INDIAN INSTITUTE OF LEGAL STUDIES

DAGAPUR, SILIGURI

SUBJECT: - MOOT COURT.

UNDER THE SUPERVISION OF

ASST. PROF RUPA PRADHAN.

SUBMITTED BY:-
NAME:-MUKESH SINGH
COURSE:-B.COM, LLB (10TH SEMESTER)
ADMIT CARD NO: - 102/B.COM/LLB/16008
CLASS ROLL NO: - 07

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 IILS MOOT COURT
2019- 2020.

IN THE HON’BLE CIVIL COURT OF BENGALURU

ON SUBMISSION TO HON’BLE CIVIL COURT OF BENGALURU

UNDER SECTION3(3)(B) OF BANGALORE CITY CIVIL COURT
ACT,1979 READ WITH SCETION 9 OF C.P.C.

SMT. LAURA (PETITIONER)

V.
EXCEL TELEFILMS (RESPONDENT)

MEMORIAL SUBMITTED ON BEHALF OF RESPONDENT.

COUNSEL APPEARING ON BEHALF OF

EXCEL TELEFILMS

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 TABLE OF CONTENTS:-
LIST OF ABBREVIATIONS------------------------------------------------------------------- 03

INDEX OF AUTHORITIES----------------------------------------------------------------------04

 LEGISLATION --------------------------------------------------------------------------------04
 CASES REFERRED---------------------------------------------------------------------------04
 BOOKS REFERRED--------------------------------------------------------------------------05
 LAW LEXICON AND DICTIONARIES-----------------------------------------------------05
 LEGAL DATABASES--------------------------------------------------------------------------05

STATEMENT OF JURISDICTION------------------------------------------------------------06

STATEMENT OF FACTS-------------------------------------------------------------------------07

ISSUES RAISED-------------------------------------------------------------------------------------10
-
SUMMARY OF PLEADINGS---------------------------------------------------------------------11

PLEADINGS-------------------------------------------------------------------------------------------13

1. Whether the petition is Maintainable before this Hon’ble Court or not?

2. Whether there was breach of duty by Excel telefilms or not?

3. Whether Excel telefilms shall be liable to pay compensation or not?

PRAYER ………………………………………………………………………….………21

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 LIST OF ABBREVIATIONS:-

AIR All India Reporter

AP Andhra Pradesh
Art Article
Bom Bombay
Cal. Calcutta
CHN. Calcutta High Court Notes
CrLJ Criminal Law Journal
Ed. Edition
HC High Court
Hon‟ble Honourable
ILR Indian Law Reporter
J. Justice
Ltd. Limited
MP Madhya Pradesh
NOC Notes of Cases
KAT Karnataka.
SC Supreme Court
SCC Supreme Court Cases
SCR Supreme Court Reporter

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 INDEX OF AUTHORITIES

LEGISLATION:-

 Indian Contract Act 1872

 The Code Of Civil Procedure 1908

CASES REFERRED:-

 Agya Kaur v Pepsu Road Transport Corporation1979-81 Punj LR 1. W

 Butterfield v. Forrester, (1809) 11 east 60.
 Columbia Saw Mill v. Nettleship L. R. 3 C. P. 499 (1868).
 Davies vs Mann 152 Eng. Rep. 588 (1842).
 Hardly v. Baxendale 1854 9 Exch 91.
 Haynes v. Harwood (1935), 1 KB 146.
 In Sudarsan Trading Co. vs. Government of Kerala And Anr., AIR 1989 SC 890
 Koninlijke Philips NV v. Amazestore (2019)(260 DLT 135).
 M Licha Setty & Sons Ltd. vs. Coffee Board Bangalore .
 Padmavati v. Dugganaika [(1975) 1 Kam. L.J. 93. 1975].
 Ravindra Padmanabhan (Dr.) vs Lakshmi Rajan And Anr (2007) CPJ 17 NC.
 Steel Authority of India V Gupta Brothers Steel Tubes Ltd .CIVIL APPEAL NO. 5241
OF 2002.
 Swadling v.Copper [(191)AC1.
 Victoria Laundry (Windsor) Ltd. V. Newman Industries Ltd 3 Ind. lO7 (851).

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BOOKS REFERRED:-

1. Contract-I, Dr. S. R. Myneni, Asia Law House

2. Contact-II, Dr. R.K. Bangia, Allahabad Law Agency
3. The Code Of Civil Procedure 1908, Universal Law Publishing, LexisNexis.

LAW LEXICON AND DICTIONARIES:--

 www.manupatra.co.in/
 Lexis Nexis www.lexisnexis.co.in/ Live Law www.livelaw.in/
 SCC Online www.scconline.in/
 The Wire www.thewire.in/
 Calcutta High Court www.calcuttahighcourt.nic.in/
 All India library www.allindialibrary.co.in/

LEGAL DATABASES:-

1. www.manupatra.com
2. www.indiancaselaws.org
3. www.indlaw.com
4. www.indiankanoon.org
5. www.judic.nic.in
6. www.lexisnexis.com
7. www.scconline.co.in
8. www.westlaw.com

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 STATEMENT OF JURISDICTION:-

It is most humbly submitted that the Petitioner has approached this Hon’ble civil Court of
Bengaluru under under section3(3)(b) of bangalore city civil court act,1979 read with
scetion 9 of c.p.c where the civil court has the jurisdiction to try all suits of civil nature are
triable by a Court unless cognizance of a particular kind of suit is expressly or impliedly
barred.

The petitioner most humbly and respectfully submits before the jurisdiction of the present
court and accepts that it has the power and authority to preside over the present case.

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 STATEMENT OF FACTS:-

1. Excel Telefilms is a company registered under the provisions of the Indian Companies Act,
2013. It is inter alia engaged in the business of providing subscription based internet
streaming service through its website and app- Excel TV. It also produces movies, television
series, reality shows etc. for streaming it online.

2. In May 2019, the creative team of Excel came up with a proposition of a new reality show
called ‘Back to Nature’. The concept of the show was quite unique and fascinating. Twelve
people from different walks of life were to compete against each other in a series of events
over a period of 12 weeks. The contestants would include celebrities such as actors, models,
athletes along with few participants from the general public.

3. Interestingly, the entire show was to be shot, at a remote secluded sparsely inhabited island
called ‘Paradise Land’. The island has a magnificent variety of flora & fauna including some
breath-taking scenic spots. The fact that the location, was not a very active tourist location
also meant that the shooting could be carried out peacefully without any hassles. The
picturesque island was finalised for the reality TV show.

4. Laura is an upcoming artist and the winner of Singing Sensation for the year 2019. Having
performed in several cities across the country, Laura had made her mark in the music
industry. Her impressive talent earned her quite a huge fan following. Laura was in talks with
GMT Inc. an international music events management / production house for a global music
tour wherein she would feature in concerts across several countries, starting from January
2020 The production house instructed her complete her assignments and keep herself free of
commitments by end of November 2019 and keep them posted of her schedule.

5. Excel Telefilms approached Laura to be a part of the show ‘Back to Nature’ as a celebrity
participant. Initially Laura was not very keen on the project. However, after much
deliberations and discussions she agreed to be a part of the show, hoping that it would help
her widen her fan base, considering the huge number of viewers Excel TV had.

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6. Laura informed GMT Inc. of her plan to participate in ‘Back to Nature’. GMT Inc.
expressed displeasure at her decision and warned her to stick to the advised time schedule.
Ignoring their warning Laura decided to go ahead with “Back to Nature” at Paradise Island.

7. The shooting of the Show began on 01.07.2019 at Paradise land wherein the participants
would stay as long as they are a part of the Competition. Laura was far from impressed with
the facilities at the accommodation. However, she chose to remain silent as she knew that any
qualms she made about the place would portray her in bad light.
8. In less than two weeks of the commencement of the shooting, Laura developed rashes,
redness, swelling, pain and itching of her skin along with high grade fever.

9. As the island was situated in a remote location, it took some time for the medical team to
arrive. The doctors diagnosed Laura as having a bacterial infection that is very common in
Paradise Island. As a matter of fact, they were amazed that the rooms were not fumigated to
avoid such risks.

10. Laura was shifted to a hospital where she was admitted and was provided medical care
for the next couple of days. Owing to the infection, Laura developed acute laryngitis and was
unable to speak coherently. She was devastated as she had to cancel her global tour and
forfeit her dream of making it global.

11. Upon being discharged, Laura instituted a civil suit against Excel before the Civil Court,
Bengaluru for negligence. She contended that Excel owed a duty of care towards her, as she
was under their care and custody during such time that she was at Paradise Island. The act of
Excel not taking adequate precaution and safeguards is a clear case of breach of duty. This
has resulted in a huge loss to Laura which she has quantified at Rs. 1 crore. She computed the
same on the following heads:

a. Medical expenses: Rs. 10 Lakhs

b. Loss of revenue on account of cancellation of tour: Rs: 50 Lakhs

c. Loss of income: Rs. 15 Lakhs

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d. Pain and suffering: Rs. 25 Lakhs

12. Excel entered appearance and filed its written statement contending that they were under
no specific obligation towards Laura as the arrangement amongst them was purely
commercial in nature. They further alleged that on account of Laura not taking precautionary
measures, she is guilty of contributory negligence. In addition to the same, Excel pleaded the
defence of Vis Major and contended that the damages not being foreseeable at all, no liability
could be fastened upon Excel.

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 ISSUES RAISED:-

ISSUES 1:-

1. Whether the petition is Maintainable before this Hon’ble Court or not?

ISSUES 2:-

2. Whether there was breach of duty by Excel telefilms or not?

ISSUES 3:-

3. Whether Excel telefilms shall be liable to pay compensation or not?

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 SUMMARY OF PLEADINGS:-

1. Whether the petition is Maintainable before this civil Court or not?

The Council on the behalf of the Respondent most humbly submits that the instant petitions
are not maintainable before the Hon’ble Court as:

[1.1] The Petition filed before the Hon’ble civil Court is not maintainable as the act to be
done by the petitioner was not violative of contract

2. Whether there was breach of duty by Excel telefilms or not?

The Council on the behalf of the Respondent most humbly submits that the there was no
contributory negligence by excel telefilms

[2.1] no contributory negligence by excel telefilms.

3. Whether Excel telefilms shall be liable to pay compensation or not?

The Council on the behalf of the Respondent most humbly submits that the excel telefilms
will not be liable to pay damages according to INDIAN CONTRACT ACT 1872.

[3.1] liable for damages according to Indian contract act 1872 [3.2] section 73 and 74 of
Indian contract act 1872.

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 PLEADINGS:-

1. Whether the petition is Maintainable before this civil Court or not?

The Council on the behalf of the Respondent most humbly submits that the instant petitions
are not maintainable before the Hon’ble Court as:

[1.] The Writ Petition filed before the Hon’ble civil Court is not maintainable as the act to
be done by the Respondent was not violative of contract

It is humbly submitted before the Learned Civil Court that the petitioner suffering the harm
has consented for the same . as in (para.4) for her personal interest by hoping that the show
would help her widen her fan base, considering the huge number of viewers Excel TV had
,and knowing The entire show was to be shot, at a remote secluded sparsely inhabited island
called ‘Paradise Land’ where can be danger . The island has a magnificent variety of flora &
fauna including some breath-taking scenic spots, (para.3) she agreed to be a part of the show.
So it is clear that Laura knows that there is a danger or harm and she is freely give her
consent to suffer the harm or a danger, then she has no remedy for the damage.( Volenti Non
Fit Injuria1)

There are many instances where it has been found that the loss is being suffered by a person
due to the act of the other, but for which he has no remedy in tort law. It so happens because
that the person suffering the harm has consented for the same.

Example, where a spectator of a cricket match gets hit by the cricket ball at the stadium
without any part of negligence and wrongful intention on the part of player or the defendant,
in that situation the plaintiff doesn’t have any remedy under tort law as he himself has
consented for such risk at the time of purchasing the tickets. This consent is a good defence
for the defendant under tort law and this is concept is termed as ‘Volenti Non Fit Injuria’.

1
https://blog.ipleaders.in/volenti-non-fit-injuria.

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The term Volenti Non Fit Injuria is a Latin maxim which refers to a willing person, an
injury is not done. It is a common law doctrine, according to this doctrine the person who
voluntarily gives consent for any harm to suffer would not be liable to claim any damages for
the same and this consent serves as a good defence against the plaintiff. The person who
himself voluntarily waived or abandoned his right cannot have any claim over it. Provided
this doctrine is only applicable to the extent that a normally prudent person would have
assumed to have suffered the risk.

From the plaintiff’s point of view, it can also be termed as ‘consent to run a risk’. In this
context, the defendant can run out of risk and can prevent himself from the tort liability
arising out of the first case. That is if, for example, consent given to a person for visiting his
house can save him from the trespass to land.

In the case of  Ravindra Padmanabhan (Dr.) vs Lakshmi Rajan And Anr2., the plaintiff had
a tumour on her breasts and therefore she went to the hospital to have it removed. While
operating her the doctor also removed the uterus even though it had nothing to do with the
tumour. Thus, the Court held the defendants liable and thus, the defence of volenti non fit
injuria was rejected.

In the case of Padmavati v. Dugganaika3, the plaintiffs had asked for a lift in the jeep of the
defendants and while travelling in it one of the screws of the wheel of the jeep fell out, as a
result, the jeep crashed and it caused the death of one of the plaintiffs. In the case, the Court
held that the defence of volenti non fit injuria will apply and thus the defendants were not
liable because by sitting in the jeep the plaintiffs had assumed the risk of being injured in an
accident.

In the case of Haynes v. Harwood4 (1935), 1 KB 146, the servant of the defendant brought

two horses in the town near a police station and left them to do some other work. The horses
were upset by the children and they broke free, seeing them in rage the plaintiff who was a
police officer went to stop the horses and in doing so he got injured and brought a case
against the owner for damages. The court held the defendant liable because the defence of
volenti non-fit injuria did not apply in a rescue case.
2
Ravindra Padmanabhan (Dr.) vs Lakshmi Rajan And Anr (2007) CPJ 17 NC.
3
Padmavati v. Dugganaika [(1975) 1 Kam. L.J. 93. 1975].
4
Haynes v. Harwood (1935), 1 KB 146

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2. WHETHER THERE WAS BREACH OF DUTY BY EXCEL TELEFILMS OR
NOT?

The Council on the behalf of the Respondent most humbly submits that the there was no
contributory negligence by excel telefilms

[2.1] CONTRIBUTORY NEGLIGENCE BY LAURA

It is humbly submitted before the Learned Civil Court that the petitioner Laura shall be guilty
of contributing negligence on her parts of being careful completing its responsibilities.

The Excel Telefilm accepts all the facts stated in his argument concerned to Issue no. 2.
Although, Excel Telefilm also argued that they were under no specific obligation towards
Laura as the arrangement amongst them was purely commercial in nature. They further
alleged that on account of Laura not taking precautionary measures, she is guilty of
contributory negligence. In addition to the same, Excel pleaded the defence of Vis Major and
contended that the damages not being foreseeable at all, no liability could be fastened upon
Excel.
Every person is expected to take reasonable care of himself. When the plantiff himself
contributes to the damage caused by negligence he is considered to be guilty of contributory
negligence, he will not be permitted to recover damages from another, even though ,the latter
was also negligence to some extent5.

CONTRIBUTORY NEGLIGENCE

Contributory negligence basically means ignorance from both the parties involved. If a
person is driving a car without any breaks met with an accident with another person who was
driving on the wrong side of the road. This results in contributory negligence. It’s a defence
available to the defendant in case of contributory negligence which prevents the plaintiff to
get compensation.

Contributory negligence is the ignorance of due care on the part of the plaintiff to avoid the
consequences of the defendant’s negligence. This concept is loosely based on the maxim-
“Volenti non fit injuria” (injury sustained voluntarily). It means If a person is not taking due
diligence in order to avoid consequences resulting out from the negligence of the defendant
the liability of negligence will be on both of them.

5
Butterfield v. Forrester, (1809) 11 east 60.

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PRINCIPLES  OF CONTRIBUTORY NEGLIGENCE

If the plaintiff is himself negligent for taking due care in order to avoid consequences and
becomes the direct cause of the damages, he is not entitled to receive any compensation.

If both the plaintiff and the defendant have taken reasonable measure and ordinary care to
such extent where they both wanted to avoid such consequences then the plaintiff can’t sue
the defendant.

The law of contributory negligence6 was summarized by the House of Lords

Swadling v.Copper7[(191)AC1] thus:

‘The law in these collision case has long been settled. In order to succeed, the plaintiff must
establish that the defendant was negligent and that negligence caused the collision of which
he complains. If it is established from his own evidence, or by evidence adduced on behalf of
the defendant, that the plaintiff could have avoided the collision by the exercise of reasonable
care, then the plaintiff fails, because his injury is due to his own negligence in failing to take
reasonable care. If, although the plaintiff was negligent, the defendant could have avoided the
collision by the exercise of reasonable care, then it is the defendant’s failure to take that
reasonable care to which the resulting damage is due and the plaintiff is entitled to recover’.

The principle underlying the doctrine of contributory negligence has been stated in
application of the maxim ‘in pari delicto polior est condition defendents’, which means that
when both parties are equally to blame, neither can hold the other liable.

In the same way in the case Laura was guilty of contributory negligence as when she started
shooting for the show, she did not find the facility of accommodation good but still she did
not complain or say anything as she through it might damage her reputation and potray her in
bad light.

6
Davies vs Mann 152 Eng. Rep. 588 (1842).
7
Swadling v.Copper [(191)AC1.

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So, she was guilty of contributory negligence as because if she had taken care of that by
saying it to the respective authority and also by proper taking care of her as in such Island
there is always a chance of getting infected by any germs or bacteria. And taking care of
herself would not lead to such a adverse situation.

In Agya Kaur v Pepsu Road Transport Corporation 8, the court held that if plaintiff does
some act along with defendant and caused injury to him then the defendant can claim defence
of contributory negligence.

The petitioner Laura shall be held liable for contributing negligence as per sec. 1(1) of the
Law Reforms (contributory Negligence) Act 1945, which says that if an accident or injury is
caused to plaintiff then compensation will be reduced by 50%.

Hardly v. Baxendale9 It is declared by the section 73 that compensation reason not to be

given for any remote for indirect loss for damage sustained by reason of the breach. It also
declares that same principles will apply where there has been a quasi contractual obligation.

Columbia Saw Mill v. Nettleship10 Parts of a saw mill were packed in several cases and
handed over to defendant, a carrier. A case was lost and as a result of complete meal could
not be created and operated. Price of the lost part and the profit he could have earned if the
mill was operated. Court allowed recovery of the price of lost fees but the intended use of the
mill was held to be too remote. Willes J. Further pointed that special damages on only
recoverable when the party sought to be chargedis aware of the occurrence of such
circumstances.

Victoria Laundry (Windsor) Ltd. V. Newman Industries Ltd 11. The substance of the
propositions let down is only such loss is recoverable as was foreseeable at the time of
making of contract from breach of it.Forcibility depends upon knowledge.

8
1979-81 Punj LR 1. W
9
1854 9 Exch 91.
10
L. R. 3 C. P. 499 (1868).
11
3 Ind. lO7 (851).

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3. WHETHER EXCEL TELEFILMS SHALL BE LIABLE TO PAY
COMPENSATION OR NOT?

The Council on the behalf of the Respondent most humbly submits that the excel telefilms
will not be liable to pay damages according to INDIAN CONTRACT ACT 1872.

[3.1] LIABLE FOR DAMAGES ACCORDING TO LAURA.

The shooting of the Show began on 01.07.2019 at Paradise land wherein the participants
would stay as long as they are a part of the Competition. Laura was far from impressed with
the facilities at the accommodation. However, she chose to remain silent as she knew that any
qualms she made about the place would portray her in bad light. And also having the personal
interest that the show would help her widen her fan base, considering the huge number of
viewers Excel TV.

There are Twelve other participants from different walks of life (para.2) but she is the only
participant who claimed of suffering. If there is any negligence in the part of Excel than many
others also have the same damage.

There is a proper hygiene and equal facilities for all the participants at the venue , so the
excel telefilm will not be liable12 for the damage13 caused to Laura.

It is humbly submitted before the Learned Civil Court that the incident happened to the
petitioner Laura in the place of shooting a new show of the Excel Telefilms Co. depends
upon the nature of the cause to know it is forcible or not. In the above case, the Excel
Telefilms approached to petitioner Laura for its new show named ‘Back to Nature’ and she
too agreed doing that show which she already knew that the shooting will be take place in a
remote place( paradise island). Where she got bacterial infected which doctor said it is
normal in that island and they checked her it was not such fugitive but which results her with

12
Koninlijke Philips NV v. Amazestore (2019)(260 DLT 135).
13
M Licha Setty & Sons Ltd. vs. Coffee Board Bangalore .

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acute laryngitis which didn’t happened to her ever. So, it was unforceable incident. Therefore
the Co. Excel Telefilms shall not be liable.

In Chairman M.P. Electricity Board, Ranipur v Achhelal Lodhi, plaintiff got injury due
to electricity shock but defendant is exempted from liability because injury caused to plaintiff
was unforceable.

Madras Railway Co. V. Covinda Ralu

Facts- Plaintiff, a tailor head delivered a sewing machine and some clothes the defendant
company to be sent to a place where he was expected to carry on his business with special
profit by reason of a forthcoming festival. Due to the fault of the company the transmission of
the machine got delayed. Plaintiff had not conveyed his special purpose to dose defendant.
Issue- Plaintiff claimed the expenses of travelling up to the place of festival and staying there
and the loss of profits which he would have earned.
Held- Court held that the damage claimed were too remote. All of this was due to the
frustration of the special purpose and that was not known to the company.

[3.2] SECTION 73 AND 74 OF INDIAN CONTRACT ACT14 1872.

It is humbly submitted that respondent is not liable for damages under Section 73 and 74 of
Indian Contract act 1872.

section 73 of Indian contract act 1872Compensation for loss or damage caused by breach of
contract.—When a contract has been broken, the party who suffers by such breach is entitled
to receive, from the party who has broken the contract, compensation for any loss or damage
caused to him thereby, which naturally arose in the usual course of things from such breach,
or which the parties knew, when they made the contract, to be likely to result from the breach
of it. —When a contract has been broken, the party who suffers by such breach is entitled to
receive, from the party who has broken the contract, compensation for any loss or damage
caused to him thereby, which naturally arose in the usual course of things from such breach,
or which the parties knew, when they made the contract, to be likely to result from the breach
of it." 

14
INDIAN CONTRACT ACT 1872.

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Section 74 of the Indian Contract Act reads as follows:- “When a contract has been broken,
if a sum is named in the contract as the amount to be paid in case of such breach, or if the
contract contains any other stipulation by way of penalty, the party complaining of the breach
is entitled, whether or not actual damage or loss is proved to have been caused thereby, to
receive from the party who has broken the contract reasonable compensation not exceeding
the amount so named or, as the case may be, the penalty stipulated for.” In Fateh Chand v
Balkishan Das , the Supreme Court stated:

Section 74 declares the law as to liability upon breach of contract where compensation is by
agreement of parties predetermined or where there is a stipulation by way of penalty 15. But
the application of the enactment is not restricted to cases where the aggrieved party claims
relief as a plaintiff. The section does not confer a special benefit upon any party. It merely
declares the law that notwithstanding any term in the contract for determining the damages or
providing for forfeiture of any property by way of penalty, the Court will award to the party
aggrieved only reasonable compensation not exceeding the amount named or penalty
stipulated. The Court also held that the jurisdiction of the court to award compensation under
section 73 in case of breach of contract is unqualified except as to the maximum stipulated,
and compensation has to be reasonable. This section has to be read in conjunction with
section 74, section 74 emphasizes that in case of breach of contract, the party complaining of
the breach is entitled to receive reasonable compensation whether or not the actual loss is
proved.

In Steel Authority of India v. Gupta Brothers Steel Tubes Ltd 16 Supreme Court held that
there is no impediment or any obstacle for the parties to a contract to make provisions of
liquidated damages for specific breaches only, leaving other types of breaches to be dealt
with as unliquidated damages. There is no principle which requires that once the provision of
liquidated damages has been made in the contract, in the event of breach of one of the parties,
such clause has to be read covering all types of breaches although parties may not have
intended and provided for compensation in express terms of all types of breaches.

15
 In Sudarsan Trading Co. vs. Government of Kerala And Anr., AIR 1989 SC 890
16
Steel Authority of India V Gupta Brothers Steel Tubes Ltd .CIVIL APPEAL NO. 5241 OF 2002.

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 PRAYER

IN THE LIGHT OF THE ISSUES RAISED, ARGUMENTS ADVANCED AND

AUTHORITIES CITED, THE COUNSEL FOR RESPONDENT HUMBLY PRAYS THAT
THE HON‟BLE CIVIL COURT OF BENGALURU

1. To declare that the petition is not maintainable before this Hon’ble court.

2. To declare there was no breach of duty by Excel telefilms .

3. To declare that The Excel telefilms shall not be liable to pay compensation .

AND/OR

PASS ANY ORDER THAT THIS HON‟BLE COURT MAY DEEM FIT IN THE
INTEREST OF JUSTICE, EQUITY AND GOOD CONSCIENCE.

AND FOR THIS ACT OF KINDNESS, THE COUNSELS FOR

THE RESPONDENT AS IN DUTY BOUND

SHALL EVER PRAY.

[COUNSEL FOR THE RESPONDENTS]

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