COMPROMISE DEED TO BE FILED BEFORE THE HON’BLE HIGH COURT

SEEKING QUASHING OF FIR & DISPOSAL OF ALL OTHER CIVIL &

CRIMINAL CASES PENDING IN VARIOUS COURTS OF THE COUNTRY IN
TERMS OF THE COMPROMISE DEED

This Compromise Deed is made at Delhi on 17/12/2023, between M/s Mishra

Medical Industries, a sole proprietorship concern duly owned and managed by
its proprietor Sh. Dilip Mishra S/o Bachhan Dev Mishra, presently having its
Registered Office at 4/53,Shivaji Nagar 122001, presently residing at B-247
Florence Elite, Sushant Lok-3, Gurgaon Haryana-122001(hereinafter
collectively referred to as the FIRST PARTY), which expression shall unless
repugnant to the context or meaning thereof, be deemed to mean and include
its administrators, successors and assigns.

AND

M/s E-spectrum Medical Solutions, a sole proprietorship concern duly owned

and managed by proprietor Sh. Pawan Bhasin S/o of Lt. Sh. Krishan Kumar
Bhasin, presently having its Registered Office at Basement GA-11 Shivaji
Enclave, Rajouri Garden, (hereinafter referred to as the “SECOND PARTY”),
which expression shall unless repugnant to the context or meaning thereof, be
deemed to mean and include its administrators, successors and assigns.

The expression “First Party” and “Second Party” shall unless repugnant to the
context or meaning thereof, be deemed to mean and include their respective
administrators, successors and assigns.

WHEREAS the First Party entered into separate Agreement dated 26 th

September,2018, with the Second Party pertaining to completion of supply
order bearing number 4680 dated 23.07.2018 awarded in pursuance of tender
bearing no. (36 Accounts/equipment’s purchase/2016-2018/17333) awarded
by Rajasthan Animal Husbandry, Jaipur, Rajasthan to Mishra Medical
Industries for the Supply of Animal Pregenency Testors, Animal Mstitis
Detectors, Animal Estrous Detectors. The said supply order was to be
completed within the partnership terms of the said agreement whereby the
proceeds from the supply order were to be equally distributed amongst both
the parties. As participating partner, the Second Party paid to the First Party a
sum of Rs. 4,00,00,000 ( Four Crore Only)/- and the First Party had received
the same on the terms and conditions mentioned in the aforementioned
Agreement dated.

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AND WHEREAS certain disputes arose between the parties resulting in filing
of various civil / criminal cases against each other.

AND WHEREAS the Second Party lodged an F.I.R. No. 0046 of 2023 which
was got registered at Police Station, Economic Offences Wing, Mandir Marg,
Delhi for offences of Criminal Breach of Trust, Cheating, Forgery, Forgery for
the purpose of Cheating and Criminal Conspiracy under Section
406,420,465,468,471/120B IPC, against the “First Party” and Unknown other
accused persons. Though the Investigating Officer is at the juncture of
Completion of Investigation in the aforesaid FIR.

AND WHEREAS at present various Criminal Cases as per Annexure “A”

arising out of Ct Case No. 201,204,291 & 292, of 2022, between Second Party
and First Party are now pending against the First Party before various Courts
including Learned Metropolitan Magistrate for further proceedings.

AND WHEREAS the First Party & Second Party have now amicably
compromised the matter out of their free will and without any force, threat,
misrepresentation and undue influence and coercion, on the terms and
conditions contained in this Compromise Deed.

AND WHEREAS the parties hereto have agreed to record the terms and
conditions applicable to the said Compromise to avoid any misgiving and
misunderstanding hereinafter;

NOW THIS DEED WITHNESSETH AS UNDER

1. That the parties hereto have mutually settled / resolved / compromised

all their disputes and differences in respect of agreement entered between
parties dated 26/09/2018 for the completion of supply order dated
23/07/2018 issued by Rajasthan Animal Husbandry, Jaipur on the terms and
conditions agreed to between the parties as enumerated below.

2(a) That the First Party has agreed and undertaken to pay to the Second
Party, an amount of Rs. 3,00,00,000/- (Rupees Three Crore), towards full
and final settlement of the dues of the second Party which were
advanced in lieu of completion of supply order of medical equipments.
It is understood and agreed that the above mentioned principle amount
will be effectuated in the following manner.
(i) Payment of a sum of Rs.1,00,00,000/- on or before 25/12/2023
(ii) Payment of a sum of Rs.50,00,000/- on or before 31/01/2024
(iii) Payment of a sum of Rs.50,00,000/- on or before 31/03/2024
(iv) Payment of a sum of Rs.50,00,000/- on or before 31/05/2024
(v) Payment of a sum of Rs.50,00,000/- on or before 31/07/2024

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 It is agreed and under between both the parties that all the payments
will be effectuated through the means of NEFT/RTGS only. Issuance of
Cheques or post dated cheques will not be deemed as a mode of
payment.

(b) That after all the payments are effected as agreed between the parties of
, the Second Party shall assist the First Party and the State of NCT of
Delhi to file this Compromise Deed before the Hon’ble High Court of Delhi
for withdrawal / dismissal of the pending Criminal Cases against the First
Party and others arising out of the FIR No. 0046 of 2023 as per details
given in Annexure “A”.

(c) That the First Party & Second Party have further agreed that the First
Party & Second Party shall also jointly file this Compromise Deed in the
following cases filed by the Second Party against the First Party & others
by filing appropriate Applications before the court of LD. MM. Tis Hazari
Courts, Delhi.

(i) Ct. Case no. 201 of 2022, titled “Pawan Bhasin Versus Dilip Mishra
(ii) Ct. Case No. 204 of 2022, titled “Pawan Bhasin Versus Dilip Mishra
and Others.
(iii) Ct. Case No. 291 of 2022, titled “ Pawan Bhasin Versus Dilip
Mishra.
(iv) Ct. Case No. 292 of 2022, titled “Pawan Bhasin Versus Dilip
Mishra.

(3) That the parties reiterate that they shall continue to abide by the terms
of the Settlement /Compromise as recorded hereinabove which are being
acted upon.

(4) That the parties agree that they shall act in such manner and execute
any such document that may be required by any of the other parties in
furtherance of the terms of the aforementioned Settlement /Compromise
or which may be necessary to fully implement and effectuate the same,
whether now or in the future at any time. The parties have agreed that
they shall fully cooperate in this regard and shall not act in any manner
which hinders or delays the implementation of the aforementioned
Settlement /Compromise.

(5) That the parties agree and clarify that the aforementioned Settlement
/Compromise has been arrived at bona fide and in good faith to achieve

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 the purposes stated hereinabove. It is agreed and clarified that there is
no fraud, coercion or undue influence imposed on any party hereto to
enter into the said Settlement /Compromise, and that the parties have
agreed to the said Settlement /Compromise out of their own free will
and volition. It is made clear that none of the parties hereto and none of
their heirs or representatives shall challenge the Settlement
/Compromise on any basis whatsoever and the parties hereto shall
ensure that such challenge, if any, is repelled and resisted in all / any
forum. The parties agree and confirm that the aforesaid Settlement
/Compromise is valid, legal binding and enforceable in all its terms.

(6) That the Parties further undertake not to institute any Civil and /or
Criminal litigation inter-se of any kind in any forum hereinafter, against
each other in view of the present settlement.

(7) That the parties shall also not engage themselves in any further direct/
indirect or proxy litigations, whether civil or criminal against each other
(including civil suits and criminal complaints for defamation), past,
present or future with regard to the present controversy, and/or
controversies/issues already raised in various existing court proceeding
and/or in relation to any controversies not so far raised that related to
any activity or past conduct of the Parties.

(8) That in view of settlement of all disputes, the parties unconditionally

withdraw all allegations leveled against each other and undertake not to
make any fresh or new allegations in future against each other.

(9) That it is made clear that the Parties have entered into this settlement
keeping in view their larger interest and are fully bound by the terms of
the settlement and have signed the same. Both the parties indemnify
each other against any loss and/or injury financial and/or otherwise.

(10) That the Parties to this Deed have agreed and undertaken not to pursue
any complaint/case before any authority/court which might have been
filed by either party that might have not been covered/mentioned above
in this Compromise Deed and the same also shall stand settled and
withdrawn.

(11) That after all the payments are effected as agreed between both the
parties as mentioned hereinabove under this Compromise Deed, the
Partnership Agreement dated 26/09/2018, which have been signed and
executed between the First Party and the Second Party in respect of
Completion of Supply order of Medical Equipment’s, shall automatically
stand determined and thereafter the parties would be relieved of their
respective contractual obligations arising out under the said agreements.

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(12) That the Parties unconditionally undertake to abide by the terms and
conditions of this Compromise Deed.

(13) That it is agreed and clearly understood by the parties that any
statement/representation/assurance given/made by the parties in this
Compromise Deed does not amount to acknowledgement of liability or
admission of any fact / allegation which is contrary to the stand/position
already taken in pending litigation in respect of aforementioned
agreement in any of the pending litigations between the parties and in
case this Compromise Deed is not fully implemented for any reason
whatsoever then in such event this Compromise Deed shall come to an
end and the parties shall revert back to their original position.

(14) That each party will be entitled to claim refund of Court Fees of their
respective proceedings.

(15) That Second Party shall claim from the other party/parties any
costs/expenses/legal charges/Advocate’s Fees etc. or reimbursement for
any amounts already spend / incurred / shared for or in any of the
existing proceedings.

(16) That in case of breach of the terms of this Compromise Deed by either
party, the other party would without prejudice to its rights under this
Deed, be entitled for specific performance as well as damages under law.

IN WITNESS WHEREOF these presents have been executed by the parties

hereto on the day, month and year first above written in the presence of
witnesses.

Witnesses : For & on behalf of For & on behalf of

______ ______

FIRST PARTY
For & on behalf of

(______)
SECOND PARTY

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 ANNEXURE “A”
DETAILS OF CRIMINAL CASES

Sl. Case TITLE Court Relating to Next

No. No. Name Date of
Hearing

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