PRAYER

Wherefore, it is humbly prayed to this Hon’ble Court that in the light of issues raised,

arguments advanced & authorities cited; this Hon’ble Court may be pleased to:

1. Dismiss the setting aside application filed by PetroPrime Innovations Pvt. Ltd. ("PPIPL")
as being devoid of merit and not maintainable before this court;

2. Declare that this court lacks jurisdiction to entertain legal proceedings against TransSwift
Logistics Pvt. Ltd. ("TSLPL") as it is a separate entity from AMSPL and not a party to the
arbitration agreement;

3. Declare that this court does not possess jurisdiction to entertain legal proceedings against
Dr. Robert Zane, the arbitrator appointed by AMSPL, as the alleged grounds for conflict of
interest do not establish any violation of procedural fairness or impartiality.

4. Uphold the validity of the arbitral award dated 30.11.2023, as issued by the Hon’ble
Arbitral Tribunal, and reject PPIPL's request for setting it aside, as the Tribunal's decision
was based on a thorough examination of the facts and applicable law.

And/ Or

Pass any other Order, Direction or Relief that it may deem fit in the Best Interests of

Justice, Equity or Good Conscience. And for this Act of Kindness, the Petitioner shall Duty

Bound forever Pray.

SD/-

Counsel for Respondent