No. 1 being a
foreign entity.
8. Further, the act of publishing the Impugned Article and Video by the
Defendant No.1 oversteps the principles of journalistic conduct. The
Article and Video against the Plaintiffs are accusatory in nature,
wherein the Defendant No.1 has tried to portray the Plaintiffs guilty
of certain financial irregularities. The acts of the Defendant No.1 are
motivated with the sole intention to sensationalize and spread

019
misinformation and thereby defame the goodwill and standing of the
Plaintiffs before the world at large.
9. It is stated that the vitriolic campaign undertaken by the Defendant
No. 1 against the Plaintiffs and the publication/dissemination of the
Impugned Article and Video by Defendant No.1 against the Plaintiffs
allowing the uploading/sharing/dissemination of the
videos/URLs/Weblinks/article by the Defendant Nos. 2 to 11 are
violative of the fundamental rights of the Plaintiffs‟ such as right to
carry out its businesses under Article 19(1)(g) and the Plaintiff No. 2
and 3‟s right to live with dignity, reputation as well as right to fair
administration of justice as guaranteed under the Constitution of India
and other laws of India. The said actions on the part of the
Defendants are guaranteed under Article 21 of the Constitution of
India.
Parties:
10. The Plaintiff No. 1 M/s SREI Infrastructure Finance Ltd.(“SIFL”) is
a leading Non-Banking Financial Institution registered as a Non-
Banking Financial Company (NBFC) with the Reserve Bank of India
(RBI) and is classified as an Infrastructure Finance Company.
Plaintiff No.1 has also been notified as a Public Financial Institution
under Section 4A of the Companies Act, 1956, by the Ministry of

020
Corporate Affairs, Government of India. Further Plaintiff no.1 is one
of India's leading asset finance and leasing institutions, constantly
and consistently delivering innovative solutions in the infrastructure
sector. SIFL is the holding company and its 100% wholly owned
subsidiary SREI Equipment Finance Limited (SEFL) has been
making significant contribution to the economy and has received
numerous awards and recognitions.
11. Plaintiff No. 2, Mr.Hemant Kanoria is one of the leading
industrialists and business icons of India and is the Chairman-cum-
Managing Director of Plaintiff No. 1. He is a pioneer in the private
infrastructure sector and has reshaped India's infrastructure landscape
with innovative ideas and a strong passion for excellence. He is also
known for unleashing the wave of rural entrepreneurship in India.
12. Plaintiff No. 3, Mr. Sunil Kanoria is the Vice-Chairman of Plaintiff
No. 1 Company and is a leading business icon, in the field of
infrastructure development and financing. Plaintiff No. 3 is a law-
abiding citizen who is actively involved with several governmental
and non-governmental organizations lending his expertise for the
growth and development in his field.

021
13. During the year under review, the Plaintiff No. 1 has received the
following awards and recognitions;
 Great Place to Work-Certified™ by Great Place to Work Institute,
for the period of March, 2019 to February, 2020.
 SREI has been declared as the Winner in the category NBFC
Excellence – Best IT/ Technology Team – Infrastructure Finance –
BFSI Technology Awards 2020
 SEFL (Subsidiary of SIFL) has been deemed the Most Trusted
Brand in the Equipment Finance Category at the Rotary Means
Business Awards in collaboration with the Economic Times, on
Aug 31st, 2019.
 The Learning and Development wing at Srei won the TISS Leap
Vault CLO Award in the category of “Virtual Learning
Programme”, July 2019.
 Srei got the ET Iconic Brand award in 2020.
 Best NBFC in SME Financing for BFSI Leadership Awards at
NBFC 100. Tech Summit 2018
 SIFL partnered with XLRI , India‟s premier business school to
create an iconic Business Case Study competition SREI XLRI
DEAL PITCH 2020
14. The Plaintiff No. 1 caters to a very large client base, many of whom
are Micro, Small and Medium Enterprises(MSMEs) and Small and

022
Medium Enterprises(SMEs) and has been instrumental in developing
the equipment financing ecosystem in India. It may be noted that the
Plaintiffs enjoy impeccable reputation and goodwill which they have
garnered over the years through business achievements, social
engagements and their philanthropic activities. Further, the Plaintiff
No. 1 is involved in various capacities in Government projects
namely Infrastructure Project Advisory, Smart City Mission
Programme, Pradhan Mantri Awas Yojna- Urban, Atal Mission for
rejuvenation and Urban Transformation(AMRUT) and other
International Engagements.
15. The Defendant No. 1 is a sham entity which has created a bogus
website namely “scamsbreaking.com” with the sole purpose of
running a smear campaign against the Plaintiffs. It claims to be a
media, publishing and broadcasting company based in Australia.
Defendant No.1 published the Article and the Video on its website.
The Defendant No. 1 has also written false and malicious mails to
various government authorities in the administration and banking
sectors merely in order to tarnish the image and goodwill of the
Plaintiffs. The defamatory and malicious Article and Video are
available on numerous websites accessible through Google and other
social media platforms.

023
16. Defendant No. 2, i.e., Google INC which is an American multi-
national technology company that specializes in internet-related
services and products, which includes online advertising
technologies, search engines, cloud computing, software and
hardware. Defendant No. 2 offers various web-based services
including the services for video viewing and sharing through
YouTube.
17. Defendant No. 3 is the Indian subsidiary of the Defendant No. 2.
18. Defendant No. 4, i.e., YouTube LLC, allows its users to upload,
view, rate and share videos. The users can create their own profiles,
known as YouTube channels on the portal for uploading their
contents. The users can upload, download, share and save the videos.
The users can also comment on the videos, report them, as also
subscribe to other users YouTube channels. Defendant No. 4 earns
advertising revenue from Google AdSense, a program which targets
ads according to site content and audience. The Video has been
uploaded by Defendant No.1 on its YouTube channel, “Scams
Breaking” on the portal of Defendant No. 4. It is relevant to state that
the location of the YouTube channel of Defendant No.1 is shown as
“India”.
024
19. Defendant No. 5, i.e., Facebook Inc. which is social media platform,
which operates and hosts Facebook in India and abroad and is the
relevant data controller for Indian and International users of
Facebook services. Defendant No. 5 is engaged in interalia providing
media services, hosting a platform enabling its users to upload
content in the nature of photos and videos as well share the same
electronically with other users. It seems that Defendant No.1 has
created a page on Facebook named “@breakingnewsimc”.
21. Defendant No. 7, i.e., Instagram, is an Internet-based social network.
It was launched in June 2011 and its features include the ability to
post photos and status updates to the stream or interest-based
communities, group different types of relationships into Circles, a
multi-person instant messaging, text and video chat, events, location
tagging, and the ability to edit and upload photos to private cloud-
based albums. Pictures relating to the Video and Article have been
uploaded by Defendant No. 1 on their Instagram handle
“@scamsbreaking”.
025
22. Defendant No.8, i.e., Twitter International Company which is an
online news and social networking service on which users post and
interact with messages known as "tweets". The users access Twitter
through its website interface, through Short Message Service (SMS)
or mobile-device application software ("app"). Defendant No.1 has
created a profile on the said social networking platform of Defendant
No.8, the username of which is “@BreakingScams”.
23. Defendant No. 9 is the Indian subsidiary of the Defendant No. 8. The
Video and Article are available on the Twitter account of the
Defendant No.1 under the user name @breakingscams.
24. Defendant No. 10, LinkedIn is an American business and
employment-oriented online service that operates via websites and
mobile apps. LinkedIn is a social network that focuses on
professional networking and career development. One can use it to
display their resume, search for jobs, and enhance their professional
reputation by posting updates and interacting with other people.
Defendant No.1 have created a profile on the said social network, the
username @Scams Breaking.
026
26. Defendant No. 12 represents every unknown and unnamed person
who has been producing and/or sharing and/or disseminating and/or
publishing or causing to publish and/or produce and/or share and/or
disseminate on the internet or through various other platforms and/or
helping/assisting in such actions as stated hereinabove including but
not limited to those provided by Defendants Nos. 1 to 11.
Brief facts:
27. It is stated that the Plaintiffs sometime around the second week of
December 2020 came to know from their followers and well-wishers
about publication of the malicious, reckless, derogatory and
defamatory Article and Video. It is stated that prior to publication of
the Video and Article, the Defendant No.1 did not approach the
Plaintiffs seeking its comments or views. Judicial notice can be taken
of the fact that unlike any act of responsible journalism, the Plaintiffs
were never approached by the Defendant No. 1 to give any comments
on the said Article and Video.
28. The relevant extracts from the transcript of the Video is reproduced
herein:
“…You are requested to be a part of our mission to expose 20
most heinous scamster families of India and to get rid of these
termites and pass the clear message that crime never pays…
027
Twenty most heinous scamster families of India
Episode 1: Bad Brothers of Kanoria
…Not only that a lawful and fair opportunity was also given to
the accused Kanoria brothers to place their parts but feeling
themselves above the law they didn't come with proper reply…
…This scam is an alarm, wake up as it rings.
…The Kanoriabrothers scam, this fraud of more than 16, 000
crore rupees is yet another example of the malfunctioning of
Indian banks, unfortunately the prestigious Reserve Bank of
India is seen as a toothless tiger unable to roar against the
enemy of India's economy…
…Who are the Kanoria brothers?
The Kanoria brother is a Kolkata-based business family. Kolkata
is the capital of West Bengal, India. The main players of the
Kanoria family are Hari Prasad Kanoria-father,
HemantKanoria-son, Sunil Kanoria-son, SujitKanoria-son,
Raghav Raj Kanoria-son of HemantKanoria.
These five masterminds mentioned above have succeeded in
their criminal activities with the help of approximately 20 other

028
accomplices who participated actively in the fraudulent game of
embezzlement of public funds by the Kanoria brothers…
…The Kanoria brothers are desperately engaged in the criminal
diversion of the public money. Public money siphoned off the
funds through shell entities. They are cheating on the banks and
on the government authorities which is punishable under the
Prevention of Money laundering act, Prevention of Corruption
act, black money and the imposition of tax act, the Income Tax
act, companies act and SEBI act and various other acts and
regulations imposed by RBI…
…The Kanoria brothers created a criminal purpose entity to
dissemble their true intentions and actions in the form of a trust
and they named it the power trust. This power trust was another
step to weaken countries economy thereby strengthening these
scammer’s roots in the game and defraud the authorities as well
as the public…
…This is a fast comfortable extra-large personal vehicle, the
power trust, with tinted glass driven by the Kanoria brothers was
used to carry out their criminal activities with the intention of
hoodwinking the country…

029
…This criminal purposes vehicle is used to transfer the money
from one brother to another under the false pretexts this power
trust has been used for siphoning funds of Rupees 3,500 crores
between SREI and IPCL via different entities and all the
information has been criminally concealed from the official
finance documents of the companies…
Preposterous.
Let's see how their criminal methodology works this flowchart
describes the deceiving style of the corrupt father-son duo
HemantKanoria and his son Raghav. (A flow chart is shown at
8:56 min of the video showing how the criminal methodology
works)
…So far it was just a glimpse of this scammer family's
functioning, they incessantly used different entities to siphon off
the public money and this time they used another entity M/s
Bhasker silicon private limited (BSPL) as well as its subsidiary
Environ Energy Corporation Limited, both these companies are
run by the agents of the Kanoria brothers…
…The Kanoria master brothers were becoming experts in this
fraudulent game. A game which is invented by them and is
played on their whims and fancies. So convenient, isn't it!?...

030
…They show this illegal transaction as inter-corporate deposits
solving a crime by committing another crime, this nefarious
family has redefined the word greed with yet another shocking
criminal move, this time they decided to loot the public money…
…and criminal web of payments created by the Kanoria brothers
to siphon the public money from one SREI group of companies
to another, a capital felony to hide another capital felony leads
to numerous capital felonies, the rollout of more traps…
…these shameless fraudsters, the truth shall prevail. When you
lie and don't get caught either you start believing that your lies
are true or that you're an expert but always remember that a lie
has a very short life and that the truth shall prevail…
…This criminality portrays well the mockery of public money
and of the government rules done by the Kanoria brothers
without any hesitation; did they rob this confidence from us as
well?...
…The termites of growth. The Kanoria brothers gradually
became fearless and unstoppable…

031
…These companies are basically criminal channels to put the
siphoned money into criminally misappropriate endues, expose
of the tip of an iceberg…
…The Kanoria brothers know no finish line, they went on
looting the public money up to 50,000 crores. These financial
terrorists of the economy must be put behind bars the negligence
on the part of the banks gave a green signal to these bandits…
…we will be back with another shocking expose of the
Kanoria brothers and their criminal connections in Indian
politics…”
(Emphasis supplied)
29. The relevant extract of the Article are reproduced herein below:
“…Indian Banks Again Blindly Shell Crores Of Public Money
Without Any Due Verifications In Yet Another Huge Scam
Commissioned By Kolkata’s Kanoria Brothers…
…Another ludicrous scam is being unveiled which would take
anybody by surprise at the scheme that is being used by the
Kanoria brothers in siphoning off money to the tune of 16000
crores INR into illegitimate and fake accounts…

032
…The Kanoria brothers had criminally setup the Power Trust as
public trust which only had people from the Kanoria business
enterprises on the board of trustees…
…The Kanoria Brothers with their political and bureaucratic
connectionshas made it easy to carry out these financial
scams…
…If Kanoria Brothers any day leave the country; the financial
institutions like AXIS banks will not be able to recover any of the
funds given to SREI and the total public money will have to be
written off which is eventually wiping out funds from the public
at large….
30. A bare reading of the contents of the Article and transcript of the
Video, makes it clear that Defendant No. 1 is trying to spread
malicious messages to the public at large using the intermediaries
being Defendant No. 2 to 11 and trying to spread misinformation
against the Plaintiff while recklessly alleging that the Plaintiffs have
been involved in siphoning off public money in collusion with banks
and other financial institutions. The Defendant No.1 has deliberately
used highly defaming and insinuating terms against the Plaintiffs
throughout the Video, by using highly provocative words like,
“termites”, “scamster family”, “criminal pockets”, “venomous

033
assassins of India’s economy”, “corrupt father-son duo”,
“robbers”, “nefarious family”, “fraudster”, “built a crime school
from public money”, “ventures of loot”, “termites of growth”,
“financial terrorists of the economy”, “bandits” etc. to describe
the Plaintiffs.
31. The said false, defamatory and disseminating allegations have been
levelled by the Defendants No. 1 with specific ulterior intentions to
harm the reputation and defame the Plaintiffs. The said smear
campaign has resulted in tarnishing the business reputation of the
Plaintiffs by lowering its credibility and reputation resulting in
irreparable injury. Further, a bare analysis of the pattern of the
libellous content posted by the Defendant No. 1 on the platforms of
the Defendants No. 2-11 would make it clear that the same is not in
pursuit of any investigative journalism but a pre-mediated attempt to
ruin the hard-earned reputation and goodwill of the Plaintiffs earned
over the years. Further, the Defendant No. 1 claims to be a Australian
based entity and it is inconceivable that an Australian media house
has covered the story of an alleged scam carried out by an Indian
entity especially considering the nature of details purportedly
highlighted pertaining to the Indian system.

034
32. It is further stated that the Videos and Article have been published
without any regard to the truth and without due care or verification.
Further, even comments were not sought from the Plaintiffs before
publishing the same. The tone and tenor of the Videos and Article are
accusatory in nature and not a case of bonafide reporting of facts and
events as the Plaintiffs have already been declared guilty. It is a clear
case of malicious reporting. It is apparent from the contents of the
Videos and the Article that the contents thereof under no
circumstances constitute to be a part of bonafide public information
and have been posted solely to tarnish the image of Plaintiffs with an
ulterior motive to extort money and make commercial gains.
33. The Videos and Article are only a hoax and the allegations contained
therein are false, misleading, baseless and defamatory. The Videos
have been created, uploaded and circulated with the intention of
creating panic in the mind of general public, adversely affecting the
goodwill and reputation of Plaintiffs amongst its employees,
stakeholders, and the public at large. The contents of the videos and
the claims made therein have resulted in serious and irreparable
damage to the impeccable reputation enjoyed by the Plaintiffs. The
malicious and misleading content is evidently prejudicing and
compromising the hard-earned reputation and goodwill of the
Plaintiffs. Content posted on the internet is accessible worldwide

035
including but not limited to the territorial jurisdiction of this Hon‟ble
Court, which is causing unwarranted and irreparable harm to the
Plaintiffs.
34. Immediately upon becoming aware of the circulation of the Video
and Article, Plaintiff No. 1 filed a complaint dated 14.12.2020 with
the Deputy Commissioner of Police, Cyber Crime Cell, Government
of India, New Delhi and a complaint dated 15.12.2020 at DIG Cyber
CID West Bengal Police on 15.12.2020. It is believed that action was
taken by the concerned authorities pursuant to which certain links
were removed and or made inactive. However Defendant No. 1 has
abused the lax policies of Defendant 2 to 11 to upload/share such
false information amongst the public at large despite the some of the
said links having been removed.
35. In the meantime, Defendant No. 1 also published another video on its
YouTube channel titled “Who’s Next | The Biggest Expose
Continues” on 15.12.2020 (“Video No.2”) (“Video” and Video No.
2” are hereinafter collectively referred to as “Videos”) The transcript
of the Video No.2. is reproduced herein below;
“ALREADY EXPOSED 16000 CRORES. THE SCAM GAME.
BUT THAT’S NOT ALL OF KANORIA BROTHERS. BIG IS YET
TO COME. MANY MORE. THOUSAND CRORES SIPHONING.

036
ABOUT THEIR FOREIGN CONNECTION. THEIR POLITICAL
SAVIOURS. THEIR MASTERS IN POWER. WE WILL EXPOSE
EVERYTHING, EVERYONE. ONE BY ONE. ONLY ON SCAMS
BREAKING. WWW.SCAMSBREAKING.COM”
36. The Plaintiffs also issued a Cease and Desist Notice dated 05.01.2021
to the Defendants No. 2-11. However, despite having issued the said
Cease and Desist Notice to the Defendants No. 2-11, no effective
action has been taken by them to remove/block the highly defamatory
Video and Article from their domains/platforms.
37. Defendant No. 5 by way of an email dated 13.01.2021 responded to
the aforesaid Cease and Desist Notice dated 05.01.2021 stating the
following;
“Hi,
Thank you for your letter to Facebook India dated 2021-01-05, a
copy of which is attached to this message for your reference.
We're responding in our capacity as Facebook Inc., which
operates the Facebook service for people from India.
Based on the information provided, we are not in a position to
take action based on your defamation concerns at this time. You
may want to reach out to the party responsible for posting the
content to resolve your issue with them directly.

037
Should you have additional information that bears on this report,
namely a court order against the reported party bearing on this
matter, you may reply to this message with that information and
we`ll continue to look into your report.
Thanks,
April
Facebook”
38. Defendant No. 8 by way of an email dated 15.01.2021 responded to
the Cease and Desist Notice dated 05.01.2021 stating the following;
“Hello,
Thank you for your report. Our team is now in the process of
investigating this matter.
We appreciate your patience and cooperation and will follow up
as soon as possible.
Please note, it is our standard policy to notify users in most
circumstances upon receipt of a removal request concerning
content on their account. We also provide a copy of the removal
request [including attachments] in our notice. Pursuant to this
policy we will forward a copy of your request to the reported user
within one business day so they can decide whether to respond to
you directly, voluntarily remove the reported content, or take

038
some other action. Please let us know, by replying directly to this
message within one business day, if we are legally prohibited
from providing notice to the user, and if so, provide the specific
legal basis (i.e. section of a statute) for such prohibition.
[Also, unless we are prohibited from doing so, Twitter will
provide a redacted copy of your report to Lumen
(https://www.lumendatabase.org/pages/about) if we withhold
some reported content.]
Sincerely,
Twitter”
39. Defendant No. 1 also repeatedly issued various false and malicious
mails such as 29.12.2020, 12.01.2021 and 18.01.2021 to various
statutory, administrative and financial bodies whereby they have
made insinuating and objectionable remarks against the Plaintiffs.
The said emails were issued with the sole intention to defame and
disparage the image, goodwill and credibility of the Plaintiffs. Such
malicious emails have been made with the specific ulterior motive to
damage the business and standing of the Plaintiffs before the world at
large.
40. Defendant No.1 has been deliberately disseminating the Videos and
the Article as also the emails mischievously, with the sole intent to
039
defame and vilify the image and reputation of the Plaintiffs for
ulterior motives.
41. It is submitted that the contents of the Videos, Article and emails are
patently false. The same is evident from the following:
a. It has been falsely alleged that the Plaintiffs have borrowed Rs.
44,000 crores from Axis Bank and that monies have been lent to
entities owned and operated by the Plaintiffs on the basis of
alleged future receivables or monies have been lent to fictitious
entities created by the Plaintiffs. It is pertinent to mention that
Axis Bank by way of a press release dated 15.12.2020 clarified
that Defendant No.1 has published the Videos and Article without
any due diligence and verification of the end use of the loan
amounts. In fact, Axis Bank further clarified that its outstanding
loan amount to SREI group and SREI entities stood at about Rs.
1211 crores and not Rs. 44,000 crores as alleged by Defendant
No.1 in the impugned Videos and the Article.
b. It has been alleged by the Defendant No.1 that the Plaintiffs are
allegedly misusing and or syphoning public funds from the Power
Trust. It is pertinent to state here that the said Power Trust was
created pursuant to the scheme of Amalgamation approved by the

040
Hon‟ble High Court of Calcutta by its Order dated 17.04.2013.
The Power Trust was formed by way of a written instrument
having three independent trustees who have no connection or
interest either with the Plaintiffs whatsoever. Therefore, the said
allegations ex facie are false and have been made for ulterior
motives as elaborated in the present suit.
c. It is has been alleged in the said Videos and the Article that
Bharat Road Network Limited(„BRNL‟) is a shadow company
created for the benefit of the Plaintiffs and their family. Based on
the information available in public domain, the Plaintiffs states
that BRNL is a Public Limited Entity and is involved in operation
of toll based projects and also performs a range of project
management functions and project advisory activities. From the
perspective of any commonality of being related company, it is
stated that the Plaintiff No. 1 and BRNL are two separate legal
entities recognized by law. Further, Plaintiff No. 2 and 3 are in no
way connected with BRNL in any manner whatsoever.
42. It is amply evident that Defendant No. 1 has with an ulterior motive
levelled false allegations against the Plaintiffs by carrying out a
smear campaign by way of the Impugned Videos and the Article
which are riddled with falsity in public domain. The Defendant No. 1
041
in furtherance of itsulterior motive has used the lax policies of
Defendant 2 to 11 to upload/share such false information amongst the
public at large. The sole intention of the Defendant No. 1 seems to be
to tarnish the image of the Plaintiffs in the eyes of the public at large.
43. It is evident that the Video and the Article have been published by
Defendant No. 1 in order to stir a controversy and garner publicity for
its own commercial gains and also spread misleading and false
information in order to adversely impact the business of the Plaintiffs
through such Article, Videos and mails.
44. It is stated that the contents of the Videos and Article do not
tantamount to journalistic reporting of news. It is submitted that
Defendant No. 1 by way of the said Videos and Article is conducting
a media trial. It is stated that the basic tenets of journalism demand
that facts are verified before the same are published. It is submitted
that there is a real and imminent threat that further dissemination of
the contents of the Videos and the Article is likely to interfere with
the administration of justice including but not limited to the
presumption of innocence as well as other constitutional safeguards
available especially to Plaintiff No. 2 and 3.
45. Such an action is in direct conflict with laws relating to privacy and
journalistic responsibility. It may be noted that the Plaintiffs have a

042
stellar reputation in the market and the Plaintiff No. 1 particularly has
successfully undertaken and completed some of the most important
infrastructure projects in the country. Further, the Plaintiff No. 1 and
its affiliates, subsidiaries, etc. have at all times adhered to all the
requisite compliances and all their entities are duly audited and that
there are no financial irregularities as is being alleged in the Videos
and the Article. Further, it is pertinent to bring to the attention of this
Hon‟ble Court that the Plaintiffs have been conferred and honoured
with various awards and titles by several renowned forums for their
work and achievements.
46. It is stated that the Defendant No.2 to 11‟s malafide intention is clear
from fact that, despite having actual knowledge of the false and
defamatory content of the Videos and the Article which is available
on their platforms, they have refused to remove/block the Videos and
Article. It is stated thatthe inaction of the Defendant No.2 to 11, even
after receiving the Cease and Desist Notice from the Plaintiffs, makes
them liable for defamation and consequent damages to the reputation
and goodwill of the Plaintiffs. It is submitted that if a person
knowingly permits another to communicate information which is
defamatory, when there would be an opportunity to prevent the
publication especially despite being put to legal notice, there would

043
seem to be no reason in principle why liability should not accrue
against the said person.
47. Pertinently, as per the Defendant No. 2 and 3‟s „Inappropriate
Content‟ Policy, any content that seeks to exploit others such as
extortion, blackmail, soliciting, etc. are not allowed to be uploaded on
the Defendant No. 2 and 3‟s website. However, despite having such a
policy in place, the Defendant No. 2 & 3 has allowed the Defendant
No. 1 to upload/share/disseminate/publish the highly defamatory and
malicious videos/URLs/Weblinks against the Plaintiffs which may be
used to exploit and blackmail the Plaintiffs thereby not adhering to its
own policy.
48. Moreover, the defamatory and malicious Videos and Article against
the Plaintiffs has caused irreparable loss and injury to the reputation
and goodwill of the Plaintiffs, thereby causing losses to its business
both present and future. It may be noted that the malicious and
derogatory Videos and Article against the Plaintiffs has not only been
viewed by the public at large but has triggered a series of further
deprecating and disparaging opinions of unknown individuals. That
from the number 'likes', 'comments' „shares‟, „retweets‟ garnered on
the Videos and Article on the various platforms of the Defendant No.
2 to 11, it is evident that the Videos and the Article are seriously
044
damaging the hard earned reputation and goodwill of the Plaintiffs.
Even after the Plaintiff having issued a Cease and Desist Notice with
a request to remove the Videos and the Article, Defendant No.2 to 11
by not removing or blocking those defamatory contents, are indirectly
encouraging the offender, to post such defamatory/false/malicious
content on the websites.
49. It is stated that the publication/dissemination and wide circulation of
the Videos and Article by the Defendants tantamount to a calculated
move to injure and malign the reputation of the Plaintiffs by exposing
them to hatred, contempt and ridicule, which affects the Plaintiffs‟
reputation and goodwill adversely in estimation of reasonable people
and the public at large. The Videos and Article are widely accessible
on various interactive social media websites such as the Defendant
No. 2 to11. The wide viewing and circulation of the Videos and
Article have not only injured the Plaintiffs‟ reputation but has also
exposed the Plaintiffs to hatred, ridicule and repulsion thereby
tarnishing the image of the Plaintiffs‟, which image the Plaintiffs took
years to build in the industry.
50. It is stated that the use of derogatory words such as “termites”,
“scamster family”, “criminal pockets”, “venomous assassins of
India‟s economy”, “corrupt father-son duo”, “robbers”, “nefarious

045
family”, “fraudster”, “built a crime school from public money”,
“ventures of loot”, “termites of growth”, “financial terrorists of the
economy”, “bandits”, has lowered the reputation of the Plaintiffs both
in the concerned industry as well as public at large.
The acts of the Defendant No.1 to write various false and malicious
mails including the ones sent on 29.12.2020, 12.01.2021 &
18.01.2021 to various statutory, administrative and financial bodies
whereby they have made reckless allegations and remarks against
the Plaintiffs, is nothing but a desperate attempt to tarnish the image
of the Plaintiffs and to defame and disparage the image, goodwill
and credibility of the Plaintiffs. Such malicious emails have been
made with the specific ulterior motive to damage the business and
standing of the Plaintiffs before the world at large. The said action is
likely to cause wrongful loss to the Plaintiffs and cause wrongful
gain towards its oblique purpose of the Defendant No. 1. Unless
such actions of the Defendant No.1 are stopped by an affirmative
order by this Hon‟ble Court, the Defendants will continually further
its evil design to vilify and defame the goodwill of the Plaintiffs
before the world at large and which will deeply impact the present
and future business of the Plaintiffs. It is stated that the Plaintiffs
reserves its right to seek damages/losses or any other relief(s) at a

046
later stage. Further, the Plaintiffs are also filing accompanying
Application under Order 2 Rule 2 of CPC, 1908 the contents of
which ought to be read as a part and parcel to the present suit and the
same are not being repeated herein for the sake of brevity and
convenience.
51. It is pertinent to mention that Plaintiff No.1 and its various group
companies routinely do business with several government and non-
government organizations for execution of infrastructure projects. It
is stated that the publication of the Videos and the Article and such
mails sent to various authorities which gives excessive adverse and
negative publicity of the Plaintiffs, is likely to adversely impact their
ongoing and future projects, on account of widespread circulation of
such misleading and false information available on the platforms of
the Defendants Nos. 2 to 11.
52. The Videos and the Article continue to be available for public
viewing on the websites of Defendant Nos. 2 to 11 thereby
continuously damaging the reputation of the Plaintiffs. It is stated that
the Plaintiffs have already received numerous inquiries regarding the
false, baseless, malicious and defamatory Videos and Article and the
malicious mails sent to the authorities and continue to receive such
enquiries, which clearly shows that the sharing/dissemination of the

047
defamatory Videos and Article and sending of such defamatory and
insidious emails have caused huge damage to the reputation of the
Plaintiffs.
53. It is submitted that Defendant No. 1 being based out of India does
not have the privilege to avail any defence or right as guaranteed
under Article 19(1)(a) and (g) of the Constitution of India.
54. It is submitted that in any event, the freedom of speech guaranteed
under the Constitution of India cannot be reckless, manipulative,
misleading or without regard to any person‟s honor or reputation.
Freedom of speech is also coupled with the basic tenement of
journalistic code of conduct, where criticism is permitted but without
infringing someone‟s reputation and without exceeding the limits and
boundaries of law to injure reputation.
55. Further, it submitted that it was the legal duty of the Defendant Nos.
2 to 11 to take steps to block access to the Videos and the Article
from the websites, when the defamatory and disparaging nature of the
content of the Videos and Article was brought to the actual
knowledge of the Defendants by the Plaintiffs. Defendant Nos. 2 to
11 by allowing the defamatory Videos and the Article to remain
posted on their websites and further dissemination by other users of

048
their website, have aided and abetted the dissemination of false and
defamatory content/information within the meaning of Section 79(3)
of the Information Technology Act. Defendant Nos. 2 to 11‟s refusal
or inaction to take down the Videos and the Article from their
respective websites resulted in Plaintiffs‟ continued reputational and
goodwill loss.
56. It is stated that the Defendant Nos. 2 to 11 do not play a passive role
in facilitating postings on the internet and are deemed publisher of the
contents of the Videos and Article at common law after receiving
notification in regard to the defamatory and false contents of the
Videos and Article. In the present case, the Defendant Nos. 2 to 11‟s
deliberate inaction has built up a negative sentiment in the social
media against the Plaintiffs and in its business, thereby causing
immense damage to the reputation and goodwill of the Plaintiffs and
the companies owned and operated by the Plaintiffs.
57. It is submitted that in terms of Rule 3(2)(b) of the Information
Technology (Intermediaries) Guidelines Rules, 2011, the Defendant
Nos. 2 to 11 as intermediaries are obligated to observe certain due
diligence while discharging their duties including an obligation to
inform users not to host, display, upload, modify, publish, transmit,
update or share information that, is grossly harmful, harassing,

049
blasphemous defamatory, obscene, pornographic, pedophilic,
libelous, invasive of another's privacy, hateful, or racially/ethnically
objectionable, disparaging, relating or encouraging money laundering
or gambling, or otherwise unlawful in any manner whatever. Further,
the intermediaries under Rule 3(4) are required to act within thirty-six
hours and work with user or owner of such information to disable
such disparaging and defamatory URLs/Weblinks upon obtaining
knowledge of the same in writing from the affected persons. Thus,
the said acts of Defendant Nos. 2 to 11 are in gross contravention of
the above-mentioned rules thereby causing irreparable loss and injury
to the goodwill and reputation of the Plaintiffs. It is submitted that the
Defendant No. 2 to 11 have failed to follow their own user terms and
guidelines displayed on their respective Websites wherein the said
Defendants are duty bound as an intermediary to inform the offender
who posted the Videos and Article that the same is not in compliance
with rules and regulations, user agreement and privacy policy for
access or usage of their computer resource.
58. The Defendant No.1‟s act of publishing the Videos and the Article
and writing such malicious mails as also the deliberate
inaction/refusal to take action on part of Defendant No. 2 to 11 has
caused immense damage to the reputation and goodwill of the
Plaintiff which shall have a cascading effect on every entity, staff,

050
employee, associate affiliated with the Plaintiffs, and even the future
endeavours of the Plaintiffs. Furthermore, the said impugned actions
have caused immense mental agony and humiliation to the Plaintiff
No. 2 and 3 as well their families.
CAUSE OF ACTION:
59. That the cause of action for filing the present suit for the first time
arose on 14.12.2020 and 15.12.2020 when the Plaintiffs came to
know and when were informed by well wishers of the defamatory
Videos and the Article posted/shared/uploaded/disseminated at the
respective websites/portals of the Defendants. The cause of action
arose on 14.12.2020 and 15.12.2020 when the defamatory Videos and
the Article was published on various social media platforms
belonging to the Defendant Nos. 2 to 11. The cause of action further
arose on 14.12.2020 when the Plaintiff No. 1 filed a complaint with
the office of the Deputy Commissioner of Police, Cyber Crime Cell,
New Delhi and on 15.12.2020 when Plaintiff No. 1 filed a complaint
with the office of DIG Cyber CID West Bengal Police.The cause of
action further arose when the malicious mails were sent to various
authorities by the Defendant No. 1 including but not limited to
29.12.2020, 12.01.2021 and 18.01.2021.The cause of action is
subsisting and still continues to arise as the defamatory Videos and

051
Article are accessible on the internet, including but not limited to the
platforms of Defendant Nos. 2 to11.
60. That the Plaintiffs have suffered, and are likely to further suffer,
irreparable harm and injury with regard to their reputation and
goodwill.
61. That the contents of the Videos and the Article available on numerous
URLs/Weblinks are utterly malicious and completely bereft of truth
and are causing an immediate pressing injury to Plaintiffs. The
Plaintiffs apprehend that the Defendants will persist with their
malicious conductof publishing and uploading videos with such
untrue contents and keep sending malicious mails to various other
authorities, and if the said defamatory Videos and Article and the
mail accounts are not removed or blocked, the Defendants No. 1 will
continue to defame the Plaintiffs which would result in immediate
and irreparable injury to the Plaintiffs‟ reputation and goodwill.
Defendants' no. 2 to 11 insistence to keep the Videos and Article on
their websites, despite having knowledge of their defamatory content,
is causing harm to the reputation of Plaintiffs on a continuing basis
and also violation and contravention of the fundamental rights of the
Plaintiffs such as right to carry on its business, live with dignity,

052
reputation as well as right to fair administration of justice as
guaranteed under the Constitution of India.
62. That the Plaintiffs have not filed any other or similar suit in this
Hon‟ble Court or in any other Court in this matter nor is any other
case pending in any court.
JURISDICTION:
63. This Hon'ble Court has territorial jurisdiction in the matter as Videos
and Article in question are uploaded/shared/disseminated on various
URLs/Weblinks including but not limited to the sites of the
Defendants which can be seen and accessed by the general public
across the globe including in New Delhi. Further, the Plaintiff No. 1
also has subordinate offices as well as business operations in Delhi.
Further, the Plaintiff No. 2 and 3 being entrepreneurs have
tremendous reputation and good in Delhi Furthermore, the concerned
authorities /central agencies which the Defendant No.1 claims to be
looking into the complaints against the purported financial
irregularities committed by the Plaintiffs have their
headquarters/offices in Delhi. The malicious emails sent by
Defendant No. 1 to various governmental authorities including MCA,
RBI have their headquarters in Delhi. Therefore, this Hon‟ble Court

053
has the necessary and requisite territorial jurisdiction to try and
entertain the present suit.
64. That the present dispute is not a commercial dispute as per Section
2(c) of the Commercial Courts, Commercial Division & Commercial
Appellate Division of High Courts Act, 2015.
COURT FEES
65. The value of the present suit for the purposes of court fee and
jurisdiction is as follows:
a) For a decree of permanent injunction whereby directing the
Defendants to permanently take down, remove, or
block/restrict access to the Videos and the Article mentioned
in the list of documents attached with the present Plaint and/or
any other active or similar URLs/weblinks which contain or
purport to contain the defamatory Videos and Article or part
thereof posted on their respective websites, and also from all
media in the control of the Defendants, including but not
limited to Defendants channels, website, webpages, the
present relief is valued at Rs. 2,00,01,000/-, accordingly ad
valorem court fees of Rs. 1,98,000/- is being affixed.

054
b) For a decree of mandatory injunction in favour of the Plaintiffs
restraining the Defendants, its agents, officers, assigns,
representatives by directing the Defendants to forthwith
block/remove the defamatory Videos and Article from
weblinks/URLs, websites, webpages, mobile application, the
present relief is valued at Rs. 200/-and accordingly ad valorem
court fees of Rs. 20/- is being affixed.
c) For a decree of mandatory injunction thereby directing the
Defendants to immediately block/remove the defamatory
Videos and Article mentioned in the URLs and any other
similar videos and articles from its websites/portals on receipt
of any complaint in future from the Plaintiffs with regard to
the defamatory Videos and Article; and also from all media in
the control of the Defendants, including but not limited to
websites, mobile applications, other platforms, this relief is
valued for the purpose of court fee and jurisdiction at Rs. 200/-
and accordingly Court fee of Rs.20/- is being affixed.
d) For a decree of mandatory injunction restraining the Defendant
No. 1 from sharing or writing any defamatory and malicious
emails to any governmental, banking and administrative

055
authorities in connection with their motive to disseminate false
and baseless allegations against the plaintiffs
e) For a Decree of Permanent Prohibitory Injunction in favour of
the Plaintiffs and against the Defendants for restraining the
Defendants or other news agencies from reporting any news
with respect to the defamatory Videos and Article, this relief is
valued for the purpose of court fee and jurisdiction at Rs. 200/-
and accordingly Court fee of Rs. 20/- is being affixed.
LIMITATION
66. The present suit is well within the period of limitation as the cause of
action first arose on 14.12.2020 and is still continuing on every day
basis.
PRAYER
In the facts and circumstances of the present case, it is most
respectfully prayed that this Hon‟ble Court may be pleased to
grant;
056
i. Pass a decree of permanent injunction in favour of the
Plaintiffs and against the Defendants, directing the Defendants
to permanently take down, remove and/ or block/restrict
access to the Videos and Articles available at numerous
URLs/weblinks mentioned in the list of documents attached
with the present Plaint and/or other active URLs/weblinks
which contain or purport to contain, the defamatory Videos
and Article or any part thereof posted on their respective
websites, and also from all media in the control of the
Defendants;
ii. Pass a decree of mandatory injunction in favour of the
Plaintiffs against the Defendants, its agents, officers, assigns,
representatives by directing the Defendants to forthwith
block/remove the defamatory Videos and Articles available at
numerous URLs/weblinks mentioned in the list of documents
attached with the present Plaint and/or other active
URLs/weblinks which contain or purport to contain, the
defamatory Videos and Article or any part thereof posted on
their respective websites, and also from all media in the
control of the Defendants;

057
iii. Pass a decree of mandatory injunction in favour of the
Plaintiffs and against the Defendants directing the Defendants
to block/remove the defamatory Videos and Article from its
websites/platforms on receipt of any complaint in future from
the Plaintiffs with regard to the same or similar Videos and
Article; and also from all media in the control of the
Defendants;
iv. For a decree of mandatory injunction restraining the
Defendant No. 1 from issuing malicious
emails/correspondences/letters to any government authorities,
banking authority and/or administrative authorities in
connection with Videos and Article and disseminate false and
baseless information against the Plaintiffs.
v. Pass a decree of Permanent Prohibitory Injunction in favour of
the Plaintiffs and against the Defendants for restraining the
Defendants or other news agencies/media houses from
reporting any news with respect to the defamatory Videos and
Article;
vi. Award Actual Cost of the present proceedings;

058
vii. Any other and farther reliefs as this Hon 'hie Court may deem fit a r
c::;�
to meet the ends ofjustice.
�
·PLAINTIFFS
Through:

SYAL&CO
Address - E-34, Greater Kailash Enclave II,
New Delhi 110048
Mobile No.: 9439349298
Email Id - syalandcompany@gmail.com
Place: New Delhi

Date: 22.01.2021
VERIFICATION:-
Verified at New Delhi on this 22nd day of January, 2021 that the contents of
para no. 1 to 59 of the present plaint are true and correct to the best of
my knowledge and belief. The contents of paragraph no. 60 to 66 are true and
correct to the information and legal advice received and believed to be true. The
content of last para is prayer before this Hon'ble Court.
·:d�
PLAINTIFFS
W ff .t ;; J I I I I tJNiili.ti :::•
059
C.S. (OS) No. OF 2021
IN THE MATTER OF:

SREI Infrastructue Finance Ltd. & Ors. ."Plaintiffs
Versus
International Media Corporation & Ors. ,..Defendants
AFFIDAVIT
I, Mr. Shiv Shankar Chowdhury, S/o. late A. N. Chowdhury, aged about 62 years,
having office Zonal office at D-II, Southern Park, 5th Floor, Saket Place, Saket, New
Delhi-I IOOl7, India do hereby solemnly affirm and declare as under that:
1. I am the Power of Attorney Holder of the Plaintiff No. 1 and I am duly authorized
to sign, verify and file the accompanying Suit/Plaint. I am fully conversant with
the facts and circumstances of the case, hence competent to swear by way of the
present Affidavit.
2. I have read and understood the contents of the accompanying Plaint/Suit and the
statements therein are true and correct to the best of my knowledge, information
~ and be~~~ There is no false statement or concealment of any material fact,
~
doc~nt or record.
fi . e-<::-"- ,,<..r~'
~ . >..~O~ij:l~ocuments filed along with the Suit/Plaint are true cQpie.~ of the respective .
. ~'"
,,'-~ ,\ i(
. . I ;'or 0((.): In7 raS-C (f,ure
j Finance Ltd,
t:,"'" .:'\ \'~'\ ongma s.
•t;.~ ~ \\
./> . /~.~ ~
""
<,y'
,\~~\¥"'~ "0 DEP0.lfl~.~:)~,

';' . VERIFICA C) ~~:~:. r .
".' , 7 .:~ _~': -~:.. :'V " ..
~<it '~~~fI;-$is -;n y of -U 2Qlt\N:hi~l contents of the
1
Veri
-..:: L
7, .. /. -7 ."cf" ~
above Affi " k re''t~~ a.~1, comc t~ e best of my kn~wI~dge, i~fo~ation a~d
...
".,' .,.y'
belief. No p~fit is fil~ : 'd no 'n~g 'aterial has been co!ilietrftfo tfi~(~¥tb~Yro t.J.Q.ance Ltd,
\\"'~' '. '~( )
/~~
. '. ,
JIM
k:
1ffC) 1/,'" ~~ \ :.~--, . 12 J~N 'lO11 DE~:;:; .,~y
,
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\ ~:o
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ff,~J0.. .; '1; \i:- i.;.~ . II
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1111'
11, I • H
060
(ORDINARY ORIGINAI~ CIVIL JURISDICTION)
C.S. (OS) No.- - - - OF 2021
IN THE MATTER OF:

SREI Infrastructue Finance Ltd. & Ors. ...Plaintiffs
Versus
AFFIDAVIT
I, Mr. Shiv Shankar Chowdhury, S/o. late A.N. Chowdhury, aged about 62 years,
having office Zonal Office at D-II, Southern Park, 5th Floor, Saket Place, Saket, New
Delhi-110017, India do hereby solemnly affirm and declare as under that:
1. I am the Special Power of Attorney Holder of the Plaintiff No.2 and I am duly
authorized to sign, verify and file the accompanying SuitlPlaint. I am fully
conversant with the facts and circumstances of the case, hence competent to
swear by way of the present Affidavit.
an~;J>elief. There is no false statement or concealment of any material fact,
:-dO~ument or record.
,t'
~" - C,;v·
<,,<§?~.t'~~11
c.e,'< (~
documents filed along with the Suit/Plaint are true copies of the re~ctive
,
~~' (:\ originals, ~-- ~t

~'·'·,0
J,'c , 0\.
~'/
/'1( _
' ~:~
~'- "J ""': "::,
~'-,\\\
•.,:'"r,,f', ,()\ -< .'I ....'"" - DEPONENT
'. S;..~j; VERIFIC ~QN -'" -:. .: \\
tl . / . '~"''' ..'. r \ \
Veri~~d' at~~~*t~>thi<,.~ :~lf JAA-if)~V that the contents of the

ab~ve Affi~a(~t~e. true.,;r ~~q,~~f)d'the ~est of my knowledge, information and
* *bel::~.rtOf it is f~~,ffilli~PO;?lO~m;l~a~~a~;, concealed there frum~~
~S oC) ~:'\,).. ~~'::':TtF'ED '~:"1i-

'r,{~ ""~JC::,...N1 DEPONE~
9 ~ \'?~.. V)\
T f'"
vllnr:~r"i fir' ") '- 'J
,'i.' .,: _
-, .:" .. " ~
'r",
S/o \iVi"'','
~.~ '~ ~~',;' ):.'0 I Idf;;::;!;;':~"'," ~~_ .
\\. ',J. '?~ ,.. l:;t- J"'< fI h;.r.-:,-,;" ..
\\0 ~~:. ,%-\ I~ ;/ . : . :•. ",';~, i:» r:'~·~0l~·I~;.·
\- ~ ~~~
qd ,I
l-;:'!-.
-;r / ".// fh:·,:: v ; • ... ·•...1 ..•.
\\~ /,(~,~,,~'. ~//"'
.."../~.;I h2\10 1Jt?f.;d ":":'~'
. . .~:.c':";' IN .i(;
"~"".f..~', I,!\ " . ,.,/ trUtt COif ". . . tie are
_~. ,~~"-,/_ , 0 'hO "~
II!l 'IT~,:;;~·,qft """ "
1'1 1"1" Ii I 1"1
061
C.S. (OS) No. OF 2021
IN THE MATTER OF:

Versus
AFFIDAVIT
having office Zonal Office at D-II, Southern Park, 5th Floor, Saket Place, Saket, New
Delhi-l l0017, India do hereby solemnly affirm and declare as under that:
1. I am the Special Power of Attorney Holder of the Plaintiff No.3 and I am duly
authorized to sign, verify and file the accompanying SuitlPlaint. I am fully
conversant with the facts and circumstances of the case, hence competent to
swear by way of the present Affidavit.
sta~ents therein are true and correct to the best of my knowledge, information
o
a~l'(l~belief. There is no false statement or concealment of any material fact,
~ I"/ ~ r?
~~dftument or record.
rf ~q;
if' q,
.iJ 3f'All documents filed along with the Suit/Plaint are true copies of the re~tive
~~ s»
....' \"0(
originals. ~
I•
\A'
~': .8 ~ -ok tv DEPONE T
....."{~~ ~ /~_._--'~~, 0 ~
~J VERIFICAT' N " (f~ """~~~
" . ·.~1 .... )1 \
~tJ, '>- \ \
JAN
I" ....
Verifi;~dat DR~\ .;':&~ 'this ~~.

.. "
°
<. , , :-, " .' " 7' ~

~Dab21 that the contents of the
above Affidavit are true aria correct to, the best of my knowledge, information and
, "
belief. No part ofit is false and nothing material has been concealed there from.
. ~~i~
DEPONENY
1'1 °W'fll 1'1 1"1

062
I

C.S. (OS) No.___ OF 2021
IN THE MATTER OF:

SREI Infrastructure Finance. Ltd. & Ors. ...Plaintiffs
Versus
CERTIFICATE OF AUIBENTICATION UNDER SECTION
65B OF THE INDIAN EVIDENCE ACT, 1872
I, Mr. Shiv Shankar Chowdhury, S/o Lt. A.N Chowdhury, aged about
62 years, having office Zonal Office at D-II, Southern Park, 5 th Floor,
Saket Place, Saket, New Delhi-110017, India do hereby solemnly
affirm and declare as under that:
1. That the information reproduced in the printout of the emails,
annexed with the Petition and are derived from the data stored in
the PlaintiffNol 's computer system.
I • • I
OELH\
Reg. No.10698
"
n 'I'
�
063
2. The said mails were downloaded from my official email account
and the printouts of the same have been taken by me by
accessing the PlaintiffNo. l's Computer System.
3. That the emails and printouts are correct and true to the best of
my knowledge and belief and the information derived from the
records maintained by the Petitioner in the ordinary course of
business and are accurate in this regard.
4. The information contained in the printout/electronic record is
derived from the information fed into the computer in the
ordinary course of activity.
5. The said Computer System continues to be used regularly to
access, store and process data/information by the Petitioner,
having lawful control over the use of the said Computer System
and the said System was and has been operating properly.
064
VERIFICATION .22 JAN 2021 I

Verified at VJ� _ _ on this _ day of ____J 2021 that the contents of the
above Affidavit are true and correct to the best of my lmowledge, information and
belief. No part of it is false and nothing material has been concealed there from.
·:d�
DEPONE�
065
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001

CS(OS) NO.______ OF 2021
IN THE MATTER OF:

Versus
INDEX PART –II

1. Index Part II 1-2
2. IA No.____________ of 2021:
1 & 2 read with Order 26 Rule 9 read with Section 151 of 3-15
the Code of Civil Procedure, 1908 along with affidavit.
3. IA No.____________ of 2021:
16-21
2 read with Section 151 of the Code of Civil Procedure,
1908 along with affidavit.
4. IA No.____________ of 2021:
Application Under Section 151 of the Code of Civil
Procedure, 1908 on behalf of the Plaintiffs for
22-26
Exemption from filing Original and/or certified copies
of the documents, typed copies of the documents which
are dim, illegible and do not have proper left hand
margin along with affidavit.
5. IA No.____________ of 2021:
Application on behalf of the Plaintiff under Section 149 27-31
read with Section 151 of the Code of Civil Procedure,
002
1908 for extension of time for filing Court Fees along

with affidavit.
PLAINTIFF
Through

SYAL&CO
Mobile No.: 9439349298
Place: New Delhi

Date: 22.01.2021
003

I.A No. ____ OF 2021

IN
C.S. (OS) No.________ OF 2021
IN THE MATTER OF:

SREI Infrastructure Finance Ltd. &Ors. ...Plaintiffs
Versus
International Media Corporation &Ors. ...Defendants
APPLICATION ON BEHALF OF THE PLAINTIFF UNDER ORDER

39 RULE 1 & 2 READ WITH ORDER 26 RULE 9 AND 10 READ
WITH SECTION 151 OF THE CODE OF CIVIL PROCEDURE, 1908.
1. That the Plaintiffs have filed the accompanying Suit for permanent
and mandatory injunction. For the sake of brevity and avoiding
repetition, the Plaintiffs are not repeating the contents of the
accompanying Suit and the contents of the same may be deemed to be
and read as part of the present Application.
2. It is stated that the Defendant No. 1 has been indulged in a malicious,
reckless, malafideand vindictive reporting of an alleged scam on a
sham and bogus website created by it, namely
“www.scamsbreaking.com”andwww.fraudsbreaking.comwith the
sole intention of carrying out a smear campaign against the Plaintiffs
by uploading/sharing/dissemination of the
004
videos/URLs/Weblinks/article on the various social media platoforms
of the Defendant No. 2 to 11on the basis of false and misleading
facts/documents/information to the world at large whose genuineness
and veracity are highly questionable.
3. The Plaintiffs are aggrieved by an article concerning the Plaintiffs on
the website of Defendant No.1 titled as “Again Blindly Shell Crores
Of Public Money Without Any Due Verifications In Yet Another Huge
Scam Commissioned By Kolkata’s Kanoria Brothers.” dated
14.12.2020 being part of an exclusive expose series titled “20 Most
Heinous Scamster Families in India” (“Article”). The said Article
also contains a 27.12-minute-long Video titled “Biggest Expose of the
Year 2020 is Here” descriptively narrating the contents of the article
(“Video”). The Article also contains pictures of Plaintiffs.
4. Further, the Defendant No. 1 has also published another video on its
YouTube channel titled “Who’s Next | The Biggest Expose
Continues” on 15.12.2020 (“Video No.2”) (“Video” and Video No.
2” are hereinafter collectively referred to as “Videos”).
5. Moreover, the Defendant No. 1 has been repeatedly issuing various
false and malicious mails such as 29.12.2020, 12.01.2021 and
18.01.2021 to various statutory, administrative and financial bodies

005
whereby it has made insinuating and objectionable remarks against
the Plaintiffs. The said emails were issued with the sole intention to
defame and disparage the image, goodwill and credibility of the
Plaintiffs. Such malicious emails have been made with the specific
ulterior motive to damage the business and standing of the Plaintiffs
before the world at large.
6. It is stated that the the contents of the Article, the Videos and the
emails are highly defamatory and malicious. The Article and the
Videos deliberately tries to malign the reputation of the Plaintiffs as
also violate the fundamental rights of the Plaintiffs guaranteed under
the Constitution of India. The Videos have been uploaded on various
digital platforms belonging to Defendant No. 2 to 11. The URLs/links
of the said video is available on numerous websites accessible
through Google and other YouTube Channels.
7. It is amply evident that Defendant No. 1 has with an ulterior motive
levelled false allegations against the Plaintiffs by carrying out a smear
campaign by way of the Impugned Videos and the Article which are
riddled with falsity in public domain. The Defendant No. 1 in
furtherance of its ulterior motive has used the lax policies of
Defendant 2 to 11 to upload/share such false information amongst the

006
public at large. The sole intention of the Defendant No. 1 seems to be
to tarnish the image of the Plaintiffs in the eyes of the public at large.
8. It is evident that the Video and the Article have been published by
Defendant No. 1 in order to stir a controversy and garner publicity for
information in order to adversely impact the business of the Plaintiffs
through such Article, Videos and mails.
9. It is stated that the contents of the Videos and Article do not
tantamount to journalistic reporting of news. It is submitted that
Defendant No. 1 by way of the said Videos and Article is conducting
a media trial. It is stated that the basic tenets of journalism demand
that facts are verified before the same are published. It is submitted
that there is a real and imminent threat that further dissemination of
the contents of the Videos and the Article is likely to interfere with
the administration of justice including but not limited to the
presumption of innocence as well as other constitutional safeguards
available especially to Plaintiff No. 2 and 3.
10. Such an action is in direct conflict with laws relating to privacy and
journalistic responsibility. It may be noted that the Plaintiffs have a
stellar reputation in the market and the Plaintiff No. 1 particularly has
007
successfully undertaken and completed some of the most important
infrastructure projects in the country. Further, the Plaintiff No. 1 and
its affiliates, subsidiaries, etc. have at all times adhered to all the
requisite compliances and all their entities are duly audited and that
there are no financial irregularities as is being alleged in the Videos
and the Article. Further, it is pertinent to bring to the attention of this
Hon‟ble Court that the Plaintiffs have been conferred and honoured
with various awards and titles by several renowned forums for their
work and achievements.
11. It is stated that the Defendant No. 2 to 11‟s malafide intention is clear
from fact that, despite having actual knowledge of the false and
defamatory content of the Videos and the Article which is available
on their platforms, they have refused to remove/block the Videos and
Article. It is stated that the inaction of the Defendant No.2 to 11, even
after receiving the Cease and Desist Notice from the Plaintiffs, makes
them liable for defamation and consequent damages to the reputation
and goodwill of the Plaintiffs. It is submitted that if a person
knowingly permits another to communicate information which is
defamatory, when there would be an opportunity to prevent the
publication especially despite being put to legal notice, there would

008
seem to be no reason in principle why liability should not accrue
against the said person.
12. It is stated that the defamatory and malicious Videos and Article
against the Plaintiffs has caused irreparable loss and injury to the
reputation and goodwill of the Plaintiffs, thereby causing losses to its
business both present and future. It may be noted that the malicious
and derogatory Videos and Article against the Plaintiffs has not only
been viewed by the public at large but has triggered a series of further
deprecating and disparaging opinions of unknown individuals. That
from the number 'likes', 'comments' „shares‟, „retweets‟ garnered on
the Videos and Articleon the various platforms of the Defendant No.
2 to 11, it is evident that the Videos and the Article are seriously
damaging the hard earned reputation and goodwill of the Plaintiffs.
13. The wide viewing and circulation of the Videos and Articlehave not
only injured the Plaintiffs‟ reputation but has also exposed the
Plaintiffs to hatred, ridicule and repulsion thereby tarnishing the
image of the Plaintiffs‟, which image the Plaintiffs took years to build
in the industry. Further, it is pertinent to mention that Plaintiff No.1
and its various group companies routinely do business with several
government and non-government organizations for execution of
infrastructure projects. It is stated that the publication of the Videos

009
and the Article and such mails sent to various authorities which gives
excessive adverse and negative publicity of the Plaintiffs, is likely to
adversely impact their ongoing and future projects, on account of
widespread circulation of such misleading and false information
available on the platforms of the Defendants Nos. 2 to 11 and thereby
cause irreparable loss and injury to the Plaintiffs.
14. It is stated that upon basic preliminary enquiries/ investigation
conducted by the Plaintiffs ongoogleto find out about the Defendant
No. 1‟s past journalistic endeavours as it claims to be a media,
publishing and broadcasting company based in Australia, the
existence of Defendant No.1 and its website is highly suspect. The
Defendant No. 1 has absolutely no journalistic credentials and is a
sham and bogus entity which has been created with the sole purpose
of running the present defamatory campaign against the Plaintiffs.
15. It is stated that the Article and the Video are not in the pursuit of
genuine and meaningful investigative journalism. Further, the act of
publishing the Impugned Article and Video by the Defendant No.1
oversteps the principles of journalistic conduct. The Article and
Video against the Plaintiffs is accusatory in nature, wherein the
Defendant No.1 has tried to portray the Plaintiffs guilty of certain
financial irregularities. The acts of the Defendant No.1 are motivated

010
with the sole intention to sensationalize and spread misinformation
and thereby defame the goodwill and standing of the Plaintiffs before
the world at large.
16. That the Plaintiffs have made out a strong prima facie case in their
favour and as such are likely to succeed on merits in the present
proceedings. The Plaintiffs respect the right to freedom of speech and
expression, however in any event, the freedom of speech guaranteed
under the Constitution of India cannot be reckless, manipulative,
misleading or without regard to any person‟s honor or reputation.
Freedom of speech is also coupled with the basic tenement of
journalistic code of conduct, where criticism is permitted but without
infringing someone‟s reputation and without exceeding the limits and
boundaries of law to injure reputation. The reckless and malicious
actions/inactions of the Defendants have cause irreparable loss and
injury to the Plaintiffs. Further, it is reiterated that the Article, the
Videos and the emails are not in the pursuit of genuine and
meaningful investigative journalism and the contents of the Article
and Video are even otherwise an abuse of freedom of speech, which
is a right not available to Defendant No. 1 being a foreign entity. The
matter is grave and urgent as once the Article and the Videos posted
on the various social media platforms of the Defendant No. 2-11 are
011
further exposed to more people or further shared by people then the
Plaintiff shall be left virtually remediless.
17. The balance of convenience lies completely in favour of the Plaintiff
and totally against the Defendants. Moreover the loss which has
and/or is likely to be caused to the Plaintiffs by the dissemination of
the defamatory and malicious Article and the Videos by the
Defendants will be incalculable and irreversible as the Plaintiff No. 1
is company of stellar repute and the Plaintiffs No. 2 and Plaintiff No.
3 also enjoy impeccable reputation and goodwill in the concerned
industry and amongst the public at large. Such loss caused to the
Plaintiffs cannot be mitigated or compensated in monetary terms.
18. Therefore, in view of the aforesaid, urgent ex-parte orders need to be
passed by this Hon‟ble Court to protect the reputation and the
goodwill of the Plaintiffs.
19. That if Interim Relief as prayed for in the present Application is not
granted to the Plaintiffs then the Plaintiffs will suffer undue hardship,
irreparable loss and injury which would be beyond any monetary
compensation.
PRAYER
012
In view of the aforesaid, it is humbly prayed that this Hon‟ble Court
may be pleased to:-
a. Pass an ex-parte ad interim injunction in favour of the
Plaintiffs and against the Defendants to take down, remove,
block/restrict or suspend access to the Videos and the Article
mentioned in the list of documents attached with the present
Plaint and/or any other active or similar URLs/weblinks which
contain or purport to contain the defamatory Videos and
Article or part thereof posted on their respective websites, and
also from all media in the control of the Defendants, including
but not limited to Defendants channels, website, webpages,
social media platforms pending adjudication/determination of
the said Suit.
b. Pass an ex-parte ad interim injunction in favour of the
Plaintiffs and against the Defendants restraining them and all
their servants, agents, employees, business partners/associates,
assignees and nominees, or any other person or persons
claiming through or under the Defendants from posting,
publishing, broadcasting, distributing or disseminating in any
form or manner whatsoever any defamatory post/news article,
videos against the Plaintiffs pending
adjudication/determination of the present Suit;

013
c. Pass any such further order (s) or other reliefs as it may deem fit and
proper in the facts and circumstances of the case and thus render justice.
�!�
APPLICANTS/PLAfNTiFFS
Through:

SYAL&CO
Address - E-34, Greater Kailash Enclave - II,
New Delhi - 110048
Mobile No.: 9439349298
Email Id- syalandcompany@gmail.com
Place: New Delhi

Date: 22.01.2021
Iii n::r11 71, I • II I f'· :�f;ifFMl...lffl'l,11:l�! :·a ;:.1: TF

014

LA No. OF 2021
IN
C.S. (OS) No. OF 2021
IN THE MATTER OF:

Versus
AFFIDAVIT
having office Zonal Office at D-II, Southern Park, 5th Floor, Saket Place, Ssaket, New
" j)elhi-H0017, India do hereby solemnly affirm and declare as under that
I. I am the Power of Attorney holder and authorized signatory of the Applicant

No.1/Plaintiff No. I and I am duly authorized to sign, verify and file the
accompanying Application. I am fully conversant with the facts and
circumstances of the case, hence competent to swear by way of the present
Affidavit.
2. I have read and understood the contents of the accompanying Application and the
and' belief. There is no false statement or concealment of any material fact'>:~IJ"
document or record. ~~
For Srei Infrastructure F~ Ltd.
3. All documents filed along with the Suit are true copies of the respective OIigj~::. ,;.e~ "
AL",'Q"o'Jc~
DEPONENT
, r ru '","'",.".",, .- -.111
~
015
016

I.A No. ____ OF 2021
IN
C.S. (OS) No.________ OF 2021
IN THE MATTER OF:

Versus
International Media Corporation&Ors. ...Defendants
APPLICATION ON BEHALF OF THE PLAINTIFF UNDER

ORDER 2 RULE 2 READ WITH SECTION 151 OF THE CODE
OF CIVIL PROCEDURE, 1908.

1. That the Plaintiffs have filed the accompanying Suitfor permanent
accompanying Suitand the contents of the same may be deemed to
be and read as part of the present Application.

017
2. It is submitted that the Plaintiffs are in the process of assessing
and ascertaining the damages/losses caused to them on account of
the malicious, reckless, malafideand vindictive reporting of an
alleged scam by the Defendant No. 1 on a sham and bogus
website created by it, namely
“www.scamsbreaking.com”andwww.fraudsbreaking.comwith
the sole intention of carrying out a smear campaign against the
Plaintiffs by uploading/sharing/dissemination of the
videos/URLs/Weblinks/article on the various social media
platoforms of the Defendant No. 2 to 11on the basis of false and
misleading facts/documents/information to the world at large
whose genuineness and veracity are highly questionable.
3. The Plaintiffs submit that there may be actions which the
Defendants have taken which are not within the knowledge of the
Plaintiffs as on the date of filing the accompanying suit. The
Plaintiffs accordingly crave leave of this Hon‟ble Court to initiate
appropriate legal proceedings to exercise its rights against the
Defendants seeking for appropriate damages. It is impossible for the
Plaintiffs to ascertain all remedies/reliefs which have either accrued
or may accrue due to the acts and conduct of the Defendants. The
018
Plaintiffs crave leave of this Hon‟ble Court to seek any other reliefs
arising out of the actions of the Defendants at a later stage.
4. Accordingly, the Plaintiffs are is filing the present Application under
Order 2 Rule 2 (3) of the Code of Civil Procedure, 1908 seeking
leave of this Hon‟ble Court to file a suit for other
reliefs/damages/compensation against the Defendants at a later
stage.
5. The present Application has been made bona fide and in the interest
of justice. The balance of convenience is in favour of the Plaintiff
Company and against the Defendants.
PRAYER
In view of aforementioned facts and circumstances, it is humbly
prayed that this Hon'ble Court may be pleased to:
a. Allow the present application and grant leave to the Plaintiff
Company to file a suit seeking damages arising from the
actions of the Defendants, at a later stage;

019
b. Pass any such further order (s) or other reliefs as it may deem fit and
�!�
Through:

SYAL&CO
New Delhi - 110048
Mobile No.: 9439349298
Place: New Delhi

Date: 22.01.2021

20
IN THE HIGH COURT OF DELID AT NEW DELHI
I.A No. OF 2021

IN
C.S. (OS) No. OF 2021
IN THE MATTER OF:
Versus
AFFIDAVIT
having office Zonal Office at D-II, Southern Park, Saket Place, Saket, New Delhi-
110017, India do hereby solemnly affirm and declare as under that
1. I am the Special Power of Attorney Holder of the Applicant No.3/Plaintiff No.3

and I am duly authorized to sign, verify and file the accompanying Application. I
am fully conversant with the facts and circumstances of the case, hence
competent to swear by way of the present Affidavit.
and belief. There is no false statement or concealment of any material fact,
document or record.
3.
21
n
~
DEPONENT
VERIFICATION
Verified at ,14l-eJ on this~iaYJ~~ ~02l that the contents of the

above Affidavit are true and correct to~e b~~'t 6fJffi~' knowledge, information and
belief. Nopartof it is false and nothing material has beenconcealed there from.
w-' JAN 2H2'".

~~
DEPONENT
_.
022

I.A No. ____ OF 2021

IN
C.S. (OS) No.________ OF 2021
IN THE MATTER OF:

Versus
APPLICATION UNDER SECTION 151 OF THE CODE OF CIVIL

PROCEDURE, 1908 ON BEHALF OF THE PLAINTIFFS FOR
EXEMPTION FROM FILING ORIGINAL AND/OR CERTIFIED
COPIES OF THE DOCUMENTS, TYPED COPIES OF THE
DOCUMENTS WHICH ARE DIM, ILLEGIBLE AND DO NOT
HAVE PROPER LEFT HAND MARGIN
MOST RESPECTFULLY SHOWETH:-
1. That the Plaintiffs have filed the accompanying Suit for permanent
accompanying Suit and the contents of the same may be deemed to
2. Along with the accompanying Suit/Plaint, the Applicants/ Plaintiffs
have filed certain documents, some of which are dim, illegible and
do not have proper left-hand margin, which are relied upon by the
Applicants/ Plaintiffs in support of their case. However, due to

023
paucity of time and in view of the urgency of the matter as stated in
the Suit, the Applicants/ Plaintiffs have not been able to get the dim
documents typed. It is, therefore, expedient in the interest of justice
that the instant Suit is entertained on the basis of the documents as
filed with the Suit.
3. In the above circumstances, the Applicants/ Plaintiffs are filing the
present Application seeking exemption from filing, certified copy,
true and typed copies of the documents which are dim, illegible and
have improper left hand margin, filed along with the accompanying
Suit. However, the Applicants/ Plaintiffs undertake to file the same
as and when directed by this Hon'ble Court.
4. The present Application is being filed bonafide and in the interest of
justice and equity. Grave prejudice and irreparable harm would be
caused to the Applicants/ Plaintiffs, if the present Application is not
allowed.
PRAYER
It is therefore respectfully prayed that this Hon‟ble Court may be pleased

to:-
a) grant exemption to the Applicants/ Plaintiffs from filing Certified
copy, typed copies of the documents which are dim, illegible and do
not have proper left hand margin, that are filed along with the
accompanying Application and entertain the Suit as such; and

024
�!�
Through:

SYAL&CO
New Delhi - 110048
Mobile No.: 9439349298
Place: New Delhi

Date: 22.01.2021

,
,,'
. 025

LA No. OF 2021
IN
C.S. (OS) No. OF 2021
IN THE MATTER OF:
Versus
AFFIDAVIT
having office Zonal Office at D-II, Southern Park, Saket Place, Ssket, New Delhi-
110017, India do hereby solemnly affirm and declare as under that:
1. I am the Special Power of Attorney Holder of the Applicant No.2/Plaintiff No. 2

document or record.
3.
/I I " f;I" r l I ' I I

026
DEP~
VERIFIC1'TR>;N . \
/:, I .•·-2::2 JAN lUZl
Verfo~a ~t
\\ . / \
\)A~
'
on this
,· ·:.
~ i~ay of _ _, 2021
'f
that the contents of the
fr~"tnr
above Affillwi:i-t are tnie ~:nq correct' to 'the best of my knowledge, information and
belief. No
'~\~ ~
pait~f i:!~~";.]"'.'f
,.., .. '"-,, '> ~. .. ;
nothi~g material has been concealed there ~
2 2 J~N 2UZl DEPONE~

027

I.A No. ____ OF 2021
IN
C.S. (OS) No.________ OF 2021
IN THE MATTER OF:

Versus
APPLICATION UNDER SECTION 151 OF THE CODE OF CIVIL

PROCEDURE, 1908 ON BEHALF OF THE PLAINTIFFS FOR
EXTENSION OF TIME FOR FILING COURT FEES.
1. That the Plaintiffs have filed the accompanying Suitfor permanent
accompanying Suitand the contents of the same may be deemed to
2. The Plaintiff submits that the present Suit is being filed in grave
urgency. The Plaintiff approached the Advocates for filing the Suit
and thereafter the Suit and accompanying Applications were drafted.

028
After the quantification of the Court Fee, the Plaintiff is in the
process of paying the Court Fees. The Court Fees being of a large
amount and on account of paucity of time, the actual Court
Fee/Stamp could not be procured and filed along with the Suit.
Therefore, the Plaintiff requests this Hon'ble Court to extend the
time for filing the court fees for a period of 2 weeks, cannot be filed
due to paucity of time.
3. The Plaintiff submits that the Suit is valued at Rs. 2,00,01,000/- and
the court fees has been quantified at Rs. 1,98,000/- and the Palintiff
is in the the process of paying and undertakes to pay the same within
2 weeks.
4. The present Application has been made bona fide and in the interest
of justice. The balance of convenience is in favour of the Plaintiff
and against the Defendants. If the Order as prayed for is not granted,
the Plaintiff would suffer irreparable loss and injury. The present
Application is bonafideand in the interest of justice.
PRAYER
In view of aforementioned facts and circumstances, it is humbly prayed
that this Hon'ble Court may be pleased to:
a. Extend the time period for filing Court Fees by a period of 2

weeks;
029
�!�
Through:

SYAL&CO
New Delhi - 110048
Mobile No.: 9439349298
Place: New Delhi

Date: 22.01.2021

'>I
030

LA No. OF 2021
IN
C.S. (OS) No. OF 2021
IN THE MATTER OF:
Versus
AFFIDAVIT
having office Zonal Office at D-II, Southern Park, Saket Place, Saket, New Delhi-
110017, India do hereby solemnly affirm and declare as under that:
1. I am the Special Power of Attorney Holder of the Applicant No.3/Plaintiff No.3

document"or record.
u.v."''lNUents filed along with the Suit are true copies of the respective originals.
r "if:; ; ; r ~ J: r · - ' i: ' · ; ; _

' 11
I r1 11:: ~ II: ill I I , II
, 031
DEPONENT
[II n:r111 i:.1 I q · ·-;:1 11·;1·•Fn-,1,-·,,,·.n!IG1&111n11m;;m;;,111,f!;.1.11 f~™l 1Wll"r'r.'Fi -!f iiTij 1: ., I.\\ ... U#Hltltiiti& ,...,
001

CS(OS) NO.______ OF 2021
IN THE MATTER OF:

Versus
INDEX PART -III

1. Index Part III 1
2. Vakalatnama
2
PLAINTIFF
Through

SYAL&CO
Mobile No.: 9439349298
Place: New Delhi

Date: 22.01.2021
002
C.S. (OS) No. ___ OF2021
IN THE MATTER OF:

SREI Infrastructure Finance Ltd. & Ors.
... PLAINTIFFS
Versus
International Media Corporation & Ors.

...DEFENDANTS
VAKALATNAMA
KNOW ALL to whom these present shall come that _Shiv _Shankar
__ _ _, the authorized signatory of the above named
Chowdhary
PLAINTIFFS do hereby appoint:-

ARJUN SYAL/MANJIRA DASGUPTA/AKSHITA SACHDEVA/SHREYAN DAS
ADVOCATE
ENROL NO. D-1180/2011, D-3104/2009, D-1052/2016, D-3113/2017
SYAL & CO.
E-34, GK-II ENCLAVE,
NEW DELHI-110048
MOBILE: 9717977915
(herein after called the advocate/s) ,\to be my/our Advocate in the above noted case authorized him :-
To act, appear and plead in the above-noted case in this Court or in any other Court in which the same may be tried
or heard and also in the appellate Court including High Court subject to payment of fees separately for each Court
by me/ us.
To sign, file verify and present pleadings, appeals cross objections or petitions for execution review, revision,
withdrawal, compromise or other petitions or affidavits or other documents as may be deemed necessary or proper
for the prosecution of the said case in all its stages.
To file and take back documents to admit and/or deny the documents of opposite party.
To withdraw or compromise the said case or submit to arbitration any differences or disputes that may arise
touching or in any manner relating to the said case.
To take execution proceedings.
The deposit, draw and receive money, cheques, cash and grant receipts thereof and to do all other acts and things
which may be necessary to be done for the progress and in the course of the prosecution of the said case.
To appoint and instruct any other Legal Practioner, authorizing him to exercise the power and authority hereby
conferred upon the Advocate whenever he may think it to do so and to sign the Power of Attorney on our behalf.
And 1/We the undersigned do hereby agree to ratify and confirm all acts done by the Advocate or his substitute in
the matter as my/our own acts, as if done by me/us to all intents and purposes.
And I/We undertake that I / we or my /our duly authorized agent would appear in the Court on all hearings and will
inform the Advocates for appearance when the case is called.
And I /we undersigned do hereby agree not to hold the advocate or his substitute responsible for the result of the said
case. The adjournment costs whenever ordered by the Court shall be of the Advocate which he shall receive and
retain himself.
And I /we the undersigned do hereby agree that in the event of the whole or part of the fee agreed by me/us to be
paid to the Advocate remaining unpaid he shall be entitled to withdraw from the prosecution of the said case until
the same is paid up. The fee settled is only for the above case and above Court. I/We hereby agree that once the fee
is paid. I /we will not be entitled for the refund of the same in any case whatsoever. If the case lasts for more than
three years, the advocate shall be entitled for additional fee equivalent to half of the agreed fee for every addition
three years or part thereof.
IN WITNESS WHEREOF 1/We do hereunto set my /our hand to these presents the contents of which have been
understood by me/us on this 22 day of_ 01. 2021. Accepted subject to the terms of fees.
ForSrei Infrastructure �d-
Authorised. Si�
Arjun Syal Shreyan Das

Advocate
Advocate
IDENTIFIED SIGNATURES OF ABOVE NAMED CLIENT
I ff iFi � 11, 11 I I ii I 1 ,: ~1::1r:Jllllflalll1R'll'W>Jlli\!IIRl!Uqr,.11 :-,, 1 11 11,, W:Mi i41R,~ll-i•lidjliiiiilifil4\ilWPZ IIZI A Uh ._.,

001
CS(OS) NO.______ OF 2021
IN THE MATTER OF:

Versus
INDEX PART – IV
S. Document Details of Document Originals or Mode of Line of Pg.

No. Parties to the in power, photocopies execution/issu custody No.
documents possession or office ance or
, control copies receipt
and
custody of
1. INDEX PART -IV 1 –
6
2. Document Plaintiff No. Plaintiff Photocopy Signed by the Plaintiff 7 –

No.1: Board 1 No. 1 Board of the No. 1 9
Resolution Director of the
dated Plaintiff
14.12.2020
3. Document Plaintiff No. Plaintiff Electronic Registered and Plaintiff 10 –

No. 2: Special 2 No. 2 Record signed by No.2 13
Power of Plaintiff No.2.
Attorney of
Plaintiff No. 2
4. Document Plaintiff No. Plaintiff Electronic Registered and Plaintiff 14 –
No.3: Special 3 No. 3 Record signed by No.3 17
Power of Plaintiff No. 3
Attorney of
Plaintiff No. 3
5. Document Plaintiffs Plaintiffs Electronic Email issued Plaintiffs 18
No.4: record by employee
Screenshots of of Plaintiffs
fraudsbreakin
g
002
6. Document Plaintiff and Plaintiffs Electronic Email issued Plaintiffs 19 –
No.5: Article Defendants and record by an and 38
dated Defendant employee of Defendants
14.12.2020 s the Plaintiffs
7. Document Plaintiff and Plaintiff Electronic Email issued Plaintiff 39 –

No.6: Press Defendants and record by an and 53
Statement Defendant employee of Defendants
dated s the Plaintiff
14.12.2020
8. Document No Plaintiff and Plaintiffs Electronic Email issued Plaintiffs
7: Video dated Defendants and record by an and 54
14.12.2020 Defendant employee of Defendants
s the Plaintiff
9. Document Plaintiffs & Plaintiffs Electronic Email issued Plaintiffs 55 –

No. 8 : Defendants and record by an and 64
Transcript of Defendant employee of Defendants
the Video s the Plaintiff
dated
14.12.2020
10. Document Plaintiffs Plaintiffs Electronic Email issued Plaintiffs
No.9: Video and and record by an and 65
dated Defendants Defendant employee of Defendants
15.12.2020 s the Plaintiff
No. 10: Record by an
Screenshot of employee of
Malya, Nirav the Plaintiffs
Modi and
Lalit Modi
No. 11: record by an
Screen employee of
shot of Lady the Plaintiff
Justice
Indian the Plaintiffs
Currency

Animated the Plaintiffs
chess
003
Tip of the the Plaintiffs
Iceberg

Pictures of the Plaintiffs
Kanoria
Family
17. Document Plaintiffs Plaintiffs Electronic Email issued Plaintiffs 72 –
No. 16: List of Record by an 73
URLs employee of
the Plaintiffs

No.17: Record by an 75
Domain employee of
information of the Plaintiffs
scamsbreaking
.com(Who is)
No. 18: record by an 77
Domain employee of
information of the Plaintiffs
fraudsbreakin
g.com(Who
is)
20. Document Defendant Plaintiffs Electronic Email issued Plaintiffs 78 –

No. 19: No. 1 and record by an 93
Privacy Policy Defendant employee of
of Defendant No. 1 the Plaintiff
No. 1
No. 20: Record by an 120
Privacy Policy employee of
of the Plaintiff
Warnermedia
No. 21: record by an –
Australian employee of 122
Securities and the Plaintiff
Investments
Commission
Database
004
23. Document Plaintiff No. Plaintiff Photocopy Email issued Plaintiff 123
No. 22: 1 No. 1 by an No.1 –
Certificate of employee of 125
Incorporation the Plaintiff
dated No. 1
04.08.2004
24. Document Plaintiff No. Plaintiff Electronic Email issued Plaintiff 126
No. 23: 1 No. 1 record by an No. 1
Brochures/Aw employee of
ards & the Plaintiff
Accolades of
SIFL
25. Document Plaintiff No. Plaintiff Photocopy Email issued Plaintiff 127
No. 24: Big 1 No. 1 by an No. 1
Deals of SIFL employee of
the Plaintiff
26. Document Plaintiffs Third Electronic Prepared by Third Party 128

No. 25: Press Party record the Third Party
Statement
issued by Axis
Bank
Address being the Plaintiff
Airport No. 1
Address
28. Document Plaintiff Plaintiff Office copy Prepared by Plaintiff 130

No. 27: No.1 No. 1 the Plaintiff No. 1 –
Complaint No. 1 138
dated
14.12.2020
filed before
DCP, Cyber
Crime Cell,
New Delhi
No. 28: No.1 No. 1 the Plaintiff No. 1 –
Complaint No. 1 171
dated
15.12.2020
filed before
DIG, Cyber
CID West
Bengal Police
30. Document Plaintiff No. Advocates Office copy Prepared by Plaintiff 172
No. 29: Copy 1 of the the advocates No. 1 –
005
of Cease and Plaintiffs of the Plaintiff 177
Desist Notice No. 1
dated
05.01.2021
31. Document Plaintiffs Defendant Electronic Email issued Defendant 178

No. 30: Copy and No. 5 Record by Defendant No. 5
of email of Defendant No. 5
Defendant No. No. 5
5 dated
13.01.2021

No.31: Copy and No. 5 Record by Defendant No. 8 –
of email of Defendant No. 5 181
Defendant No. No. 8
8 dated
15.01.2021

No. 32: Copy the Plaintiff –
of email dated 192
29.12.2020

No.33: Copy and the No. 1 record by Defendant No. 1 –
of emails Defendant No. 1 202
dated No. 1
12.01.2021
No.34: Copy and the No. 1 record by Defendant No. 1 –
of emails Defendant No. 1 240
dated No. 1
18.01.2021
36. Document Plaintiff No. Plaintiff Electronic Prepared by Plaintiff 241
No.35: Master 1 No. 1 record the Plaintiff No. 1 –
data of SREI No. 1 249
37. Document Third party Third Electronic Prepared by Third party 250
No.36: Master party record third party –
data of BRNL 251
Master data of
SREI
006
38. Document Defendant Defendant Electronic Prepared by Defendant 252
No.37: No. 2 No. 2 record Defendant No. No. 2 –
Inappropriate 2 254
Content policy
of Google
PLAINTIFF
Through

SYAL&CO
Mobile No.: 9439349298
Place: New Delhi

Date: 22.01.2021
$REI Document No- 1
007
CERTIFIED TRUE COPY OF THE RESOLUTION PASSED AT THE MEETING

(NO. FY 19-20/07) OF THE COMMITTEE OF DIRECTORS OF THE COMPANY
HELD ON FRIDAY, THE 14TH FEBRUARY, 2020 AT 'BOARD ROOM', 7
ALIPORE AVENUE, KOLKATA - 700 027
ISSUE OF POWER OF ATTORNIES (POAs) IN FAVOUR OF EXECUTIVES/

AUTHORISED REPRESENTATIVES OF THE COMPANY FOR THE FINANCIAL
YEAR 2020-21
It was informed to the Committee that the Company has initiated and / or needs to
initiate/contest/defend legal proceedings against/by various parties in respect of various
transactions being undertaken by the Company and for smooth functioning and for proper
follow up on those matters, it is required to authorise persons as representatives of the
Company to take necessary legal steps in connection with the aforesaid matter on behalf of
the Company before the appropriate Court(s), Tribunal(s), Judicial and Quasi- Judicial
forums within the territorial jurisdiction of India only, from time to time as and when
required.
The Members discussed the matter and thereafter passed the following resolution:
"RESOLVED THAT based on the recommendation of the Legal Department of the

Company, following executives / representatives enlisted herein below are hereby authorised
by the Company for signing and taking necessary steps to file/contest/defend any litigation
etc. on behalf of the Company for which separate Power of Attorney (POA) are to be issued
in their favour and which shall be effective from 1st April, 2020 or date of issue of such
POA, whichever is later
Sl. No. Name/ Father's Name Jurisdiction Validity of Power of Attorney

1. Mr. Rajdeep Khullar All over India 31st March, 2021 or as long as the
S/o Late Tilak Raj Khullar constituted attorney remains in the
employment/ association with the
Company or its subsidiary or associate
companies, whichever is earlier.
2. Mr. Ashish Bhattacharyya All over India 31st March, 2021 or as long as the
S/o Late Benoy Bhattacharyya constituted attorney remains in the
3. SK. Abidur Rahaman All over India 31st March, 2021 or as long as the
S/o SK. Aminur Rahaman constituted attorney remains in the
Srei Infrastructure Finance Limited

Registered Office 'Vishwakarma' 86C, Topsia Road (South) , Kolkata - 700046
Tel.: +91.33.22850112-15, 61607734, Fax: +91.33.2285 7542/8501
Email: corporate@srei.com Websie: www.srei.com
CIN No.L29219WB1985PLC055352
$REI 008

4. Mr. Vikash Prasad Singh All over India 31st March, 2021 or as long as the
S/o Late Sri Arvind Kumar Singh constituted attorney remains in the
5. Mr. Sourav Roy All over India 31st March, 2021 or as long as the
S/o Sri Shankar Roy constituted attorney remains in the
6. Mr. Shakunt Vyas All over India 31st March, 2021 or as long as the
S/o Sri Hari Prasad Vyas constituted attorney remains in the
7. Mr. Joydeep Datta Gupta All over India 31st March, 2021 or as long as the
S/o Sri Prabal Kumar Datta Gupta constituted attorney remains in the
8. Mr. Pulak Bagchi All over India 31st March, 2021 or as long as the
S/o Late Sri Purnendu Bagchi constituted attorney remains in the
9. Mr. Sohan Kumar Jha All over India 31st March, 2021 or as long as the
S/o Sri Dhirendra Kumar Jha constituted attorney remains in the
10. Mr. Projoy Chatterjee All over India 31st March, 2021 or as long as the
S/o Sri Pradip Chatterjee constituted attorney remains in the
11. Mr. Shiv Shankar Chowdhury All over India 31st March, 2021 or as long as the
S/o Late A. N. Chowdhury constituted attorney remains in the
12. Mr. Subhadeep Nandi All over India 31st March, 2021 or as long as the
S/o Sri Krishnanath Nandi constituted attorney remains in the
employment/ association with of the

Registered Office 'Vishwakarma' 86C, Topsia Road (South) , Kolkata - 700046
Tel.: +91.33.22850112-15, 61607734, Fax: +91.33.2285 7542/8501
CIN No.L29219WB1985PLC055352
$REI 009

13. Mr. Shounak Chatterjee All over India 31st March, 2021 or as long as the
S/o Sri Tapan Chattopadhyay constituted attorney remains in the
14. Mr. Ajay Kumar Gupta All over India 31st March, 2021 or as long as the
S/o Sri Jagdish Prasad Gupta constituted attorney remains in the
15. Mr. Ganesh Prasad Bagree All over India 31st March, 2021 or as long as the
S/o Late Meghraj Bagree constituted attorney remains in the
RESOLVED FURTHER THAT for the above purpose Mr. Hemant Kanoria, Chairman,
Mr. Sunil Kanoria, Vice Chairman, Mr. Rakesh Kumar Bhutoria, Chief Executive Officer,
Mr. Sandeep Kumar Sultania, Chief Financial Officer and Mr. Sandeep Lakhotia, Company
Secretary of the Company, be and are hereby severally authorised to execute the above
referred Power of Attorneys on behalf of the Company and to take necessary steps as may be
required for the purpose,
RESOLVED FURTHER THAT if so required Mr. Hemant Kanoria, Chairman, Mr. Sunil
Kanoria, Vice Chairman, Mr. Rakesh Kumar Bhutoria, Chief Executive Officer, Mr. Sandeep
Kumar Sultania, Chief Financial Officer, Mr. Ganesh Prasad Bagree, Senior Vice President,
and Mr. Pulak Bagchi, Authorised Signatory of the Company be and are hereby severally
authorised to issue authorisation letters on behalf of the Company in favour of any executives
/ representatives of the Company authorizing them to file/contest/defend any litigation etc.
on behalf of the Company, which shall include authority to appear before the appropriate
Court(s), Tribunal(s), Judicial and Quasi- Judicial forums within the territorial jurisdiction of
India from time to time as and when required on behalf of the Company and to take necessary
steps as may be required for the purpose."
Certified true copy

For Srei Infrastructure Finance Limited
 

 
Company Secretary
FCS 7671

Registered Office 'Vishwakarma' 86C, Topsia Road (South), Kolkata - 700046
Tel.: +91.33.22850112-15, 61607734, Fax: +91.33.2285 7542/8501
CIN No.L29219WB1985PLC055352
i Document No- 2
010
2305b5
'
SPECIAL POWER OF ATTORNEY
I
I I, Hemant Kanoria son of Sri Hari Prasad Kanoria of "Vishwakarma"
• 86C, Topsia Road (South), Kolkata 700046 being a plaintiff in the
proposed Civil suit to be filed in Hon'ble High Court Delhi and/ or

I
any other appropriate court/ (s) at Delhi against defendants Shiv
I
Raman Head (Asia Pacific) Chief Officer Legal Compliances,
International Media Corporation, Scarnsbreaking.com, Google India

I
Pvt. Ltd. Youtube LLC, Facebook India Online Services Pvt. Ltd.,
I
Instagram, Twitter Communications India Pvt. Ltd., Linkedin
'
'
Technology Information Pvt. Ltd., Microsoft Corporation, Ashok
I Kumar hereinafter referred to as "the said suit". I accordingly hereby

I nominate, constitute and appoint Shri Shiv Shankar Chowdhury
I
o/
I
,19 JAN 2021
-
I
011
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sourv;i'f'RP7HANDA
Licensed St,1m p Vendor
8/2, K. S. Roy Road , Kol-1
012
I son of Late A. . of 5th Floor, D-2 Southern Park, Saket
Place, Saket, New Delhi-110017, as my a ttorney for me, in m y name
and on my behalf to do or execute all or any of the following acts or
things in connection with the said suit:
1. To represent me before the said court or in any other, wh ere the
said suit is transferred in connection with the said suit.
2. To en gage or a ppoint any solicitor, counsel, advocate, pleade r or
lawyer to conduct the said suit and Sign Vakalatnama of the said
purpose.
3. To prosecute the said suit and proceedings, to sign and verify all
plaints, pleadings, applications, petitions or documents before the
court and to deposit, withdraw and receive document and any money
or moneys from the court or from the defendant either in execu tion of
the decree or otherwise and sign and deliver proper receipts for me
and discharges for the same.
4 . To apply for inspection and inspect documents and records, to
obtain copies of documents and papers.
5 . To compromise the suit as it may deem fit and proper m the
interest of the Plaintiff/ (s) .
6. To do generally all other acts and things for the conduct of the said
suit as I could have done the same if I were personally present.
And I hereby for myself, my heirs, executors, administrators and legal
representatives, ratify and confirm and agree to ratify and confirm
whatsoever our said attorney shall do or purport to do by virtue of
these presents.
2
, . J"\ Q ) sz
013
IN Wl1'N e~R W
' • · HEREOF', I the Raid Mr. Hem.ant Ka..noria has hereunto
8
et hnci 8Ub8cribcd my ha nd this .\9.~ .:....... day of January, 2021.
Sign ' d O.nd delivered by the within named WJTNESS at Kolkata.
/nceof
Signature of Mr. HEMANT KANORIA
11-~:rJ .~ ~
~;~ ~i.,.J,
Witnesses:
Sieuture11 f
are Attertect o the EJ1:ecur1n1t,
ldenri arioo
ofdae Ad,OC:~e
.~ ·- h__
Notary
S~ Na.tru C IsCa ,,,
No tary.Govt. of W B
R.gd . No . 447/19 .
City CivU Court, Calcuttl!II
/ , B;r,,,.Joji r ),(o-i~
J a, oId Po 1r o r ~ iC! t ~ ~ "'< • ,._. ,JS JAN 2021
k O Lkofe- - ~ O OO iJ /
3
Document No- 3
014
E 230564
I
t
SPECIAL POWER OF AITORNEY
I, Sunil Kanoria son of Sri Hari Prasad Kanoria of "Vishwakarma"
86C, Topsia Road (South), Kol.kata 700046 being a plaintiff in the
proposed Civil suit to be filed in Hon'ble High Court Delhi and/or
any other appropriate court/(s) at Delhi against defendants Shiv

t
Raman Head (Asia Pacific} Chief Officer Legal Compliances,
• International Media Corporation, Scamsbreaking.com, Google India

I
Pvt. Ltd. Youtube LLC, Facebook India Online Services Pvt. Ltd.,
I
Instagrarn, Twitter Communications India Pvt. Ltd., Linkedin
I
Technology Information Pvt. Ltd., Microsoft Corporation, Ashok
I
Kumar hereinafter referred to as "the said suit". I accordingly hereby
I
1
I 19 JAN 202J
I
015
0~67SO
~.tNt', ... , ..... ... .... .. Data
- ........ .
N 4l\l ft, . •, · • • • • • • • • • •••• ••••I ••II I• t t I
SOUMIT~ A ~ NOA
Licensed Sta mp Ve nd or
8/Z, K. S. Roy Road, Kol-l
• . 447 016
. of W.B. 1
ii)' Date ·1
og.2024 1 J.~ - II
,C/1
'0 _;7
nominate, constitute <1"1fffffi'fi1'li hri Shiv Shankar Chowdhury son of Late
A.N. Chowdhury of 5th Floor, D-2 Southern Park, Saket Place, Saket, New
Delhi-110017 as my attorney for me, in my name and on my behalf to do or
execute all or any of the following acts or things in connection with the said
suit:
1. To represent me before the said court or in any other, where the said suit is
transferred in connection with the said suit.
2. To engage or appoint any solicitor, counsel, advocate, pleader or lawyer to
conduct the said suit and Sign Vakalatnama of the said purpose.
3. To prosecute the said suit and proceedings, to sign and verify all plaints,
pleadings, applications, petitions, appeals, rejoinder affidavit or documents etc
before the court and to deposit, withdraw and receive document and any
money or moneys from the court or from the defendant either in execution of
the decree or otherwise and sign and deliver proper receipts for me and
discharges for the same.
4 . To apply for inspection and inspect documents and records, to obtain copies
of documents and papers.
5. To compromise the suit as it may deem fit and proper in the interest of the
Plaintiff/ (s).
6. To do generally all other acts and things for the conduct of the said suit as 1
could have done the same if I were personally present.
And I hereby for myself, my heirs, executors, administrators and legal
representatives, ratify and confirm and agree to ratify and confirm whatsoever
our said attorney shall do or purport to do by virtue of these presents.
19 JAN 202,
2
I 017
IN WITN ESS WH EREOF, I the said Sunil Kanoria has hereunto set and
8ub~ rlbtd my hand this .. !~~.'.. ..... day of January, 2021. Signed and
d livered by the within named WlTNESS at Kolkata.
Signature of Mr. SUNIL KANORIA
Witnesses:
Signature/a of the E:~cu!•· ··,

arc Attcatcd ou the ldcnti(
of lb Advom,
2.
otary
s~ .,,,, f s(am
No tary.Govt . o f W.B .
Regd . N o . 4 4 7/19
City Civil C o u rt , C~kutta
IS JAN 202/
3
Document No- 4
II Q) IDID t
018
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f- ➔ C O A Not Secure I fraudsbrea king.com/category/breaking-news * O D Q :i.
BREAKING NEWS BREAKING NEWS BREAKING NEWS
'Ghost Boat' with $80 Indian Banks Again ScamsBreaking.com

million cocaine haul Blindly Shell Crores Of reaffirms the contents
washes ashore on ... Public Money With ... of its expose again ...
7month ago 7month ago 7month ago
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the /\xis Bank terming our allegation as
Locals attempted to move the boat on The ScamsBreaking.com has baseless. The statement made by the
their own, but the sheer weight made unearthed the 16 thousand crores banker...
it impossible. scam which has been commissioned
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Show All X
12/21/2020 Scams Breaking - Indian Banks Again Blindly Shell Crores Of Public Money Without Any Due Verifications In Yet Another Huge Scam C…
LATEST NEWS Document No- 5 019

BYU beats No. 18 San Diego St despite Mitchell's 35 points 2 days ago
TODAY 2020-12-21
15:29:46
Indian Banks Again Blindly Shell Crores

Of Public Money Without Any Due
Veri cations In Yet Another Huge Scam
Commissioned By Kolkata’s Kanoria
Brothers.
2020-12-14 00:00:00
https://scamsbreaking.com/news/indian-banks-again-blindly-shell-crores-of-public-money-without-any-due-verifiactions-in-yet-another-huge-scam-co… 1/20
ScamsBreaking.com has already submitted the documentary evidence to Indian 020

Law enforcement agencies including that of CBI, ED, Income Tax O ce, Ministry
of Finance etc. The collected evidences clearly not only show but also establish the
siphoning of more than 16 Thousand of cores of public money and the report also
shows that this Scam can cross the number of 50 Thousand Crores and also the
illegal routing of the public money out of India.
The ScamsBreaking.com has unearthed the 16 thousand crores scam which has
been commissioned at Kolkata by Kanoria Brothers. The forensic and legal due
diligence has revealed various shocking facts about the scams.
Another ludicrous scam is being unveiled which would take anybody by surprise at
the scheme that is being used by the Kanoria brothers in siphoning o money to
the tune of 16000 crores INR into illegitimate and fake accounts. Huge amounts of
money have been routed through transfer of funds to shell entities under false
pretext, fraudulent documentation, creation of fake companies which existed only
on paper etc which nally make its way to a SREI account. Through a well-planned
strategy, the Kanoria family has smoothly funnelled over Rs. 16000 crores, one of
the largest so far into their account.
The Kanoria Family runs three main businesses namely SREI Infrastructure
Finance Limited (SREI), SREI Equipment Finance Limited (SEFL) and India Power
Corporation Limited (IPCL). The SREI entities are funded by various banks while
the IPCL is funded by Government institutions like Power Finance corporation etc.
The Kanoria brothers have evolved various means to siphon o the huge public
money and created multiple shell and criminal purposes vehicles. The soul aim of
such criminal creations was to illegally transfer the money from one to another
bogus entity. The most unfortunate part of this entire scam is that Indian lending
institutions have become highly incapable of fallowing the even basic norms of
verifying the end use of so lent out money. In addition to others; the AXIS bank is
the worst lender shelling out public money blindly and without any due
veri cation in Kanoria brothers scams.
The Kanoria Family created countable bogus entities and Power Trust was one021 of
them. The Power Trust is a registered trust at Kolkata in the state of West Bengal
and run by Kanoria Brother’s Agents and yet the Kanorias dare to call it Public
Trust.
They set up a public trust by the name of Power Trust which has been used as the
criminal purposes vehicle to siphon funds. SREI has been setting up various
businesses of infrastructure nancing, infrastructure development and related
business interests in projects such as roads, ports, telecom, power, rural
infrastructure, housing, hospitality and healthcare over three decades. Over many
years there have been serious violations of several civil and criminal laws and
regulations.
The scam has been pulled o mainly by sanctioning and disbursing huge amounts
in secured and unsecured transfer of funds to bogus and dubious shell companies
on the basis of sham documentation, duly promoted by the Kanoria brothers.
These companies have in turn passed the money back either to Power Trust or to
other bogus entities which has amounted into money laundering, cheating, tax
evasion and various other substantive o ences thereof. The ScamsBreaking.com
has collected substantial documentary evidence which has been submitted to the
Indian law enforcement agencies for further investigations.
The Kanoria brothers had criminally setup the Power Trust as public trust which
only had people from the Kanoria business enterprises on the board of trustees.
The board has Mr. Dipak Rudra, who is the director of IPCL, Mr. Ajay Kumar
Agarwal – statutory auditor for the SREI group of companies, he is also the
director of Shristi Infrastructure, which is a SREI promoted entity. Mr. Shounik
Mitra a lawyer by profession who has been representing SREI group of companies
as their legal counsel on various legal cases.
It is quite alarming to note that Power Trust has agents or employees of the
Kanoria group, whereas a public trust should be governed by independent and
unrelated individuals from the public space. The o cial claim of the Kanoria
brothers has been that Power Trust runs as an independent trust thus having an
independent board of trustees and a minimum shareholding from the public, this 022
was accounted at less than 25%. The chief function of the trust has been to only
transfer funds!
The ScamsBreaking.com has gone deeply to examine the way the fraud has been
committed, India Power Corporation Limited (IPCL) transfers funds to Power Trust
on the pretext of CSR funds. These funds are then further transferred to another
Kanoria shell entity. There has been a transfer of more than INR 3500 crores
between SREI and IPCL via various shell companies which have been concealed in
all nancial statements of the companies.
In the past the Indian government has been very strict against shell and bogus
companies. Traditionally, shell companies in India have been used for rotation and
siphoning o of funds by the promoters through ctitious sales, in ated
purchases, unjust commissions or for creation of equity for ultimate owners who
are shielded by cloaks of deceit. It is to be noted that transactions between IPCL
and SREI are related party transactions (RPT’s) which have been deliberately
concealed amounting to criminal violation and mandatory disclosure
requirements. All money that is transferred to Power Trust is shown as CSR funds.
Most interestingly, IPCL’s nancial statements for the year 2017-18 show transfers
to the tune of INR 557 crores of public money to Power trust under the false
pretext of purchase of investments. Power Trust actually received INR 695 crores
which was further diverted to other shell entities promoted by the Kanoria
brothers. This could happen also because of the fact that the very auditor itself has
also been hand and glove with Kanoria Brothers.
Shockingly, another instance of looting public money is with the M/S Bhaskar
Silicon Pvt. Ltd (BSPL) and its further subsidiary Environ Energy Corporation Ltd.,
both loss making shell companies of the Kanoria brothers availed loans to the tune
of INR 2400 crores using SREI Infrastructure fraudulent documents. These
companies further siphoned INR 1000 crores to Power Trust. This INR 1000 crores
was routed back to SREI Infrastructure. There is also a signi cant deviation of the
company on material disclosure of information in all of the cases where the shell 023
entities are actively suppressing facts on terms of borrowing, terms of repayment
and the lending institution they are borrowing from.
The ScamsBreaking.com also deeply investigated the fact that Kanoria Brothers’
agents run Bharat Road Network limited (BRNL), along with its subsidiaries which
are controlled and managed by common board of directors and employees from
SREI. SREI purchased shares, that were actually trading at INR 25-40 per share, at a
premium of INR 195 per share. This was a smart move. Now by this illegal step
SREI smartly made the nancials of BRNL ‘Green’ thus creating reserve surplus for
BRNL. A whopping INR 2575 crores public money was siphoned o under the garb
of fake loans. If we are to trail the end use of public money then we will
understand that INR 1114 crores has been further invested in BRNL subsidiaries
and this information has been kept under wraps.
Our Forensic Investigation also revealed that Sahaj E village Limited and its
subsidiary Rural Innovation labs Pvt Limited which are operated by Kanoria
Brothers’ agents having zero value in the market was given INR 1213 crores as loan
at a paltry 6% P. A. interest as against the regular rate of 18% p. a. These loans were
given on the basis of a cash in ow that never existed! This act has also generated a
notional loss for SREI to the tune of INR 146 crores per annum. These illegal
nancial transactions were merely recorded as intercorporate deposits.
The Biggest Expose of the Year 2020 is Here …
024
The ScamsBreaking.com had constituted an special team to understand the depth
of this syndicate which further revealed that another shell entity by the name of
M/S Swaymbhu Natural Resources Private Limited which exists only on papers as a
loss making company since incorporation, managed to receive public money -
INR 895 crores from SREI of which INR 346.3 crores was siphoned to Power trust.
With a classic case of fudged books of accounts when it came to repayment, the
Kanoria brothers funded a huge amount through another entity thus enabling a
show of complete repayment of the loan. In reality it was just an eyewash with
clear looting.
The Forensic Report also unearthed that by the Kanoria Brothers Vara Technology
Pvt. Ltd. was given INR 138 crores on the basis of xed assets amounting to merely
INR 3.8 crores by SREI. M/S Vara Infotech Private Limited, a shareholder in
Kanoria Foundation (SREI owned trust), has also been used by Kanoria Brothers to
siphon o public funds and provide criminal advantage to other group companies.
The Kanoria Brothers have through SREI given INR 395.1 crores which was further
routed under the garb of investment to another entity promoted by the Kanoria
brothers - SREI Alternative Trust. It would be interesting to note that Vara Infotech
Private Limited is a loss-making company and this has been documented as
‘Future in ow’ during the SREI mortgage. This means that if the company does
not show any pro ts, the loans will be written o as bad debt.
Further, A clear case of unsecured lending was with the case of Avarsekar Realty
Pvt. Ltd., another related company of the Kanoria group which received INR 118
crores from SREI without any security whatsoever. M/s Bharat Nirman Fund
promoted by Kanoria Brothers and SREI Infrastructure were earlier shareholders
of Aversekar Realty, and ceased to be shareholders immediately after the loan was
granted to Avarsekar Realty.
The Kanoria Brothers also used Victor Buildwel Private Limited (VBPL) is another
shell company promoted by the Kanoria Brothers’ SREI Alternative Trust (SAT).
They have showed an inventory of INR 17.3 crores as land in greater Noida, UP.
Here again the Kanoria brothers funnelled INR 70 crores against a non-existent 025
property.
The Investigation also reveals that Attivo Economic Zones Private Limited another
company promoted by Kanoria Brothers’ SREI Alternative Investment Trust-
Bharat Nirman Fund. Attivo received INR 2207 crores from SREI and INR 240
crores was routed to Power trust. This transaction was left out from the company
balance sheet so that no questions could be raised. The balance amount was
completely misused. The modus operandi has been that a company has no veri ed
assets, negative net worth and is a loss making company as shown on books of
accounts and exists merely on paper.
It is also revealed that M/s I log Ports Private Limited, another shell company of the
Kanoria brothers showed land worth INR 300 crores on their books. As per eld
veri cation, the land is not even close to being pegged at INR 3 crores. The
company without even mortgaging this land were able to source INR 585 crores of
public funds through SREI. In order to evade taxes, the company has
misrepresented nancial statements by capitalising all its expenses showing no
revenue expenses.

The Kanoria Brothers with their political and bureaucratic connections has made it
easy to carry out these nancial scams. Predicate Consultants Private Limited
(PCPL) is again promoted by the Kanoria brothers incorporated in 2014 as a
nancial consultancy. Mr. Tapas Chakraborty, shareholder at PCPL who also holds
a key role at SREI was given INR 375 crores from which INR 138 crores was further
transferred to Power trust! This is merely the tip of the iceberg with so many shell
companies created as a medium to funnel funds to the tune of INR 16000 crores.

A detailed forensic and legal audit conducted by ScamsBreaking.com has given
various terrifying facts which we will cover in our next exposes but one of them
was Axis Bank, As per the records maintained by MCA (A ministry of Corporate
026
a airs website) the Axis Bank etc. have provided loans to SREI Infrastructure and
Finance Limited to the tune of INR 44,000 crores without any due diligence and
veri cation of end use of the loan amount. This loan amount has been disbursed
with sham receivables including related party transactions. If Kanoria Brothers any
day leave the country; the nancial institutions like AXIS banks will not be able to
recover any of the funds given to SREI and the total public money will have to be
written o which is eventually wiping out funds from the public at large. The Open
charges vide the MCA records shows the status of current exposer of Axis Bank.

Axis Bank has granted total loan of INR 46,000 appx, following is the details
and Particulars of Loan.
CHARGE STATUS DATE HOLDER NAME AMOUNT (Rs. PROPERTY TYPE
ID Crore)
100241419Creation -Feb- AXIS BANK350.00 Book debts, Movable
2019 LIMITED property
-Nov-
10240661 Modi cation2018 AXIS BANK9,080.00 Book debts, Movable
LIMITED property
-Jan-
10240661 Modi cation2017 AXIS BANK10,011.50 Book debts, Movable
LIMITED property
Book debts, Others
-Dec- AXIS
10240661 Modi cation2014 BANK9,011.50 (Lease Rentals, Hire
LIMITED Purchase & Loan
Instalments)
Book debts, Others 027

-Dec- AXIS
10240661 Modi cation2013 BANK7,598.00 (Lease Rentals, Hire
Instalments)
Book debts, Others
-Jun-
10240661 Modi cation2012 AXIS BANK5,900.00 (Lease Rentals, Hire
Instalments)
Book debts, Movable
property (not being
10240661 Creation -Sep- AXIS BANK2,100.00 pledge), Others (Lease
2010 LIMITED Rentals, Hire
Purchase & Movable
Fixed Assets)
Immovable property
or any interest there
100169072Creation -Mar- AXIS TRUSTEE in, Book debts,
2018 SERVICES
LIMITED
309.76 Movable property (not
being pledge), Others
(NA.)
Immovable property
or any interest there
100084804Creation -Feb- AXIS TRUSTEE in, Book debts,
2017 SERVICES
LIMITED
335.18 Movable property (not
(NA.)
028

Immovable property
-Oct- AXIS TRUSTEE or any interest there
100058633 Creation 2016 SERVICES 293.36 in, Book debts,
LIMITED Movable property (not
(NA.)
Immovable property
AXIS TRUSTEE or any interest there
10583932 Creation 2015 -Jul- SERVICES 163.54 in, Book debts,
LIMITED Movable property (not
(NA.)
Immovable property
AXIS TRUSTEE or any interest there
10539943 Creation 2014 -Dec- SERVICES 19.00 in, Movable property
LIMITED (not being pledge),
Others
(Receivable/Loans)
-Jun- AXIS TRUSTEE Immovable property
10513221 Creation 2014 SERVICES 45.00 or any interest there
LIMITED in, Book debts
AXIS TRUSTEE Others
-Mar- SERVICES
10332173 Modi cation2014 97.18 (Receivables/Rights
LIMITED pursuant to On-
Lending Contract)
https://scamsbreaking.com/news/indian-banks-again-blindly-shell-crores-of-public-money-without-any-due-verifiactions-in-yet-another-huge-scam-c… 10/20
Others 029
10332173 Creation -Jan- AXIS TRUSTEE (Receivables/Rights
2012 SERVICES
LIMITED
97.18 pursuant to On-
Lending Contract)
10467825 Creation -Dec- AXIS TRUSTEE Immovable property,

2013 SERVICES
LIMITED
21.50 Book debts
10416498 Creation -Jan- AXIS TRUSTEE Immovable property,

2013 SERVICES
LIMITED
34.20 Book debts
10388027 Creation -Oct- AXIS TRUSTEE

SERVICES 113.30 Immovable property,
2012 LIMITED Book debts
10380714 Creation -Sep- AXIS TRUSTEE

2012 SERVICES
LIMITED
166.70 Immovable property
10358125 Creation -Mar- AXIS TRUSTEE Immovable property,

2012 SERVICES
LIMITED
24.89 Book debts
10325986 Creation -Dec- AXIS TRUSTEE Immovable property,

2011 SERVICES
LIMITED
200.00 Book debts
Book debts, Others
10072748 Creation -Aug- AXIS BANK200.00 (Lease Rentals, Hire
2007 LIMITED Purchase & Loan
Instalments)

*Out of the total loan above of INR 46000 appx, the loan amount secured 030
by
Movable Property, Receivables are INR 44,000

HOLDER AMOUNT
CHARGE IDSTATUS DATE NAME (Rs. PROPERTY TYPE
Crore)
100241419 Creation -Feb- AXIS BANK350.00 Book debts, Movable
2019 LIMITED property
-Nov- AXIS BANK9,080.00
10240661 Modi cation2018 Book debts, Movable
LIMITED property
-Jan- AXIS BANK10,011.50
10240661 Modi cation2017 Book debts, Movable
LIMITED property
Book debts, Others
-Dec- AXIS BANK9,011.50 (Lease Rentals, Hire
10240661 Modi cation2014 LIMITED Purchase & Loan
Instalments)
Book debts, Others
-Dec- AXIS BANK7,598.00 (Lease Rentals, Hire
Instalments)
Book debts, Others
-Jun- AXIS BANK5,900.00 (Lease Rentals, Hire
Instalments)
031
Book debts, Movable
property (not being
10240661 Creation 2010-Sep- AXIS BANK2,100.00 pledge), Others
LIMITED (Lease Rentals, Hire
Purchase & Movable
Fixed Assets)
AXIS TRUSTEE Others
10332173 -Mar- SERVICES 97.18 (Receivables/Rights
Modi cation2014
LIMITED pursuant to On-
Lending Contract)
Others
AXIS TRUSTEE
-Jan- SERVICES (Receivables/Rights
10332173 Creation 2012 LIMITED 97.18 pursuant to On-
Lending Contract)
Book debts, Others
10072748 Creation 2007 -Aug- AXIS BANK200.00 (Lease Rentals, Hire
Instalments)
44,445.36

*Terms used in Charges –
Book Debts – This means the receivables or the amount to be received from all the
customers to whom loans have be nanced.

Movable Property – It includes all the assets like furniture & Fixture, o ce
equipment and movable Plane & Machinery like computers, laptops etc.

Lease Rental Hire Purchase & Loan Instalments – Kanoria Brothers have given 032
various properties on lease and the lease rental received from them will be used to
pay the loan.

Others – it includes all current assets for instance Intercorporate deposit given to
related parties, long term and short-term loan provided to various group
companies.

The act of non-compliance of o cial obligation on axis bank part is not only
immoral but also punishable. Now it is to be seen that whether bank will take
quick action or go on covering the bad deeds of its employees.

The acts committed by Kanoria Brothers and their Sta , Auditors, Lawyers and
others co-conspirators are highly violative and punishable under various
Indian laws i.e. Companies Act | PMLA | SEBI Laws | Income Tax Act | Indian
Penal Code | Prevention of Corruption act | Black Money (Undisclosed Foreign
Income and Assets) and Imposition of Tax Act | Chartered Accountants Act |
Advocates Act | RBI Rules and Guidelines

_______________________________________
DISCLAIMER: This Expose is the part of our exclusive Series “20 Most Heinous
Scamster Families of India” and ScamsBreaking.com takes full responsibility
of this Program in all respects of law. We have fallowed all the SOPs before this
Worldwide Webcast. This expose is the sole outcome of extensive legal and
forensic due diligence and deep research on the subject matter and the same is
dully supported with enough of substantive lawful evidence, we would also like
to submit that much before this Webcast we have submitted the detailed report
of this scam to Indian Law enforcement agencies like Central Bureau Of
Investigation, Enforcement Directorate, Department of Income tax, SEBI,
Serious Fraud Investigation o ce Ministry of Finance Ministry of Corporate
12/21/2020
Serious Fraud Investigation o ce, Ministry of Finance, Ministry of Corporate
Scams Breaking - Indian Banks Again Blindly Shell Crores Of Public Money Without Any Due Verifications In Yet Another Huge Scam C…
a airs etc. As per commands of law, the opportunity was given to Kanoria 033
Family and their sta members but the Kanoria Family repeatedly failed to
justify the criminal conduct on their part as discussed in this expose. The aim
to webcast this expose or series “20 Most Heinous Scamster Families of
India” is to make sure that ourishing scams in various part of the globe must
rest and all of them are dealt with tough hands of law.
   
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©2020 International Media Corporation.All Rights Reserved
Document No- 6
039
14th of December, 2020 | Sydney, Australia
PRESS STATEMENT
INDIAN BANKS AGAIN BLINDLY SHELL CRORES

OF PUBLIC MONEY WITHOUT ANY DUE
VERIFIACTIONS IN YET ANOTHER HUGE SCAM
COMMISSIONED BY KOLKATA’S KANORIA
BROTHERS.
Team ScamsBreaking.com
ScamsBreaking.com has already submitted the documentary

evidence to Indian Law enforcement agencies including that of CBI,
ED, Income Tax Office, Ministry of Finance etc. The collected
evidences clearly not only show but also establish the siphoning of
more than 16 Thousand of cores of public money and the report also
shows that this Scam can cross the number of 50 Thousand Crores
and also the illegal routing of the public money out of India.
The ScamsBreaking.com has unearthed the
16 thousand crores scam which has been commissioned at
Kolkata by Kanoria Brothers. The forensic and legal due diligence
has revealed various shocking facts about the scams.
040
Another ludicrous scam is being unveiled which would take

anybody by surprise at the scheme that is being used by the
Kanoria brothers in siphoning off money to the tune of 16000
crores INR into illegitimate and fake accounts. Huge amounts of
money have been routed through transfer of funds to shell entities
under false pretext, fraudulent documentation, creation of fake
companies which existed only on paper etc which finally make its
way to a SREI account. Through a well-planned strategy, the
Kanoria family has smoothly funnelled over Rs. 16000 crores, one
of the largest so far into their account.
The Kanoria Family runs three main businesses namely SREI
Infrastructure Finance Limited (SREI), SREI Equipment Finance
Limited (SEFL) and India Power Corporation Limited (IPCL). The
SREI entities are funded by various banks while the IPCL is funded
by Government institutions like Power Finance corporation etc.
The Kanoria brothers have evolved various means to siphon off the
huge public money and created multiple shell and criminal
purposes vehicles. The soul aim of such criminal creations was to
illegally transfer the money from one to another bogus entity. The
most unfortunate part of this entire scam is that Indian lending
institutions have become highly incapable of fallowing the even
basic norms of verifying the end use of so lent out money. In
addition to others; the AXIS bank is the worst lender shelling out
public money blindly and without any due verification in Kanoria
brothers scams.
041
The Kanoria Family created countable bogus entities and Power

Trust was one of them. The Power Trust is a registered trust at
Kolkata in the state of West Bengal and run by Kanoria Brother’s
Agents and yet the Kanorias dare to call it Public Trust.
They set up a public trust by the name of Power Trust which has
been used as the criminal purposes vehicle to siphon funds. SREI
has been setting up various businesses of infrastructure financing,
infrastructure development and related business interests in
projects such as roads, ports, telecom, power, rural infrastructure,
housing, hospitality and healthcare over three decades. Over many
years there have been serious violations of several civil and
criminal laws and regulations.
The scam has been pulled off mainly by sanctioning and
disbursing huge amounts in secured and unsecured transfer of
funds to bogus and dubious shell companies on the basis of sham
documentation, duly promoted by the Kanoria brothers. These
companies have in turn passed the money back either to Power
Trust or to other bogus entities which has amounted into money
laundering, cheating, tax evasion and various other substantive
offences thereof. The ScamsBreaking.com has collected
substantial documentary evidence which has been submitted to
the Indian law enforcement agencies for further investigations.
The Kanoria brothers had criminally setup the Power Trust as
public trust which only had people from the Kanoria business
enterprises on the board of trustees. The board has Mr. Dipak
Rudra, who is the director of IPCL, Mr. Ajay Kumar Agarwal –
042
statutory auditor for the SREI group of companies, he is also the

director of Shristi Infrastructure, which is a SREI promoted entity.
Mr. Shounik Mitra a lawyer by profession who has been
representing SREI group of companies as their legal counsel on
various legal cases.
It is quite alarming to note that Power Trust has agents or
employees of the Kanoria group, whereas a public trust should be
governed by independent and unrelated individuals from the
public space. The official claim of the Kanoria brothers has been
that Power Trust runs as an independent trust thus having an
independent board of trustees and a minimum shareholding from
the public, this was accounted at less than 25%. The chief function
of the trust has been to only transfer funds!
The ScamsBreaking.com has gone deeply to examine the way the
fraud has been committed, India Power Corporation Limited (IPCL)
transfers funds to Power Trust on the pretext of CSR funds. These
funds are then further transferred to another Kanoria shell entity.
There has been a transfer of more than INR 3500 crores between
SREI and IPCL via various shell companies which have been
concealed in all financial statements of the companies.
In the past the Indian government has been very strict against
shell and bogus companies. Traditionally, shell companies in India
have been used for rotation and siphoning off of funds by the
promoters through fictitious sales, inflated purchases, unjust
commissions or for creation of equity for ultimate owners who are
shielded by cloaks of deceit. It is to be noted that transactions
043
between IPCL and SREI are related party transactions (RPT’s)

which have been deliberately concealed amounting to criminal
violation and mandatory disclosure requirements. All money that
is transferred to Power Trust is shown as CSR funds.
Most interestingly, IPCL’s financial statements for the year 2017-
18 show transfers to the tune of INR 557 crores of public money to
Power trust under the false pretext of purchase of investments.
Power Trust actually received INR 695 crores which was further
diverted to other shell entities promoted by the Kanoria brothers.
This could happen also because of the fact that the very auditor
itself has also been hand and glove with Kanoria Brothers.
Shockingly, another instance of looting public money is with the
M/S Bhaskar Silicon Pvt. Ltd (BSPL) and its further subsidiary
Environ Energy Corporation Ltd., both loss making shell
companies of the Kanoria brothers availed loans to the tune of INR
2400 crores using SREI Infrastructure fraudulent documents.
These companies further siphoned INR 1000 crores to Power Trust.
This INR 1000 crores was routed back to SREI Infrastructure.
There is also a significant deviation of the company on material
disclosure of information in all of the cases where the shell entities
are actively suppressing facts on terms of borrowing, terms of
repayment and the lending institution they are borrowing from.
044
The ScamsBreaking.com also deeply investigated the fact that

Kanoria Brothers’ agents run Bharat Road Network limited (BRNL),
along with its subsidiaries which are controlled and managed by
common board of directors and employees from SREI. SREI
purchased shares, that were actually trading at INR 25-40 per
share, at a premium of INR 195 per share. This was a smart move.
Now by this illegal step SREI smartly made the financials of BRNL
‘Green’ thus creating reserve surplus for BRNL. A whopping INR
2575 crores public money was siphoned off under the garb of fake
loans. If we are to trail the end use of public money then we will
understand that INR 1114 crores has been further invested in
BRNL subsidiaries and this information has been kept under
wraps.
Our Forensic Investigation also revealed that Sahaj E village
Limited and its subsidiary Rural Innovation labs Pvt Limited which
are operated by Kanoria Brothers’ agents having zero value in the
market was given INR 1213 crores as loan at a paltry 6% P. A.
interest as against the regular rate of 18% p. a. These loans were
given on the basis of a cash inflow that never existed! This act has
also generated a notional loss for SREI to the tune of INR 146
crores per annum. These illegal financial transactions were merely
recorded as intercorporate deposits.
The ScamsBreaking.com had constituted an special team to
understand the depth of this syndicate which further revealed that
another shell entity by the name of M/S Swaymbhu Natural
Resources Private Limited which exists only on papers as a loss
making company since incorporation, managed to receive public
045
money - INR 895 crores from SREI of which INR 346.3 crores was
siphoned to Power trust. With a classic case of fudged books of
accounts when it came to repayment, the Kanoria brothers funded
a huge amount through another entity thus enabling a show of
complete repayment of the loan. In reality it was just an eyewash
with clear looting.
The Forensic Report also unearthed that by the Kanoria Brothers
Vara Technology Pvt. Ltd. was given INR 138 crores on the basis of
fixed assets amounting to merely INR 3.8 crores by SREI. M/S
Vara Infotech Private Limited, a shareholder in Kanoria
Foundation (SREI owned trust), has also been used by Kanoria
Brothers to siphon off public funds and provide criminal advantage
to other group companies. The Kanoria Brothers have through
SREI given INR 395.1 crores which was further routed under the
garb of investment to another entity promoted by the Kanoria
brothers - SREI Alternative Trust. It would be interesting to note
that Vara Infotech Private Limited is a loss-making company and
this has been documented as ‘Future in flow’ during the SREI
mortgage. This means that if the company does not show any
profits, the loans will be written off as bad debt.
Further, A clear case of unsecured lending was with the case of
Avarsekar Realty Pvt. Ltd., another related company of the Kanoria
group which received INR 118 crores from SREI without any
security whatsoever. M/s Bharat Nirman Fund promoted by
Kanoria Brothers and SREI Infrastructure were earlier
shareholders of Aversekar Realty, and ceased to be shareholders
immediately after the loan was granted to Avarsekar Realty.
046
The Kanoria Brothers also used Victor Buildwel Private Limited

(VBPL) is another shell company promoted by the Kanoria
Brothers’ SREI Alternative Trust (SAT). They have showed an
inventory of INR 17.3 crores as land in greater Noida, UP. Here
again the Kanoria brothers funnelled INR 70 crores against a non-
existent property.
The Investigation also reveals that Attivo Economic Zones Private
Limited another company promoted by Kanoria Brothers’ SREI
Alternative Investment Trust- Bharat Nirman Fund. Attivo received
INR 2207 crores from SREI and INR 240 crores was routed to
Power trust. This transaction was left out from the company
balance sheet so that no questions could be raised. The balance
amount was completely misused. The modus operandi has been
that a company has no verified assets, negative net worth and is a
loss making company as shown on books of accounts and exists
merely on paper.
It is also revealed that M/s I log Ports Private Limited, another shell
company of the Kanoria brothers showed land worth INR 300
crores on their books. As per field verification, the land is not even
close to being pegged at INR 3 crores. The company without even
mortgaging this land were able to source INR 585 crores of public
funds through SREI. In order to evade taxes, the company has
misrepresented financial statements by capitalising all its
expenses showing no revenue expenses.
047
The Kanoria Brothers with their political and bureaucratic

connections has made it easy to carry out these financial scams.
Predicate Consultants Private Limited (PCPL) is again promoted by
the Kanoria brothers incorporated in 2014 as a financial
consultancy. Mr. Tapas Chakraborty, shareholder at PCPL who
also holds a key role at SREI was given INR 375 crores from which
INR 138 crores was further transferred to Power trust! This is
merely the tip of the iceberg with so many shell companies created
as a medium to funnel funds to the tune of INR 16000 crores.
A detailed forensic and legal audit conducted by

ScamsBreaking.com has given various terrifying facts which we
will cover in our next exposes but one of them was Axis Bank, As
per the records maintained by MCA21 (A ministry of Corporate
affairs website) the Axis Bank etc have provided loans to SREI
Infrastructure and Finance Limited to the tune of INR 44,000
crores without any due diligence and verification of end use of the
loan amount. This loan amount has been disbursed with sham
receivables including related party transactions. If Kanoria
Brothers any day leave the country; the financial institutions like
AXIS banks will not be able to recover any of the funds given to
SREI and the total public money will have to be written off which
is eventually wiping out funds from the public at large. The Open
charges vide the MCA records shows the status of current exposer
of Axis Bank.
048
Axis Bank has granted total loan of INR 46,000 appx, following is the
details and Particulars of Loan.
AMOUNT
CHARGE (Rs.
ID STATUS DATE HOLDER NAME Crore) PROPERTY TYPE
6-Feb- Book debts, Movable
100241419 Creation 2019 AXIS BANK LIMITED 350.00 property
30-Nov- Book debts, Movable
10240661 Modification 2018 AXIS BANK LIMITED 9,080.00 property
12-Jan- Book debts, Movable
10240661 Modification 2017 AXIS BANK LIMITED 10,011.50 property
Book debts, Others
(Lease Rentals, Hire
16-Dec- Purchase & Loan
10240661 Modification 2014 AXIS BANK LIMITED 9,011.50 Instalments)
Book debts, Others
6-Dec- Purchase & Loan
Book debts, Others
8-Jun- Purchase & Loan
Book debts, Movable
property (not being
pledge), Others (Lease
2-Sep- Rentals, Hire Purchase &
10240661 Creation 2010 AXIS BANK LIMITED 2,100.00 Movable Fixed Assets)
Immovable property or
any interest there in,
Book debts, Movable
20-Mar- AXIS TRUSTEE property (not being
100169072 Creation 2018 SERVICES LIMITED 309.76 pledge), Others (NA.)
Book debts, Movable
28-Feb- AXIS TRUSTEE property (not being
049
100058633 Creation 7-Oct-2016 AXIS TRUSTEE 293.36 Immovable property or

SERVICES LIMITED any interest there in,
Book debts, Movable
property (not being
pledge), Others (NA.)
Book debts, Movable
31-Jul- AXIS TRUSTEE property (not being
Movable property (not
16-Dec- AXIS TRUSTEE being pledge), Others
10539943 Creation 2014 SERVICES LIMITED 19.00 (Receivable/Loans)
27-Jun- AXIS TRUSTEE any interest there in,
10513221 Creation 2014 SERVICES LIMITED 45.00 Book debts
Others
(Receivables/Rights
28-Mar- AXIS TRUSTEE pursuant to On-Lending
10332173 Modification 2014 SERVICES LIMITED 97.18 Contract)
Others
(Receivables/Rights
23-Jan- AXIS TRUSTEE pursuant to On-Lending
10332173 Creation 2012 SERVICES LIMITED 97.18 Contract)
2-Dec- AXIS TRUSTEE Immovable property,
31-Jan- AXIS TRUSTEE Immovable property,
16-Oct- AXIS TRUSTEE Immovable property,
7-Sep- AXIS TRUSTEE
10380714 Creation 2012 SERVICES LIMITED 166.70 Immovable property
6-Mar- AXIS TRUSTEE Immovable property,
7-Dec- AXIS TRUSTEE Immovable property,
Book debts, Others
13-Aug- Purchase & Loan
10072748 Creation 2007 AXIS BANK LIMITED 200.00 Instalments)
050
*Out of the total loan above of INR 46000 appx, the loan amount secured by
Movable Property, Receivables are INR 44,000
AMOUNT
(Rs.
CHARGE ID STATUS DATE HOLDER NAME Crore) PROPERTY TYPE
6-Feb- AXIS BANK Book debts, Movable
100241419 Creation 2019 LIMITED 350.00 property
30-Nov- AXIS BANK Book debts, Movable
10240661 Modification 2018 LIMITED 9,080.00 property
12-Jan- AXIS BANK Book debts, Movable
10240661 Modification 2017 LIMITED 10,011.50 property
Book debts, Others
16-Dec- AXIS BANK Purchase & Loan
10240661 Modification 2014 LIMITED 9,011.50 Instalments)
Book debts, Others
6-Dec- AXIS BANK Purchase & Loan
Book debts, Others
8-Jun- AXIS BANK Purchase & Loan
Book debts, Movable
property (not being
pledge), Others (Lease
2-Sep- AXIS BANK Rentals, Hire Purchase
10240661 Creation 2010 LIMITED 2,100.00 & Movable Fixed Assets)
Others
AXIS TRUSTEE (Receivables/Rights
28-Mar- SERVICES pursuant to On-Lending
10332173 Modification 2014 LIMITED 97.18 Contract)
Others
051
10332173 Creation 23-Jan- AXIS TRUSTEE 97.18 (Receivables/Rights

2012 SERVICES pursuant to On-Lending
LIMITED Contract)
Book debts, Others
13-Aug- AXIS BANK Purchase & Loan
10072748 Creation 2007 LIMITED 200.00 Instalments)
44,445.36
*Terms used in Charges –

1. Book Debts – This means the receivables or the amount to be received
from all the customers to whom loans have be financed.
2. Movable Property – It includes all the assets like furniture & Fixture,
office equipment and movable Plane & Machinery like computers,
laptops etc.
3. Lease Rental Hire Purchase & Loan Instalments – Kanoria Brothers

have given various properties on lease and the lease rental received
from them will be used to pay the loan.
4. Others – it includes all current assets for instance Intercorporate

deposit given to related parties, long term and short-term loan
provided to various group companies.
052
The act of non-compliance of official obligation on axis bank part

is not only immoral but also punishable. Now it is to be seen that
whether bank will take quick action or go on covering the bad
deeds of its employees.
The acts committed by Kanoria Brothers and their Staff, Auditors,
Lawyers and others co-conspirators are highly violative and
punishable under various Indian laws i.e. Companies Act | PMLA
| SEBI Laws | Income Tax Act | Indian Penal Code | Prevention
of Corruption act | Black Money (Undisclosed Foreign Income and
Assets) and Imposition of Tax Act | Chartered Accountants Act |
Advocates Act | RBI Rules and Guidelines
Issued by
Head-Asia Pacific
ScamsBreaking.com
International Media Corporation
________________________________________________________________
DISCLAIMER: This Expose is the part of our exclusive Series “20 Most
Heinous Scamster Families of India” and ScamsBreaking.com takes full
responsibility of this Program in all respects of law. We have fallowed all the
SOPs before this Worldwide Webcast. This expose is the sole outcome of
extensive legal and forensic due diligence and deep research on the subject matter
and the same is dully supported with enough of substantive lawful evidence, we
053
would also like to submit that much before this Webcast we have submitted the
detailed report of this scam to Indian Law enforcement agencies like Central
Bureau Of Investigation, Enforcement Directorate, Department of Income tax,
SEBI, Serious Fraud Investigation office, Ministry of Finance, Ministry of
Corporate affairs etc. As per commands of law, the opportunity was given to
Kanoria Family and their staff members but the Kanoria Family repeatedly failed
to justify the criminal conduct on their part as discussed in this expose. The aim
to webcast this expose or series “20 Most Heinous Scamster Families of India” is
to make sure that flourishing scams in various part of the globe must rest and all
of them are dealt with tough hands of law.
1/28/2021 Gmail - Video dated 14.12.2020
054
Arjun Syal <syalandcompany@gmail.com>
Video dated 14.12.2020 Document No- 7

Arjun Syal <syalandcompany@gmail.com> Thu, Jan 28, 2021 at 9:53 AM
To: dhiraj.kumar48@gmail.com
https://www.youtube.com/watch?v=DXYa9NmVwvI&t=379s
https://mail.google.com/mail/u/1?ik=01ff38b68c&view=pt&search=all&permmsgid=msg-a%3Ar-6007183864602634613&simpl=msg-a%3Ar-6007183864602634613 1/1
Document No- 8 055
Dear viewers, scamsbreaking.com takes full responsibility of this program in all

respects of law the present expose is made possible after extensive legal and forensic
investigation supported with lawful evidence duly submitted to Indian law
enforcement agencies like CBI, ED, SFIO and many others. You are requested to be a
part of our mission to expose 20 most heinous scamster families of India and to get rid
of these termites and pass the clear message that crime never pays…
Twenty most heinous scamster families of India
Episode 1: Bad Brothers of Kanoria
Dear viewers here we are with the most exciting and exclusive exposure of the year
2020. This year has already been very tough for all of us. Sadly there are few in the
powers who never stop to make it tougher for a common man. They believe that when
the situation is bad in the country they must make it worse and take personal
advantage, what a disgrace to humanity and the nation.
Scamsbreaking.com has dared to expose a criminal misappropriation of the public

money more than 16,000 crores which is more than 200 million US dollar. First of all
we would like to announce that this exclusive expose is duly supported with
indefeasible and substantive documentary evidence duly admissible before any
honorable code of law which we have already submitted to the Indian law
enforcement agencies not only that a lawful and fair opportunity was also given to the
accused Kanoria brothers to place their parts but feeling themselves above the law
they didn't come with proper reply.
What's the new scam?
A common man deposits his hard-earned money in the bank with confidence and trust
he feels secured and satisfied that his money is in the safe hands but is it? do we really
know what happens with our bank money?
We wish there were a GPS to track our money as well. It's absolutely necessary for us
to know how these financial institutions use our money without our knowledge or
consent. AXIS bank is the worst and most heinous example of this case who blindly
056
kept on giving money after money More than 45,000 crores merely on the basis of
alleged future receivables and fake lending to fraudulent and fictitious borrowers.
This scam is an alarm, wake up as it rings.
Financial institutions like AXIS bank, Power Finance Corporation, REC limited and
some other have immorally and unethically transferred the public money into some of
the criminal pockets, the scammers of the present fraud are truly the venomous
assassins of India's economy. When it comes to helping the poor, the middle class or
the farmers then our banks become very professional and take almost all the
belongings as mortgage but when big businessmen approach them our banks come
drooling desperate to give away the public money without strong verification and
security.
Where do their policies and work ethics disappear. If your banks love charities so
much then why don't they do it with their own money?
The Kanoria brothers scam, this fraud of more than 16, 000 crore rupees is yet another
example of the malfunctioning of Indian banks, unfortunately the prestigious Reserve
Bank of India is seen as a toothless tiger unable to roar against the enemy of India's
economy. For better comprehension we shall go step by step so that every common
man is aware of these new fraudsters in the market. What happens with the public
money, how the banks misuse our capital and our trust.
Who are the Kanoria brothers?
The Kanoria brother is a Kolkata-based business family. Kolkata is the capital of

West Bengal, India. The main players of the Kanoria family are Hariprasad
Kanoria, father Hemant kanoria son Sunil Kanoria, son Sujit Kanoria, Raghav
Raj Kanoria son of Hemant Kanoria.
These five masterminds mentioned above have succeeded in their criminal activities
with the help of approximately 20 other accomplices who participated actively in the
fraudulent game of embezzlement of public funds by the Kanoria brothers.
057
What is their business?
Let's understand what kind of business this family runs and what there is reach?
The Kanoria family runs three principal businesses, SREI infrastructure finance
limited (SIFL) SREI equipment finance limited (SEFL), and India Power Corporation
limited (IPCL). The SREI entities are funded by the banks and other financial
institutions whereas IPCL is funded by the power funding institutions of government
of India such as power finance corporation, REC limited.
What did they do?
The Kanoria brothers are desperately engaged in the criminal diversion of the public
money. Public money siphoned off the funds through shell entities. They are cheating
on the banks and on the government authorities which is punishable under the
Prevention of Money laundering act, Prevention of Corruption act, black money and
the imposition of tax act, the Income Tax act, companies act and SEBI act and various
other acts and regulations imposed by RBI.
We will explain in detail their modus operandi and you will realize how blind they
think we and the Indian law enforcement agencies are.
The Kanoria brothers created a criminal purpose entity to dissemble their true
intentions and actions in the form of a trust and they named it the power trust. This
power trust was another step to weaken countries economy thereby strengthening
these scammer’s roots in the game and defraud the authorities as well as the public.
This is a fast comfortable extra large personal vehicle, the power trust, with tinted
glass driven by the Kanoria brothers was used to carry out their criminal activities
with the intention of hoodwinking the country.
They claimed that it's a public trust but is it really? The power trust reveals the
involvement of some other players in the game namely, trustee Deepak Rudra, who
is also the director of IPCL, trustee Ajay Kumar Agarwal, who is the statutory
auditor for SREI group of companies and also the director of Sristhi infrastructure
development limited, a SRE promoted entity. Trustee Shounak Mitra, who is one of
058
a lawyer by profession and admittedly represents SREI company before various

courts of law.
These three new characters also have an important role to play in this series of crime.
This power trust was claimed by the Kanoria brothers as a public trust having an
independent board of trustees but the reality says otherwise. This bogus entity is run
by the agents and employees of the Kanoria brothers.
This criminal purposes vehicle is used to transfer the money from one brother to
another under the false pretexts this power trust has been used for siphoning funds of
Rupees 3,500 crores between SREI and IPCL via different entities and all the
information has been criminally concealed from the official finance documents of the
companies.
Preposterous.
Let's see how their criminal methodology works this flowchart describes the
deceiving style of the corrupt father-son duo Hemant Kanoria and his son Raghav. (A
flow chart is shown at 8:56 min of the video showing how the criminal methodology
works)
This is the modus operandi followed by these robbers to siphon off the public
money, it is now evident that the transactions between SREI and IPCL are related
party transaction (RPTs) which have been criminally concealed and wrongfully
violated the mandatory disclosure requirements. Furthermore IPCL doesn't disclose
any transaction with the power trust, shareholder of IPCL in its financial reports. The
money transferred to the power trust is shown as the transfer for CSR funds.
Here's another flowchart (at 9:41) to show you the trail of the criminal diversion
executed by the Kanoria brothers of the public money lent by the banks. As per the
financial statement of IPCL for the year of 2017- 2018 the Kanoria brothers used
India Power Corporation to siphon off rupees 557 crores of public money to our trust
under the false pretext of investments whereas the power trust received rupees 695
crores and they further diverted off the same money to another Kanoria brother’s shell
entity, it is one thing to be clever and another thing to be illegal, the scammer family.
059
So far it was just a glimpse of this scammer family's functioning, they incessantly
used different entities to siphon off the public money and this time they used another
entity M/s Bhasker silicon private limited (BSPL) as well as its subsidiary Environ
Energy Corporation Limited, both these companies are run by the agents of the
Kanoria brothers.
The interesting part here is that both these companies are so drowned in loss that they
would fail to avail a loan of rupees 24 and shockingly these entities were given a hefty
amount of the public money which is 2,400 crores Indian Rupees, this shows the level
of fraud carried out by this business family via SREI infrastructure. These both
dummy borrowers further siphoned off rupees 1,000 crores to their power trust and
the remaining amount was diverted as per the whims and fancies of the Kanoria
brothers
This criminal move starts from SREI infrastructure and ends at SREI infrastructure,
just when you think that this is the limit of their fraud, we present to you another eye-
opening expose, Bharat Road Network limited (BRNL) is another medium of
siphoning off the public money. BRNL and its subsidiary are controlled and managed
by the agents of SREI, that is same common directors/company employees
How did they scam us here?
SREI purchased the shares at a premium of rupees 195 per share when the actual
trading rate in the market was rupees 25 to 40 per share. Once again SREI duped us
by making the finance of BRNL green and creating a reserve and surplus for BRNL
then again it siphoned off the whooping the public money of 2,575 crores Indian
rupees under the grab a fake loan to the worthless entities and as a mortgage they had
only future cash inflow which is of the record. What a move.
BRNL further invested rupees 1,114 crores in its subsidiaries and concealed every
penny of the public money under the label of further investment. The Kanoria master
brothers were becoming experts in this fraudulent game. A game which is invented by
them and is played on their whims and fancies, so convenient, isn't it.
060
Here's one more example to shock you, Sahaj E Village limited and its subsidiary
Rural Innovation Labs Private Limited are managed by the agents of SREI group.
This company has absolute negative network but it was still given the public money
of rupees 1,213 crores at the rate of 6 per annum, against the benchmark rate of 18 per
annum solely on the basis of future cash inflow which was nowhere to be witnessed.
The Kanoria brothers cleverly generated a fake national loss of SREI of rupees 146
crores per annum which is a direct injury to the public exchequer. They show this
illegal transaction as inter-corporate deposits solving a crime by committing another
crime, this nefarious family has redefined the word greed with yet another shocking
criminal move, this time they decided to loot the public money through another shell
entity that is Swaymbhu Natural Resources Private Limited which solely existed on
papers, this fake company was projected as bankrupt. In order to get rupees 895 crores
from SREI out of which rupees 346.3 crores were siphoned off to the power trust. At
the time of loan repayment, the Kanoria brothers again funded back Swaymbhu
Natural Resources Private Limited with another chunk of the public money looted by
one of their entities. This flowchart (at 15:12) is a clear analysis of the complex and
criminal web of payments created by the Kanoria brothers to siphon the public money
from one SREI group of companies to another, a capital felony to hide another capital
felony leads to numerous capital felonies, the rollout of more traps.
The game of the Kanoria brothers develops further, this time they used Vara
technology private limited as the medium, the master brothers through SREI gave
rupees 138 crores of the public money to Vara technology private limited in the form
of fixed assets amounting rupees 03.8 crores as per the balance sheet of Vara. This
process of money lending and undertaking done by the Kanoria brothers violates the
basic principles of RBI the flowchart (at 16:15) below depicts how the public money
was siphoned off through Vara.
You reap what you saw…
Something similar is happening with these shameless fraudsters, the truth shall
prevail. When you lie and don't get caught either you start believing that your lies are
true or that you're an expert but always remember that a lie has a very short life and
061
that the truth shall prevail. The Kanoria brothers were living under the impression that
their game will never get exposed but little did they know checkmate says
scamsbreaking.com.
The Kanoria brothers kept creating new dummy borrowers to gulp the public money
as much as possible. The Kanoria brothers had given Vara a sum of rupees 395.1
crores which was further distributed to other two SREI alternative trust. Please note
that Vara is a loss-making company and for the sake of mortgage SREI ended up
mortgaging the future inflow this means that if a company is in loss then its loan
becomes a bad debt which drags you down.
The above flow chart (at 17:35) shows that the Kanoria brothers have taken a
kickback, thanks to their SREI alternative trust, nothing gets spared.
Now comes in action, Avarsekar Realty Private Limited, this company received a sum
of rupees 118 crores of the public money from SREI without any security this is
called unsecured lending.
One must remember that Bharat Nirman fund promoted by the Kanoria brothers and
SREI infrastructure was earlier a shareholder of ARPL, this explains the reason
behind the unsecured lending from SREI to ARPL.
This criminality portrays well the mockery of public money and of the government
rules done by the Kanoria brothers without any hesitation; did they rob this
confidence from us as well?
It seems like that, it's like that they built a crime school from the public money and
announced themselves as the principal and trustee and treated the public in law as
kindergarten kids who are unaware of anything.
Well-built shell entities Victor Buildwell Private Limited is another shell company
which exists only on papers. This company is promoted by the Kanoria brothers SREI
alternative trust (SAT). This company is the most befitting example of window
dressing by the Kanoria brothers. On papers they show a possession of a non-existing
land of worth rupees 17.3 crores in Greater Noida, Uttar Pradesh, following this style,
062
the Kanoria brothers siphoned off rupees 70 crores of the public money in the account
of the company, the mojo jojo.
Attivo Economic Zone Private Limited is another criminal cannon of gutter worms
promoted by the Kanoria brothers, SREI, SAT and Bharat Nirman fund.
SREI gave this company rupees 2,207 crores of the public money out of which
rupees 240 crores was routed back to the power trust, criminal purpose vehicle under
the umbrella term of inter-corporate deposits. All this was kept off the records on the
balance sheet to avoid all enquiry and allegations.
The balance money was misused in other pretexts, you can easily understand how
these evil genius siphoned of the public money through Attivo economic zone private
limited, ventures of loot, the company has no verified assets exists only on papers
which makes it a shell entity shows continuous loss on the balance sheet and has
negative net worth. I Log Ports private limited is such entity of the Kanoria brothers.
This company shows a possession of land worth rupees 300 crores but according to
the field verification that land is not worth more than 3 crores.
The Kanonia brothers through SREI gave rupees 585 crores of public money to I Log
Ports private limited sans mortgage, this favor was done in expectation of the future
cash inflows but as we are now aware that the company is already in loss and it's
almost non-operational. The only asset that the company has is the land, which is
again deceiving in nature.
Furthermore to evade taxes the company has misrepresented the financial statements
with the help of window dressing and has capitalized all its expenses with zero
revenue, this is an evidence in itself, that the loan given by SREI to I Log Ports
private limited was for personal benefit and another move to siphon off the public
money, the termites of growth. The Kanoria brothers gradually became fearless and
unstoppable.
With money comes power and connections that is their political connections gave
them a push to increase their appetite.
063
Predicate Consultants private limited (PCPL) is SREI’s promoted consultancy

company, incorporated in 2014 to carry on the business as financial consultants one of
the shareholders Tapas Chakraborty, key management personnel of SREI was given a
sum of rupees 375 crores of the public money out of which a sum of rupees 138
crores kicked back at the power trust.
By this time it is evident that the Kanoria brothers have created many shell entities as
medium to siphon off the public money. These companies are basically criminal
channels to put the siphoned money into criminally misappropriate endues, expose of
the tip of an iceberg
The Kanoria brothers know no finish line, they went on looting the public money up
to 50,000 crores. These financial terrorists of the economy must be put behind bars
the negligence on the part of the banks gave a green signal to these bandits.
Axis bank has provided loans to SREI infrastructure and finance limited of rupees
44,000 crores without any due diligence. In this case a fraudster friend is also a
fraudster, providing loans without security and guarantee is also proud in itself which
is punishable.
Axis bank has given the entire loan on the basis of almost sham receivables which
also includes related party transactions. Further, it is already been revealed that SREI
has duped stakeholders and investors as well as the government authorities to the tune
of more than rupees 16,000 crores by borrowing funds and routing them back within
the group companies. The company has misrepresented facts and figures in financial
statements which is an offence as per SEBI. As per OECD guidelines, due diligence is
mandatory before sanctioning any loan but Axis bank took its name too seriously and
said yes to give loans without due diligence, without verifying the receivables.
AXIS bank intentionally or unintentionally has failed in verifying the details provided
by SREI at the time of loan approval and granted the loan on favorable terms. If SREI
is declared fraud then AXIS bank won't be able to recover the funds from SREI and
all 44,000 crores Indian rupees which is eventually public money will be lost.
064
Once again the public will suffer because they have always been taken for granted in
our country. A common man is made so common that his money is a piece of paper
and a rich client's money is the real deal. This makes Axis bank a part of this
scandalous fraud of rupees 16,000 crores done by SREI as it's the Axis bank which
granted money to SREI to rotate the funds within the group.
If the bank would have performed its duties sincerely then our money would still be
ours. It wouldn't be wrong to say that where there's corruption there's Indian politics
involved, it's not an easy task to fool our government machinery until and unless the
government officials are supporting the fraudsters at some level
The story of this criminal empire and the connection with the political masters or co-
beneficiaries who have been protecting these termites from any kind of prosecution is
also coming soon.
Scamsbreaking.com possesses an authentic set of very strong legal evidence against

them which is enough to make them regret their wrongdoings. We are concerned
about you about your money and therefore we need your support to bring this series
of heinous crimes to an end.
This report is just an expose at the tip of an iceberg what you'll see next is even bigger
and most shocking. Scamsbreaking.com has put in lots of efforts to turn the tide, so
stay tuned as we will be back with another shocking expose of the Kanoria brothers
and their criminal connections in Indian politics.
1/28/2021 Gmail - Video dated 15.12.2020 065
Video dated 15.12.2020

Document No- 9
Arjun Syal <syalandcompany@gmail.com> Thu, Jan 28, 2021 at 9:54 AM
To: dhiraj.kumar48@gmail.com
https://www.youtube.com/watch?v=Le5uwCzPzPk
https://mail.google.com/mail/u/1?ik=01ff38b68c&view=pt&search=all&permmsgid=msg-a%3Ar-2933640327361791755&simpl=msg-a%3Ar-2933640327361791755 1/1
Document No- 10
066
Document No- 11
067
Document No- 12
068
Document No- 13
069
Document No- 14 070
Document No- 15 071
Document No- 16 072
List of URLs against Kanoria Brothers
Sr. URL
No.
1. https://www.youtube.com/watch?v=DXYa9NmVwvI&feature=youtu.be
2. https://scamsbreaking.com/news/indian-banks-again-blindly-shell-crores-of-public-
money-without-any-due-verifiactions-in-yet-another-huge-scam-commissioned-by-
kolkatas-kanoria-brothers-axis-bank-is-the-biggest-stakeholder-201214
3. https://www.scamsbreaking.com/news/scamsbreakingcom-reaffirms-the-contents-of-its-
expose-against-kanoria-brothers-axis-bank-and-other-consortium-lenders-must-check-
their-internal-lending-system-201216
4. https://www.desidime.com/amp/discussions/axis-bank-scam-by-kanoria-brothers-srei-
16-000-crores-160000000000
5. https://mobile.twitter.com/erbmjha/status/1338866012741980162
6. https://m.facebook.com/permalink.php?id=110943470740650&story_fbid=1853298133
02015
7. https://www.bizzbuzz.news/industry/banks/raise-capital-lend-more-rbi-guv-tells-banks-
753694?infinitescroll=1
8. https://www.reddit.com/r/india/comments/kdih0y/indian_banks_again_blindly_shell_cr
ores_of_public/
9. https://twitter.com/Khushi10s/status/1339095703339986947
10. https://twitter.com/BreakingScams/status/1339087294758854657
11. https://fraudsbreaking.com/news/indian-banks-again-blindly-shell-crores-of-public-
money-without-any-due-verifiactions-in-yet-another-huge-scam-commissioned-by-
kolkatas-kanoria-brothers-axis-bank-is-the-biggest-stakeholder-201214
12. https://ne-np.facebook.com/breakingnewsimc/videos/2738330446481884/
13. https://www.linkedin.com/posts/scams-breaking_finance-money-scams-activity-
6744905936197980160-e46g/
14. https://www.linkedin.com/posts/scams-breaking_scamsbreaking-scam2020-india-
activity-6744517012657053697-PjDT/
15. https://www.linkedin.com/posts/scams-breaking_business-media-news-activity-
073
6744145377739460608-414B/
16. https://www.instagram.com/tv/CIxiZ-vKQxd/?igshid=15erkznq0phzz
17. https://www.instagram.com/p/CIz1hDdDQEe/
18. https://www.instagram.com/p/CIxSpYpjJyl/
19. https://www.instagram.com/p/CIxFk9Gql-Y/
Below mentioned are URLs of the Google photos that are against us and are infringing
Sr. No. URL

1. https://www.google.com/search?q=kanoria+brothers+scam+by+Scamsbreaking+com
&sa=N&biw=1366&bih=625&tbm=isch&source=iu&ictx=1&fir=tgjg08t4biPygM%2
52CJzhuGZxbV5KD6M%252C_&vet=1&usg=AI4_-
kTW8IlxzckVrmfX8ehqrDO8ReRZfQ&ved=2ahUKEwj_mau22OjtAhVT4jgGHToB
D_4Q9QF6BAgVEAE#imgrc=tgjg08t4biPygM
D_4Q9QF6BAgVEAE#imgrc=rOzaYsm6m-Il1M
D_4Q9QF6BAgVEAE#imgrc=fUD46vNU0c-mMM
Document No- 17
074
075
Document No- 18
076
077
1/20/2021 Privacy Policy - Scams Breaking
Document No- 19 078

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may be developed, managed, marketed and sold by a variety of our affiliates. We share
Information that may identify you internally among affiliates publicly recognized as a
WarnerMedia affiliate, such as Xandr and the AT&T family of companies. Public recognition
may derive from, for example, use of common branding elements, advertising, press, social
media reports or other public form of notice. We require the affiliate to protect the
Information consistent with this Policy. We may also combine Information that identifies you
personally with data that comes from an affiliate that has a different privacy policy. When
we do that, our Policy applies to the combined data set. You can learn about our
WarnerMedia and AT&T affiliates by visiting the WarnerMedia affiliates’ page.
Business partners and third parties. We may also share Information with business
partners and third parties (e.g., other companies, retailers, research organizations,
advertisers, ad agencies, advertising networks and platforms, participatory databases,
publishers, and non-profit organizations) that may want to market products or services to
you. If we share personal information with such unaffiliated third parties for their own
marketing purposes, we provide you with an opportunity to opt out of such uses either at 082
the point of collection or through the choice mechanisms set forth in this Privacy Policy. To
learn more about your choices, please see our Your Choices and Controls section below.
Linked sites. Some of our Sites contain links to other sites, including Social Media Sites,
whose information practices may be different from ours. Information you submit to other
sites will be governed by the other sites’ privacy policies and terms.
Sponsors and co-promotions. We may sometimes offer content or programs (e.g.,
contests, sweepstakes, promotions, games, applications or Social Media Site integrations)
that are sponsored by or co-branded with identified third parties. By virtue of these
relationships, the sponsoring or co-branding parties may collect or obtain Information from
visitors that participate in the activity. We have no control over these sponsoring or co-
branding parties’ use of this Information. We encourage you to visit the privacy policy of
any such sponsoring or co-branding party to learn about their data practices prior to
providing Information through sponsored or co-branded content or programs.
Advertising networks. We may share certain information with parties to provide
advertising to you based on your interests. For more information, please see our Ad Choices
section below.
YOUR CHOICES AND CONTROLS

Marketing communications and sharing with third parties. We provide you with an
opportunity to express your preferences with respect to receiving certain marketing
communications from us, and our sharing of personal information with unaffiliated third
parties for their direct marketing purposes. If you ever decide in the future that you would
like to update these preferences, you may (i) log in to an account you have created with us
at one of our Sites to adjust your settings, or (ii) send us an email at
wmprivacy@warnermediagroup.com. To opt out of receiving our email marketing
communications, you can also follow the “unsubscribe” instructions provided in any
marketing email you receive from us. If you previously chose to receive push notifications
on your mobile device from us, but no longer wish to receive them, you can manage your
preferences through your device or app settings, depending on the type of device. If you
have signed up to receive text messages from us and no longer wish to receive such
messages, you may follow the instructions to stop the delivery of such messages, which
may include by replying “STOP” to the received text message.
For residents, please see below for additional information on the choices we provide to you.
Ad Choices. On our own or working with affiliates or third parties, we may present
advertisements and engage in data collection, reporting, ad delivery and response
measurement, and site analytics on our Sites and on third party websites across the
Internet and applications over time. We, our affiliates, or third parties may use cookies, web
beacons, pixels, software development kits (“SDKs”) or similar technologies to collect
information across websites, services, and apps over time to perform this activity. We, our
affiliates, or third parties may use and transfer this information in order to help serve
advertising that may be more relevant to your interests on and off our Sites and across your
devices and browsers. This type of advertising is known as interest-based advertising. We,
our affiliates, or third parties may also use this information to associate your different
browsers and devices together for interest-based advertising and for other purposes like
research, analytics, internal operations, fraud prevention, and enhancing consumer

experiences. 083
For more information about interest-based advertising on your desktop or mobile browser,
and to opt out of this type of advertising by third parties that participate in self-regulatory
programs, please visit the Network Advertising Initiative website and/or the Digital
Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising
website. To learn more about interest-based advertising in mobile apps and to opt out of
this type of advertising by third parties that participate in the DAA’s AppChoices tool, please
use this link to download the version of AppChoices for your device.
Please note that any opt-out choice you exercise through these programs will apply to
interest-based advertising by the third parties you select, but will still allow the collection of
data for other purposes, including research, analytics, and internal operations. You may
continue to receive advertising, but that advertising may be less relevant to your interests.
To opt out of our own collection, use, and transfer of data as described above for interest-
based advertising, please visit our Privacy Center to opt-out. Please note that if you opt out,
we will continue to collect data for other purposes, including research, analytics, and
internal operations. You may continue to receive advertising on our Sites based on your
activities on our Sites.
You may have more options depending on your mobile device and operating system. For
example, most device operating systems (e.g., iOS for Apple phones, Android for Android
devices, and Windows for Microsoft devices) provide their own instructions on how to limit
or prevent the delivery of tailored in-application advertisements. You may review the
support materials and/or the privacy settings for the respective operating systems to learn
more about these features and how they apply to tailored in-app advertisements.
Precise location information. To disable the collection of precise location information
from your mobile device through our mobile apps, you can access your mobile device
settings and choose to limit that collection.
See also our Cookies and Other Technical Information section for more choices about
managing other technical and usage information.
COOKIES AND OTHER TECHNICAL INFORMATION

Cookies and other technologies. We, and our affiliates, vendors, and business partners
may send “cookies” to your computer or use similar technologies to understand and
enhance your online experience at our Sites and through our advertising and media across
the Internet and mobile apps.
Cookies are small text files placed in your browser. We may also use pixels or “web
beacons” that monitor your use of our Sites. Web beacons are small strings of code that
provide a method for delivering a graphic image on a webpage for the purpose of
transferring data, such as the IP address of the computer that downloaded the page on
which the web beacon appears, the URL of the page on which the web beacon appears, the
time the page containing the web beacon was viewed, the type of browser that fetched the
web beacon, and the identification number of any cookie on the computer previously placed
by that server. We may also integrate SDKs into our applications to perform similar
functions as cookies and web beacons. For example, SDKs may collect technical and usage
information such as mobile device identifiers and your interactions with the Site and other
mobile apps.
We may use cookies and other technologies to help recognize your browser or device,
maintain your preferences, provide certain Site features, and collect Information about 084
interactions with our Sites, our content, and our communications. For example, when
corresponding with you via HTML capable email, web beacons and other technologies let us
know about your activity, including whether you received and opened our email, clicked
through a link, or otherwise interacted with our content, and this information may be
associated with Information previously collected.
We may also use cookies and other technologies (i) to provide, develop, maintain,
personalize, protect, and improve our Sites, products, programs, and services and to
operate our business, (ii) to perform analytics, including to analyze and report on usage and
performance of our Sites and marketing materials, (iii) to protect against, identify, and
prevent fraud and other unlawful activity, (iv) to create aggregate data about groups or
categories of our users, (v) to synchronize users across devices, affiliates, business
partners, and select third parties, and (vi) for us and our affiliates, business partners, and
select third parties to target, offer, market, or advertise products, programs, or services.
Cookies and other technologies also facilitate, manage, and measure the performance of
advertisements displayed on or delivered by or through us and/or other networks or sites.
By visiting the Site, whether as a registered user or otherwise, you acknowledge, and agree
that you are giving us your consent to track your activities and your use of the Site through
the technologies described above, as well as similar technologies developed in the future,
and that we may use such tracking technologies in the emails we send to you.
Managing cookies and other technologies. Cookies can either be persistent (i.e., they
remain on your computer until you delete them) or temporary (i.e., they last only until you
close your browser). Check your browser settings to learn how to delete cookies.
You may adjust your browser to reject cookies from us or from any other website.
Controlling cookies via browser controls may not limit our use of other technologies. Please
consult your browser’s settings for more information. However, blocking cookies or similar
technology might prevent you from accessing some of our content or Site features.
Some of our Sites may use locally stored objects (“LSOs”) to provide certain content, such
as video on demand, video clips, or animation, and a better user experience. Adobe’s Flash
player and similar applications use this technology to remember settings, preferences, and
usage similar to browser cookies. Flash cookies are not managed through your web
browser, but you can access your Flash management tools by visiting Adobe’s web site.
Your browser may also offer other tools to delete or reject other LSOs; please check your
browser’s settings or help menu for more information.
Some of our sites may use Google Analytics to analyze traffic. You can find out more
information about Google Analytics cookies by visiting the following location
provided: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-
usage. To opt out of Google Analytics relating to your use of our Sites, you can download
and install the Browser Plugin available by visiting the following location
provided: https://tools.google.com/dlpage/gaoptout?hl=en.
Some Sites may feature Nielsen proprietary measurement software, which will allow users
to contribute to market research, such as Nielsen TV Ratings. To learn more about the
information that Nielsen software may collect and your choices, please see the Nielsen
Digital Measurement Privacy Policy by visiting the following location
provided: https://www.nielsen.com/us/en/legal/privacy-statement/digital-measurement/
We do not currently take actions to respond to Do Not Track signals because a uniform
technological standard has not yet been developed. We continue to review new technologies
and may adopt a standard once one is created.
See the Your Choices and Controls section to learn how to control data collection for certain
purposes. 085
INFORMATION SECURITY
We have put in place reasonable controls designed to help safeguard the personal
information we collect via the Sites. However, no security measures are perfect, and we
cannot assure you that personal information that we collect will never be accessed or used
in an unauthorized way.
HOW YOU CAN ACCESS OR CORRECT INFORMATION

To access personal information that we have collected about you online from Sites on which
this Privacy Policy is posted, or to update your user profile, please log into your account if
you have created one with us, or send an email to info@scamsbreaking.com For residents,
please see below for additional information on accessing information about you.
ADDITIONAL INFORMATION REGARDING CHILDREN’S PRIVACY

On most Sites, we do not knowingly collect information from children. On some Sites, we
may ask the user to provide us with the user’s age information. If the person indicates that
he or she is under 13 years old, as permitted by law, we will (i) collect no or limited
personal information (e.g. persistent identifier and/or email address only) from that
individual, (ii) inform the child that a parent’s verifiable consent is required, and/or (iii)
collect the email address of the user’s parent in addition to the user’s email address. We
may use the parent’s email address to seek the parent’s verifiable consent or notify the
parent of his/her child’s online activities and enable the parent to unsubscribe his/her child
from a newsletter or other similar activity. Once a parent provides consent, we may use any
information collected from a child consistent with the rest of this Privacy Policy and/or the
terms of the consent provided by the parent. If a user is under 13, we will not condition
his/her participation in an online activity on the disclosure of more personal information
than is reasonably necessary to participate in the activity. If you would like to review any
personal information that we have collected online from your child, have this personal
information deleted from our active servers, and/or request that there be no further
collection or use of your child’s personal information, or if you have questions about these
information practices, you may contact us at wmprivacy@warnermediagroup.com, or at
WarnerMedia Privacy Office, 4000 Warner Blvd., Bldg. 160, Burbank, CA 91522.
INTERNATIONAL TRANSFER
We operate internationally, and many of our computer systems are currently based in the
United States, which means Information we collect will be processed by us in the U.S.
where data protection and privacy regulations may not offer the same level of protection as
in other parts of the world, such as the European Union. If you use or visit our Sites from
outside the United States, you consent to the collection and/or processing in the United
States of Information we collect from you. 086
NOTIFICATION REGARDING PRIVACY POLICY UPDATES

From time to time, we may update this Privacy Policy. We will notify you about material
changes to this Privacy Policy by placing a notice on our Sites. We encourage you to
periodically check back and review this policy so that you always know our current privacy
practices.
HOW TO CONTACT US
If you have any questions about this Privacy Policy you may contact us at:
wmprivacy@warnermediagroup.com or at WarnerMedia Privacy Office, 4000 Warner Blvd.,
Bldg. 160, Burbank, CA 91522 or contact us toll free at 833-WM-PRVCY (833-967-7829) or
TTY: 833-PRVCY-TT (833-778-2988).
SCAMSBREAKING AND CCPA PRIVACY RIGHTS AND DISCLOSURES

This Scamsbreaking.com and CCPA Privacy Rights and Disclosure section was last updated
July 1, 2020 and addresses legal obligations and rights laid out in the Scamsbreaking.com
Consumer Privacy Act (“CCPA”) and other laws that apply only to Scamsbreaking.com
residents. These obligations and rights apply to businesses doing business in
Scamsbreaking.com and to Scamsbreaking.com residents and information that identifies,
relates to, describes, is reasonably capable of being associated with, or could reasonably be
linked, directly or indirectly, with Scamsbreaking.com consumers or households
(“Scamsbreaking.com Information”). It does not apply to information that has been de-
identified or aggregated as provided by CCPA.
Scamsbreaking.com INFORMATION WE COLLECTED AND SHARED

This section provides the information Scamsbreaking.com residents need to exercise their
rights over their Scamsbreaking.com Information. Here is information about the
Scamsbreaking.com Information we have collected from and shared about consumers in the
year before this section was last updated.
Scamsbreaking.com Information We Collected
In the year before this section was last updated, we may have collected the
following categories of Scamsbreaking.com Information:
• Address and other identifiers — such as name, phone number, postal address, zip code,
email address, account name or number, date of birth, driver’s license number, payment
card numbers, or other similar identifiers
• Characteristics of protected classifications — such as race, ethnicity, or sexual orientation
• Unique and other online identifiers — such as IP address, device IDs, or other similar
identifiers that relate to your device and its operating system
• Commercial information — such as products or services purchased, obtained, or

considered, or other purchasing or consuming histories or tendencies 087
• Internet or other electronic network activity information — such as browsing history,
search history, and information regarding your interactions with our Sites, and content such
as videos, ads, websites, and devices such as smart TVs, streaming media, browsers and
apps
• Professional information or educational Information — such as your current occupation
• Biometric information
• Audio, visual, or similar information — such as photos, videos, video footage (CCTV) or
recordings you choose to post to our Sites or provide by granting us access to your camera
while using Sites or services
• Location information — such as your device’s precise location in connection with certain
Sites
• Inferences or audience segmentation — such as individual profiles, preferences,
characteristics, and behaviors
• In-Game or online viewing activities — such videos, content, and pages viewed
We may have collected or sold these categories of Scamsbreaking.com
Information for the following business or commercial purposes:
• Performing services on behalf of the business — such as customer service, processing or
fulfilling orders, providing content recommendations, and processing payments
• Auditing customer transactions
• Fraud and crime prevention
• Debugging errors in systems
• Marketing and advertising
• Internal research, analytics and development — e.g., user-preference analytics
• Developing, maintaining, provisioning or upgrading networks, products, services, or
devices
We may have obtained Scamsbreaking.com Information from a variety of sources,
including:
• Directly from you — such as technical and usage information when you use our Sites
• Linked sites — such as Social Media Sites and third-party platforms
• Our affiliates
• Our joint ventures and promotional and strategic partners
• Information suppliers
• Distributors and other vendors
• Marketing mailing lists
• Other users submitting information about you — such as to invite you to participate in an
offering, make recommendations, or share content
• Publicly available sources
Disclosures of Scamsbreaking.com Information:
In the year before this section was last updated, we may have disclosed the
following categories of Scamsbreaking.com Information to third parties:

considered, or other purchasing or consuming histories or tendencies 088
apps
Sites
We may have disclosed each of these categories of Scamsbreaking.com
Information to the following categories of third parties:
• Affiliates — These entities are associated with us through common ownership. For a list of
affiliates, please visit the affiliates’ page.
• Service Providers — These entities process information on our behalf for business
purposes, helping us provide products or services to you
• Social Media Platforms — These entities maintain networks connecting individuals and
organizations — such as Facebook, LinkedIn, or Twitter
• Advertising Partners — These entities help us advertise our products or services, as well
as connect us with others who want to place advertisements on some of our products or
services
• Analytics Partners — These entities help us collect data on how our products or services
are used, so that we can improve them and better understand our consumers
• Promotional Partners — We partner with these entities to jointly promote our products, for
example by running contests or other promotional campaigns
• Government Entities — These entities include law enforcement authorities, regulatory
agencies, and courts
Categories of Scamsbreaking.com Information sold to third parties
The CCPA defines ‘sale’ very broadly. It includes the sharing of
Scamsbreaking.com Information in exchange for anything of value. According to
this broad definition, in the year before this section was last updated, we may
have sold the following categories of Scamsbreaking.com Information to third
parties:
considered, or other purchasing or consuming histories or tendencies
apps 089
Sites
We may have sold each of these categories of Scamsbreaking.com Information to
the following categories of third parties:
• Affiliates — These entities are associated with us through common ownership. For a list of
affiliates, please visit the affiliates’ page.
• Social Media Platforms — These entities maintain networks connecting individuals and
organizations — such as Facebook, LinkedIn, or Twitter
• Advertising Partners — These entities help us advertise our products or services, as well
as connect us with others who want to place advertisements on some of our products or
services
• Analytics Partners — These entities help us collect data on how our products or services
are used, so that we can improve them and better understand our consumers
• Promotional Partners — We partner with these entities to jointly promote our products, for
example by running contests or other promotional campaigns
YOUR Scamsbreaking.com PRIVACY RIGHTS TO REQUEST

DISCLOSURE OF INFORMATION WE COLLECT AND SHARE ABOUT YOU
If you are a Scamsbreaking.com resident, Scamsbreaking.com Civil Code Section 1798.83
permits you to request information about our practices related to the disclosure of your
personal information by certain members of the WarnerMedia family of companies to certain
third parties for their direct marketing purposes. You may be able to opt out of our sharing
of your personal information with unaffiliated third parties for the third parties’ direct
marketing purposes in certain circumstances. Please send your request (along with your full
name, email address, postal address, and the subject line labeled “Your Scamsbreaking.com
Privacy Rights”) by email at wmprivacy@warnermediagroup.com.
In addition, if you are a Scamsbreaking.com resident, the CCPA grants you the right to
request certain information about our practices with respect to Scamsbreaking.com
Information. In particular, you can request the following:
• The categories and specific pieces of your Scamsbreaking.com Information that we’ve
collected
• The categories of sources from which we collected Scamsbreaking.com Information
• The business or commercial purposes for which we collected or sold Scamsbreaking.com
Information
• The categories of third parties with which we shared Scamsbreaking.com Information
You can submit a request to us for the following additional information:
• The categories of third parties to whom we’ve sold Scamsbreaking.com Information, and
the category or categories of Scamsbreaking.com Information sold to each 090
• The categories of third parties to whom we’ve disclosed Scamsbreaking.com Information,
and the category or categories of Scamsbreaking.com Information disclosed to each
YOUR RIGHT TO REQUEST THE DELETION OF Scamsbreaking.com

INFORMATION
Upon your request, we will delete the Scamsbreaking.com Information we have collected
about you, except for situations when that information is necessary for us to: provide you
with a product or service that you requested; perform a contract we entered into with you;
maintain the functionality or security of our systems; comply with or exercise rights
provided by the law; or use the information internally in ways that are compatible with the
context in which you provided the information to us, or that are reasonably aligned with
your expectations based on your relationship with us.
YOUR RIGHT TO ASK US NOT TO SELL YOUR Scamsbreaking.com

INFORMATION
You can always tell us not to sell your Scamsbreaking.com Information by visiting
our Privacy Center.
HOW TO EXERCISE YOUR Scamsbreaking.com RIGHTS

You may exercise your rights to request access to your Scamsbreaking.com Information,
deletion of your Scamsbreaking.com Information, or to request we not sell your
Scamsbreaking.com Information by visiting our Privacy Center. You can also contact us toll
free at 833-WM-PRVCY (833-967-7829) or TTY: 833-PRVCY-TT (833-778-2988) and an
agent will assist you with submitting a request. These requests are generally free. When
you submit a request, we will usually ask you to provide an email address which we will
contact to confirm the request was not fraudulently submitted.
In addition, for access and deletion requests, we will use a third-party verification service to
confirm that you are who you say you are. Our verification service does this by matching
information you provide against information held about you in its records, or, if necessary,
by allowing you to submit documents proving your identity.
If you are the parent of a child under 13 years of age, you may also submit a request on
behalf of your child. In that event, we will ask you to provide your child’s email address, to
verify your identity, and to submit a signed form authorizing us to proceed with the request
regarding your child’s Scamsbreaking.com Information.
You may also designate an authorized agent to submit a request on your behalf. To do so,
we will require either (1) a valid power of attorney, or (2) signed written permission from
you. In the event your authorized agent is relying on signed written permission, we may
also need to verify your identity and/or contact you directly to confirm permission to
proceed with the request.
Your authorized agent can make a request by contacting us toll free at 833-WM-PRVCY
(833-967-7829) or TTY: 833-PRVCY-TT (833-778-2988). 091
OUR SUPPORT FOR THE EXERCISE YOUR DATA RIGHTS

You have the right not to receive discriminatory treatment if you exercise any of the rights
explained in this section of the Privacy Policy. We are committed to providing you control
over your Scamsbreaking.com Information, we will not disadvantage you if you choose to
exercise your rights.
Scamsbreaking.com CONSUMERS UNDER 16 YEARS OLD

CCPA has specific rules regarding the use of Scamsbreaking.com Information from
consumers under 16 years of age. In particular, consistent with the CCPA, if we knowingly
collect the Scamsbreaking.com Information of a consumer under the age of 16, we will not
sell the information unless we receive affirmative permission to do so. If the consumer is
between the ages of 13 and 16 years of age, the consumer may provide that permission; if
the consumer is under the age of 13, the consumer’s parent or guardian must provide the
permission. As of the Effective Date of this Privacy Policy, we do not have actual knowledge
that we sell Scamsbreaking.com Information of consumers under 16 years of age.
If you would like further information on how we handle Scamsbreaking.com Information
from consumers under the age of 16 years of age, or if you have questions about these
information practices, you may contact us at wmprivacy@warnermediagroup.com, or at
WarnerMedia Privacy Office, 4000 Warner Blvd., Bldg. 160, Burbank, CA 91522.
Scamsbreaking.com CONSUMERS UNDER 18 YEARS OLD

Scamsbreaking.com consumers who are registered users of the Sites and under 18 years of
age may request removal of content or information they posted on the Sites. We will
remove such content or information when we are required to do so by law. To request
removal of content or information you posted on the Sites, you may contact us at
wmprivacy@warnermediagroup.com, or at WarnerMedia Privacy Office, 4000 Warner Blvd.,
Bldg. 160, Burbank, CA 91522.
However, even if we remove the content or information that you posted, we cannot
completely prevent further use or disclosure of that content or information by others once
you have shared it in a publicly available forum.
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WarnerMedia Privacy Policy

Thank you fo r visit ing a WarnerMedia property. This Privacy Policy explains our online information pract ices and t he choices you can make abou t infor mat ion
collect ed t hrough our webs ites, applicat ions ("apps"), services, connected devices (e.g., connect ed TVs), and ot her offerings (each a "Site" o r co llectively, t he
"Sites"). This Privacy Policy applies to any Site t hat links directly to this policy. Fo r certain offer ings on our Sites, there may be addit ional not ices about our
informat ion practices and choices. Please read those addit ional privacy disclosures to understand how t hey apply to you. Our Privacy Policy is designed to
provide transparency into our privacy pract ices and principles. You can learn about o ur WarnerMedia and AT&T affiliates by visit ing t he affiliates' page.
TABLE OF CONTENTS
• INFORMATION WE COLLECT
• HOW WE USE THE INFORMATION
• INFORMATION SHARING AND DISCLOSURE
• YOUR CHOICES AND CONTROLS
• COOKIES AND OTHER TECHNICAL INFORMATION
• INFORMATION SECURITY
• HOW YOU CAN ACCESS OR CORRECT INFORMATION
• ADDITIONAL INFORMATION REGARDING CHILDREN'S PRIVACY
• INTERNATIONAL TRANSFER
• NOTIFICATION REGARDING PRIVACY POLICY UPDATES
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• NOTIFICATION REGARDING PRIVACY POLICY UPDATES
• HOW TO CONTACT US
• CALIFORNIA AND CCPA PRIVACY RIGHTS AND DISCLOSURES
• AFFILIATES (Please visit t he afflllates' page to review our list of affiliat es)
INFORMATION WE COLLECT
We may co llect dif ferent types of information during your interact ions wit h our Sites and t hro ugh our advertising and media across t he Int ernet and mobile
apps. This info rmation may include personal informat ion (e.g., name, phone number, postal address, email address, and certain payment information),
t echnica l info rmat ion (e.g., device identifier, IP address, browser type, operat ing system) and usage information (e.g., how you use and navigate t o and from
our Sites, and informat ion about content o r adve rt isements you have been shown or have cl icked on). We may combine t hese types of informat ion together,
and collect ively refer to all of this informat ion in t his Privacy Policy as "Informat io n:· Info rmation may be collect ed as described below and t hrough t he use of
cookies, web beacons, pixels, and ot her similar t echnologies by us or by other companies on our behalf. Below we describe the t ypes of Information we may
collect:
Registration, account, and sign-up Information. We may co llect Informat ion in the course of your use of, o r reg ist ration wit h, our Sites. For example, when
you crea te an account, reg ist er for or download an app, or sign-up for a product or service, you may provide us wit h certain personal info rmat ion. This type of
personal info rmat ion may include name, phone number, postal address, fax number, email address, o r certain payment info rmat ion (e.g., credit card and
billing informat ion). We may also collect Information abou t your interest in and use of various products, programs, services, and content available on or
t hrough our Sites.
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Other information you provide. When you interact with our Sit es, you may share other information about yourself by, fo r example, publishing and sharing
t he informat ion with t he Site's webs ite or in t he Site's commun ity, crea t ing a or profile, or filing out a survey o r application. Sometimes you may also choose
to provide more sensit ive fo rms of personal information to us, such as information regarding your physical o r mental health, biometric data, race o r ethnicity,
religious or philosophica l beliefs, sex life, sexual orientat ion, politica l opinions, or t rade union membership. For example, we may collect this type of sensit ive
informat ion if you part icipate in surveys, focus groups, or opport unit ies to t est new product s, programs, or services. We co llect t his sensit ive informat ion wit h
your consent, if required by law, and we t ake steps to protect and limit any use of it to the purposes for wh ich it is provided.
Information from others; inviting friends. On some of our Sites we may collect Information ot her people submit about you. For example, a friend might
submit Inform ation to invite yo u t o part icipat e in an offering, make recommendations, or share content . By processing t hese request s, we may receive your
Informat ion, incl uding a recipient's nam e, postal address, email address, telephone number, or informat ion about your interest in and use of va rious product s,
program s, serv ices, and content. Some of our Sites also allow users to invite friends to participate in activit ies by providing t heir f riends' cont act details or
import ing contact s f rom you r address book or from ot her sites.
Information from other sources. We may combine Informat ion we rece ive online with ot her informat ion, including usage information from our other Sites
and our on line advert ising and media. We may also supplement o r combine Informat ion with information from a va riety of ot her sources or outside records,
such as demographic, transact ion history, or personal information, and we may use t hat combined information in accordance wit h th is Privacy Policy.
Information you provide through social media. You can engage wit h som e of our content and off erings, such as v ideos, games, apps, and other offerings
on or th rough t hird part y communit ies, fo rums, and social media sites, platform s, services, plug-ins, and applicat ions ("Social Media Sites"). When you link to
or interact wit h our Sites, content, o r offerings th rough Social Media Sites, you may allow us t o receive certain Informat ion f rom your social media account
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or interact wit h our Sites, content, o r offerings th rough Social Media Sites, you may allow us t o receive certain Informat ion f rom your social media account
(e.g., name, user ID, email address, prof ile photo, phot os and videos, gender, birthday, location, your list of f riends and t heir contact details, people you follow
and/or who fo llow you, t he post s or t he 'likes' you make). We may also receive Information from your interaction wit h our content (e.g., content viewed, game
performance, high scores, and informat ion about advert isements you have been shown or have clicked on). By providing th is Information or ot herwise
interacting wit h our Sites t hrough Social Media Sites, you consent to our use of Information f rom t he Social Media Sit es in accordance with t his Privacy Policy.
For informat ion about how you can customize your privacy sett ings on Social Media Sit es, and how those Social Media Sites handle you r personal information
and content, please refer to t heir privacy help guides, privacy policies, and t erms of use.
Information you provide through public forums. If you post or share Informat ion o r content, such as photos, lett ers, videos, or comment s, while
part icipat ing in online forums on our Sites, or when you interact wit h our Sit es t hrough Social Media Sites, depending on your privacy sett ings, t his
Informat ion o r content and your username may become public on t he Internet o r wit hin a community of users. We cannot prevent further use of t his
Informat ion once you share it in a publicly available forum. Fo r information about how you can customize your privacy sett ings on Social Media Sites, and how
t hose Social Media Sites handle your personal informat ion and content, please refer t o t heir privacy help guides, privacy policies, and terms of use.
Location information. We may have access to cert ain Information about yo ur locat ion, such as you r co untry or address, when you provide it eit her directly
or via device informat ion. If you access our Sites on your mobile device, we may collect Information abou t your device's precise location. We also m ay derive a
general locat ion from device information (such as an IP address).
Information you provide through camera access. For some Sites, we will ask fo r permission to access your device's camera. If you grant permission, you
may be able to t ake pictures or video within the app experience or to access certain augmented rea lity ("AR") features. Some of t hese features may rely on
camera svstems to t rack movement s of vou r eves and ot her facial f eatures or vour immediate surroundinas to aoolv AR effects. Informat ion aat hered from
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camera systems to t rack movement s of you r eyes and ot her facial f eatures or your immediate surroundings to apply AR effects. Information gat hered from
some facial scanning t echnology (e.g. True Depth API), is only used to make t hese serv ices and f eatures available t o you and is o nly persist ent on t he device
during use of t he AR features. Other facia l scanning t echnology may be used for resea rch, analytics, and enhancing consumer experiences.
Video and streaming information. Fo r some Sit es, we collect info rmat ion about t he fi lms, TV shows, and videos that you view. For example, if you stream
video cont ent using our Sites, we may collect info rmat ion about you r interaction wit h t hat content or service, such as t he t it le and genre, watch lists you
comp ile, and searches you conduct, duration and number of st reams and downloads and system information relat ed to st reaming and download quality.
Technical and usage information. We also collect certain t echnica l and usage info rmat ion when you use our Sites, such as t he type of device, browser, and
operating system you are using, your Internet service provider or mobile ca rrier, unique device ident if ier, IDFA or IDFV, MAC address, IP address, device and
browser settings, t he we bpages and apps you use, advertisements you see and interact with, and certa in Site usage informat ion. See our Cookies and Other
Technical Information section for more information on how we may use these technologies to collect t his Information.
HOW WE USE THE INFORMATION

We use Information for t he purposes described in th is policy or disclosed at the t ime of collection or with your consent.
Providing and marketing products and services. We may use t he Info rmat ion we collect about you t hrough our Sites to fulfi ll your requests fo r, and
ot herwise provide o r analyze you r use of our products, programs, serv ices and cont ent, to facilitat e sharing and ot her interactions with Social Media Sites,
and t o provide, develop, maintain, personalize, protect, and improve your experience and our offerings. For example, we use Informat ion we collect to enable
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and t o provide, develop, maintain, personalize, protect, and improve your experience and our offerings. For example, we use Informat ion we collect to enable
you to do t hings like (i) watch tra ilers, movies, programs, and video clips, (ii) get entertainment news and updates, (iii) get information about our products,
programs, services, and content, (iv) locate and access personalized information or functionality based on your interests or locat ion (e.g., find stores,
theaters, o r show t imes), (v) buy digita l content, movie t ickets, or other purchases (vi) play games, (vii) engage with interactive features, activit ies, and Social
Media Sites, (viii) read and post comments, content, and reviews, (ix) fill out surveys or provide feedback, or (x) enter promotions, contests, and sweepstakes.
We may also use Information to offer, market, and advert ise products, programs, and services from us and our aff iliates, business part ners, and select th ird
parties that we believe may be of interest t o you.
Communicating with you and others. We may use Information about you to communicate with you, such as (i) to notify you when you win one of our
contests or sweepstakes or when we make changes t o our policies or user agreements, (ii) to respond to your inquiries and provide you with customer
service, (iii) to communicate wit h you abou t your purchases or t ransact ions, (iv) t o contact you about your account, or (v) to send you information about
promotions, offerings, and Site features. You may also choose to receive push notificat ions from us on you r mobile device. If you choose to submit content
for publication on line o r in other fo rums, we may publish your screen name or username and other Information you have provided t o us on our Sites, the
Internet, or elsewhere. We use Information that you provide about ot hers t o enable us to send them invitations, promotions, or ot her content on your behalf
or through our Sites. From t ime to t ime, we also may use this Information to offer, market, or advertise products, programs, or services to t hem from us and
our affiliates, and business partners.
Use of technical and usage Information. We may use t echnica l and usage information t o improve the design, f unct ionality and content of our Sites and to
enable us t o personalize your experience w ith our Sites and offerings. For example, we may use th is Informat ion (i) to provide, develop, maintain, personalize,
protect, and improve our Sites, products, programs, and services and t o operate our business, (ii) t o perform analytics, including to analyze and report on
usage and performance of our Sites, (iii) to prot ect against, identify, and prevent fraud and ot her unlaw ful act ivity, (iv) to create aggregate data about groups
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usage and per formance of our Sit es, (iii) to prot ect against, ident ify, and prevent fra ud and ot her unlaw ful act ivity, (iv) to creat e aggregat e data about groups
or cat egories of our users, and (iv) fo r us and our aff iliates, business partners, and select t hird parties t o target, offer, market, or advertise product s,
programs, or services.
Compliance. We may use Information we co llect t o detect, investigate, and prevent act ivit ies on our Sites t hat may vio late our t erms of use, could be
fraudulent, violate copyright, or other ru les or t hat may be otherwise illegal, to comply with legal requirements, and to prot ect our right s and t he rights and
safety of our users and ot hers.
INFORMATION SHARING AND DISCLOSURE

We may share and disclose Informat ion in the fo llowing ways or for any ot her purpose disclosed at t he t ime of co llection:
With your consent. We may disclose Informat ion when you provide us with your consent to do so.
Legal and law enforcement purposes. We may disclose Information in response t o legal process, for example in response to a court order or a subpoena, o r
in response to a law enforcement agency's request. We also may disclose such Informat ion to t hird part ies: (i) in con nect ion w it h fraud prevent ion act ivit ies,
(ii) where we believe it is necessary t o invest igat e, prevent, or t ake act ion regarding illegal activit ies, (iii) in situations t hat may involve vio lat io ns of our terms
of use or other ru les, (iv) to protect our rights and t he rights and safety of others, and (v) as ot herwise requ ired by law.
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Change of control. We may transfer Info rmat ion in t he event of a business t ransact ion, such as if we or one of our business units o r our relevant assets are
acquired by, sold to, or merged with another company o r as part of a bankrupt cy proceeding or a business reorganizat ion.
Service providers. Organizat ions t hat perfo rm services fo r us may have access to Informat ion to help carry out the services t hey are perfo rming for us,
such as, but not limited t o, creation, maintenance, hosting, and delivery of our Sit es, products, and serv ices, conduct marketing, handle payments, email and
order fulfillment, administer contest s, cond uct research and analyt ics, or customer service.
Affiliates. We may disclose Informat ion to affiliat es. For example, we may share Informat ion we collect with our affiliates to provide, improve, offer, market,
and otherwise communicate wit h you about t heir own product s and services. Our products and services may be developed, m anaged, marketed and sold by a
variety of our affiliates. We share Informat ion t hat may ident ify you internally among affi liates publicly recognized as a WarnerMedia affi liate, such as Xandr
and t he AT&T fam ily of companies. Public recognit ion may derive f rom, for example, use of comm on branding elements, advertising, press, social media
reports o r ot her public form of notice. We requ ire the affiliate to protect t he Informat ion consist ent with t his Policy. We may also combine Informat ion t hat
ident ifi es you personally with data t hat comes from an affi liate t hat has a different privacy policy. When we do t hat, our Policy applies to t he combined data
set. You can learn about our WarnerMedia and AT&T affiliates by visit ing t he affiliat es' page.
Business partners and third parties. We may also share Informat ion wit h business partners and t hird part ies (e.g., ot her companies, retailers, research
organizations, advert isers, ad agencies, advertising networks and platforms, part icipatory databases, publishers, and non-profit o rganizat io ns) t hat may want
to market product s or services to you. If we share personal informat ion wit h such unaffiliated third parties for their own m arketing purposes, we provide you
wit h an opportunity to opt out of such uses eit her at t he point of collect ion or t hrough the choice mechanisms set forth in t his Privacy Policy. To learn m ore
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wit h an opportunity to opt out of such uses eit her at t he point of collect ion or t hrough the choice mechanisms set forth in t his Privacy Policy. To learn more
about your choices, please see our Your Choices and Cont rols section below.
Linked sites. Some of our Sites contain links to ot her sites, including Social Media Sites, whose informat ion practices may be different from ours.
Informat ion you submit to other sites will be governed by t he other sites' privacy policies and t erms.
Sponsors and co-promotions. We may sometimes offer content or programs (e.g., contest s, sweepstakes, promotions, games, applicat ions or Social Media
Site integrations) t hat are sponsored by or co-branded wit h identified third part ies. By virtue of t hese relationships, t he sponsoring o r co-brand ing part ies
may collect or obtain Informat ion from visito rs t hat participate in the activity. We have no cont rol over t hese sponsoring or co-branding parties' use of t his
Informat ion. We encourage you to visit t he privacy policy of any such sponsoring or co-branding party to learn about t heir data pract ices prior t o providing
Informat ion t hrough sponsored o r co -branded content or programs.
Advertising networks. We may share certain information wit h parties to provide advertising to you based on you r interests. For more info rmat ion, please
see our Ad Choices section below.
YOUR CHOICES AND CONTROLS

Marketing communications and sharing with third parties. We provide you wit h an opportunity to express your preferences with respect to receiving
certain market ing communications from us, and our sharing of personal information with unaffiliated t hird parties fo r t heir direct marketing purposes. If you
ever decide in the fu ture t hat you wou ld like t o update t hese preferences, you may (i) log in to an account you have created with us at one of our Sites t o
adiust vour sett inas. o r (ii) send us an email at wmDrlvacvli>warnermedlaarouD.com. To oot out of rece ivina our email marketina communicat ions. vou can
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adj ust your sett ings, o r (ii) send us an email at wmprlvacy@warnermedlagroup.com. To opt out of rece iving our email m arketing communicat ions, you can
also follow t he "unsubscribe" instruct ions provided in any marketing email you receive from us. If you previously chose to receive push not ifi cations on your
m obile device from us, but no longer wish to receive them, yo u can manage your preferences t hrough you r device o r app settings, depending on t he type of
device. If you have signed up to receive text messages f rom us and no longer wish to receive such messages, you may follow t he instruct ions to stop t he
delivery of such messages, which may incl ude by replying "STOP" t o t he received text message.
For California residents, please see below for additional informat ion on the choices we provide to you.
Ad Choices. On our own or working wit h affiliates or t hird parties, we m ay present advert isements and engage in data collect ion, repo rt ing, ad delivery and
response measurement, and site analyt ics on our Sit es and on t hird party webs ites across the Internet and applicat ions over t ime. We, our aff iliat es, o r t hird
part ies may use cookies, web beacons, pixels, software development kits ("SDKs") or similar t echnologies to co llect informat ion across websit es, serv ices, and
apps over t ime to perform t his activity. We, our affi liates, or third parties may use and t ransfer t his informat ion in order to help serve advertising t hat m ay be
m ore relevant to you r interests on and off our Sit es and across your devices and browsers. This type of advertising is known as interest-based adve rt ising.
We, our affiliates, or t hird parties may also use t his inform ation to associate you r different browsers and devices toget her for interest-based advert ising and
for other purposes like research, analyt ics, internal operat ions, fraud prevent ion, and enhancing consumer experiences.
For more inform ation abou t interest-based advert ising on your desktop or m obile browser, and to opt ou t of t his type of advertising by t hird part ies t hat
part icipat e in self-regulatory program s, please visit t he Network Advertising Initiative website and/or t he
Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising website. To learn more about interest-based
advertising in mobile apps and t o opt o ut of t his type of advertising by th ird parties t hat participate in t he DAA's AppCho ices t ool, please use t his link to
download the version of AppCholces for your device. Please note t hat any opt-out choice you exercise t hrough t hese programs will apply to interest -
based advertising by t he t hird part ies you select, but will st ill allow t he collect ion of data for other purposes, incl uding research, analyt ics, and internal
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based advert ising by t he t hird part ies you select, but will st ill allow t he collect ion of data for other purposes, including research, analyt ics, and internal
operations. You may cont inue to receive advertising, bu t that advertising may be less relevant to your interests.
To opt out of our own co llection, use, and transfer of data as described above for interest-based advert ising, please visit our Privacy Center to opt -out.
Please note t hat if you o pt out, we will continue to collect dat a for ot her purposes, including research, analytics, and internal operations. You may cont inue to
receive advert ising on our Sit es based on your act ivit ies on our Sites.
You may have more opt ions depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones,
Android for And ro id devices, and Windows for Microsoft devices) provide their own inst ruct ions on how to limit o r prevent t he delivery of t ailored in-
applicat ion advert isements. You may review t he support materials and/or t he privacy sett ings for t he respect ive o perat ing systems to learn more abou t
t hese features and how t hey apply to tailored in-app advertisement s.
Precise location Information. To disable t he collect ion of precise locat ion info rmat ion from your mobile device t hrough our mobile apps, you can access
your mobile device sett ings and choose t o limit t hat collect ion.
See also our Cookies and Other Technical Information sect ion for more choices about managing other t echnical and usage info rmat ion.

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Cookies and other technologies. We, and our affiliat es, vendors, and business part ners may send "cookies" to yo ur compute r o r use similar technologies t o
understand and enhance your online experience at our Sites and t hrough our advertising and media across the Internet and mobile apps.
Cookies are sm all t ext f iles placed in your browser. We may also use pixels o r "web beacons" that monitor yo ur use of our Sites. Web beacons are small st rings
of code that provide a method fo r delivering a graphic image on a webpage for the purpose of t ransferring data, such as t he IP address of t he computer t hat
downloaded t he page on which the web beacon appears, the URL of t he page on which t he web beacon appears, t he t ime t he page containing t he web
beacon was viewed, the type of browser t hat fetched the web beacon, and t he ident ificat ion number of any cookie on t he computer previously placed by t hat
server. We may also integrat e SD Ks into o ur applicat ions to perfo rm similar functions as cookies and web beacons. Fo r example, SDKs may collect t echnica l
and usage informat ion such as mobile device identifiers and your interactions wit h t he Site and other mobile apps.
We may use cookies and ot her technologies to help recognize yo ur browser or device, maintain your preferences, provide certain Site feat ures, and collect
Informat ion about int eract ions wit h our Sites, our content, and our communications. For example, when corresponding with you via HTML capable email, web
beacons and ot her technologies let us know about your activity, including whet her you received and opened our email, clicked through a link, o r otherwise
interacted with our content, and t his info rmat ion may be associated wit h Info rmat ion previously collected.
We may also use cookies and ot her technologies (i) to provide, develop, maint ain, personalize, protect, and improve our Sites, product s, programs, and
services and to operate our business, (ii) to perfo rm analyt ics, including t o analyze and report on usage and performance of our Sites and marketing
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We may also use cookies and ot her technologies (i) to provide, develop, maint ain, personalize, protect, and improve our Sites, product s, programs, and
services and to operate our business, (ii) to per fo rm analyt ics, including t o analyze and report on usage and performance of our Sites and marketing
m aterials, (iii) to prot ect against, ident ify, and prevent fraud and ot her unlawful act ivity, (iv) t o create aggregate data about g roups or categories of our users,
(v) t o synchronize users across devices, affiliates, business partners, and select third parties, and (vi) for us and our affi liates, business part ners, and select
t hird part ies t o t arget, offer, market, o r advert ise product s, programs, or services. Cookies and other t echnologies also facilitat e, manage, and measure the
performance of advertisement s displayed on o r delivered by or t hrough us and/or other networks or sites. By visit ing t he Site, whet her as a registered user
or ot herwise, you acknowledge, and agree t hat you are g iving us your consent to t rack you r act ivit ies and your use of t he Site t hrough the technologies
described above, as well as similar technologies developed in the f ut ure, and t hat we may use such tracking techno logies in t he emails we send to you.
Managing cookies and other technologies. Cookies can eit her be persist ent (i.e., t hey remain on you r computer unt il you delet e them) or t emporary (i.e.,
t hey last only until you close you r browser). Check you r browser sett ings to learn how to delete cookies.
You may adj ust your browser to reject cookies from us o r f rom any other website. Controlling cookies via browser cont ro ls may not limit our use of other
t echnologies. Please consu lt your browser's sett ings for m ore information. However, blocking cookies or similar technology might prevent you from
accessing some of our content o r Sit e featu res.
Some of our Sites may use locally sto red objects ("LSOs") to provide certain content, such as video on dem and, video cl ips, or animation, and a better user
experience. Adobe"s Flash player and similar applications use t his technology to remember sett ings, preferences, and usage similar to browser cookies. Flash
cookies are not managed t hro ugh you r web browser, but you can access your Flash management tools by v isiting Adobe's web site. Yo ur browser m ay also
offer ot her too ls t o delete or reject other LSOs; please check your browser's settings or help menu for more informat ion.
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Some of our sites may use Google Analytics t o analyze t raffic. You can f ind out m ore info rmation about Google Analyt ics cookies by v isit ing t he following
locat ion provided: https://developers.google.com/analytlcs/devguldes/collectlon/analytlcsjs/cookle-usage. To opt o ut of Google Analyt ics relat ing
to your use of our Sites, you can download and install t he Browser Plugin available by visit ing t he following locat ion provided:
https://tools.google.com/dlpage/gaoptout?hl=en.
Some Sites may featu re Nielsen proprietary measurement software, which will allow users to cont ribute to market research, such as Nielsen TV Rat ings. To
learn more abou t the informat ion t hat Nielsen sof tware may co llect and you r choices, please see t he Nielsen Digital Measurement Privacy Policy by v isit ing
t he following location provided: https:/fwww.nlelsen.com/us/en/legal/prlvacy-statement/dlgltal-measurement/
We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We
continue to review new technologies and may adopt a standard once one Is created.
See the Your Choices and Controls section to learn how to control data collection for certain purposes.
INFORMATION SECURITY
We have put in place reasonable cont ro ls designed to help safeguard the personal information we co llect v ia t he Sites. However, no security measures are
perfect, and we cannot assure you that personal informat ion that we co llect will never be accessed o r used in an unau t horized way.

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To access personal informat ion t hat we have collected about you on line f rom Sites on which this Privacy Policy is post ed, o r to updat e your user profile,
please log into you r account if you have created one with us, o r send an email to wmprlvacy@warnermedlagroup.com. Fo r California residents, please see
below fo r addit ional information on accessing info rmat ion about you.
ADDITIONAL INFORMATION REGARDING CHILDREN'S PRIVACY

On most Sites, we do not knowingly collect info rmat ion from children. On some Sites, we may ask t he user to provide us wit h t he user's age info rmat ion. If
t he person indicates t hat he o r she is under 13 years old, as permitt ed by law, we will (i) collect no o r limited personal informat ion (e.g. persist ent ident ifier
and/or em ail address only) from that individual, (ii) inform the child that a parent's verifiable consent is required, and/or (iii) collect t he email address of t he
user's parent in addit ion to t he user's email address. We may use t he parent's email address to seek t he parent's ve rif iable consent or not ify t he parent of
his/her child's online act ivit ies and enable the parent to unsubscribe his/her child from a newsletter or ot her similar activity. Once a parent provides consent,
we may use any information collected from a child consistent with the rest of t his Privacy Policy and/or t he t erms of t he consent provided by the parent. If a
user is under 13, we will not cond it ion his/her participation in an online act ivity on t he disclosure of more personal information t han is reasonably necessary
to participate in t he act ivity. If you wou ld like t o review any personal information t hat we have collected on line from your child, have this personal info rmat ion
deleted from our act ive serve rs, and/or request t hat t here be no further collect ion o r use of your child's personal information, or if you have quest ions about
t hese information pract ices, you m ay contact us at wmprlvacy@warnermedlagroup.com, or at WarnerMedia Privacy Office, 4000 Warner Blvd., Bldg. 160,
Burbank, CA 91522.
We operate internat ionally, and m any of our computer systems are currently based in t he United States, which means Info rmat ion we collect will be
processed by us in the U.S. where data prot ect ion and privacy reg ulat ions m ay not offer t he sam e level of prot ection as in other part s of t he world, such as
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We operate internat ionally, and many of our computer systems are currently based in t he United States, which means Info rmat ion we collect will be
processed by us in the U.S. where data prot ect ion and privacy reg ulat ions may not offer t he same level of prot ection as in other part s of t he wor ld, such as
t he European Union. If you use or visit our Sites from outside the United St ates, you consent to t he collection and/or processing in t he United St ates of
Infor mat ion we collect from you.
NOTIFICATION REGARDING PRIVACY POLICY UPDATES

From time t o t ime, we may update t his Pr ivacy Policy. We will notify you abou t ma terial changes to t his Privacy Policy by placin g a not ice on our Sites. We
encourage you t o periodica lly check back and review t his policy so t hat you always know our current privacy practices.
HOW TO CONTACT US
If you have any questions about t his Pr ivacy Policy you may co ntact us at: wmprlvacy@warnermedlagroup.comor at WarnerMedia Privacy Office, 4000
Warner Blvd., Bldg. 160, Burbank, CA 91522 or contact us toll f ree at 833-WM-PRVCY (833-967-7829) or TTY: 833-PRVCY-TT (833-778- 2988).
CALIFORNIA AND CCPA PRIVACY RIGHTS AND DISCLOSURES

CALIFORNIA AND CCPA PRIVACY RIGHTS AND DISCLOSURES
This Californ ia and CCPA Pr ivacy Right s and Disclosure sect ion was last updated July 1, 2020 and addresses legal obligations and rights laid out in t he
California Consumer Privacy Act ("CCPA") and ot her laws t hat apply only to California residents. These obligations and rights apply to businesses doing
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This Californ ia and CCPA Privacy Right s and Disclosure sect ion was last updated July 1, 2020 and addresses legal obligations and rights laid out in t he
Californ ia Consumer Privacy Act ("CCPA") and ot her laws t hat apply only to California residents. These obligations and rights apply to businesses doing
business in Califo rnia and to Califo rnia res idents and info rmat ion t hat ident ifi es, relates to, describes, is reasonably capable of being associat ed wit h, or could
reasonably be linked, direct ly o r indirect ly, wit h California consumers o r househo lds ("California Information"). It does not apply to informat ion that has been
de-identifi ed or aggregat ed as provided by CCPA.
CALIFORNIA INFORMATION WE COLLECTED AND SHARED
This sect ion provides the informat ion Califo rnia res idents need t o exercise t heir rights over t heir California Information. Here is informat ion about t he
Californ ia Informat ion we have co llected f rom and shared about consumers in the year before t his sect ion was last updated.
California Information We Collected
In the year before this section was last updated, we may have collected the following categories of California Information:
• Address and other ident ifiers - such as name, phone number, postal address, zip code, email address, account name or number, date of birth, drive r's
license number, payment ca rd numbers, or ot her similar identifiers
• Charact eristics of prot ected classifi cat ions - such as race, ethnicity, o r sexual o rientation
• Unique and ot her online ident ifiers - such as IP address, device IDs, or other similar ident ifi ers that relate to your device and its operat ing system
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• Unique and ot her online ident ifiers - such as IP address, device IDs, or other similar ident ifiers that relate to your device and its operat ing system
• Commercial information - such as products or services purchased, obt ained, or considered, or other purchasing or consum ing histo ries or
t endencies
• Internet o r other elect ronic network activity information - such as browsing history, search history, and information regarding your interactions w it h
our Sites, and content such as videos, ads, websites, and devices such as smart TVs, st reaming media, browsers and apps
• Professional information or educat ional Information - such as your cu rrent occupat ion
• Aud io, visual, or similar information - such as photos, videos, video footage (CCTV) or recordings you choose t o post to our Sites or provide by
grant ing us access t o your camera wh ile using Sites o r services
• Location information - such as your device's precise location in connection with certa in Sites
• Inferences or audience segmentat ion - such as individual profiles, preferences, charact eristics, and behaviors
• In-Game or online viewing activit ies - such videos, cont ent, and pages viewed
We may have collected or sold these categories of California Information for the following business or commercial purposes:
• Perform ing services on behalf of the business - such as customer service, processing or fu lf illing orders, providing content recommendat ions, and
processing payment s
• Aud it ing customer transact ions
• Fraud and crime prevention
MarKeuna ana aayems1oa
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• Fraud and crime prevent ion

• Marketing and advert ising
• Internal resea rch, analyt ics and development - e.g., user-preference analyt ics
• Developing, maintaining, provisioning or upgrading networks, product s, services, or devices
We may have obtained California Information from a variety of sources, Including:
• Direct ly f rom you - such as technical and usage informat ion when you use our Sites
• linked sites - such as Social Media Sites and t hird -part y platforms
• Our affi liates
• Our j oint ventures and promot ional and strat egic partners
• Informat ion suppliers
• Dist ribu tors and other vendors
• Marketing mailing list s
• Other users submitt ing information abou t yo u - such as t o invite you to participate in an offering, make recommendations, or share content
• Publicly available sources
Disclosures of California Information:

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Disclosures of California Information:
In the year before this section was last updated, we may have disclosed the following categories of California Information to third parties:
• Charact eristics of prot ected classificat ions - such as race, ethnicity, o r sexual o rientation
• Commercial information - such as products or services purchased, obt ained, or considered, or other purchas ing or consuming histo ries or
t endencies
• Internet o r other elect ronic network activity informat ion - such as browsing history, search history, and informat ion regarding your interactions w it h
our Sites, and content such as videos, ads, websites, and devices such as sm art TVs, st reaming media, browsers and apps
• Audio, visual, or similar informat ion - such as photos, videos, video footage (CCTV) or recordings you choose t o post to o ur Sites or provide by
grant ing us access t o your camera while using Sites o r services
• Locat ion information - such as your device's precise location in connection wit h certa in Sites
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We may have disclosed each of these categories of California Information to the following categories of third parties:
• Affiliat es - These ent it ies are associated with us through common ownership. For a list of affiliates, please visit t he affiliates' page.
• Service Providers - These ent ities process information on our behalf fo r business purposes, helping us provide product s or services to you
• Social Media Platforms - These ent it ies maint ain networks connect ing individuals and o rganizat ions - such as Facebook, Linkedln, o r Twit ter
• Advertising Part ners - These ent it ies help us advertise our products or services, as we ll as connect us wit h ot hers who want t o place advertisements
on some of our products o r services
• Analytics Partners - These ent it ies help us co llect data on how our products or services are used, so t hat we can improve t hem and better
understand our consumers
• Promot ional Part ners - We partner wit h t hese ent it ies to jo int ly promot e our products, for example by running contests or ot her promotional
campaigns
• Government Ent ities - These ent it ies incl ude law enforcem ent authorit ies, regu latory agencies, and courts
Categories of California Information sold to third parties
The CCPA defines 'sale' very broadly. It Includes the sharing of California Information In exchange for anything of value. According to this broad
definition, in the year before this section was last updated, we may have sold the following categories of California Information to third parties:
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The CCPA defines 'sale' very broadly. It Includes the sharing of California Information in exchange for anything of value. According to this broad
definition, in the year before this section was last updated, we may have sold the following categories of California Information to third parties:
• Charact eristics of prot ected classifi cat ions - such as race, ethnicity, o r sexual o rientation
• Commercial information - such as products or services purchased, obt ained, or considered, or other purchas ing or consuming histo ries or
t endencies
• Internet o r other elect ronic network activity informat ion - such as browsing history, search history, and informat ion regarding your interactions w it h
our Sites, and content such as videos, ads, websites, and devices such as sm art TVs, st reaming media, browsers and apps
• Audio, visual, or similar informat ion - such as photos, videos, video footage (CCTV) or recordings you choose t o post to o ur Sites or provide by
grant ing us access t o your camera while using Sites o r services
• Locat ion information - such as your device's precise location in connection wit h certa in Sites
We may have sold each of these categories of California Information to the following categories of third parties:
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We may have sold each of these categories of California Information to the following categories of third parties:
• Affiliat es - These ent it ies are associated with us through common ownership. For a list of affiliates, please visit t he afflllates' page,
• Social Media Platforms - These ent it ies maint ain networks connect ing individuals and o rganizat ions - such as Facebook, Linkedln, o r Twitt er
• Advertising Part ners - These ent it ies help us advertise our products or services, as we ll as connect us wit h ot hers who want t o place advertisements
on some of our products o r services
• Analytics Partners - These ent it ies help us co llect data on how our products or services are used, so t hat we can improve t hem and better
understand our consumers
• Promot ional Part ners - We partner wit h t hese ent it ies to jo int ly promot e our products, for example by running contests or ot her promotional
campaigns
YOUR CALIFORNIA PRIVACY RIGHTS TO REQUEST DISCLOSURE OF INFORMATION WE COLLECT AND SHARE ABOUT YOU
If you are a Californ ia resident, Californ ia Civil Code Sect ion 1798.83 permits you to request informat ion about our pract ices relat ed to t he disclosure of your
personal info rmat ion by certain members of the WarnerMedia fam ily of companies to certa in t hird parties fo r t heir direct marketing purposes. You may be
able to opt out of our sharing of you r personal information with unaffiliated t hird parties fo r t he t hird part ies' direct marketing purposes in certain
circumstances. Please send your request (along with your fu ll name, email address, post al address, and t he subject line labeled "Your California Privacy
Right s") by email at wmprlvacy@warnermedlagroup.com.
In addit ion, if you are a Californ ia resident, t he CCPA g rants you the right to request certain information about our practices wit h respect to California
Informat ion. In particu lar, you can request t he following:
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• The categories and specif ic pieces of your California Info rmat ion t hat we've collected
• The categories of sources f rom which we collected California Informat ion
• The business o r commercial purposes for which we collected o r sold California Information
• The categories of t hird parties wit h which we shared California Information
You can submit a request to us for the fo llowing addit ional informat ion:
• The categories of t hird parties to whom we've sold California Info rmation, and t he cat egory or categories of California Information sold t o each
• The categories of t hird parties to whom we've disclosed Californ ia Information, and t he category or categories of California Informat ion disclosed t o
each
YOUR RIGHT TO REQUEST THE DELETION OF CALIFORNIA INFORMATION
Upon your request, we will delete t he California Info rmat ion we have co llected about you, except for situat ions when t hat information is necessary for us to:
provide you wit h a product or service t hat you request ed; per fo rm a cont ract we entered into wit h you; maintain the funct ionality or security of our systems;
comp ly with or exercise right s provided by t he law; o r use t he information int ernally in ways t hat are compat ible wit h the context in which you provided t he
informat ion to us, or t hat are reasonably aligned with your expect ations based on you r relationship wit h us.
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YOUR RIGHT TO ASK US NOT TO SELL YOUR CALIFORNIA INFORMATION
You can always tell us not t o sell your Californ ia Information by visit ing our Privacy Center.
HOW TO EXERCISE YOUR CALIFORNIA RIGHTS
You may exercise you r rights t o request access to your California Information, deletion of your Californ ia Informat ion, o r to request we not sell your Californ ia
Information by visit ing our Privacy Center. You can also contact us toll f ree at 833-WM-PRVCY (833-9 67-7829) or TTY: 833-PRVCY-TT (833 -778-2988) and an
agent will assist you with submitting a request. These requests are generally free. When you submit a request, we will usually ask you to provide an email
address wh ich we will contact t o confirm the request was not f raudulently submitt ed.
In addit ion, for access and delet ion request s, we will use a third-party ve rification service t o confirm t hat you are who you say you are. Our verification service
does this by matching information you provide against information held about you in its records, or, if necessary, by allowing you to submit documents
proving you r identity.
If you are the parent of a child under 13 yea rs of age, you may also submit a request on behalf of your child. In t hat event, we will ask you to provide your
child's email address, to verify your identity, and t o submit a signed form authorizing us to proceed with t he request rega rding you r child's California
Information.
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You may also designate an authorized agent to submit a request on your behalf. To do so, we will require eit her (1) a va lid power of attorney, or (2) signed
written permission f rom you. In t he event your aut horized agent is relying on signed written permission, we may also need t o verify your ident ity and/or
contact you direct ly t o confirm permission t o proceed with the request.
Your authorized agent can make a request by contacting us t oll f ree at 833-WM-PRVCY (833-967-7829) or TTY: 833 -PRVCY-TT (833-778 -2988).
OUR SUPPORT FOR THE EXERCISE YOUR DATA RIGHTS
You have the right not t o receive discriminatory t reatment if you exercise any of the rights explained in this sect ion of the Privacy Policy. We are commit t ed
to providing you cont rol over your California Information, we will not disadvantage you if you choose t o exercise your right s.
CALIFORNIA CONSUMERS UNDER 16 YEARS OLD
CCPA has specific rules regarding the use of California Information from consumers under 16 years of age. In particular, consistent with the CCPA, if we
knowingly collect t he California Informat ion of a consumer under the age of 16, we will not sell t he informat ion unless we receive affirmat ive permission to do
so. If the consumer is between the ages of 13 an d 16 years of age, t he consumer may provide t hat permission; if t he consume r is under the age of 13, t he
consume r's parent o r guardian must provide the permission. As of t he Effect ive Dat e of this Privacy Policy, we do not have actual knowledge t hat we sell
Californ ia Information of consumers under 16 years of age.
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If you would like further informat ion on how we handle Califo rnia Information from consumers under t he age of 16 years of age, o r if you have questions
about t hese information pract ices, you may cont act us at wmprlvacy@warnermedlagroup.com, or at WarnerMedia Privacy Office, 4000 Warner Blvd., Bldg.
160, Burbank, CA 91522.
CALIFORNIA CONSUMERS UNDER 18 YEARS OLD
Californ ia consumers who are reg ist ered users of t he Sites and under 18 yea rs of age may request remova l of content or information t hey posted on t he
Sites. We will remove such content or information when we are required to do so by law. To request rem oval of content or information you posted on t he
Sites, you may contact us at wmprlvacy@warnermedlagroup.com, o r at WarnerMedia Privacy Office, 4000 Warner Blvd., Bldg. 160, Burbank, CA 91522.
However, even if we remove t he content or information t hat you post ed, we cannot completely prevent furt her use or disclosure of that cont ent o r
informat ion by ot hers once you have shared it in a publicly available forum.
Document No- 21 121
Result List
Extracted from ASIC's database at AEST 22:55:31 on 20/01/2021

Search Filters
Keyword:International Media Corporation
Category:Name Availability
As at the time of this extract, the name checked is not considered identical to any name registered on the ASIC database.
The name is similar to the following registered name(s):
-A maximum of 200 results are displayed on the result list-
Name Number
INTERNATIONAL MULTIMEDIA CORPORATION PTY. LTD ACN 053 711 747
* INTERNATIONAL MEDICAL CORPORATION PTY. LTD. ACN 010 173 181
INTERNATIONAL DIAMOND CORPORATION PTY LTD ACN 168 831 785
INTERNATIONAL MARKETING CORPORATION PTY LTD ACN 080 071 334
INTERNATIONAL MINING CORPORATION PTY LTD ACN 122 823 661
* INTERNATIONAL MINERALS CORPORATION PTY LTD ACN 077 989 783
INTERNATIONAL MINERALS CORPORATION PTY LTD ACN 058 373 836
INTERNATIONAL AUSTRALIA CORPORATION PTY LTD ACN 151 747 769
INTERNATIONAL BUSINESS CORPORATION (NAMREDEL)
ACN 057 309 145
PTY. LTD.
INTERNATIONAL BUSINESS CORPORATION (ST. KILDA RD
ACN 057 661 015
) PTY LTD
* INTERNATIONAL FRUIT CORPORATION PTY. LTD. ACN 006 573 253
* INTERNATIONAL FACILITY CORPORATION (NEWCASTLE
ACN 051 887 355
) PTY. LTD.
INTERNATIONAL TRADING CORPORATION PTY LTD ACN 111 259 397
INTERNATIONAL TELERADIOLOGY CORPORATION PTY L
ACN 104 826 360
TD
INTERNATIONAL INVESTMENTS CORPORATION
* INTERNATIONAL BUSINESS CORPORATION PTY. LTD. ACN 057 661 079
INTERNATIONAL BUSINESS CORPORATION (CAMBERWEL
ACN 058 470 161
L) PTY LTD
INTERNATIONAL BUSINESS CORPORATION (QUEEN ST) PT
ACN 096 827 959
Y LTD
INTERNATIONAL BUSINESS CORPORATION PTY LTD ACN 165 009 432
INTERNATIONAL DEVELOPMENT CORPORATION PTY LTD ACN 008 917 824
INTERNATIONAL DISTRIBUTION CORPORATION PTY LTD ACN 616 288 834
* INTERNATIONAL ENTERTAINMENT CORPORATION PTY
ACN 072 466 132
LTD
INTERNATIONAL ENTERTAINMENT CORPORATION PTY L
ACN 091 532 660
IMITED
* INTERNATIONAL FACILITY CORPORATION PTY. LTD. ACN 010 835 551
INTERNATIONAL LEISURE CORP. PTY LTD ACN 612 205 857
INTERNATIONAL OPTICAL CORPORATION PTY LTD ACN 634 030 738
* INTERNATIONAL PACIFIC CORPORATION LIMITED ACN 008 458 366
* INTERNATIONAL PHILATELIC CORPORATION LTD ACN 009 089 696
INTERNATIONAL PACIFIC CORPORATION PTY. LTD. ACN 064 608 171
20/01/2021 AEST 22:55:31 1

122
Result List
Name Number
INTERNATIONAL RESOURCE CORPORATION PTY. LIMITED ACN 062 699 469
INTERNATIONAL TRAINING CORPORATION PTY LTD ACN 132 275 828
THE INTERNATIONAL FUSION CORPORATION PTY LTD ACN 619 167 805
THE INTERNATIONAL FUSION CORPORATION
Disclaimer
This service is provided solely for general information only. The provision of this service does not guarantee that a name found not to be
identical to any protected name currently on the ASIC database or will be a name acceptable under the provisions of the Corporations Law
and/or Corporations Regulations. Accordingly, ASIC will not be liable for the consequences of any action or activity undertaken, or expense
incurred, by a party seeking to rely upon this service as granting them entitlement to use a name.
20/01/2021 AEST 22:55:31 2

Document No- 22 123
124
125
Awards & Accolades Document No- 23
126
Great Place to Best Company in Cons

Iconic Brands of India Game Changers of
Work-Certified™ by truction Equipment
2020 India 2018
Great Place to Work Finance 2020
by Economic Times by Economic Times
Institute by CIA World
Best NBFC in SME

Best Employer Award Best BFSI Company in
Financing for BFSI
India 2018 by “Dream Companies to Brand Excellence &
Leadership Awards
Employer Branding Work for” Award 2018 Marketing by
2018 at 3rd NBFC100
Institute Equipment Times
Tech Summit, 2018
Document No- 24 127
Document No- 25
Axis Bank|
AXIS/CO/CS/428/2020-21 128
15t h December 2020
Listing & Compliance Department Listing Department

National Stock Exchange of India Limited BSE Limited
Exchange Plaza, 5th Floor 1s t Floor, New Trading Ring, Rotunda Building
Plot No. C/1, “G” Block P. J. Towers, Dalal Street
Bandra-Kurla Complex Fort,
Bandra (E), Mumbai – 400 051 Mumbai – 400 001
NSE Symbol: AXISBANK BSE Scrip Code : 532215
Dear Sirs,
SUB: CLARIFICATION ON PRESS STATEMENT DATED 14 TH DECEMBER 2020, ISSUED BY SYDNEY, AUSTRALIA
BASED SCAMS BREAKING ON ITS WEBSITE BREAKING@SCAMSBREAKING.COM
W e draw your attention to a press statement dated 14 t h December 2020, issued by Sydney, Australia
based Scams Breaking on its website breaking@scamsbreaking.com, in which Axis Bank Limited has been
mentioned at v arious places. According to the said publication:
“as per the records m aintained by MCA21 (A m inistry of Corporate affairs website) the Axis Bank etc.
have provided loans to SREI Infrastructure and Finance Lim ited to the tune of INR 44,000 cr ores without
any due diligence and verification of end use of the loan am ount. This loan am ount has been
disbursed with sham receivables including related party transactions.”
The Bank has receiv ed queries seeking more information on these exposures. A ccordingly, we clarify as
below:
1. The Bank has complied with its underwriting practices and approv al processes for any exposure taken
in relation to SREI Equipment Finance Limited and SREI Infra Finance Limited (collectiv ely “SREI
entities”). Axis Bank’s outstanding as on December 14, 2020 are set out in the table below:
Entities Outstanding Fund Outstanding Non Fund Total

Based Based
SREI entities 366 45 411
SREI group (including 731 69 800
SREI entities)
All amounts in Rs Crore, rounded off to nearest Rs crore
2. Axis Trustee Serv ices Ltd. acts in its fiduciary capacity as a trustee and / or custodian and charges
registered by it is not a reflection of the exposure of Axis Bank Limited.
In summary, the report is grossly inaccurate and baseless insofar as Axis Bank Limited’s outstanding to SREI
entities or underwriting practices and processes are concerned. W e are ev aluating all remedies av ailable
to us against the author/publisher of the captioned report.
You are requested to take note of abov e and arrange to bring the same to the notice of all concerned.
Thanking you,
Yours Sincerely,
For Axis Bank Limited
GIRISH Digitally signed by
GIRISH VASUDEVAN
VASUDEVA KOLIYOTE
Date: 2020.12.15
N KOLIYOTE 15:06:33 +05'30'
Girish V. Koliyote
Company Secretary
AXI S BANK
Legal & CS: Ax is House, W adia I nt ernat ional Cent re, Pandurang Budhkar marg, W orli, Mumbai 400 025
Regist ered Address: "Trishul" - 3rd Floor, Opp. Samart hesw ar Temple, Near Law Garden, Ellisbridge,
Ahmedabad - 380006. Telephone No.: 079-26409322 Fax No.: 079-26409322
CI N : L65110GJ1993PLC020769 W ebsit e: w ww.ax isbank.com
1/20/2021 Regus Express - Sydney, International Airport - Regus Express - Google Maps
Document No- 26
Regus Express - Sydney, International Airport - Regus Express 129
Map data ©2021 Google 200 m
Regus Express - Sydney,

International Airpo - Regus
Express
5.0 ★★★★★ 4 reviews
O ce space rental agency
Directions Save Nearby Send to your Share

phone
https://www.google.com/maps/place/Regus+Express+-+Sydney,+International+Airport+-+Regus+Express/@-33.9353615,151.1650636,15z/data=!4m5!3m4!1s0x0:0… 1/4
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Document No- 29
SYAL & CO 172
(ADVOCATES & SOLICITORS)
CEASE AND DESIST NOTICE
By Registered AD/Speed Post/E-mail
To,
1. Mr. Sanjay Gupta,
Country Manager,
Google India Pvt. Ltd.
2. Mr. Satya Raghavan

Director, Youtube Content Partnerships, India
Google India Pvt Ltd, 1st Floor,
3 North Avenue, Maker Maxity,
Bandra Kurla Complex,
Bandra East, Mumbai-400051, India.
3. Mr. Ajit Mohan

Vice President and Managing Director, India
Facebook India Online Services Pvt. Ltd.
Building No.20, Raheja Mindspace,
Telengana
4. Bipasha Chakrabarti
Director, Communications, India
Instagram
Building No.20, Raheja Mindspace,
Telengana
5. Manish Maheshwari
Managing Director
Twitter Communications India Pvt. Ltd
E-34, Greater Kailash Enclave, New Delhi – 110048, India

Tel: +91 11 4107 9789, +91 11 49403158 | Email: syalandcompany@gmail.com; syal.arjun@gmail.com; work@syalandco.com;
SYAL & CO 173
C-20, G Block, Near MCA Bandra Kurla Complex,

Bandra (E) Mumbai-400051, Maharashtra
6. Ashutosh Gupta
Country Manager
Linkedin Technology Information Pvt. Ltd.
16A/20, WEA Main Ajmal Khan Road,
Karol Bagh New Delhi-110005
05.01.2021
SUB: CEASE AND DESIST NOTICE ON BEHALF OF [SREI

Infrastructure and Finance Limited and SREI Equipment Finance Ltd]
Dear Sir,
We write to you on behalf of [SREI Infrastructure and Finance Limited and

SREI Equipment Finance Limited having their registered office at
VISHWAKARMA', 86C, Topsia Road, Kolkata, West Bengal-
700046][hereinafter as ‘Our Clients’] and serve upon you this cease-and-desist
notice:
1. M/s SREI Infrastructure Finance Ltd.(“SIFL”) is a reputed leading Non-

Banking Financial Institution registered as a Non-Banking Financial
Company (NBFC) with the Reserve Bank of India (RBI) and is
classified as an Infrastructure Finance Company. SIFL was the first
Indian infrastructure NBFC to be listed on the London Stock Exchange
way back in 2005. It also has the distinction of having a wide spectrum
of international institutions as its stakeholders such as IFC (International
Finance Corporation - World Bank Group) KfW& DEG Germany
(financial institutions owned by the Government of Germany), FMO
(financial institution owned by the Government of Netherlands), BIO
(financial institution owned by the Government of Belgium), FINFUND
(financial institution owned by the Government of Finland), Fidelity,
Norges Bank and many more. Highly recognized projects have been
undertaken by it. It has been successfully running its business in the
Infrastructure Finance sector since its very inception. Members of the
Kanoria family have been pioneers in the private infrastructure sector
and have reshaped India's infrastructure landscape with innovative
ideas and a strong passion for excellence and are known for
unleashing the wave of rural entrepreneurship in India.
2. On 14.12.2020, a highly defamatory and malicious article titled as
“Again Blindly Shell Crores Of Public Money Without Any Due
Verifications In Yet Another Huge Scam Commissioned By

SYAL & CO 174
Kolkata’s Kanoria Brothers.” has been published by one

Scamsbreaking.com (“Article”) concerning the Kanoria family,
SIFL, its directors and various group companies. The said Article
contains a 27.12-minute-long video titled “Biggest Expose of the
Year 2020 is Here” (“Video”) descriptively narrating the contents
of the Article. The Article also contains pictures of the Kanoria
family and directors of SIFL & various group entities. The Article
and the Video malign the reputation of the Kanoria family, SIFL,
its directors and various group companies as also violate their
fundamental rights guaranteed under the Constitution of India. The
Video and the Article are accessible on Google at
https://www.google.com/search?sxsrf=ALeKk037xxSW2J31YgPQn
f-
u_fvu1dweFw%3A1609160021619&ei=VdXpX9iWJebVz7sPzMmg
yAs&q=scams+breaking.com+kanoria+&oq=scams+breaking.co
m+kanoria+&gs_lcp=CgZwc3ktYWIQAzIFCCEQoAE6BwgjEMk
DECc6BAgjECdQ3hdYuSxgiTBoAHAAeACAAbkBiAGjC5IBBDAu
MTCYAQCgAQGqAQdnd3Mtd2l6wAEB&sclient=psy-
ab&ved=0ahUKEwiYleab3PDtAhXm6nMBHcwkCLkQ4dUDCA0
&uact=5
3. The Video and the Article have been widely published on
numerous websites and social media platforms, inter alia,
Facebook, YouTube, Twitter, Instagram, LinkedIn etc., the details
of which are provided herein below:
a. YouTube:
https://www.youtube.com/watch?v=DXYa9NmVwvI
b. Facebook:
https://www.facebook.com/breakingnewsimc/videos/273833044648
1884.
c. Instagram:
https://www.instagram.com/p/CIz1hDdDQEe/ and
https://www.instagram.com/p/CI2VT9jjIrR/
d. Twitter:
https://twitter.com/BreakingScams/status/1338773925870718976.
e. LinkedIn:
i. https://www.linkedin.com/posts/scams-breaking_whatsapp-
video-at-180501-activity-6742279131477639168-jRTM
ii. https://www.linkedin.com/posts/scams-
breaking_scamsbreaking-scam2020-india-activity-
6743035259996139520-bnMD
iii. https://www.linkedin.com/posts/scams-
breaking_scamsbreaking-scams-indianscam-activity-
6744124472116203520-Ptig

SYAL & CO 175
iv. https://www.linkedin.com/posts/scams-breaking_business-
media-news-activity-6744145377739460608-414B
v. https://www.linkedin.com/posts/scams-
breaking_scamsbreaking-scam2020-india-activity-
6744517012657053697-PjDT
4. It is incumbent for us to point out that the contents of the

aforementioned Video and Article, are completely devoid of any truth
and are false, defamatory and derogatory. The Video and Article have
been published with a view to malign the reputation of the Kanoria
family, SIFL, its directors and various group companies, without
any verification of the correct facts.
5. We hereby put you to notice that:
a) The Video and Article accessible through and on your website are
defamatory on the face of it. The contents thereof are completely
contrary to facts, baseless and false. The Video and Article are
derogatory and defamatory in nature.
b) The contents of the Video and the Article is reckless, disparaging
and malicious, published without any regard to the truth and without
due care or verification. It is apparent from the contents of the
Videos and the Article that the contents thereof do not form part of
bonafide public information and have been posted solely to tarnish
the image of the Kanoria Family, SIFL, its directors and various
group companies.
c) The Video and the Article go so far as to declare the Kanoria Family,
SIFL, its directors and various group companies, guilty of serious
economic crimes which are totally baseless and misleading. The
allegations made therein are unfounded and demonstrate a complete
lack of journalistic ethics and code of conduct.
d) The Video and the Article endorse and extract completely false
allegations without making any attempt to verify the truth.
e) The reckless and repeated publication of the contents of the
Video and the Article on the internet has a cascading effect on
the reputation and goodwill of the Kanoria Family, SIFL, its
directors and various group companies. The Video and the
Article have been published by Scamsbreaking.com with the
sole intent to stir a controversy in order to garner publicity for
information in order to adversely impact the business of the
Kanoria Family, SIFL, its directors and various group
companies.
f) From internal enquiries and investigations, it appears that
Scamsbreaking.com is a sham website created to target and malign

SYAL & CO 176
the reputation of the Kanoria Family, SIFL, its directors and

various group companies. It is evident that Scamsbreaking.com
and the persons acting on its behalf are deliberately publishing
defamatory and malicious content to cause loss of reputation,
goodwill and irreparable injury to the Kanoria Family, SIFL, its
directors and various group companies through widespread
misinformation.
g) The details of the information collated by our clients on
Breakingscams are as follows for your needful action:
Doesnt give a Legit Phone Number or Email.
[12/15, 7:57 AM] Rahul Mehta: Domain Name:
SCAMSBREAKING.COM
Updated Date: 2020-10-31
Creation Date: *2020-08-31*
Registrant Organization: International Media Corporation
Registrant Street: Australia Square, Level, Plaza
Registrant City: Sydney
Registrant State/Province: New South Wales
Registrant Postal Code: 2000
Registrant Country: AU
Registrant Phone: *+61.123456789*
Registrant Email: worldimcnews@gmail.com
Admin Email: worldimcnews@gmail.com
on 11th November it changed the address to a US Maryland address and
hid the Organization details.
Updated Date: 2020-11-27
Creation Date: 2020-08-31
Registrar Registration Expiration Date: 2022-08-31T14:23:19Z
Registry Registrant ID: Not Available From Registry
Registrant Name: Domain Admin
Registrant Organization: Privacy Protect, LLC (PrivacyProtect.org)
Registrant Street: 10 Corporate Drive
Registrant City: Burlington
Registrant State/Province: MA
Registrant Postal Code: 01803
Registrant Country: US
Registrant Phone: +1.8022274003
Registrant Phone Ext:
Registrant Fax:
Is 3 months, and 14 days old. That website was first developed on Aug
31st, 2020.
The address given on the website, The Nigel Love Building, Level 8/10
Arrival Ct, Mascot NSW 2020, Australia is a Regus Serviced Office.
h) Pertinently, Axis Bank by way of a press release dated

15.12.2020 clarified that the Video and Article have been
published without any due diligence and verification of the end
use of the loan amounts.

SYAL & CO 177
6. Since you the notices above mentioned now stand on notice that the
Video and the Article are defamatory in nature, you are called upon to
remove the said Video and Article within 24 hours of receipt of this
notice from your website and all other online sites/databases controlled
by you. You are also advised to ensure that no further publication is
made against Kanoria Family, SIFL, its directors and various group
companies directly or indirectly relating to the Video and Article
published by Scamsbreaking.com.
7. Should you fail to comply with the above, we shall be compelled to take
legal action against you, which may be in the nature of civil action or
criminal proceedings for defaming the reputation of Kanoria Family,
SIFL, its directors and various group companies.
8. We reserve all rights and remedies available in law.
Yours sincerely,
Arjun Syal
On behalf of SREI Infrastructure Finance Ltd./SREI Equipment Finance Ltd.

1/20/2021 Document No- 30
Gmail - Your correspondence to Facebook
178
Your correspondence to Facebook

Facebook <case++aazttr66zn2ode@support.facebook.com> Wed, Jan 13, 2021 at 2:15 PM
Reply-To: Facebook <case++aazttr66zn2ode@support.facebook.com>
To: syalandcompany@gmail.com
Hi,
Thank you for your letter to Facebook India dated 2021-01-05, a copy of which is attached to this message for your
reference. We're responding in our capacity as Facebook Inc., which operates the Facebook service for people from India.
Based on the information provided, we are not in a position to take action based on your defamation concerns at this time.
You may want to reach out to the party responsible for posting the content to resolve your issue with them directly.
Should you have additional information that bears on this report, namely a court order against the reported party bearing
on this matter, you may reply to this message with that information and we`ll continue to look into your report.
Thanks,
April
Facebook
>On Mon Jan 11, 2021 23:31:55, Syal & Co wrote:

>
A39wpN
2986K
https://mail.google.com/mail/u/1?ik=01ff38b68c&view=pt&search=all&permmsgid=msg-f%3A1688760525064032811&simpl=msg-f%3A1688760525064032811 1/1
1/20/2021 Gmail - Fwd: Case# 0188044083: Twitter Receipt of Correspondence / Your letter dated January 5th 2021 [ ref:_00DA0K0A8._5004w24eFRn:ref ]
Document No- 31 179

shreyan das <dasshreyan@gmail.com>
Fwd: Case# 0188044083: Twitter Receipt of Correspondence / Your letter dated

January 5th 2021 [ ref:_00DA0K0A8._5004w24eFRn:ref ]
Arjun Syal <syal.arjun@gmail.com> 16 January 2021 at 12:06
To: shreyan das <dasshreyan@gmail.com>, Manjira Dasgupta <dasguptamanjira@gmail.com>, Akshita Sachdeva
<akshitasachdeva30@gmail.com>
---------- Forwarded message ---------

From: Twitter Support <support@twitter.com>
Date: Fri, Jan 15, 2021 at 3:54 PM
Subject: Case# 0188044083: Twitter Receipt of Correspondence / Your letter dated January 5th 2021 [
ref:_00DA0K0A8._5004w24eFRn:ref ]
To: syal.arjun@gmail.com <syal.arjun@gmail.com>
Dear Arjun Syal,
The content you have reported is not hosted by Twitter; it appears to be posted on
a third-party website. We do not provide support for content posted on third-party
websites and are therefore unable to take any action regarding this content. You
may wish to contact the support team of the third-party website where the content
is posted.
If you would like us to review specific content on Twitter, please provide us with a
list of direct URLs to the Tweets at issue. For more information about how to find
a Tweet URL, please visit https://support.twitter.com/articles/80586. If we do
receive a report that identifies specific and existing content on Twitter, we will
evaluate it and respond accordingly.
To assist in our review of the reported content for possible violations of our Terms
of Service (https://twitter.com/tos) and/or local law, we kindly ask that you provide
any additional relevant information. For example, if you have more context to
provide, or any additional Tweet URLs, please let us know by responding to this
message.
https://mail.google.com/mail/u/0?ik=f4d0feea9c&view=pt&search=all&permmsgid=msg-f%3A1689024226379715972&simpl=msg-f%3A1689024226379715972 1/3
Twitter is not in a position to monitor future accounts or Tweets. Unless we are

provided with an existing Twitter username (e.g., @twittersafety and
180
http://twitter.com/twittersafety), or existing Tweets, we are unable to further
evaluate your report.
If we do receive a report that identifies specific and existing content on Twitter, we

will evaluate it and respond accordingly. For more information about how to find a
Tweet URL, please visit https://support.twitter.com/articles/80586.
Twitter provides a communication service. As a policy, we do not mediate content

or intervene in disputes between users. Users are allowed to post content,
including potentially inflammatory content, provided that they do not violate the
Twitter Terms of Service (https://twitter.com/tos) and Rules
(https://twitter.com/rules). For information on reporting a Terms of Service
violation, please see our help page: https://help.twitter.com/en/rules-and-
policies/twitter-report-violation.
If you have obtained legal process (such as a court order) related to this matter,
we ask that you please provide us with a copy of this documentation for our
review, to assist us in further evaluating your request. For security reasons this
email address does not accept attachments, but we can review the legal process
if uploaded via the following URL:
https://help.twitter.com/en/upload?verifier=5004w000024eFRnAAM%
7CoXaOtXQ30deBgTg6ToAvuDD3HjF8KX80ZztEKTdJAwUZB80QLhK%
2FXSQtac1hzfkYCKi7rgZgUsph67qT5KQffw%3D%3D&casenumber=
0188044083
As a convenience and without prejudice, we are willing to forward a copy of your

correspondence to the reported user so they can decide to respond to you directly
or voluntarily remove the reported content. Please confirm that we may forward
your initial correspondence to the reported user.
Sincerely,
Twitter
181
Help | Privacy
Twitter, Inc. 1355 Market Street, Suite 900 San Francisco, CA 94103
ref:_00DA0K0A8._5004w24eFRn:ref
1/20/2021 Gmail - Fwd: FW: Legal Compliances’ Pursuance mail | Kanoria Brothers| Scam of 2020
Document No- 32
182
Fwd: FW: Legal Compliances’ Pursuance mail | Kanoria Brothers| Scam of 2020
R D Khullar /Srei <rdkhullar@srei.com> Wed, Dec 30, 2020 at 10:30 AM
To: Arjun Syal <syalandcompany@gmail.com>
As discussed yesterday

From: Hemant Kanoria /Srei <hemant@srei.com>
Date: Tue, 29 Dec 2020, 18:55
Subject: FW: Legal Compliances’ Pursuance mail | Kanoria Brothers| Scam of 2020
To: R Khullar <rdkhullar@srei.com>
From: Office of Chief Officer Legal Compliance [mailto:scamsbreaking@outlook.com]

Sent: Tuesday, December 29, 2020 1:27 PM
To: mdceo@psbindia.com; psbcmd@vsnl.com; fareed.ahmed@psb.co.in; ho.pr@psb.org.in;
ed@psbindia.com
Cc: dgpwestbengal@gmail.com; cp@kolkatapolice.gov.in; cyberps@kolkatapolice.gov.in; Shiv Raman-Head
(AsiaPacific) <head.asiapacific@scamsbreaking.com>; kahnoiabros@yahoo.co.in;
hemant@kanoriafoundation.co.in; hemant@srei.com; sunil@kanoriafoundation.co.in; sunil@srei.com;
shounak.mitra@khaitanco.com; saikat.bardhan@indiapower.com; corporate@srei.com;
secretarial@srei.com; corporate@srei.com; gpa@cal.vsnl.net.in; corporate@indiapower.com;
saikat.bardhan@indiapower.com; info@bharatpay.co.in; sanjay.chaurasia@varaunited.com;
sujitkanoria@bharatconnect.com; sanjeev.seth@ipclindia.com; bohyderabad@rbi.org.in;
ccasansol@indiapower.com
Subject: Legal Compliances’ Pursuance mail | Kanoria Brothers| Scam of 2020
Importance: High
To,
THE CHAIRMAN & DIRECTORS
PUNJAB AND SIND BANK
INDIA
Dear Sir,
Please refer to our exclusive investigative news report

submitted to your office, followed by an expose commenced
via worldwide webcast on 14th of December 2020.

183
It has been more than ten days, and now we are

going ahead with a second round of expose on Kanoria
Brothers and their yet more criminal conducts with the Indian
government and foreign connection, and now for the very
same purpose, we would like to know your side of a version
and action taken on expose, as we are sure that entire India
now wants at least a healthy investigation on our report.
However, ScamsBreaking.com challenges that even a single
fact as detailed below, if it comes to even slightly less true,
we will take the responsibility and face the heat of law.
Please appreciate below our pointwise specific issues on

which we need your version and action taken report so that
the same
can be the part of our next expose Part-2. i.e.:-
What action your good office has taken on the fact that
the Kanoria Family created countable bogus entities, and
Power Trust was one of them. The Power Trust is a
registered trust at Kolkata in the state of West Bengal
and run by Kanoria Brothers' agents, and yet the
Kanorias dare to call it Public Trust. How did this
happen? Why did your good office not taken action on
such a sham entity, which was used merely to siphon off
the public money?
the Kanoria Brothers Family set up a public trust by the
name of Power Trust, which has been used as the
criminal purposes vehicle to siphon off the funds. The
scam has been pulled off mainly by sanctioning and
disbursing huge amounts in the secured and unsecured
transfer of funds to bogus and dubious shell companies
on the basis of sham documentation, duly promoted by
the Kanoria brothers. These companies have, in turn,

passed the money back either to Power Trust or to other 184
bogus entities, which have amounted to money
laundering, cheating, tax evasion, and various other
substantive offenses thereof. The ScamsBreaking.com
has collected substantial documentary evidence, which
has been submitted to the Indian law enforcement
agencies for further investigations. The Kanoria brothers
had criminally setup the Power Trust as a public trust,
which only had people from the Kanoria business
enterprises on the board of trustees. The board has Mr.
Dipak Rudra, who is the director of IPCL, Mr. Ajay Kumar
Agarwal – statutory auditor for the SREI group of
companies, he is also the director of Shristi
Infrastructure, which is the SREI promoted entity. Mr.
Shounik Mitra, a lawyer by profession who has been
representing the SREI group of companies as their legal
counsel on various legal cases. Please suggest that how
such agents of Kanoria Family are allowed to operate
criminal entities just to park the black money of Kanoria
Brothers and thereby causing substantive undue criminal
gains to Kanoria Family?
the Power Trust has agents or employees of the Kanoria
group, whereas a public trust should be governed by
independent and unrelated individuals from the public
space. The official claim of the Kanoria brothers has
been that Power Trust runs as an independent trust, thus
having an independent board of trustees and a minimum
shareholding from the public; this was accounted for less
than 25%. The chief function of the trust has been to only
transfer funds?
Further, what do you have to say on the point that the

way the fraud has been committed, India Power
Corporation Limited (IPCL) transfers funds to Power
Trust on the pretext of CSR funds?
185
Further, what do you have to say on the point that these
public funds are then further transferred to another
Kanoria shell entity? There has been a transfer of more
than INR 3500 crores between SREI and IPCL via
various shell companies, which have been concealed in
all financial statements of the companies. Why has no
action been taken so far in this regard?
What do you have to say on the point that between IPCL

and SREI are related party transactions (RPT's) which
have been deliberately concealed, amounting to a
criminal violation and mandatory disclosure
requirements? Why the entire public and bank money
that is transferred to Power Trust is shown as CSR
funds?
What do you have to say on the point that IPCL's

financial statements for the year 2017-18 show transfers
to the tune of INR 557 crores of public money to Power
trust under the false pretext of purchase of investments?
Power Trust actually received INR 695 crores, which was
further diverted to other shell entities promoted by the
Kanoria brothers. This could also happen because of the
fact that the very auditor itself has also been hand in
glove with Kanoria Brothers?
What do you have to say on the point that M/S Bhaskar

Silicon Pvt Ltd (BSPL) and its further subsidiary Environ
Energy Corporation Ltd., both loss-making shell
companies of the Kanoria brothers, availed loans to the
tune of INR 2400 crores using SREI Infrastructure
fraudulent documents and these companies further
siphoned INR 1000 crores to Power Trust?
Why has no action been taken when this INR 1000 crore
was routed back to SREI Infrastructure and on a 186
significant deviation of the company on material
disclosure of information in all of the cases where the
shell entities are actively suppressing facts on terms of
borrowing, terms of repayment and the lending institution
they are borrowing from?
Why did your good office not examine and investigate

the fact that Kanoria Brothers' agents run Bharat Road
Network Limited (BRNL), along with its subsidiaries,
which are controlled and managed by a common board
of directors and employees from SREI, SREI purchased
shares, that were actually trading at INR 25-40 per share,
at a premium of INR 195 per share. This was a smart
move. Now by this illegal step, SREI smartly made the
financials of BRNL 'Green,' thus creating a reserve
surplus for BRNL. A whopping INR 2575 crores public
money was siphoned off under the garb of fake loans. If
you are to trail the end-use of public money, then you will
understand that INR 1114 crores have been further
invested in BRNL subsidiaries, and this information has
been kept under wraps?

the fact that Sahaj E village Limited and its subsidiary
Rural Innovation labs Pvt Limited which are operated by
Kanoria Brothers' agents having zero value in the market
was given INR 1213 crores as a loan at a paltry 6% P. A.
interest as against the regular rate of 18% p.a. these
loans were given on the basis of a cash inflow that never
existed! This act has also generated a notional loss for
SREI to the tune of INR 146 crores per annum. These
illegal financial transactions were merely recorded as
intercorporate deposits?
What is your side of a version on the fact that another

shell entity by the name of M/S Swaymbhu Natural 187
Resources Private Limited, which exists only on papers
as a loss-making company since incorporation, managed
to receive public money-INR 895 crores from SREI of
which INR 346.3 crores was siphoned to Power trust,
with a classic case of fudged books of accounts when it
came to repayment, the Kanoria brothers funded a huge
amount through another entity thus enabling a show of
complete repayment of the loan, In reality, it was just an
eyewash with clear looting?

the fact that M/s Vara Technology Pvt. Ltd. was given
INR 138 crores on the basis of fixed assets amounting to
merely INR 3.8 crores by SREI. M/S Vara Infotech
Private Limited, a shareholder in Kanoria Foundation
(SREI owned trust), has also been used by Kanoria
Brothers to siphon off public funds and provide a criminal
advantage to other group companies. The Kanoria
Brothers have, through SREI, given INR 395.1 crores,
which was further routed under the garb of investment to
another entity promoted by the Kanoria brothers - SREI
Alternative Trust. It would be interesting to note that Vara
Infotech Private Limited is a loss-making company, and
this has been documented as 'Future inflow' during the
SREI mortgage, which means that if the company does
not show any profits, the loans will be written off as bad
debt?
How do you see the case of unsecured lending of

Avarsekar Realty Pvt. Ltd., another related company of
the Kanoria group which received INR 118 crores from
SREI without any security whatsoever, M/s Bharat
Nirman Fund promoted by Kanoria Brothers and SREI
Infrastructure were earlier shareholders of Aversekar
Realty and ceased to be shareholders immediately after
the loan was granted to Avarsekar Realty?
188
the fact that Victor Buildwel Private Limited (VBPL) is
another shell company promoted by the Kanoria
Brothers' SREI Alternative Trust (SAT), They have shown
an inventory of INR 17.3 crores as land in Greater Noida,
UP. Here again, the Kanoria brothers funnelled INR 70
crores against a non-existent property?

the fact that Attivo Economic Zones Private Limited,
another company promoted by Kanoria Brothers' SREI
Alternative Investment Trust- Bharat Nirman Fund. Attivo
received INR 2207 crores from SREI, and INR 240
crores were routed to Power trust. This transaction was
left out from the company balance sheet so that no
questions could be raised. The balance amount was
completely misused. The modus operandi has been that
a company has no verified assets, negative net worth,
and is a loss-making company as shown on books of
accounts and exists merely on paper?
Why such huge public money was lent to Kanoria Family

run entity to misappropriate public money as in the case
of M/s I log Ports Private Limited, another shell company
of the Kanoria brothers showed land worth INR 300
crores on their books. As per field verification, the land is
not even close to being pegged at INR 3 crores. The
company, without even mortgaging this land were able to
source INR 585 crores of public funds through SREI; in
order to evade taxes, the company has misrepresented
financial statements by capitalizing all its expenses
showing no revenue expenses?
the Predicate Consultants Private Limited (PCPL), which
is again promoted by the Kanoria brothers incorporated
in 2014 as a financial consultancy. Mr. Tapas

Chakraborty, a shareholder at PCPL who also holds a 189
key role at SREI, was given INR 375 crores, from which
INR 138 crores was further transferred to Power trust!
This is merely the tip of the iceberg with so many shell
companies created as a medium to funnel funds to the
tune of INR 16000 crores?
Please also reply saying that have you investigated the

fact of how much public money the Kanoria family has
transferred out of India?
The Kanoria Family has been running this criminal

syndicate of window dressing for many years; why did
you not take any action so far?
The Kanoria Family's political influences are known to all;

is it this reason which prevented you from taking action
so far, and thus you kept your eyes closed?
What actions does your good office purpose to take

against the respective bank officials who deliberate kept
the eyes closed and kept on lending public money to
cause criminal gains to Kanroria Brothers family on the
basis of bogus and sham documentations?
The Kanoria Brothers have also tried to induce and

intimidate the ScamsBreaking.com; what is the policy of
your good office to keep such whistle-blowers
indemnified from such intimidations?
Please also note that we have conducted this

expose on our responsibility, and we will not leave
this case to go in junk and so we will keep 190

extremely strict follow-ups to make sure that guilty
is taken to justice.
We are ready to assist your good office further, if

you need more assistance from us.
Thanking You !
Sd/-
Chief Officer
Legal Compliances
ScamsBreaking.com
10 Arrivals Court, Level 8,
The Nigel Love Building
Mascot Sydney -2020
Copy to-:
1. The, DGP, West Bengal

2. The Commissioner of Kolkata Police
3. The Head, Cyber Cell, Kolkata Police
4. M/S SREI Infrastructure Finance Limited
5. M/S SREI Equipment Finance Ltd.
6. M/S India Power Corporation Ltd
7. M/S Power Trust
8. M/S Kanoria Foundation
9. Mr. Hari Prasad Kanoria 191

10. Mr. Hemant Kanoria
11. Mr. Raghu Raj Kanoria
12. Mr. Sunil Kanoria
13. Mr. Sujit Kanoria
14. Ms. Champa Kanoria
15. Mr. Dipak Rudra
16. Mr. Ajay Kumar Agarwal
17. Mr. Shounik Mitra
18. Mr. Srinivasachari Rajagopal
19. Ms. Punita Kumar Sinha
20. Mr. Malay Mukherjee
21. Mr. Shyamlendu Chatterjee
22. Mr. Tamali Sengupta
23. M/S Kanoria Brothers and its other accomplice
Follow us on:
192
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Disclaimer:
"This communication /e-mail/attachment/s / file/s are privileged and confidential, and is directed to the addressee
for the use of the addressee only. If this communication /e-mail/attachment/s / file/s reaches anyone other than the
intended recipient, we request the reader not to reproduce, copy, disseminate or in any manner distribute it. We further
request such recipient to notify us immediately by return email and delete the original message. Please note that any views
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be liable/responsible for the proper, timely and complete transmission thereof.."
1/20/2021 Gmail - Fwd: FW: Legal Actions follow Up mail-1| Kanoria Brothers| Scam of 2020
Document No- 33 193

Fwd: FW: Legal Actions follow Up mail-1| Kanoria Brothers| Scam of 2020
R D Khullar /Srei <rdkhullar@srei.com> Tue, Jan 12, 2021 at 2:48 PM
To: Rohit Parashar /Srei <Rohit.Parashar@srei.com>, Arjun Syal <syalandcompany@gmail.com>
Please see below advise of cmd for necessary action

From: Hemant Kanoria /Srei <hemant@srei.com>
Date: Tue, 12 Jan 2021, 12:53
Subject: FW: Legal Actions follow Up mail-1| Kanoria Brothers| Scam of 2020
To: R D Khullar /Srei <rdkhullar@srei.com>, Anjan Chakraborty /Corporate Strategy & Planning/Srei
<anjan.chakraborty@srei.com>, Pulak Bagchi /Srei <pulak.bagchi@srei.com>
Now that we have the persons’s name,let us file a case and move full fledged
From: Shiv Raman-Head (AsiaPacific) [mailto:head.asiapacific@scamsbreaking.com]

Sent: Tuesday, January 12, 2021 12:16 PM
To: secy.mca@nic.in; anjali.mca@nic.in; asfa.mca@nic.in; nandita.mca@nic.in; shorey.mca@nic.in;
roc.kolkata@mca.gov.in; rd.east@mca.gov.in; kvr.murty@gov.in; gyaneshwar.s@gov.in
Cc: dgpwestbengal@gmail.com; cp@kolkatapolice.gov.in; cyberps@kolkatapolice.gov.in;
hemant@kanoriafoundation.co.in; hemant@srei.com; sunil@kanoriafoundation.co.in; sunil@srei.com;
shounak.mitra@khaitanco.com; corporate@srei.com; secretarial@srei.com; corporate@srei.com;
gpa@cal.vsnl.net.in; corporate@indiapower.com; info@bharatpay.co.in; sujitkanoria@bharatconnect.com;
cp-pol.gb@up.gov.in; addcp-pollo.gb@up.gov.in; addcp-polhq.gb@up.gov.in; dcp-polhq.gb@up.gov.in;
dgp@up.nic.in; adglo.up@nic.in; atodgp@up.nic.in; dgpcontrol-up@nic.in; digcomplaint-up@nic.in;
adglo@up.nic.in; igadmin-up@nic.in; csup@nic.in; hgovup@gov.in; psrajbhavan@mp.gov.in;
lokayukta@hotmail.com; lokayukta@up.nic.in; bohyderabad@rbi.org.in; ccasansol@indiapower.com
Subject: Legal Actions follow Up mail-1| Kanoria Brothers| Scam of 2020
Importance: High
Urgent Legal Matter
To,
1. The Hon’ble Minister
Ministry of Corporate Affairs
Government of India, New Delhi (India)
2. Ministry of Corporate Affairs 194

Government of India
New Delhi (India)
3. Regional Director, Eastern Region

Ministry of Corporate Affairs
Kolkata, West Bengal
4. The Registrar Of Companies

Kolkata, West Bengal
Dear Sir/Madam
This is a legal actions follow up mail seeking the status report

on the actions taken by your good office on our exclusive
investigative news report submitted to your office, followed by
an expose commenced via worldwide webcast on 14th of
December 2020.
As we are all set to proceed with a second round of

expose on Kanoria Brothers and their yet more criminal
conducts with the Indian government and foreign connection,
and now for the very same purpose, we would like to know
your side of a version and action taken on expose, as we are
sure that entire India now wants at least a healthy
investigation on our report. However, ScamsBreaking.com
challenges that even a single fact as detailed below, if it
comes to even slightly less true, we will take the
responsibility and face the heat of law.
195
Please appreciate below our pointwise specific issues on
which we need your version and action taken report so that
the same
can be the part of our next expose Part-2. i.e.:-
the Kanoria Family created countable bogus entities, and
Power Trust was one of them. The Power Trust is a
registered trust at Kolkata in the state of West Bengal
and run by Kanoria Brothers' agents, and yet the
Kanorias dare to call it Public Trust. How did this
happen? Why did your good office not taken action on
such a sham entity, which was used merely to siphon off
the public money?
the Kanoria Brothers Family set up a public trust by the
name of Power Trust, which has been used as the
criminal purposes vehicle to siphon off the funds. The
scam has been pulled off mainly by sanctioning and
disbursing huge amounts in the secured and unsecured
transfer of funds to bogus and dubious shell companies
on the basis of sham documentation, duly promoted by
the Kanoria brothers. These companies have, in turn,
passed the money back either to Power Trust or to other
bogus entities, which have amounted to money
laundering, cheating, tax evasion, and various other
substantive offenses thereof. The ScamsBreaking.com
has collected substantial documentary evidence, which
has been submitted to the Indian law enforcement
agencies for further investigations. The Kanoria brothers
had criminally setup the Power Trust as a public trust,
which only had people from the Kanoria business
enterprises on the board of trustees. The board has Mr.
Dipak Rudra, who is the director of IPCL, Mr. Ajay Kumar
Agarwal – statutory auditor for the SREI group of
companies, he is also the director of Shristi

Infrastructure, which is the SREI promoted entity. Mr. 196
Shounik Mitra, a lawyer by profession who has been
representing the SREI group of companies as their legal
counsel on various legal cases. Please suggest that how
such agents of Kanoria Family are allowed to operate
criminal entities just to park the black money of Kanoria
Brothers and thereby causing substantive undue criminal
gains to Kanoria Family?
the Power Trust has agents or employees of the Kanoria
group, whereas a public trust should be governed by
independent and unrelated individuals from the public
space. The official claim of the Kanoria brothers has
been that Power Trust runs as an independent trust, thus
having an independent board of trustees and a minimum
shareholding from the public; this was accounted for less
than 25%. The chief function of the trust has been to only
transfer funds?
Further, what do you have to say on the point that the

way the fraud has been committed, India Power
Corporation Limited (IPCL) transfers funds to Power
Further, what do you have to say on the point that these

public funds are then further transferred to another
Kanoria shell entity? There has been a transfer of more
than INR 3500 crores between SREI and IPCL via
various shell companies, which have been concealed in
all financial statements of the companies. Why has no
action been taken so far in this regard?
What do you have to say on the point that between IPCL

and SREI are related party transactions (RPT's) which
have been deliberately concealed, amounting to a

criminal violation and mandatory disclosure 197
requirements? Why the entire public and bank money
that is transferred to Power Trust is shown as CSR
funds?
What do you have to say on the point that IPCL's

financial statements for the year 2017-18 show transfers
to the tune of INR 557 crores of public money to Power
trust under the false pretext of purchase of investments?
Power Trust actually received INR 695 crores, which was
further diverted to other shell entities promoted by the
Kanoria brothers. This could also happen because of the
fact that the very auditor itself has also been hand in
What do you have to say on the point that M/S Bhaskar

Silicon Pvt Ltd (BSPL) and its further subsidiary Environ
Energy Corporation Ltd., both loss-making shell
companies of the Kanoria brothers, availed loans to the
tune of INR 2400 crores using SREI Infrastructure
fraudulent documents and these companies further
siphoned INR 1000 crores to Power Trust?
Why has no action been taken when this INR 1000 crore
was routed back to SREI Infrastructure and on a
significant deviation of the company on material
disclosure of information in all of the cases where the
shell entities are actively suppressing facts on terms of
borrowing, terms of repayment and the lending institution
they are borrowing from?

the fact that Kanoria Brothers' agents run Bharat Road
Network Limited (BRNL), along with its subsidiaries,
which are controlled and managed by a common board
of directors and employees from SREI, SREI purchased

shares, that were actually trading at INR 25-40 per share, 198
at a premium of INR 195 per share. This was a smart
move. Now by this illegal step, SREI smartly made the
financials of BRNL 'Green,' thus creating a reserve
surplus for BRNL. A whopping INR 2575 crores public
money was siphoned off under the garb of fake loans. If
you are to trail the end-use of public money, then you will
understand that INR 1114 crores have been further
invested in BRNL subsidiaries, and this information has
been kept under wraps?

the fact that Sahaj E village Limited and its subsidiary
Rural Innovation labs Pvt Limited which are operated by
Kanoria Brothers' agents having zero value in the market
was given INR 1213 crores as a loan at a paltry 6% P. A.
interest as against the regular rate of 18% p.a. these
loans were given on the basis of a cash inflow that never
existed! This act has also generated a notional loss for
SREI to the tune of INR 146 crores per annum. These
illegal financial transactions were merely recorded as
What is your side of a version on the fact that another

shell entity by the name of M/S Swaymbhu Natural
Resources Private Limited, which exists only on papers
as a loss-making company since incorporation, managed
to receive public money-INR 895 crores from SREI of
which INR 346.3 crores was siphoned to Power trust,
with a classic case of fudged books of accounts when it
came to repayment, the Kanoria brothers funded a huge
amount through another entity thus enabling a show of
complete repayment of the loan, In reality, it was just an
eyewash with clear looting?

the fact that M/s Vara Technology Pvt. Ltd. was given 199
INR 138 crores on the basis of fixed assets amounting to
merely INR 3.8 crores by SREI. M/S Vara Infotech
Private Limited, a shareholder in Kanoria Foundation
(SREI owned trust), has also been used by Kanoria
Brothers to siphon off public funds and provide a criminal
advantage to other group companies. The Kanoria
Brothers have, through SREI, given INR 395.1 crores,
which was further routed under the garb of investment to
another entity promoted by the Kanoria brothers - SREI
Alternative Trust. It would be interesting to note that Vara
Infotech Private Limited is a loss-making company, and
this has been documented as 'Future inflow' during the
SREI mortgage, which means that if the company does
not show any profits, the loans will be written off as bad
debt?
How do you see the case of unsecured lending of

Avarsekar Realty Pvt. Ltd., another related company of
the Kanoria group which received INR 118 crores from
SREI without any security whatsoever, M/s Bharat
Nirman Fund promoted by Kanoria Brothers and SREI
Infrastructure were earlier shareholders of Aversekar
Realty and ceased to be shareholders immediately after
the loan was granted to Avarsekar Realty?

the fact that Victor Buildwel Private Limited (VBPL) is
another shell company promoted by the Kanoria
Brothers' SREI Alternative Trust (SAT), They have shown
an inventory of INR 17.3 crores as land in Greater Noida,
UP. Here again, the Kanoria brothers funnelled INR 70
crores against a non-existent property?

the fact that Attivo Economic Zones Private Limited,
another company promoted by Kanoria Brothers' SREI

Alternative Investment Trust- Bharat Nirman Fund. Attivo 100
received INR 2207 crores from SREI, and INR 240
crores were routed to Power trust. This transaction was
left out from the company balance sheet so that no
questions could be raised. The balance amount was
completely misused. The modus operandi has been that
a company has no verified assets, negative net worth,
and is a loss-making company as shown on books of
accounts and exists merely on paper?
Why such huge public money was lent to Kanoria Family

run entity to misappropriate public money as in the case
of M/s I log Ports Private Limited, another shell company
of the Kanoria brothers showed land worth INR 300
crores on their books. As per field verification, the land is
not even close to being pegged at INR 3 crores. The
company, without even mortgaging this land were able to
source INR 585 crores of public funds through SREI; in
order to evade taxes, the company has misrepresented
financial statements by capitalizing all its expenses
showing no revenue expenses?
the Predicate Consultants Private Limited (PCPL), which
is again promoted by the Kanoria brothers incorporated
in 2014 as a financial consultancy. Mr. Tapas
Chakraborty, a shareholder at PCPL who also holds a
key role at SREI, was given INR 375 crores, from which
INR 138 crores was further transferred to Power trust!
This is merely the tip of the iceberg with so many shell
companies created as a medium to funnel funds to the
tune of INR 16000 crores?
Please also reply saying that have you investigated the

fact of how much public money the Kanoria family has
201
The Kanoria Family has been running this criminal
syndicate of window dressing for many years; why did
you not take any action so far?
The Kanoria Family's political influences are known to all;

is it this reason which prevented you from taking action
so far, and thus you kept your eyes closed?
What actions does your good office purpose to take

against the respective bank officials who deliberate kept
the eyes closed and kept on lending public money to
cause criminal gains to Kanroria Brothers family on the
basis of bogus and sham documentations?
The Kanoria Brothers have also tried to induce and

intimidate the ScamsBreaking.com; what is the policy of
your good office to keep such whistle-blowers
indemnified from such intimidations?
Please also note that we have conducted this

expose on our responsibility, and we will not leave
this case to go in junk and so we will keep
extremely strict follow-ups to make sure that guilty
is taken to justice.
We are ready to assist your good office further, if

you need more assistance from us.
Thanking You !
Sd/-
Chief Officer
202
Legal Compliances
ScamsBreaking.com
Mascot Sydney -2020
Follow us on:
Follow us on:
"Don't print this email unless you really need to,consider the environment"
Disclaimer:
"This communication /e-mail/attachment/s / file/s are privileged and confidential, and is directed to the addressee
for the use of the addressee only. If this communication /e-mail/attachment/s / file/s reaches anyone other than the
intended recipient, we request the reader not to reproduce, copy, disseminate or in any manner distribute it. We further
request such recipient to notify us immediately by return email and delete the original message. Please note that any views
or opinions presented in this email are solely those of the author and do not necessarily represent those of the company.
The Company does not guarantee and shall neither be liable for security of any information transmitted electronically nor
be liable/responsible for the proper, timely and complete transmission thereof.."
Document No- 34
203
Sent: Monday, January 18, 2021 12:23 PM
To: narendramodi1234@gmail.com; connect@mygov.nic.in; pkmishra.pmo@gov.in; rsecy@nic.in; s
ecy-ca@nic.in; hshso@nic.in; secy-
dea@nic.in; appointment.fm@gov.in; amitshah.bjp@gmail.com; amitshah.mp@sansad.nic.in
Cc: dgpwestbengal@gmail.com; cp@kolkatapolice.gov.in; cyberps@kolkatapolice.gov.in; Shiv
Raman-Head (AsiaPacific)
<head.asiapacific@scamsbreaking.com>; hemant@kanoriafoundation.co.in; hemant@srei.com; sunil
@kanoriafoundation.co.in; sunil@srei.com; shounak.mitra@khaitanco.com; corporate@srei.com; sec
retarial@srei.com; corporate@srei.com; gpa@cal.vsnl.net.in; corporate@indiapower.com; info@bhar
atpay.co.in; sujitkanoria@bharatconnect.com; bohyderabad@rbi.org.in; ccasansol@indiapower.com;
cybercrimegb-up@nic.in; cmup@nic.in; uttam.nahta@mca.gov.in; dgp@up.nic.in
Subject: Legal Compliances’ Pursuance mail | Kanoria Brothers| Scam of 2020
Importance: High
To,
Sh. Narendra Modi
The Hon’ble Prime Minister of India
Sh. Amit Shah

The Hon’ble Home Minister of India
The Hon’ble Minister

Ministry of Corporate affairs
The Hon’ble Minister,

Ministry of Finance
Dr. P. K. Mishra, Principal Secretary

To The Prime Minister of India
Shri Rajesh Verma, Secretary

Ministry of Corporate affairs
204
Shri A.B.P. Pandey, Revenue Secretary
Ministry of Finance, Government of India
New Delhi (India)
Shri Tarun Bajaj, Secretary-Economic Affairs

Ministry of Finance, Government of India
New Delhi (India)
Sh. Ajay K. Bhalla

Union Home Secretary
Hon’ble Prime Minister Sir and Other

Respected Dignitaries,
Please refer to our exclusive investigative

news report submitted to your office,
followed by an expose commenced via
worldwide webcast on 14th of December
2020.
It has been more than 30 days, and

now we are going ahead with a second
round of expose on Kanoria Brothers and
their yet more criminal conducts with the
Indian government and foreign connection,
and now for the very same purpose, we
would like to know your side of a version and
action taken on expose, as we are sure that
entire India now wants at least a healthy
investigation on our report. However,
ScamsBreaking.com challenges that even a
single fact as detailed below, if it comes to
205
even slightly less true, we will take the
Please appreciate below our pointwise

specific issues on which we need your version
and action taken report so that the same
Can be the part of our next expose Part-2. i.e.
:-
 What action your good office has taken

on the fact that the Kanoria Family
created countable bogus entities, and
Power Trust was one of them. The
Power Trust is a registered trust at
Kolkata in the state of West Bengal and
run by Kanoria Brothers' agents, and
yet the Kanorias dare to call it Public
Trust. How did this happen? Why did
your good office not taken action on
such a sham entity, which was used
merely to siphon off the public money?

on the fact that the Kanoria Brothers
Family set up a public trust by the
name of Power Trust, which has been
used as the criminal purposes vehicle
to siphon off the funds. The scam has
been pulled off mainly by sanctioning
and disbursing huge amounts in the
secured and unsecured transfer of
funds to bogus and dubious shell
companies on the basis of sham
documentation, duly promoted by the
Kanoria brothers. These companies
206
have, in turn, passed the money back
either to Power Trust or to other bogus
entities, which have amounted to
money laundering, cheating, tax
evasion, and various other substantive
offenses thereof. The
ScamsBreaking.com has collected
substantial documentary evidence,
which has been submitted to the
Indian law enforcement agencies for
further investigations. The Kanoria
brothers had criminally setup the Power
Trust as a public trust, which only had
people from the Kanoria business
enterprises on the board of trustees.
The board has Mr. Dipak Rudra, who is
the director of IPCL, Mr. Ajay Kumar
Agarwal – statutory auditor for the SREI
group of companies, he is also the
director of Shristi Infrastructure, which is
the SREI promoted entity. Mr. Shounik
Mitra, a lawyer by profession who has
been representing the SREI group of
companies as their legal counsel on
various legal cases. Please suggest that
how such agents of Kanoria Family are
allowed to operate criminal entities just
to park the black money of Kanoria
Brothers and thereby causing
substantive undue criminal gains to
Kanoria Family?

on the fact that the Power Trust has
agents or employees of the Kanoria
207
group, whereas a public trust should be
governed by independent and
unrelated individuals from the public
space. The official claim of the Kanoria
brothers has been that Power Trust runs
as an independent trust, thus having
an independent board of trustees and
a minimum shareholding from the
public; this was accounted for less than
25%. The chief function of the trust has
been to only transfer funds?
 Further, what do you have to say on the

point that the way the fraud has been
committed, India Power Corporation
Limited (IPCL) transfers funds to Power

point that these public funds are then
further transferred to another Kanoria
shell entity? There has been a transfer
of more than INR 3500 crores between
SREI and IPCL via various shell
companies, which have been
concealed in all financial statements of
the companies. Why has no action
been taken so far in this regard?
 What do you have to say on the point

that between IPCL and SREI are related
party transactions (RPT's) which have
been deliberately concealed,
amounting to a criminal violation and
mandatory disclosure requirements?
208
Why the entire public and bank money
that is transferred to Power Trust is
shown as CSR funds?

that IPCL's financial statements for the
year 2017-18 show transfers to the tune
of INR 557 crores of public money to
Power trust under the false pretext of
purchase of investments? Power Trust
actually received INR 695 crores, which
was further diverted to other shell
entities promoted by the Kanoria
brothers. This could also happen
because of the fact that the very
auditor itself has also been hand in

that M/S Bhaskar Silicon Pvt Ltd (BSPL)
and its further subsidiary Environ Energy
Corporation Ltd., both loss-making shell
companies of the Kanoria brothers,
availed loans to the tune of INR 2400
crores using SREI Infrastructure
fraudulent documents and these
companies further siphoned INR 1000
crores to Power Trust?
 Why has no action been taken when this

INR 1000 crore was routed back to SREI
Infrastructure and on a significant
deviation of the company on material
disclosure of information in all of the
cases where the shell entities are
209
actively suppressing facts on terms of
borrowing, terms of repayment and the
lending institution they are borrowing
from?
 Why did your good office not examine

and investigate the fact that Kanoria
Brothers' agents run Bharat Road
Network Limited (BRNL), along with its
subsidiaries, which are controlled and
managed by a common board of
directors and employees from SREI, SREI
purchased shares, that were actually
trading at INR 25-40 per share, at a
premium of INR 195 per share. This was
a smart move. Now by this illegal step,
SREI smartly made the financials of
BRNL 'Green,' thus creating a reserve
surplus for BRNL. A whopping INR 2575
crores public money was siphoned off
under the garb of fake loans. If you are
to trail the end-use of public money,
then you will understand that INR 1114
crores have been further invested in
BRNL subsidiaries, and this information
has been kept under wraps?

and investigate the fact that Sahaj E
village Limited and its subsidiary Rural
Innovation labs Pvt Limited which are
operated by Kanoria Brothers' agents
having zero value in the market was
given INR 1213 crores as a loan at a
paltry 6% P. A. interest as against the
210
regular rate of 18% p.a. these loans
were given on the basis of a cash
inflow that never existed! This act has
also generated a notional loss for SREI
to the tune of INR 146 crores per
annum. These illegal financial
transactions were merely recorded as
 What is your side of a version on the fact

that another shell entity by the name of
M/S Swaymbhu Natural Resources
Private Limited, which exists only on
papers as a loss-making company
since incorporation, managed to
receive public money-INR 895 crores
from SREI of which INR 346.3 crores was
siphoned to Power trust, with a classic
case of fudged books of accounts
when it came to repayment, the
Kanoria brothers funded a huge
amount through another entity thus
enabling a show of complete
repayment of the loan, In reality, it was
just an eyewash with clear looting?

and investigate the fact that M/s Vara
Technology Pvt. Ltd. was given INR 138
crores on the basis of fixed assets
amounting to merely INR 3.8 crores by
SREI. M/S Vara Infotech Private Limited,
a shareholder in Kanoria Foundation
(SREI owned trust), has also been used
by Kanoria Brothers to siphon off public
211
funds and provide a criminal
advantage to other group companies.
The Kanoria Brothers have, through
SREI, given INR 395.1 crores, which was
further routed under the garb of
investment to another entity promoted
by the Kanoria brothers - SREI
Alternative Trust. It would be interesting
to note that Vara Infotech Private
Limited is a loss-making company, and
this has been documented as 'Future
inflow' during the SREI mortgage, which
means that if the company does not
show any profits, the loans will be
written off as bad debt?
 How do you see the case of unsecured

lending of Avarsekar Realty Pvt. Ltd.,
another related company of the
Kanoria group which received INR 118
crores from SREI without any security
whatsoever, M/s Bharat Nirman Fund
promoted by Kanoria Brothers and SREI
Infrastructure were earlier shareholders
of Aversekar Realty and ceased to be
shareholders immediately after the
loan was granted to Avarsekar Realty?

and investigate the fact that Victor
Buildwel Private Limited (VBPL) is
another shell company promoted by
the Kanoria Brothers' SREI Alternative
Trust (SAT), They have shown an
inventory of INR 17.3 crores as land in
212
Greater Noida, UP. Here again, the
Kanoria brothers funnelled INR 70 crores
against a non-existent property?

and investigate the fact that Attivo
Economic Zones Private Limited,
another company promoted by
Kanoria Brothers' SREI Alternative
Investment Trust- Bharat Nirman Fund.
Attivo received INR 2207 crores from
SREI, and INR 240 crores were routed to
Power trust. This transaction was left out
from the company balance sheet so
that no questions could be raised. The
balance amount was completely
misused. The modus operandi has
been that a company has no verified
assets, negative net worth, and is a
loss-making company as shown on
books of accounts and exists merely on
paper?
 Why such huge public money was lent

to Kanoria Family run entity to
misappropriate public money as in the
case of M/s I log Ports Private Limited,
another shell company of the Kanoria
brothers showed land worth INR 300
crores on their books. As per field
verification, the land is not even close
to being pegged at INR 3 crores. The
company, without even mortgaging
this land were able to source INR 585
crores of public funds through SREI; in
213
order to evade taxes, the company
has misrepresented financial
statements by capitalizing all its
expenses showing no revenue
expenses?

on the fact that the Predicate
Consultants Private Limited (PCPL),
which is again promoted by the
Kanoria brothers incorporated in 2014
as a financial consultancy. Mr. Tapas
Chakraborty, a shareholder at PCPL
who also holds a key role at SREI, was
given INR 375 crores, from which INR
138 crores was further transferred to
Power trust! This is merely the tip of the
iceberg with so many shell companies
created as a medium to funnel funds
to the tune of INR 16000 crores?
 Please also reply saying that have you

investigated the fact of how much
public money the Kanoria family has
 The Kanoria Family has been running this

criminal syndicate of window dressing
for many years; why did you not take
any action so far?
 The Kanoria Family's political influences

are known to all; is it this reason which
prevented you from taking action so
214
far, and thus you kept your eyes
closed?
 What actions does your good office

purpose to take against the respective
bank officials who deliberate kept the
eyes closed and kept on lending public
money to cause criminal gains to
Kanroria Brothers family on the basis of
bogus and sham documentations?
 The Kanoria Brothers have also tried to

induce and intimidate the
ScamsBreaking.com; what is the policy
of your good office to keep such
whistle-blowers indemnified from such
intimidations?
Please also note that we have

conducted this expose on our
responsibility, and we will not leave this
case to go in junk and so we will keep
extremely strict follow-ups to make sure
that guilty is taken to justice.
We are ready to assist your good

office further, if you need more
assistance from us.
Thanking You !
Sd/-
Chief Officer
215
Legal Compliances
ScamsBreaking.com
Mascot Sydney -2020
216
To: director@sfio.nic.in
<head.asiapacific@scamsbreaking.com>; kahnoiabros@yahoo.co.in; hemant@kanoriafoundation.co.i
n; hemant@srei.com; sunil@kanoriafoundation.co.in; sunil@srei.com; shounak.mitra@khaitanco.co
m; corporate@srei.com; secretarial@srei.com; corporate@srei.com; gpa@cal.vsnl.net.in; corporate@i
ndiapower.com; info@bharatpay.co.in; sujitkanoria@bharatconnect.com; cp-
pol.gb@up.gov.in; addcp-pollo.gb@up.gov.in; addcp-polhq.gb@up.gov.in; dcp-
polhq.gb@up.gov.in; dgp@up.nic.in; adglo.up@nic.in; atodgp@up.nic.in; dgpcontrol-
up@nic.in; digcomplaint-up@nic.in; adglo@up.nic.in; igadmin-up@nic.in; csup@nic.in; Shiv
<head.asiapacific@scamsbreaking.com>; hgovup@gov.in; psrajbhavan@mp.gov.in; lokayukta@hot
mail.com; lokayukta@up.nic.in; bohyderabad@rbi.org.in; ccasansol@indiapower.com
Subject: Re: Legal Actions follow Up mail-1| Kanoria Brothers| Scam of 2020
Importance: High
Urgent Legal Matter
To,
THE DIRECTOR
SERIOUS FRAUD INVESTIGATION OFFICE
GOVERNMENT OF INDIA
NEW DELHI
Dear Sir,
This is a legal actions follow up mail seeking

the status report on the actions taken by your
good office on our exclusive investigative
2020.
As we are all set to proceed with a

second round of expose on Kanoria Brothers
and their yet more criminal conducts with the
217

can be the part of our next expose Part-2.
i.e.:-


218
219
Kanoria Family?



220
shown as CSR funds?


221
from?


222


223

224

paper?

225
expenses?



226
any action so far?

closed?


intimidations?

227
We are ready to assist your good office
further, if you need more assistance from
us.
Thanking You !
Sd/-
Chief Officer
Legal Compliances
ScamsBreaking.com
Mascot Sydney -2020
228
To: director@cbi.gov.in; information@cbi.gov.in; hozdel@cbi.gov.in
<head.asiapacific@scamsbreaking.com>; kahnoiabros@yahoo.co.in; hemant@kanoriafoundation.co.i
n; hemant@srei.com; sunil@kanoriafoundation.co.in; sunil@srei.com; shounak.mitra@khaitanco.co
m; saikat.bardhan@indiapower.com; corporate@srei.com; secretarial@srei.com; corporate@srei.com
; gpa@cal.vsnl.net.in; corporate@indiapower.com; info@bharatpay.co.in; sanjay.chaurasia@varaunit
ed.com; sujitkanoria@bharatconnect.com; sanjeev.seth@ipclindia.com; bohyderabad@rbi.org.in; cca
sansol@indiapower.com
Subject: Please refer to our exclusive investigative news report submitted to your office, followed by
an expose commenced via worldwide webcast on 14th of December 2020.
Importance: High
Extremely Urgent Legal Matter
To,
The Director
Central Bureau Of investigation
Government of India
New Delhi
Dear Sir,
Please refer to our exclusive investigative

2020.
It has been more than ten days, and

now we are going ahead with a second
round of expose on Kanoria Brothers and
their yet more criminal conducts with the
229

can be the part of our next expose Part-2.
i.e.:-


230
Kanoria Family?
231




232
shown as CSR funds?



233
from?


234


235


236

paper?

237
expenses?



any action so far?
238
closed?


intimidations?

We are ready to assist your good office

further, if you need more assistance from
us.
Thanking You !
239
Sd/-
Chief Officer
Legal Compliances
ScamsBreaking.com
Mascot Sydney -2020
Copy to-:
1. The, DGP, West Bengal

2. The Commissioner of Kolkata Police
3. The Head, Cyber Cell, Kolkata Police
4. M/S SREI Infrastructure Finance Limited
5. M/S SREI Equipment Finance Ltd.
6. M/S India Power Corporation Ltd
7. M/S Power Trust
8. M/S Kanoria Foundation
9. Mr. Hari Prasad Kanoria
10. Mr. Hemant Kanoria
11. Mr. Raghu Raj Kanoria
12. Mr. Sunil Kanoria
13. Mr. Sujit Kanoria
14. Ms. Champa Kanoria
15. Mr. Dipak Rudra
16. Mr. Ajay Kumar Agarwal
17. Mr. Shounik Mitra
18. Mr. Srinivasachari Rajagopal
19. Ms. Punita Kumar Sinha
20. Mr. Malay Mukherjee
21. Mr. Shyamlendu Chatterjee
22. Mr. Tamali Sengupta
240
23. M/S
Kanoria Brothers and its other
accomplice
1/20/2021 Company Master Data
Document No- 35
Company Master Data
241
CIN L29219WB1985PLC055352
Company Name SREI INFRASTRUCTURE FINANCE LIMITED
ROC Code RoC-Kolkata
Registration Number 055352
Company Category Company limited by Shares
Company SubCategory Non-govt company
Class of Company Public
Authorised Capital(Rs) 15000000000
Paid up Capital(Rs) 5030863330
Number of Members(Applicable in case of
0
company without Share Capital)
Date of Incorporation 29/03/1985
VISHWAKARMA,86C,TOPSIA ROAD (SOUTH),
Registered Address
KOLKATA WB 700046 IN
Address other than R/o where all or any books of
-
account and papers are maintained
Email Id secretarial@srei.com
Whether Listed or not Listed
ACTIVE compliance ACTIVE compliant
Suspended at stock exchange -
Date of last AGM 19/09/2020
Date of Balance Sheet 31/03/2020
Company Status(for efiling) Active
Charges
Charge Date of Date of
Assets under charge Status
Amount Creation Modification
Book debts 1000000000 17/11/2006 - CLOSED
Book debts; Movable property (not being pledge) 1000000000 29/07/2009 - CLOSED
Movable property (not being pledge) 14441500 26/02/2005 - CLOSED
2000000000 03/05/2013 18/03/2015 CLOSED
Book debts; Floating charge; Movable property (not being
1400000000 25/06/2014 - CLOSED
pledge)
6150000 15/08/2003 - CLOSED
4100000 01/11/2003 - CLOSED
127500000 29/04/2005 - CLOSED
www.mca.gov.in/mcafoportal/companyLLPMasterData.do 1/9
Book debts; Movable property (not being pledge) 650000000 29/04/2002 09/01/2006 CLOSED
Book debts 1000000000 10/07/2012 - 242
CLOSED
Book debts; Floating charge 50000000 23/11/2006 - CLOSED
600000000 08/09/1999 10/02/2007 CLOSED
5000000000 10/03/2011 29/12/2011 CLOSED
1000000000 07/02/2011 29/12/2011 CLOSED
Movable property (not being pledge) 572710086 23/07/2009 - OPEN
47925004 15/01/2005 - CLOSED
1328601 15/04/2003 - CLOSED
Book debts; Movable property (not being pledge) 350000000 17/04/2007 - OPEN
2000000000 22/12/2017 - OPEN
pledge)
Immovable property or any interest therein 190000000 16/12/2014 - OPEN
971814000 23/01/2012 28/03/2014 OPEN
Book debts 500000000 06/12/2006 - OPEN
5500000000 18/03/2011 28/11/2011 CLOSED
1750000000 23/06/2009 - CLOSED
pledge)
Book debts 200000000 23/03/2009 - OPEN
Book debts 2000000000 13/08/2007 - OPEN
1700000000 04/02/2003 28/05/2007 OPEN
Book debts 500000000 27/10/2014 - OPEN
2750000000 30/03/2011 02/03/2012 CLOSED
Book debts 50000000 04/01/2007 - OPEN
410000000 20/07/2001 28/06/2007 CLOSED
Immovable property or any interest therein; Book debts 2000000000 23/01/2012 - CLOSED
1600000000 20/03/2013 18/03/2014 CLOSED
1/20/2021 Company Master Data 243
Immovable property or any interest therein; Book debts 2000000000 07/12/2011 - OPEN
3598000 15/04/2003 - CLOSED
100000000 05/02/2003 22/05/2003 CLOSED
12523500000 11/09/2001 06/09/2006 CLOSED
1050000000 20/08/2004 20/02/2007 CLOSED
Immovable property or any interest therein 1635426000 31/07/2015 - CLOSED
1000000000 14/01/2011 - CLOSED
pledge)
2000000000 23/06/2009 19/09/2011 CLOSED
22590000 11/08/2006 - OPEN
Book debts; Floating charge 1000000000 17/09/2015 - OPEN
Book debts 45000000 12/10/2004 - OPEN
4244575 16/01/2005 - CLOSED
Book debts; Movable property (not being pledge) 501000000 28/12/1994 29/03/2005 OPEN
500000000 05/12/2009 25/01/2011 CLOSED
16942500 30/08/2006 - OPEN
Immovable property or any interest therein 3261431000 17/11/2014 - CLOSED
780000000 11/03/2008 - OPEN
pledge)
300000000 29/12/2000 01/02/2007 CLOSED
Book debts 50000000 24/12/2003 29/11/2006 CLOSED
2300000000 24/01/2007 - OPEN
Book debts 330000000 19/02/2008 - OPEN
1000000000 28/03/2013 15/11/2014 CLOSED
Book debts 3000000000 28/09/2015 - OPEN
300000000 10/02/1999 18/04/2007 CLOSED
2250000000 09/02/2009 29/03/2010 CLOSED
570000000 11/08/2000 28/06/2007 OPEN
2000000 14/05/2003 - CLOSED
2000000000 03/08/2009 13/09/2011 CLOSED
250000000 07/08/2010 - CLOSED
2000000000 28/10/2015 - OPEN
Book debts 250000000 14/09/2015 - OPEN
2000000000 30/03/2010 - CLOSED
pledge)
1750000000 29/09/2010 29/11/2012 CLOSED
19656108 29/01/2004 - CLOSED
Book debts 3500000 20/09/2004 - OPEN
150000000 28/03/2005 - CLOSED
1000000000 18/03/2014 24/02/2015 CLOSED
4082835 29/09/2006 - OPEN
Immovable property or any interest therein; Movable
1500000000 30/06/2010 - CLOSED
property (not being pledge)
4269600 29/05/2003 - OPEN
300000000 23/05/2008 - CLOSED
pledge)
2500000000 29/12/2011 28/01/2015 CLOSED
90800000000 02/09/2010 30/11/2018 OPEN
pledge)
Immovable property or any interest therein; Book debts;
6000000000 06/03/2014 - CLOSED
Floating charge; Movable property (not being pledge)
1/20/2021 Company Master Data 24 5
150000000 26/10/2007 - CLOSED
Movable property (not being pledge)
1500000000 17/01/2011 30/11/2011 CLOSED
2104000 21/03/2004 - OPEN
250000000 22/02/1999 14/05/2007 CLOSED
100000000 07/06/2004 20/01/2007 CLOSED
1000000000 23/03/2010 - CLOSED
200000000 28/06/2006 - OPEN
Floating charge 25800000 31/03/2007 - OPEN
4740000 31/03/2004 - OPEN
300748302 23/03/2006 17/11/2006 CLOSED
300000000 27/06/2005 - CLOSED
800000000 14/02/2005 21/05/2008 CLOSED
2025000000 27/12/2006 01/06/2009 CLOSED
2000000000 23/12/2009 19/11/2011 CLOSED
680000000 24/02/2012 10/10/2013 CLOSED
730000000 31/08/2007 13/12/2007 CLOSED
2618901 11/07/2003 - CLOSED
Book debts 124000000 19/05/2000 31/03/2004 CLOSED
615000000 03/03/1998 28/06/2007 CLOSED
500000000 09/04/2013 - CLOSED
pledge)
1500000000 04/01/2007 08/10/2007 CLOSED
2250000000 29/03/2006 26/05/2009 CLOSED
2000000000 03/03/2014 - OPEN
500000000 08/08/2013 - CLOSED
pledge)
2000000000 28/06/2013 18/03/2014 CLOSED
17681800 01/09/2006 - OPEN
1000000000 18/03/2011 16/11/2011 CLOSED
8650000000 31/03/1995 31/12/2012 CLOSED
1352800 27/05/2003 - OPEN
900000000 02/12/1999 21/02/2008 CLOSED
500000000 26/02/2008 - CLOSED
pledge)
400000000 29/11/2005 23/04/2007 OPEN
500000000 23/03/2002 31/03/2008 CLOSED
1050000000 14/02/2000 22/02/2007 CLOSED
170000000 27/01/2011 - CLOSED
650000000 20/02/2012 30/09/2015 CLOSED
Goodwill; Book debts; Movable property (not being pledge) 300000000 21/09/2006 - OPEN
2750000000 06/07/2007 19/05/2008 CLOSED
7000000000 29/11/2012 25/03/2014 CLOSED
Book debts 1200000000 14/01/2008 - OPEN
3732600 15/04/2003 - CLOSED
250000000 02/06/2006 - CLOSED
Goodwill; Book debts; Movable property (not being pledge) 300000000 21/09/2006 - OPEN
1/20/2021 Company Master Data 24 5
2250000000 22/12/2006 26/05/2009 CLOSED
800000000 26/12/2005 16/06/2008 CLOSED
3500000000 28/07/2009 27/12/2011 CLOSED
400000000 05/10/1994 02/08/2008 CLOSED
1500000000 29/03/2010 - CLOSED
pledge)
2000000000 26/09/2011 18/03/2014 CLOSED
4362000 15/04/2003 - CLOSED
3786200 15/04/2003 - CLOSED
Book debts 500000000 18/01/2016 - OPEN
8840000 30/08/2006 - OPEN
2000000000 21/07/2008 - OPEN
pledge)
150000000 20/08/2007 - CLOSED
pledge)
200000000 29/04/2006 31/12/2007 CLOSED
2424350 15/07/2003 - CLOSED
1000000000 28/12/2005 28/03/2007 CLOSED
2420000 25/04/2003 - OPEN
3500000000 19/07/2011 28/09/2011 CLOSED
248
550000000 15/07/2004 21/02/2007 CLOSED

Floating charge; Movable property (not being pledge) 1000000000 30/01/2014 - 246
CLOSED
1596435000 08/12/2011 19/11/2012 CLOSED
550000000 17/12/1999 11/03/2006 CLOSED
3000000000 30/12/2008 - CLOSED
pledge)
105000000 12/10/2005 10/11/2006 OPEN
Book debts; Floating charge; As per DOH dated 28.03.2017 1500000000 28/03/2017 - OPEN
As stated in Page 33 under Part B of Schedule I (D 2933636000 07/10/2016 - OPEN
Book debts; Hypo. of receivables of specific assets 1000000000 29/12/2016 - OPEN
2000000000 20/09/2017 - OPEN
pledge)
Book debts; Specific assets for operating lease, lease rentals 1000000000 22/12/2016 - OPEN
Receivables/Rights concerning On-Lending Contracts 1096351500 25/01/2017 - OPEN
Assignment of Rent Receivable 1000000000 17/02/2017 - CLOSED
Book debts; Specific pool of assets and receivables 1000000000 30/12/2016 - CLOSED
Book debts; Documents covering title to goods under LC 500000000 22/02/2017 - CLOSED
As stated in Page 28 under Part B of Schedule I (D 3351778000 28/02/2017 - OPEN
Book debts; Lease Rentals, Hire Purchase & Installments 200000000 18/03/2016 03/05/2017 CLOSED
NA. 3097608000 20/03/2018 - OPEN
existing security 255645482 30/09/2020 - OPEN
Book debts 3000000000 02/08/2018 - OPEN
3500000000 06/02/2019 - OPEN
pledge)
Movable property (not being pledge) 500000000 30/03/2017 15/03/2019 OPEN
1057565000 16/05/2019 - OPEN
Directors/Signatory Details
DIN/PAN Name Begin date End date Surrendered DIN
00022609 SRINIVASACHARI RAJAGOPAL 25/01/2003 -
00048249 SHYAMALENDU CHATTERJEE 29/04/2009 -
AAXPL4123C SANDEEP KUMAR LAKHOTIA 01/02/2005 -
00193015 HEMANT KANORIA 30/10/1990 -

00358658 TAMALI SENGUPTA 04/02/2019 - 249
00416964 RAM KRISHNA AGARWAL 12/05/2016 -
00421564 SUNIL KANORIA 05/07/1989 -
ALWPS5812P SANDEEP KUMAR SULTANIA 05/07/2018 -
02272425 MALAY MUKHERJEE 26/10/2017 -
05229262 PUNITA KUMAR SINHA 20/05/2013 -
ADPPB9322E RAKESH KUMAR BHUTORIA 16/11/2018 -
1/20/2021 Company Master Data Document No- 36
Company Master Data
250
CIN L45203WB2006PLC112235
Company Name BHARAT ROAD NETWORK LIMITED
ROC Code RoC-Kolkata
Registration Number 112235
Company Category Company limited by Shares
Company SubCategory Non-govt company
Class of Company Public
Authorised Capital(Rs) 1000000000
Paid up Capital(Rs) 839500000
Number of Members(Applicable in case of
0
company without Share Capital)
Date of Incorporation 22/12/2006
Plot No. X1-2 & 3, Ground Floor, Block-EP, Sector-V, Salt
Registered Address
Lake City, Kolkata Parganas North WB 700091 IN
Address other than R/o where all or any books of 5B, Vishwakarma, 86C, Topsia Road (South), Kolkata
account and papers are maintained 700046 WB IN
Email Id cs@brnl.in
Whether Listed or not Listed
ACTIVE compliance ACTIVE compliant
Suspended at stock exchange -
Date of last AGM 25/09/2020
Date of Balance Sheet 31/03/2020
Company Status(for efiling) Active
Charges
Charge Date of Date of
Assets under charge Status
Amount Creation Modification
Unattested Indenture of Pledge dated 31.12.2018 1300000000 31/12/2018 - OPEN
750000000 23/12/2013 - CLOSED
500000000 05/08/2014 - OPEN
1400000000 23/04/2013 - CLOSED
pledge)
Pledge of 2,54,97,450 shares of MTPL held by BRNL 1650000000 19/04/2017 - OPEN
1300000000 04/07/2014 - CLOSED
1400000000 25/03/2013 - CLOSED
pledge)
6345700000 12/12/2014 - OPEN
Pledge of shares 11095500000 13/11/2017 - OPEN
Motor Vehicle (Hypothecation); Movable property (not
2700000000 09/01/2018 - OPEN
being pledge)
Unattested Indenture of Pledge dated 29.12.18 2750000000 29/12/2018 - OPEN
Pledge of shares held by BRNL 950000000 31/12/2018 - CLOSED
Pledge of shares and OCPID held by BRNL 1200000000 31/12/2018 - OPEN
Pledge of shares held by BRNL 2250000000 31/12/2018 - CLOSED
Pledge of shares and OCDs held by BRNL 800000000 31/12/2018 - OPEN
Pledge of shares and OCPIDs held by BRNL 550000000 31/12/2018 - OPEN
Pledge of shares and OCPIDs held by BRNL 950000000 29/12/2018 - OPEN
Book debts; Movable property (not being pledge); As per
2000000000 24/03/2020 - OPEN
Sch 1 of DOH
Directors/Signatory Details
DIN/PAN Name Begin date End date Surrendered DIN
00441872 BAJRANG KUMAR CHOUDHARY 23/03/2011 -
00642736 SANTANU RAY 30/07/2019 -
00826834 PRAFUL TAYAL 14/05/2020 -
05308908 BRAHMDUTT 14/05/2020 -
06547361 TUKTUK KUMAR 06/10/2016 -
AGXPB2497B ARINDAM BHOWMICK 24/07/2020 -
AHYPM8893Q NARESH MATHUR 17/12/2017 -
08889866 VIPIN KUMAR SAXENA 25/09/2020 -
1/21/2021 Inappropriate content - Advertising Policies Help
Document No- 37
252
Inappropriate content
Display & Video 360 users must comply with this Google Ads policy. Visit the Display & Video 360 help center for
additional restrictions.
We value diversity and respect for others, and we strive to avoid offending users, so we don’t allow ads or destinations
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IN THE HIGH COURT OF DELHI AT NEW DELHI

(CIVIL ORIGINAL JURISDICTION)

CS(OS) NO.______ OF 2021

IN THE MATTER OF:

International Media Corporation & Ors. ...Defendants

S.NO PARTICULARS PG. NO

S.NO PARTICULARS PG. NO

S.NO PARTICULARS PG. NO

S.N Document Details of Document in Originals or Mode of Line of Pg.

1. INDEX PART -IV 1-6

3. Document Plaintiff No. Plaintiff No. Electronic Registered and Plaintiff

4. Document Plaintiff No. Plaintiff No. Electronic Registered and Plaintiff

5. Document Plaintiffs Plaintiffs Electronic Email issued by Plaintiffs

6. Document Plaintiff and Plaintiffs and Electronic Email issued by Plaintiffs

7. Document Plaintiff and Plaintiff and Electronic Email issued by Plaintiff

8. Document No Plaintiff and Plaintiffs and Electronic Email issued by Plaintiffs

11. Document Plaintiffs Plaintiffs Electronic Email issued by Plaintiffs

13. Document Plaintiffs Plaintiffs Electronic Email issued by Plaintiffs

14. Document Plaintiffs Plaintiffs Electronic Email issued by Plaintiffs

15. Document Plaintiffs Plaintiffs Electronic Email issued by Plaintiffs

16. Document Plaintiffs Plaintiffs Electronic Email issued by Plaintiffs

20. Document Defendant Plaintiffs and Electronic Email issued by Plaintiffs

27. Document Plaintiffs Plaintiffs Electronic Email issued by Plaintiffs

31. Document Plaintiffs and Defendant Electronic Email issued by Defendant

32. Document Plaintiffs and Defendant Electronic Email issued by Defendant

34. Document Plaintiffs and Defendant Electronic Email issued by Defendant

35. Document Plaintiffs and Defendant Electronic Email issued by Defendant

ARJUN SYAL/MANJIRA DASGUPTA/AKSHITA

Place: New Delhi

CS(OS) NO.______ OF 2021

IN THE MATTER OF:

International Media Corporation & Ors. ...Defendants

S.NO PARTICULARS PG. NO

ARJUN SYAL/MANJIRA DASGUPTA/AKSHITA

Place: New Delhi

IN THE HIGH COURT OF DELHI AT NEW DELHI

CS(OS) NO.______ OF 2021

IN THE MATTER OF:

STATUS INVOKED: Suit for permanent and mandatory injunction

Arjun Syal/Manjira Dasgupta/ Akshita Advocates for the Defendants

Advocates for the Plaintiff

E-34, Greater Kailash Enclave II, New

INTERLOCUTORY APPLICATIONS (IAS)

S.No Year Filed by Provisions of Law Nature of Remarks

CS(OS) NO.______ OF 2021

IN THE MATTER OF:

Will you kindly treat the accompanying Suit as an urgent one in

accordance with the High Court Rules and Orders.

The grounds of urgency are mentioned in the accompanying Suit and

ARJUN SYAL/MANJIRA DASGUPTA/AKSHITA

Place: New Delhi

CS(OS) NO.______ OF 2021

IN THE MATTER OF:

The enclosed Suit in the aforesaid matter is being filed on behalf of

the Plaintiff and is likely to be listed on 01.02.2021 or any date thereafter.

Please take notice accordingly.

ARJUN SYAL/MANJIRA DASGUPTA/AKSHITA

Place: New Delhi

15.12.2020 Plaintiff No. 1 filed a complaint dated 15.12.2020 at

Axis Bank by way of a press release dated 15.12.2020

objectionable remarks against the Plaintiffs. The said

Hence the present Suit.

IN THE HIGH COURT OF DELHI AT NEW DELHI

C.S. (OS) No.________ OF 2021

IN THE MATTER OF:

SREI Infrastructure Pvt. Ltd. & Ors. ...Plaintiff

International Media Corporation & Ors. ..Defendants