La commission anticorruption n'a pas tardé à réagir après la déclaration de Roshi Bhadain. Dans un communiqué émis cet après-midi, l'ICAC parle d'un « arrest of order » du Commissaire de police et non d'un mandat d'arrêt.
Original Title
Bhadain v ICAC (Application Under Article 806 of the Code de Procedure Civile) 190423
La commission anticorruption n'a pas tardé à réagir après la déclaration de Roshi Bhadain. Dans un communiqué émis cet après-midi, l'ICAC parle d'un « arrest of order » du Commissaire de police et non d'un mandat d'arrêt.
La commission anticorruption n'a pas tardé à réagir après la déclaration de Roshi Bhadain. Dans un communiqué émis cet après-midi, l'ICAC parle d'un « arrest of order » du Commissaire de police et non d'un mandat d'arrêt.
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;
a10.
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 wasnot 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.
eS24.
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 ..”
835,
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 aa1.
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
1049.
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,
aona 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
252.
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
2Bve
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 InvestigationsRone
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
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