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INTHE SUPREME COURT OF MAURITIUS {Before the Honourable Judge in Chambers) {Application under Articte 806 of the Code de Procédure Civile) {n the matter of:- Mr Sudarshan Bhadain GCSK, of Avenue |'Quragan, Albion APPLICANT ws 1. THE INDEPENDENT COMMISSION AGAINST CORRUPTION, represented by its Director General, of Reduit Triangle, Moka 2. THE COMMISSIONER OF POLICE, service to be effected at Line Barracks Police Station, Port Louis RESPONDENTS Im the presence of:- THE DIRECTOR OF PUBLIC PROSECUTIONS, service to be effected at Garden Tower, La Poudidre Street, Port Louis CO-RESPONDENT And in the matter of:- EK PARTE: Mr Sudarshan Bhadain GCSK, of Avenue t’Ouragan, Albion APPLICANT }, Sudarshan Bhadain GCSK, a Barristor-at-Law of Avenue L'Ouragan, Albion and tiuider of NIC No. 82504713102669 MAKE SOLEMN AFFIRMATION AS HINDU AND SAY THAT 1. tam the Applicant in the above matter | am a practising Barrister-at-Law and Fellow Chartered Certified Accountant. | was elevated to the rank of Grand Commander of the Star and Key ("GCSK’) by the President of the Republic of Mauritius in March 2016.1 am also the leader of a Political Party, namely the “Reform Party” since January 2017. On the 17" December 2014, | was appointed as Minister of Financial Services, Good Governance and Institutional Reforms. | subsequently chose not to be a Minister in the new government which was formed on 23“January 2017 and resigned my seat in the National Assembly on 23” June 2017, | stood as candidate for the ‘Reform Party’ in the subsequent by-election which were held on 17'December 2017 and in the National Assembly general elections which were held on the 7"November 2019. The Respondent No.1 is a body corporate established under the Prevention of Corruption Act 2002 (“the PoCA”) as an independent commission, which is administered and managed by a Board. Factual Background ~ ‘Request to attend ICAC’ On Friday 7" april 2023, | received a letter signed by Mr P. Aleear, Ag. Assistant Director of investigations, of the Respondent No.1 entitled ‘Request to attend ICAC’. [Annex A] The letter referred to an investigation being conducted pertaining to the appointment of a ‘Consultant’,namely Mr Andrew Jarlath Stephenson, in February 2015 at the Ministry of Financial Services, Good Governance and Institutional Reforms (‘the Ministry’). | was further ‘kindly requested’ to attend the Respondent's No.1 headquarters at Réduit Triangle, on Tuesday 11'"April 2023 at 10.00 hrs for enquiry. Letter of reply to the Respondent's invitation On 10"April 2023, I replied to Mr P. Aleear’s letter explaining, inter alia that: {i) the matter referred to by him, dates back over eight (8) years, which is an abuse of process and | cannot collaborate with his invitation; a 10. uw {i Thad reported Mr Andrew Stephenson publicly a5 @ person who was politically involved in making malicious fake videos to tarnish my Im26e {ii) the invitation of ICAC is driven by political motive and | would be grateful if they would stop their persecution against me, as Leader of the Reform Party: {iv)_more importantly, | drew the attention of Mr P. Aleear to the decision of a full bench of the Supreme Court in the case of Dowarkasing M vICAC [2013] SCI 1384 and the case of Bhadain v ICAC SC! 2005. ‘Annex B and Annex B1 are copies of the said letter dated 10 April 2023 Decision of full bench of Supreme Court in r Dowarkasing M v ICAC [2013] SC) 138A rhe case of Dowarkasing v ICAC clearly explains the legal procedure for the Respondent No.t to follow with regard to a ‘request to attend’ its premises under section 47 of the pach and the application of an ‘order’ under section 50 of the POCA. tn the judgment delivered by Hon. ¥. KJ Yeung Sik Yuen then Chief Justice, and Hon. Late P. Fekna, Judge, the statutory procedure, which is binding on the Respondent No.1, is clearly stated as follows: under section 47, the Respondent may decide to invite @ person to collaborate in its further investigation without any ‘compulsive element underiying the invitotion, A person who does not turn up for a hearing in response to the invitation does not commit any offence.” section 50, in our view, covers a different situation which can be qualified os 0 post-section 47 situation. It is where @ person fails to respond to a request under section 47 that section 50 gathers its importance.” the Respondent is empowered under section 50(1}to direct a number of orders to any person either to attend for the purpose of being examined orally, t produce any book, document, record or article, to provide hard copies 0 information which may be stored in an electronic device, or to furnish a swor written starement of information which may have been required through a notic served on him.” [emphasis added) 12, 13, 14, 15. 16. v7. Leakage of confidential information to the press and media by the Respondent No.1 | state that the Respondent No.1 has never issued any section 50 order for me to be examined or to furnish any written statement, In fact, on Friday 14" April 2023, | was contacted by several journalists and reporters who were briefed by the Respondent No.1. One article amongst many others stated that “Le leader du Reform Party, Roshi Badhain, est recherché par lICAC depuis une semaine pour y étre interrogé.” Another article published by Radio One stated the following “Les enquéteurs chargés des dossiers n’écartent pas l’option de solliciter Vintervention du commissaire de police pour la suite des procedures.” | explained to the journalists and reporters who contacted me, that the Respondent No.1 had sent me a letter requesting me to attend and that | had already replied to them legally in writing on 10" April 2023. | was awaiting to see if they would issue a section 50 order as required by law, to which | would be legally obliged to comply. Events of morning of 18" April 2023 | state that in the morning of 18 April 2023, | was shocked to learn from several journalists and reporters who kept phoning me and asking me for my reaction with regard to the ‘mandat d’arrét’ which had been issued against me. | stated that | was not aware and they told me that | was being ‘activement recherché par la Police’ Defimedia.infopublished an article entitled “Roshi Bhadain recherché par I'ICAC” at around 10.30 hrs and TOP FM Mauritius published an article “Recruitment d’un conseiller en 2015: I'ICAC en présence d’un ordre d’arrestation de Roshi Bhadain”.These articles are annexed and marked as Annex C and Annex D. At around 11 hrs, | was contacted by one SP Gerard a Police officer posted at the Respondent No.1 and he informed me that he had instructions from the Respondent No.2 to come and arrest me if | do not attend the Respondent’s No.1 headquarters. | told him that this approach was not according to law and amounted to a persecution and harassment. | told to SP Gerard that | had written to the Respondent No.1 and no ‘Order’ under section 50 of the PoCA had ever been issued to me.| explained that I was not committing any offence, as held by the Supreme Court in the case of Dowarkasing, which | had referred in my letter to the Respondent No.2 18. SP Gerard told me that he was going to seek instructions from his superiors and to call him back.A few minutes later, | called him to tell him that | will retain the services of Counsel and attend the Respondent's No.1 premises the next day. SP Gerard stated that he had conferred with the Respondent No.1 and if | did not come immediately he would come to arrest me at my place. 19. | then told SP Gerard to give me a couple of hours, to retain the services of Counsel and | would come at around 1 p.m. on the same day, which | did. Events which occurred at ICAC premises 20. I reached the Respondent's No.1 headquarters at around 12.50 p.m. accompanied by my Counsel and was taken to a room where three officers of the Respondent No.1 were present namely, Ag Dep. Director of Investigation, Mr J. Soobrayen, Chief Investigator |. Burkatally, and Investigator M. Purgaus. 21. Lasked them why they wanted me to attend and they inserted an entry in the diary book and informed me as follows: You are informed that you were the then Minister of Financial Services, Good Governance and institutional Reforms from 15.12.2014 to 26.01.2017. As the then Minister in January 2015, it is suspected that you made use of your position of Minister in the appointment of Mr. Andrew Jarlath Stephenson as Consultant at the said Ministry by illegally interfering into the appointment process and which were not done as per proper procedures. As Minister, you have used means and ways and deliberately caused established procedures to be flouted to favour the appointment of Andrew Jarlath Stephenson as Consultant and with whom you were well acquainted. 22. 1 was then cautioned, informed of my Constitutional rights and | was invited fora written statement, to which | replied the following: “ wish to state that the procedure being adopted by the ICAC is contrary to law and in breach of my fundamental rights for a fair enquiry. | wish to state that | received a letter from the ICAC on Friday 7” April 2023, requesting me to attend ICAC on a matter which dated back more than 8 years and which according to the letter had to do with the appointment of a certain Andrew Stephenson as 5 ‘consultant’ at the Ministry of Financial Services, Good Governance and Institutional Reforms in February 2015. I replied in writing to the ICAC by way of letter dated 10 April 2023, where | explained the reasons as to why | cannot collaborate with the Invitation which was sent to me requesting me to attend. in my letter, | drew the ottention of Mr P. Aleear, Ag Assistant Director of investigation of ICAC to the decision of the full bench of the Supreme Court ie IMr Sik Yuen Chief Justice and Mr Fekna Judge in the case of Dowarkasing vs ICAC 2013 SCI 138A Record Number 106926, wherein it is clearly stated that when ICAC conducts a further investigation under POCA, it may decide to invite a person in Its further investigation without any compulsive element underlying the invitation, The judgment clearly states that when a person does not turn up and does not respond to the invitation he does not commit any offence. 1 am now referring the ICAC to Page 3, 3” paragraph of the said judgment. In addition, the last paragraph at page 3 of the said judgment states ‘Section 50, in ‘cur view, covers a different situation which can be qualified as a post-section 47 situation. It is where a person fails to respond to a request under Section 47 that Section 50 gathers its importance. The Respondent (meaning ICAC) is empowered tinder Section 50(1) to direct a number of orders to any person either fo attend for the purpose of being examined orally, to produce any book, document, record ‘or article, to provide hard copies of information which may be stored in an electronic device, or to furnish a sworn written statement of information which may have been required through a notice served on him. | am nol producing a copy of judgment of Dowarkasing, which ICAC is duty bound to follow by law, as sections 47 and 50 of POCA have been interpreted by the Supreme Court of Mauritius. Based on what | have been informed by Mr Soobrayen, | have been invited to give a written statement. | am now asking the ICAC to follow the law and to provide me with a ‘notice which sets ‘out all information’ required from me under the notice, as specifically provided for in the Supreme Court case of Dowarkasing v TCAC and also by the statute which sets up and provides for how ICAC {functions ie. section 50(1)(d) of POCA, in the present circumstances.” 23. Following my statement which was recorded in the Diary Book of the Respondent No.1 by Mr Purgaus, Mr Soobrayen left the Interview Room and informed us that he was going to see the Ag Director General of the Respondent to seek legal advice. eS 24. 25. 26. 27. 28. At 14.20 hrs, Mr Soobrayen came back after his meeting and informed me after inserting an entry in theDiary Book that he had sought advice from the Ag Director General and he was advised that the Supreme Court judgment of Dowarkasing was not applicable in the present matter and that my convocation is under the Judges Rule. | told Mr Soobrayen that the Respondent No.1 could not ignore a judgment of the Supreme Court, Mr Soobrayen then replied that according to him, section 50 orders can be used only for witnesses and not for suspects. | referred him to section 50(2)(4) and explained that it cannot apply only to witnesses. After discussions, weagreed that the matter be referred before the Hon. Judge sitting in Chambers for the issue to be determined. My Counsel then agreed with Mr Soobrayen that an entry be made to that effect in the Diary Book of the Respondent No.1 and | stated as follows: “after having discussed with Mr Soobrayen, in the light of the statement made by Mr Soobrayen, itis therefore agreed as a matter of fairness that the applicability of the decision of the full bench of the Supreme Court in the case of Dowarkasing V/s ICAC has to be determined by the Hon. Judge sitting in Chambers and that the enquiry be put in abeyance until determination by the Supreme Court | hereby undertake to enter an application before the Hon. Judge in Chambers under Article 806 of the Code de Procedure Civile to determine the matter and | shall do so at an earliest convenience...” Mr Soobrayen agreed to the aforementioned statement and informed me that he was going to see SP Gerard to inform him of the agreed course of action as the Respondent No.2 had already issued a ‘mandat d’arrét’ and his representative based at the Respondent No.1 had to be informed. SP Gerard thencame into the interview room for the first time accompanied by Mr Soobrayen and he told me that he had been instructed to arrest me and to lodge a provisional charge. My Counsel invited him to take cognizance and read the entry which had been made in the Diary Book of the Respondent No-1, inasmuch as there has been an agreed course of action, which he was not made aware of. 29. 30. 31. 32. 33. 34, SP Gerard then told me that he had to seek further instructions from the Respondent No.2and left the room. Following this, Mr Soobrayen also left the room to seek instructions from the Ag Director General of the Respondent No.1 who had apparently already left the premises. ‘At some point, there was a confusion as to the course of action to be adopted inasmuch as SP Gerard was making several phone calls and despite our agreed course of action, Mr Soobrayen came back into the room and surprisingly, insisted to proceed with my interviewand record my version of events based on the statement given to them by Mr Stephenson. SP Gerard came back and told me that | had to be arrested and provisionally charged because he had to follow his orders. | explained to him that his course of action would be unlawful as | had not given my version of events to the allegation which had been made against me and he could not have ‘reasonable’ suspicion of an offence having been committed. | further told him that the suspicion had to be unequivocal and could not be the mere suspicion of a Police officer, as held in the case of Manraj v ICAC. SP Gerard then told me that he would allow me to go upon the condition that | give an undertaking to come back to the Respondent's No.1 headquarters on the following day after my professional legal commitments. He then, however, insisted that | would be provisionally charged and would be taken to Court. | insisted that he could not lawfully do that as | had not committed any offence and my version had to be recorded first, after a notice setting out all information required from me is served upon me by the Respondent No.1 under section 50 of the PoCA. Heft the premises of the Respondent No.1 at around 17.19 hrs. 1 was shocked to hear on the MBC news at 19.30 hrs, the erroneous version of Mr Soobrayen was broadcast to the nation at large, with images of me entering the ICAC. The MBC news reporter stated:"/a commission anticorruption c’est donc base sur la procedure a suivre dans ce genre de situation, c'est @ dire sollciter Intervention du commissiare de police pour emmettre un ordre d'arrét, chose faite dans la matinée du 18 avril «. a noter cette précision de lo commission anticorruption, [a section 50 de la PoCA ne s‘applique qu’aux témoins et non pas aux suspects dans ce cas précis ..” 8 35, 36. 37. 38. 39. 40. It was then further stated by the MBC news reporter that: “Cette convocation de Roshi Bhadain c’est fait sous la section 7 du Prevention of Corruption Act “public official using his office for gratification” qui répresente une offence sous la loi.” {never interfered illegally in the appointment of any ‘consultant’ {In fact and in truth, late Mr Somduth Nemchand and Mr Andrew Stephenson were both well acquainted for having worked together at the Respondent No.1 in or about 2003. The Respondent No. 1has heen hiding this crucial fact | am aware that late Mr Somduth Nemchand was the Head of Administration and Secretary of the Commission of the Respondent No.1 and he had negotiated with and appointed Mr Andrew Stephenson as ‘Consultant! at the ICAC. This fact is also well known to the current Director General of Respondent No.1, Mr Navin Beekharry, who was then the Commissioner of ICAC, to whom Mr Andrew Stephenson reported. As far as | recall, in January 2015, Mr Andrew Stephenson had proposed his services to the newly created Ministry.At about the same time, the then Prime Minister and also Cabinet had referred important confidential files on matters which required investigation by the Ministry of Good Governance. In this regard, specialised forensic skills set were required As Mr Andrew Stephenson had proposed his specialist skills and services, late Mr Somduth Nemchand contacted him as he knew him very well and considered his suitability to be appointed ‘Consultant’ at the newly created Ministry.Mr Andrew Stephenson had worked as ‘Consultant’ at the ICAC and had the requisite experience on how to handle sensitive and confidential enquiries, which had important security aspects for the country. | had no objection to his appointment, as | also knew Mr Andrew Stephenson and was aware of hiscompetency in this field, provided that Mr Somduth Nemchand followed the proper procedures which at his level and under his prerogative. | further state that my then office of Minister was not a public office.Section 112 of the Constitution provides that a ‘public office’ shall not be construed as including any office, appointment to which is restricted to members of the National Assembly and | was not a a1. 42, 43 44, 45, 46. 41. 48. ‘public officer’ as provided for in section 111 of the Supreme Law of Mauritius. It was certainly not my role, responsibility or duty to appoint any ‘Consultant’ at the Ministry, ' reiterate that the prerogative of hiring and/or appointing any ‘Consultant’ fell under the responsible public officer at the Ministry, | have never ‘illegally interfered’ into the appointment process of Mr Andrew Stephenson as stated to me by the Respondent No.1 If the appointment process of Mr Andrew Stephenson was not done ‘as per proper Procedures’ as alleged by the Respondent No.1, it falls under the responsibility of the relevant public officers, i.e. late Mr Somduth Nemehand and Mr Ram Prakash Nowbuth who was the Permanent Secretary, who ought to have ensured that proper procedures were indeed followed. In early February 2015, | had been in office for six weeks and the Ministry was a newly created one. | was told by the public officers, late Mr Somduth Nemchand and Mr Ram Prakash Nowbuth, that the appointment for a consultant and/or legal adviser in a Ministry is not advertised publicly. {In fact and in truth, it was these public officers who consulted the Prime Minister's Office and the Ministry of Finance for the properguidance and procedures to follow and they acted accordingly. There must be records of those consultations at the PMO and the relevant Ministries. | further state that it is not the duty of the Minister to go into these details and verify same, as these public officers were experienced officers who know how to do their job best. |tis impossible for me to even find out about the appointment process of Mr Andrew Stephenson as Mr Somduth Nemchand has passed away in year 2018 and I do not have access to the records and the documents of the Ministry. The investigation being conducted by the Respondent No.1 is illfounded both in law and on the facts and | am being harassed by the Respondents to provide explanations on a matter which | am not privy to and which dates back over eight years. Need for Urgent Intervention of the Honourable Judge in Chambers The above matters, facts and circumstances clearly demonstrate that the Respondents. are acting in an illegal manner in breach of the provisions of the PoCA and they are 10 49. 50. 5; determined to unfairly lodge a provisional charge against me in breach of section 10 of the Constitution The acts and doings of the Respondents will cause serious prejudice to me, both in my capacity as leader of a political party and as a practising Barrister-at-Law. Such prejudice cannot be compensated in damages. The balance of convenience clearly lies in my favour and the urgent intervention of the Honourable Judge sitting in Chambers is therefore required, That in the circumstances and in order to protect my rights, itis therefore urgent and necessary that: A An interim order in the nature of an injunction be issued restraining and Prohibiting the Respondent No.1 either by itself or through any préposé or any Person acting or purporting to act under the Respondent No.1 from acting ultra vires the provisions of the Prevention of Corruption Act and in breach of section 10 of the Constitution following ICAC’s letter dated 6 April 2023 and proceeding with my interview under FIR 666/15 without having first obtained prior legal advice to that effect from the Co-Respondent and the hearing and determination Of my intended application by Motion to the Supreme Court for leave to apply for a judicial review of the decision and decision making process of the Respondents, including the warrant of arrest issued by the Respondent No.2 at the request of Respondent No.1, and An interim order in the nature of an injunction restraining and prohibiting the Respondent No.2 either by itself or through any préposé or any person acting or Purporting to act under the Respondent No.2 from arresting or detaining me and from lodging any provisional charge against me without having first obtained prior legal advice to that effect from the Co-Respondent and the hearing and determination of the my intended application by Motion to the Supreme Court for leave to apply for a judicial review of the decision and decision making process of the Respondents, including the warrant of arrest issued by the Respondent No.2 at the request of Respondent No.1, a ona date and hour to be fixed in such Summons to show cause, if any, as to why the Interim order in the nature of an injunction should not be converted into an interlocutory order of injunction pending the hearing and determination of my intended application by Motion to the Supreme Court for leave to apply for a judicial review of the decision and decision making process of the Respondents, including the warrant of arrest issued by the Respondent No.2 at the request of Respondent No.1 In the alternative D, Should the Honourable Judge in Chambers decline to grant the orders prayed for at Paragraphs A, B and C above, the Applicant then prays for a Summons to be sued ealing upon the abovenamed Respondents and Co-Respondent to be and appear before the Honourable Judge sitting in Chambers on a date and hour to be fixed in such Summons to show cause, if any, as to why an Interlocutory Order of Injunction should not be issued restraining and prohibiting, (0) Respondent No.2 either by itself or through any préposé or any person acting OF purporting to act under the Respondent No.1 from acting ultra vires the provisions of the Prevention of Corruption Act and in breach of Section 10 of the Constitution following ICAC’s letter dated 6 April 2023 and proceeding with my interview under FIR 666/15 without having first obtained prior legal advice to that effect from the Co-Respondent and the hearing and determination of my intended application by Motion for leave to apply for a judicial review of the decision and decision making Process of the Respondents, including the warrant of arrest issued by the Respondent No.2 at the request of Respondent No.1; and Ail) Respondent No.? either by itself or through any préposé or any person acting oF purporting to act under the Respondent No.2 from arresting or detaining me and from lodging any provisional charge against the applicant without having first obtained prior legal advice to that effect from the Co-Respondent and the hearing and determination of my intended application by way of Motion to the Supreme Court for leave to apply for a judicial review of the decision and decision making process of 2 52. 53. the Respondents, including the warrant of arrest issued by the Respondent No.2 at the request of Respondent No.1, | undertake to provide such security as the Court may deem fit, in the event that the Court’s ruling lies against me, | pray accordingly, SOLEMNLY AFFIRMED BY THE ABOVENAMED DEPONENT, CHAMBERS NEW COURT HOUSE, PORT-LOUIS, THIS DAY OF APRIL, 2023 Drawn up py me Beto) A Yash BACGOBIN Attornéy-at-Law ti elpal Court Officer This is to certify that this affidavit will form part of an application to be entered before the Honourable s0dge in Chambers CHES Yash BALGQBIN Attorney-at-Law 2B ve ese Ho ICAC inoerenvent commissio! AGAINST CORRUPTION : é Ref: ICAC/FIR/666/15 Mr. Sudarshan BHADAIN € On Aver Ouragan Avene Alou): 06 April 2023, Sir Request to attend ICAC ‘The Corruption Investigation Division of the Commission is conducting an investigation pertaining to the appointment of Mr Andrew Jarlath Stephenson a5 Consultant at the Ministry of Financial Services, Good Governance and Institutional Reforms in February 2015. In this context, you are kindly requested to attend ICAC Headquarters, Reduit Triangle, Moka on Tuesday 11° April 2023 at 10.00 am for enquiry You may be assisted by Counsel. For any query, please contact ASP Burkatally on 402-6651. Yours faithfully P. Alecdt Ag, Assistant Director of Investigations Rone ROSHI BHADAIN, acsx BARRISTER-AT-LAW 10" April 2023 MrP. Alcear AB. Assist Reduit Triangle Moka Dear Mr Allear, Re: Your Request to Attend Sour Request to Attend {am informed that your invitation is ctiven by political motive and 1 would be grateful if you Could stop your persecution, politcal Wendt and harassment against me as the Leader of the Reform Party You may wish to note that 1 have "Ported Mr Stephenson publicly as a Person who was Politically involved i making malicious fake videos to tumien my image, Your lever states that the matter "aarding Mr Stephenson dates back over 8 years which is ‘an abuse of process and I cannot colt laborate with your invitation, Accordingly, your attention is drawn to the decision of a full bench of the Supreme Court in the case of Dowarkasing Mv 1c ‘AC (2013 SCJ 138A] and also the ase of Bhadain v [CAC [SCI 2005}, Yours faithfully, Mr Sudarshan Bhadain, GCSK FOC A | L.B(Hon) ROSHI BHADAIN, Gcsk BARRISTER AT LAW 9 1 Apel MEP Aloear Me Acntant Dinstor ot tivesty Independent Commission Against ¢ orruption TOAC Headguatery Rodut Inangle Moka Dear Mr Aticar, Re: V aur Request ty Attend Ac taur Requestto Attend Tam informed that your inv status Ould Stop OU pers uit the Retorm Party, S deen by politcal mouse and t Would be eratetul you 1 SerMetta and harassin eT against Me as the Leader ot Vou may wish to note that I have Feported Mr Stephenson Publicly as a person who was Politically involved in making malici 1s fake videos to tamish my image. Accordingly. your attention is drawn to the decision of a full bench of the Supreme Court in ‘Be case of Dowarkasing Mv ICAC [2013 SCJ 1384) and also the case of Bhadain v ICAC ‘Yours taithtully, Recah caters lou) aa MY Sudatan Bhadain, GeSk FCA Lt ton Reeve oS fos uk hee ab ren, n - ie slap Bus teatanty yo Defimedia.info e Q a . Eo About Videos More v 14)ou) Defimedia. info Roshi Bhadain recherché par Mleac Sharac TOP Fy Mauritius Oa. More + & lau About oS TOP Fy Mauritius ~ Ith.6 BREAKING NEws Videos Recruteme dunco Nseiller €n 2015: :L'ICAc en Présence d'un Ordre q': arrestation N de Roshj Bhadain: Plus de tails Sur ;

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