Amzt Gupta. Page 1 5, ,0 13.55., BCL (099ml), {Camila} I Adwmz?a 07,2 Record; SupreweriCow?i? of India Ema/[772671; N0. 13/946/2002 Attorney, New York: 32221? Bar. {Emma} 44 76 7 7.7) 18.08.2015 Agarwal Law Associates, Advocates, I, 48, Lawyers Chamber, Supreme Court of India New Delhi 110 001. Sub: Legal Notice dated 08.08.2015 sent on behalf of Essar Steel India Limited to my Clients. Dear Sir, Under the instruction from and on behalf of my Clients: The Caravan Magazine oticee o. Mr. Paresh Nath, Editor in Chief (Noticee No. Mr; Anant Nath, Editor (Noticee No. Mr. Vinod K. jose, Executive Editor oticee No. and Mr. Krishn Kaushik, (N oticee No. 6) all c/o The Caravan Magazine, Delhi Press Patra Prakashan Pvt. Ltd, having its registered of?ce at E3, Jhandewalan Estate, New Delhi, I address you as under: 1. That my Clients have placed before me the above mentioned legal notice wherein it is I stated that by publishing the cover story, ?Purchasing Power How Essar Wields' In?uence over Indian Government and Finance? in August 2015 Edition of the Caravan Magazine and by posting the said article online on the website my Clients have defamed, insulted and harmed the reputation of your Client. At the very outset my Clients vehemently deny each and every statement, contention, averment and allegation made in the said notice, except where speci?cally admitted. 2. That it may be noted no entity such as ?Delhi Press Club,? mentioned as Noticee No. 7 in the legal notice exists at the address mentioned against such Noticee. Furthermore, no gentleman by the name of ?Mr. Hartosh Singh Pal? designated as Political Editor as oticee o. 5 in the legal notice works with the Noticee o. 1. My clients are not aware nor associated with ?Delhi Press Club? which has been stated to be present at the registered address of Delhi Press Patra Prakashan Pvt. Ltd. Likewise, my clients are not aware of Mr. Hartosh Singh Pal. You are therefore, requested to ask your clients to verify their facts. 3. That the legal notice? on behalf of your Client is untenable in law and facts. The publication of the aforesaid cover story ?Purchasing Power How Essar Wields In?uence over Indian Government and Finance? (hereinafter referred. to as ?the Cover Story?) by my Clients does not constitute any offence. The legal notice and the threat of initiating legal proceedings against my Clients has been made, to harass my Clients. The legal notice has been sent with malafide' intent to stifle and suppress freedom of speech and expression and is a malicious, motivated and illegal attempt to throttle the truth. I. - OFFICE: - 17 - LGF LAJPAT - NEW DELHI-110 024 CHAMBER: 21 CHAMBER SUPREME COURT OF INDIA - NEW DELHI 110 001 MOBILE: +91-98102 73846 a TELE +91~11-29834841, 23384953, 46142114 E-MAIL: amit@mitterlaw.com . Amz't Gupta Page 2 of 10 That my Clients are publishing a very reputed magazine, which is renowned for long? form narrative journalism, co?vering interalia politics and culture in India. Extensive and in?depth research is done before publishing any cover story in the magazine. The successive editions of the magazine have been appreciated and well received by intelligible sections of the society. That my Clients take pride in the fact that each cover story and article published, in The Caravan Magazine is original, authentic, accurate and an outcome of painstaking efforts and research. My Clients and The Caravan have always abided by the highest standards of independent and responsible journalism, who see it their duty and role to inform the readers, truthfully on all matters of public interest. I That by publishing an independent magazine, my Clients are playing a critical role in our democracy through . exercising and upholding the fundamental right to freedom of speech and expression guaranteed under Article 19(1)(a) of the Indian Constitution. The Cover Story published by my Clients is an exercise of freedom of speech and expression on their part. As the Cover Story deals with a subject that is of public importance, by publishing their honest opinion and reasonably veri?ed facts my Clients have advanced the fundamental right of all citizens to know and be. informed. On all such matters ofpublic interest and public importance, the media has a right and duty to report and the-public has a right to know, and the same cannot constitute defamation or any other crime in law. That my Clients have published the Cover Story after comprehensive research over a period of time and a reasonable verification of facts. The publication of the Cover Story is not actuated by malice or by personal animosity but is a genuine attempt to put facts in public discussiOn as the matter is of signi?cant public import and interest. The state of overnance and the influence Of lar co orate houses .on matters of I rp A a governance has been a constant topic of discussion for past several years Within the country. That the Cover Story mentioned hereinabove printed in August 2015 edition of the magazine and posted on the website is a result of extensive research, investigation and interviews by its author. For the purposes of the Cover Story, its author personally Visited several places to learn about the actual facts such as Raipur, Bilaspur, Naya . Raipur, -, Bailadila, Pullpaar Village in Chhatisgarh, and Singrauli, Amiliya Village in Madhya Pradesh,IMumbai and had interviews with several sources having information about the functioning and activities of your clients including chief executive of a bank, . leading investment banker, senior analyst with an international financial ?rm, senior researcher of a ratings ?rm that has tracked Essar?s companies closely, business journalists who have covered various industries in which Essar has major presence, former SBI banker, former banking secretary, ex member of ?Chattisgarh Legislative Assembly, former DGP of Chattisgth state, local journalists in Chattisgarh, villagers, and accessed documents available with local authorities in Chhattisgarh, documents ?led by Essar in Chhattisgarh High Court, and also relied on the facts provided by the i whistleblower who was admittedly an employee of your client having full legal access to various correspondence pertaining to working and functioning of your client. The Cover Story also relies on various news items, government and court records, which are already in public domain. My Clients have not spread any false Amz?t Gupta." Page 3 of 10 rumours about the conduct and reputation of your client nor have made any baseless, misconstrued and misconceived' allegations on their own. That my clients adopt the best journalistic practices and have extremely responsible while publishing any cover story or article. Admittedly an email was sent to Mr. Manish Kedia, the senior vice president of corporate affairs of Essar Services India Private Limited, with questions about many of the issues raised?by the whistle blower?s emails and the author?s 'own reporting. The contents ?of the email sent on 13.07.2015 to your clients for their cOmrnents is annexed as Annexure A with this reply. It is unfortunate that no direct response was received to the questions raised by the author of the Cover Story. .As respOnsible publication, my clients have in any event carried out in the Cover Story response received from Mr. Manish Kedia. Thus, the allegations made in your legal notice that the CovervStory contains statements and imputations in a reckless manner and a deliberate attempt to cause harm and prejudice toyour client,? is baseless, frivolous and wrong. There was no reason or occasion for my clients to mention the version given by your clients in the very same Cover Story, if the publication of the Cover Story was actuated by any intention to malign the reputation of your client. I That there are no defamatory or malicious imputations made by my Clients in the Article which are false. My Clients assert the truth of the content of their Article as a complete justification. It is significant that neitherwhile replying to the email sent by my clients to Mr. Manish Kedia, nor is the legal notice there is no response to Several crucial facts stated in the Cover Story, such as: On 22.01.2014, Greenpeace protested at the Essar House over power plant in Mahan . forest; The exact debt accumulated by various entities of the Essar Group and their promoters; A whiStleblower having access to Essar?s internal communications approached Mr. Prashant Bhushan and a public interest litigation is pending before the Supreme COurt on the issue of favours provided by Essar group to various journalists, politicians and bureaucrats; I The Indian Express had revealed details of various services Essar performed; There have been allegations from Villagers in the State of Chattisgarh accusing Essar of illegally acquiring land for its projects; Various people have been given jobs within the Essar group on the recommendation of politicians, bureaucrats and journalist; Favours have been granted to politicians, bureaucrats and journalists by giving them' accommodation within the Essar guest house or arranging for their travel at Essar?s own costs; ?hwyw Gupta 10. 11. el?age 4 of 10 . A General Manager of Essar' Steel was arrested by the Chattisgarh Police in September 201i on the charges of paying -money to the naxalities; A spreadsheet was prepared in the month. of November 2010, giving details of iPads to be offered to several journalists, politicians and bureaucrats; . Essar Group?s" name has ?gured both in Coalgate and 2 seams; Essar produces 3 Information System Report wherein action plans required at the end of Essar having included recommendation such as suppressing an issue or arranging favourable reports from various government departments; (1) Executives from the Essar group have been arrested by the Delhi Police in February this year: for stealing sensitive government documents from the petroleum The Directorate of Revenue Intelligence had issued a Show Cause Notice to Essar in March this year claiming that various Essar owned companies had in?ated invoices . for imported equipment as a method of siphoning money out of the country. The complicated strutture of the companies owned by Essar Global Fund Limited is so created for maximum opacity. Ravi Ruia and Anshuman Ruia have been disalloWed'to travel outside India without seeking the court?s approval. HDFC and Bank of India have declared their exposure to Essar Steel as Non Performing Assets. Essar?s companies have defaulted on its borrowings earlier as well. Essar started work on its plantnear the Mahan forests even before it had got all the permissions from the government. (3) Essar funded or provided assistance for Salwa Judum. In View of the admitted position, the allegations and contentions made in your legal notice are an afterthought, baseless, false, wrong and frivolous. Without prejudice to the aforesaid, the parawise reply to the contents of your legal notice are as under: That the contents of Para 1 2 of your legal notice under reply, pertain to your client?s organization. The said aspect has been already covered in the Cover Story along with various other information which is either in public domain or came to knowledge to the author of the Cover Story while researching. and writing the Cover Story. . . . Page '5 of 10 12. (ii) \m 'Amucupm That the contents of Para 3 of your legal notice under reply are correct to the extent that my clients have published the Cover Story and the same is also available on the website. - - I It is however, vehemently and categorically denied that my clients have made several innuendos and imputations against Essar and/or its promoters with the intention to harm or knowing or having reason to believe that such imputations will-harm the reputation of Essar and its promoters to defame them without any justi?cation. It is also denied that the Cover Story contains defamatory content without lawful justi?cation. I It is reiterated that the Cover Story is based on extensive research, investigation and interviews by its author and as a responsible and mature publishers, my clients have carried a pro?le of Essar and its promoters for the purpose of larger public discourse on' various issues relating to corporate working in India and its affect on governance - and implications for the masses. It is undeniable that concerns have been raised and do persist on the issue of allocation of mines within the tribal region of India as well as huge debts being incurred by publicly listed companies. It is wrong and denied that the statements made in the Cover Story are false and defamatory and the speci?c response to the allegations made in the legal notice is as follows: i The title and description of the Article do not contain any defamatory statements against your client. Even though it has mentioned that the title and the description on Page 28 is false and defamatory, there is no response as to whether Essar does try to in?uence the. Indian Government and its policies. Furthermore, the various emails leaked by the whistleblower along with several other documents, information and interviews do indicate that Essar group does wield in?uence over the Indian Government. i The inference drawn in Para 3 of the legal notice is entirely based on your client?s understanding. It is an admitted fact the Supreme Court cancelled allocation of coal blocks as a result of arbitrary and illegal allotments. It is an admitted fact that criminal investigation was ordered by the Hon?ble supreme Court over the issue of coal blocks allocation. There is also no denial of the fact that the allocation of coal blocks without conducting any auction has been linked to the widespread favours and corruption in allocation procedure. Paragraph 157 of Supreme Court?s judgment dated 25th August 2014 is as follows: ?7 5 7. A: we have alreaaj/ found that the allocation; made, hoth under the Screening Committee route and the Govern/neat route, are arhz'tragl and illegal, what rhoula' he the consequences, theinue which remain: to he tackled. We are of the view that, to thir limited extent, the matter require: further hearing. The statement extracted in Para 3 of the Legal Notice is based on extensive research, interviews and feedback from several individuals who are aware about the a Page ?6 0% T0- it Gupta (iv) activities of your client or have been, atfected by its activities. Multiple sources, including the chief executive of a bank, a leading investment banker, and a senior . analyst, with an international ?nancial firm mentioned in the Cover "Story voiced this issue with the author of the Cover Story. The following is an excerpt from a private repOrt prepared by a firm that advises international companies about mVestinent in India, that was shared by its author: ?Delpite a well?docamented etring of defanltr and accnratzonr of?nancia/ thenaniganr, the Rnial' have fandamentalh/ retained their access" to Indian and foreign retiree: of capital that are leg; to their growth and, indeed, their terminal. The family whim/h; employs at little at porrihle of ity own accumulated wealth mach of which it renamed/y parked outside of India to enter new hntz?netrer or to eagband exzkting operations. Error has" admith/ lohhied?r I in New Delhi, which control: India?r largert hank: and ?nancial inytitntiont (Flt), cnltivating he] leaders acronthe The Raid! areparticnlarh/ clore to LK. Advani, the former Deputy Prime. Minirter and leader, and have warm relation; with the current Communication In?rmation Technology -Minirter, quanidhi Maran, who is alro?om Madras. .. . Even Ettar?e'hntinem model and modnr evolved recentl there it 4/2214]! at leatt one iven? in dealing with Errar, commented another Bomha} ohterver: the Rniax? partners" ailing/3? have more to. lore than Brian Furthermore, the charge regarding .land pursuit has been repeatedly voiced by villagers,?in Dhurli village?and then in Pullpaar, both 'of which are cases which point to the company being more concerned about itself and by extension its promoters than the rightful owners of the land. It is denied'that the statements/ incident extracted in Para 3 (iv) of your legal notice are false and baseless. It is reiterated that the statements/incident is based on true account of the information provided to the author .of the Cover Story through different sources. With respect to the statements regarding payment to leader of Maoists movement, the Cover Story has on record statements of the former DGP of Chhattisgarh, Vishwaranjan where he says a former Essar executive admitted. to him about this. The Cover Story also refers to an excerpt from Nandini Sundar?s essay a wikileaks cable where a US Consulate General staff member claims a senior Essar employee claimed this to i The statement that i5 hetter at managing the government than managing iti?na'ncer? isa paraphrased quote from the chief executive of a bank, and attributed to him. Also, it appears that only a part of the line has been extracted, whereas the complete line is as follows: Gupta (V) (vi) (vii) (ix) Page 7 of 10 ?iA/l told, the emails Jahi?z?aaz?iaz?e what the chief executive of a hank chat har lea! lo Esme" ill the pad told we: Ihac 55507? is hotter at Maleagiig the gamma/72ml z?haa maieagihg its - ?ea/acct? The incident regarding help extended by Essar to Narendra Modi and reCeived its bene?ts later are attributed to a senior of?cial of the NDA regime and to a former senior executive of Essar. The statement excerpted in Para 3 of the Legal Notice as based on Essar?s internal emails which prove that they had access to documents like minutes of meetings of Group of Ministers; minutes of meeting headed by principal secrtary in PMO TKA Nair; letter written by petroleum .minister Veerappa Moily to his joint secretary Giridhar Armane; budget proposals of the petroleum_ ministry; etc. The statement is based on hard facts and cannot be termed as defamatory. It is interesting to note that your client has never denied the existence of the emails which have been leaked by the ?whistleblower and their contents. _The statement excerpted in Para of the Legal Notice is again based on the fact that Kumar Mangalam Birla and Shashi Ruia wrote letters to the Prime Minister and the Minister of Environment and Forest, and later the Finance Minister who was also the head of the Group of Ministers heading over the decision on Mahan coal block. The .Cover Story also details how Essar?s executives were in touch with various ministers and bureaucrats whose ministries were part of the group of ministers and directly relevant. to the decision 0n Mahan coal block. Essar also provided jobs to the kin and supporters of these ministers and bureaucrats as and when asked by them. The statement extracted in Para 3 is not the entire sentence. The statement hasn?t been made by the author of the Cover Article but was made by Shubhranshu ?Choudhary, who told it on recOrd to the author. The full sentence is as follows: ??Choadhagl told methat the Dharli .ragbaach claimed to haz/e foged the rignalarer of 19a? fellow villager; to allow Emar a claim over their land. The statement extracted in Para 3 is again not the entire sentence. The statement hasn?t been made by the author of. the Cover Article but was made by Manish Kunjam, who told it on record to the author. The full sentence is as follows: I?l?Ie recalled thaf the reprerehcatioe an?ed him, ?lea chahiye? Kitna do your/ant? How mach? Errar, he alleged offered to pry him Re. 5 crore to dog) the protem. He did not agree. I The contents of Para 3 of the legal notice are based on your client?s own interpretation and further rely only on partial sentences from the Cover Story. It hasn?t been stated that Essar has fabricated the land related documents. The Cover Story only states that Essar was able to transfer the land in its name without conducting a Gram Sabha, after Sarma Alba sold them the land without proper . authorizatiOn required in ai'Schedule area. I .. 9 Pagetl of 10 Gupta (X) (xi) (xii) Furthermore, only a part of a statement has been extracted to make false allegations against my clients. It may be noted that my clients have published the following: ?There rope to .rtateforeer go hand+in?hand with perristent .ru.rpieion.r that Essar ha; airo paid protection manta/i to MaoirtJ?'?'?roniethi7ig that, true, would neean the oornpaiy/ hay funded oppoeing rider in one of India v/orrt internal oon?iotr. There is no denial onbehalf of the Client, that have indeed, been accusations, we have already mentioned in the Cover Story that they have paid money to Maoists. Also, there have been accusations that they gave money for Salwa Judum. In the absence of any corroboration, my clients have only stated ?suspicions? andnothing more. It also undeniable that Essar did give money for a relief camp initially. Also, Essar has hosted Mahendra Karma,'the leader of Salwa judum and other high of?cials of Chhattisgarh?s administration and police force at their guest houses in Delhi. The statement extracted in Para 3 is again not the entire sentence. The statement hasn?t been made by the author of the Cover Article but is directly attributed to the former DGP of Chhattisgarh state, Vishwaranjan. The full sentence is as follows: former director general of police in Chhattiegarh, Vixhzvarary'an, told nee that a senior Errar executive, cuter he had retired, admitted privately that? the eornpaiy/ used to pay protection many to the Maoists The statement extracted in Para 3 of the legal notice is based on the multiple examples provided in the Cover story and previous stories published on Vantage section of my client?s website, wherein Essar?s executives claimed to have planted stories ?led by reporters of various newspapers, magazines and wire services. Example of the Essar?s staff keeping tabs on the desk directly provided in the next sentence, of the Cover Story. All this information is available through ESSar?s internal email exchanges between senior executives. The full paragraph for that sentence: ?En?ar?r executiver not onh/ claimed eonneetion: with reporter! and editors who could plant .rtorier, hut also kept tahr on (leek-level next/{paper sta?f On 9 2012, a general manager with Euar?r corporate relation: group, Pan/exhit Kaul, zvrote to Saurahh Saxena of Aafaetorr, an external puhlie?relation: ?rm, telling him to ?catch hold cf delve guy!? to emu/e that the following day/?5 headliner, ahout the Giuarat government?s action; agaith Error, were written in ?our favour or at leart neutral Kaul end the nzimive raging, helieve Mint is" carving a negative headline we can try to get it Mild. (?Cujarat real; Errar?r hank the Mint headline read the following day.) In response to the contents of Para 3 of the Legal Notice it may be noted that the quote of the former SBI banker suggesting Essar had parked money abroad, is directly attributed to a former senior official in the NDA regime. The following is the relevant part: i. Gupta Page 9 of 10 a "Hronnd ma dine, at senior 5B1 banker ar/eed .t/ae q?ia'az? to ted l/ae Raids to Im'ng. Joine If rnonej 15/963; nod anroad back to India. ?Ynko bole [ya/oar re poira leg/e. Ye/o 1?70! mne learn paz'ra nn/oi loaf, bee/yon! parka bed, [lee ojfdoz? read be war told?Ted ?own to bring in. rnoneJ/??o/n ontride. 1799/ 569/ t/oere ?1 none, t/oere ?5 50 rnne/e. The statement that ?Error doer not bone Z/oe next porno/e a; a borrower? has been misquoted for reasons best known to your Client. The Chief Executive of the bank mentioned in the Cover Story told the following to the author: ?Indian promoterr bane kneaded/?l- relied on debt to grow, and Z/oe rbz'efexeentz'ne ofez [me that bar lent to End!? in flee part told rne ?oat t/oe Rainy were no dg??erenz?. Bat, be added, Error does not bane ?doe bertpom?n/e rebntotz'on or a narrower. The allegation that my client?s mentioning of the total debt of the Essar Group has affected your client adversely is wrong and denied. The ?gures mentioned by the author of the Cover Story is based on his reporting in Mumbai after meeting various people who told him they had studied Essar?s ?nances. Furthermore, neither younor your Client have ever stated that the total debt of Essar Group to controvert the numbers mentioned in the Cover Story. The statement extracted in para 3 is based on a direct quote from a senior researcher of a rating firm that has tracked some of the Essar?s companies closely. The contents of Para 4 of the Legal Notice are ,wrong and denied. While youriclient may chose to deny all the statements made in the. Cover Story, the Cover Story is based on extensive research and interviews and uncontroverted facts. It is denied that false, defamatory statements and imputations have been published in a reckless 'manner With a deliberate intent to cause harm and prejudice to your Client. It is denied that the innuendos in the Cover Story'are insulting, harmful and defamatory. It denied that statements, innuendos and imputations are highly offensive, insulting distasteful and defamatory of your Client and of Essar and its promoters. It is denied that my client?s magazine contain false and defamatory statements, innuendos and imputations. It is denied that my clients have made any statement deliberately and knowingly to bring your Client, Essar and the promoters into disrepute, dislike, ridicule, contempt and disesteem in the eyes of right thinking members of the society generally. It is denied that my clients have made any statement irresponsibly, maliciously and with the oblique motive of somehow furthering narrow commercial and publicity interests atthe cost of your client, Essar and its promoters? image, reputation and goodwill. That my'clients do not believe in publishing false and malicious stories nor do they need to gain publicity by scandaliz'ing an issue. It should be noted that my client?s magazine has already received wide recognition, both nationally as .well as internationally and several leading international publications have recognized ?The Caravan? for its nuanced and detailed writing on politics, economy, arts and culture on South Asia. The New Yorker magazine from USA had written, ?The Caravan consistently publishes some of the best long form reporting in India?. The New Gupta - a, . Page 1.0 of 10 Republic, a leading political magazine from Washington USA, had mentioned, ?For those with an interest in India, it he'Caravan] has become an absolute must?read. Its analysis of lndian politics is essential and its c0verage is robust?. The GUardian newspaper of London had labeled ?The Caravan? as ?India?s best English?language magazine?. Over the years ?The Caravan? has become an International magazine on politics and culture, which is respected globally for it?s nuanced writing and detailed reportage. client?s magazine, ?The Caravan? has also won a string of awards for excellence in journalism over the last few years. That the contents of para. 50f the Legal Notice are wrong and denied. The contents of the foregoing para are reiterated since most of the statements made in para ?5 of the legal .noticeare a repetition of para which have already been, categorically denied. It is denied that my clients are liable to pay damage to your client. It is also denied that my clients have become criminally liable for defamation. It is denied that the Cover Story has caused or continues to cause serious harm to the image, goodwill and reputation of your client and the Essar and its promoters. - 6. I That in view of the foregoing, the contents of para 6,of the Legal Notice are without any substance. My clients are under no kind of any legal obligation or requirement to ?cease and desist? from publishing, issuing, circulating, distributing or advertising in any manner whatsoever any information concerning your client, Essar' and its promoters. i 7. I That as mentioned above, my client is not required to take any of the steps mentioned in para 7 of the Legal Notice. 8 It. may noted that my clients have published the Article in exercise of, their fundamental rights guaranteed under the Constitution of India. It is also worth noting that Courts have held'that freedom of expression which includes freedom of the press has a capacious content and is not restricted to expression of thoughts and ideas which are acceptedgand acceptable, but also those which offend or shock any section of the population. It also includes the right to receive information and ideas of all kinds from different sources. I I . 8. That in response to Para 8 of the Legal Notice, it may be noted that my clients are not liable for either civil or criminal or tortuous liabilities for exercising their fundamental rights. 7 Therefore, you are advised to correctly inform and instruct your Client not to indulge in any misadventure or harassment of my Clients by ?ling any false, unfounded and frivolous legal proceedings and withdraw the legal notice dated 08.08.2015. Thanking you, (r mit Gupta, A Email .to 'Manish Kedia and Ganesh Pai sent on 13 July, 20%?5 at 5:30 PM. Hello Mr. Kedia, Thank you for your email. Listed below are the questions for which i would, like to have answers from Essar. Once again, '1 request you to let?me know at the earliest about the meeting I requested in, my previous email. I will not be able to carry any response from the company that arrives after Thursday morning, 16 July 2015. l. i What were the total revenues of the Essar Group for 2014- 2015 ?nancial year? What is the net worth of Shas?hi and Ravi Ruia? 3. What is the total debt of the Essar Group? 4. What is. the debt of the holding company, Essar Global Fund Limited? 5. Is it true that some of Essar Group?s companies have recently been irregular in making their interest- payments on the loans? How many banks have declared their exposure to Essar's companies as non?performing assets? 6. How much has Essar borrowed from Standard Chartered bank in the last ?ve years? 7. How much of this was borrowed by the holding company? What is the? total outstanding loan taken by Essar Group?s companies from India?s public sector banks? 9. Many investors, bankers, stockbrokers believe that you haven?t created wealth for your shareholders; rather, shareholders have always lost money with Essar?s companies. What do the promoters of the company have to say about this? 10. Why are most of the group?s companies headquartered in-Cayman Islands and British Virgin Islands when most of your assets are in India? 11. The emails leaked by a whistleblower indicate a very large public relations operation conducted by the Essa?r Group. They prove that the company hired people recommended by various ministers, politicians and bureaucrats. The emails also show that Essar?s top executives, including Prashant Ruia, shared classi?ed government documents, including minutes of meetings held by ministers, proposals for the annual budget, and letters written by government of?cials, which the company should not be in possession of. How were the documents accessed? Aren?t the company executives in contravention of law by possessing and sharing these documents? I 12. Does Essar own nearly 200 acres of land in Pullpaar village in Dantewada? When did .Essar buy this land? Was there a gram sabha conducted before Essar got this land? ?13. What does Essar want us do with this land? 14. iLoeais said that Essar hasn?t hired-a single person from the villages in their piants' in B'aiiadila and the power piant near forest. Even the ones who work there are do so on ~contraet basis; Essar promised to hire at {east one person of each household. that was displaeed by its power plant, but it it true? if yes, "why haven?t the villagers been hired? ?15. Has Essar, at any point, paid money to .MaoiSt groups or representatives, either directly or indirectly? 16. What isthe status of the case against Mr. DVCS Varma in which he was accused of, along "with: others, of paying money to Maoist interests? - 17. Whatis the status of the case against Ravi Ruia and Anshuman Ruia in the matter of second generation telecom- spectrum allocation? 1 am inquiring, more precisely, about the relationship between L00p Telecom and Essar. 18. Has any member of the Ruia family been restricted by any court in the country to travel abroad? 19. .Is it true that Sha-shi and Ravi Ruia, and?Anshuman and Prashant Ruia are non-resident Indians, NRls? '20. The Ruia family has been accused of siphoning off money from Essar's companies and I having it parked abroad. Is this true? 21. How muCh money has Essar given to political parties in the last ?ve years? Could you tell me what the break-up of this expenditure is, party?wise? 22. Have the Ruias ever given money toNarendra Modi, as a BJP of?cial, {for the party's funds for state elections? Did this happen during the 19905, in Madhya Pradesh? If yes, how much money was given? 23. What is the nature of the Ruias' relationship with Gurumurthy? 24. What is the nature of the Ruias' relationship With LK Advani? 25. Did someone from the Ruia family. approach the NDA government in 1998? 1999 toseek ?nancial help, to restructure its loans and raise more funds? Thank you, Krishn