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[Cites 7, Cited by 0]

Delhi High Court

Deepak Beri vs Atul Beri on 24 December, 2020

Author: Rekha Palli

Bench: Rekha Palli

                                                                               Via Video Conferencing
                      $~
                      *    IN THE HIGH COURT OF DELHI AT NEW DELHI

                                                                              Reserved on: 23.10.2020

                                                                          Date of Decision: 24.12.2020

                            +        O.M.P.(I)(COMM) 326/2016, CCP(O) 66/2016, I.A.
                                     12815/2016, I.A. 13/2017, I.A. 786/2017, I.A. 1329/2017,
                                     I.A. 3226/2017, I.A.3751/2017, I.A. 3345/2018, I.A.
                                     3975/2018, I.A. 3982/2018, I.A. 3983/2018, I.A. 4707/2018,
                                     I.A. 4708/2018, I.A. 5293/2018, I.A.16583/2018, I.A.
                                     4728/2019
                                     DEEPAK BERI                                        .... .Petitioner
                                                              Through:    Mr. Sandeep Sethi, Sr.
                                                                          Advocate with Mr.Akshay
                                                                          Makhija, Mr.Saurabh Seth,
                                                                          Ms.Sumeera     Seth     and
                                                                          Mr.Siddhanth Kumar, Advs.

                                                          Versus

                                     ATUL BERI & ANR.                                 .......Respondents
                                                   Through:               Mr. Arun Kathpalia, Sr. Adv.
                                                                          with    Mr.Jayant      Mehta,
                                                                          Mr.Samar Singh Kachwaha,
                                                                          Mr.Raghavendra Bajaj, Ms.
                                                                          Shivangi Nanda, Mr. Agnish
                                                                          Aditya      and       Ms.Anu
                                                                          Srivastava, Advs. for R-1
                                                                          Ms.Priya Kumar, Mr.Adhish
                                                                          Srivastava,         Mr.Tejas
                                                                          Chhabra      &      Mr.Kunal
                                                                          Dhawan, Advs. for R-2.

                                                                   WITH



                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                     Page 1 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                             +        O.M.P.(I)(COMM) 72/2017 & I.A. 2752/2017
                                     ATUL BERI                                .......Petitioner
                                                              Through:   Mr. Arun Kathpalia, Sr. Adv.
                                                                         with    Mr.Jayant    Mehta,
                                                                         Mr.Samar Singh Kachwaha,
                                                                         Mr.Raghavendra Bajaj, Ms.
                                                                         Shivangi Nanda, Mr. Agnish
                                                                         Aditya      and     Ms.Anu
                                                                         Srivastava, Advs.

                                                          Versus
                                     DEEPAK BERI & ORS                               ......Respondents
                                                   Through:              Mr. Sandeep Sethi, Sr.
                                                                         Advocate with Mr.Akshay
                                                                         Makhija, Mr.Saurabh Seth,
                                                                         Ms.Sumeera     Seth    and
                                                                         Mr.Siddhanth Kumar, Advs.
                                                                         for R-1
                                                                         Ms.Priya Kumar, Mr.Adhish
                                                                         Srivastava,        Mr.Tejas
                                                                         Chhabra     &     Mr.Kunal
                                                                         Dhawan, Advs. for R-2.

                                                              WITH

                            +       O.M.P.(I)(COMM)      396/2018,     I.A.  9515/2019,               I.A.
                                    10747/2019, I.A.11914/2019, I.A. 11915/2019

                                     ATUL BERI                                         ........Petitioner
                                                              Through:   Mr. Arun Kathpalia, Sr. Adv.
                                                                         with    Mr.Jayant    Mehta,
                                                                         Mr.Samar Singh Kachwaha,
                                                                         Mr.Raghavendra Bajaj, Ms.
                                                                         Shivangi Nanda, Mr. Agnish
                                                                         Aditya      and     Ms.Anu
                                                                         Srivastava, Advs.

                                                          Versus
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                    Page 2 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                                      DEEPAK BERI & ORS.                              .......Respondents
                                                   Through:              Mr. Sandeep Sethi, Sr.
                                                                         Advocate with Mr.Akshay
                                                                         Makhija, Mr.Saurabh Seth,
                                                                         Ms.Sumeera     Seth    and
                                                                         Mr.Siddhanth Kumar, Advs.
                                                                         for R-1
                                                                         Ms.Priya Kumar, Mr.Adhish
                                                                         Srivastava,        Mr.Tejas
                                                                         Chhabra     &     Mr.Kunal
                                                                         Dhawan, Advs. for R-2.

                                                              WITH

                            +        I.A. 10911/2018, I.A. 13916/2018, I.A. 13917/2018, I.A.
                                     16532/2018, I.A. 16971/2018, I.A. 16972/2018, E.A.
                                     562/2019, E.A. 563/2019, I.A. 2074/2019, I.A. 3600/2019,
                                     I.A. 7325/2019, I.A. 8455/2019, I.A. 9977/2019,     E.A.
                                     25/2020,E.A. 26/2020, E.A. 418/2020, E.A.419/2020, E.A.
                                     430/2020, E.A. 533/2020, E.A. 534/2020, E.A. 543/2020,
                                     E.A. 544/2020 IN O.M.P(ENF)(COMM) 187/2018

                                     DEEPAK BERI                                      ........Petitioner
                                                              Through:   Mr. Sandeep Sethi, Sr.
                                                                         Advocate with Mr.Akshay
                                                                         Makhija, Mr.Saurabh Seth,
                                                                         Ms.Sumeera     Seth    and
                                                                         Mr.Siddhanth Kumar, Advs.

                                                          Versus
                                     ATUL BERI                                        .......Respondents
                                                              Through:   Mr. Arun Kathpalia, Sr. Adv.
                                                                         with    Mr.Jayant     Mehta,
                                                                         Mr.Samar Singh Kachwaha,
                                                                         Mr.Raghavendra Bajaj, Ms.
                                                                         Shivangi Nanda, Mr. Agnish
                                                                         Aditya      and      Ms.Anu
                                                                         Srivastava, Advs.

                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                    Page 3 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                                                    WITH
                             +O.M.P.(ENF.)(COMM) 117/2019, CCP(O) 71/2019, E.A.
                             910/2019, E.A. 911/2019, I.A. 9592/2019, E.A. 305/2020,
                             E.A.306/2020

                            ATUL BERI                                                 ......Petitioner
                                                              Through:   Mr. Arun Kathpalia, Sr. Adv.
                                                                         with    Mr.Jayant    Mehta,
                                                                         Mr.Samar Singh Kachwaha,
                                                                         Mr.Raghavendra Bajaj, Ms.
                                                                         Shivangi Nanda, Mr. Agnish
                                                                         Aditya      and     Ms.Anu
                                                                         Srivastava, Advs.

                                                              Versus
                             DEEPAK BERI & ORS                                       .....Respondents
                                                              Through:   Mr. Sandeep Sethi, Sr.
                                                                         Advocate with Mr.Akshay
                                                                         Makhija and Mr.Saurabh
                                                                         Seth, Ms.Sumeera Seth, and
                                                                         Mr.Siddhanth Kumar, Advs.
                                                                         for R-1
                                                                         Ms.Priya Kumar, Mr.Adhish
                                                                         Srivastava,        Mr.Tejas
                                                                         Chhabra      &    Mr.Kunal
                                                                         Dhawan, Advs. for R-2.

                      CORAM:
                      HON'BLE MS. JUSTICE REKHA PALLI

                      REKHA PALLI, J

                      1.    The present decision deals with five petitions filed before this Court;
                      two execution petitions seeking enforcement of the Arbitral Award dated
                      02.08.2016 along with three petitions filed under Section 9 of the
                      Arbitration and Conciliation Act, 1996 (hereinafter referred to as 'the Act').

                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                    Page 4 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                       2.    For the sake of convenience, the parties will hereinafter be referred to
                      by their names. The facts in brief, relevant to the purpose of the present
                      decision, are as follows:
                            i.      The parties to these petitions are two brothers, Mr. Deepak Beri
                             and Mr. Atul Beri, and their aged father, Mr. S.K. Beri; the brothers
                             are feuding about the division of business assets belonging to the
                             Beri family. In the early 1950's, Mr. S.K. Beri set up various
                             companies engaged in the industry of manufacture and sale of
                             industrial knives in the country and his business comprised of two
                             incorporated companies, the flagship concern M/s DB Engineering
                             Pvt. Ltd, ('DBEPL') and M/s Banaras Marbles & Granite Ltd.
                             ('BMGL'), as also two partnership firms, namely S.K. Beri & Bros.
                             ('SKB') and DB Company ('DBC'). All the four entities are closely
                             held family concerns and do not have any outside shareholder. These
                             businesses thrived with the passage of time and Mr. S.K. Beri, in the
                             year 1982, inducted his two sons to join him with the fond hope that
                             the business empire would grow and expand with their participation.
                             The businesses were operating from the following premises:
                                            (i)   A-119, Okhla Phase-II, Delhi;
                                            (ii)  B-113, 114, 115, 131, 132, Sector 6, Noida,
                                                  Uttar Pradesh;
                                            (iii) F-61, Sector 11, Noida, Uttar Pradesh;
                                            (iv)      C-27, Sector 59, Noida, Uttar Pradesh;
                                            (v)       A-32, Sector 64, Noida, Uttar Pradesh;
                                            (vi)      B-1, Sector 68, Noida, Uttar Pradesh;
                                            (vii) C-57, Phase-II, Noida, Uttar Pradesh; and
                                            (viii) Plot at C-12, Ecotech-11, Greater Noida,
                                                   Uttar Pradesh
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                        Page 5 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                            ii.      However, Mr. S.K. Beri found his hopes of a united family
                             concern dashed in the light of growing differences and acrimony
                             between his sons, each of whom accused the other of siphoning off
                             funds from the family businesses for their personal greed. Against
                             this backdrop of growing familial conflict, Mr. SK Beri, in the year
                             2014, began contemplating the idea of dividing the businesses
                             between the brothers in order to achieve a quietus in these disputes.
                             As a result, on 20.01.2016, Mr. S.K. Beri, Mr. Deepak Beri and Mr.
                             Atul Beri entered into a mediation-cum-arbitration agreement
                             whereunder a Chartered Accountant, Mr. Manoj Nagrath, was
                             appointed as the mediator/arbitrator to resolve the disputes between
                             them.
                          iii.      In terms of the mediation-cum-arbitration agreement, Mr.
                             Nagrath was firstly required to endeavour resolving the disputes by
                             way of mediation which, at that stage, had appeared to be successful
                             and fruitful, culminating in three separate agreements. The first
                             agreement was the Memorandum of Understanding (MoU) executed
                             on 17.02.2016 and signed by the two brothers and their father, which
                             contemplated the division of the businesses. This was followed by a
                             second agreement executed on 14.03.2016 or the 'Minutes of
                             Meeting' which was signed between the father and the arbitrator,
                             Mr. Nagrath; these Minutes set out the detailed mode of division of
                             the businesses and while the document was not signed by the two
                             brothers, it was accepted by them. The last document is the Deed of
                             Arrangement dated 30.04.2016 signed between the two brothers and
                             their father and, collectively, these three agreements shall be referred
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                 Page 6 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                             to as the 'family settlement' agreements. Although a detailed
                            reference to the terms of these family settlement agreements will be
                            made later, it may be useful to sum up the manner in which the
                            parties agreed to divide ownership of the businesses:
                                 A. The two incorporated companies, M/s DB Engineering Pvt.
                                       Ltd, ('DBEPL') and M/s Banaras Marbles & Granite Ltd.
                                       ('BMGL'),were allocated to Mr. Atul Beri, to the exclusion of
                                       Mr. Deepak Beri,
                                 B. The two partnership entities, S.K. Beri & Bros. ('SKB') and
                                       DB Company ('DBC'), were allocated to Mr Deepak Beri, to
                                       the exclusion of Mr. Atul Beri.
                                 C. Mr. S.K. Beri, their father, retained 50% ownership in all the
                                       four business entities.
                           iv.         Since DBEPL, falling in the share of Mr. Atul Beri, was the
                           flagship company of the family business and had more assets than any
                           of the three other business entities, the parties agreed that certain
                           assets belonging to DBEPL, which included three of its six
                           immovable properties, would be allocated in the name of Mr. Deepak
                           Beri. This is how the properties came to be divided between the
                           brothers:

                                 S.               Property           Allocated to    Corresponding
                                 No.                                                    Clause
                                 1      B-113, 114, 115, 131, 132,        -         Clause 2 of the
                                        Sector 6, Noida owned by                    MoU.
                                        DBC to remain with Mr.
                                        Deepak Beri
                                 2      C-27, Sector 59, Noida Mr. Deepak Beri Clauses 2 and 16
                                        belonging to DBEPL*    for the operations of the MoU.
                                                               of his concern

                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                    Page 7 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                                                                     SKB.
                              3       A-32, Sector 64, Noida, Mr. Deepak Beri Clause 2 and 16
                                      belonging to DBEPL      for the operations of the MoU.
                                                              of his concern
                                                              SKB.
                              4       A-119, Okhla Phase-II,               -          Clause 2 of the
                                      belonging to SKB to remain                      MoU.
                                      with Mr. Deepak Beri


                              5       B-1, Sector 68, Noida                -          Clause 4 of the
                                      belonging to DBEPL to                           MoU.
                                      remain with Mr. Atul Beri.


                              6       F-61, Sector 11, Noida               -          Clause 4 of the
                                      belonging to DBEPL to                           MoU
                                      remain with Mr. Atul Beri.
                              7       C-57,    Phase-II,   Noida           -          Clause 4 of the
                                      belonging to BMGL to                            MoU
                                      remain with Mr. Atul Beri*
                              8       Plot at C-12, Ecotech-11, Mr. Atul Beri for Clause 4 of the
                                      Greater Noida             the use of his MoU
                                                                concern BMGL
                              * Since the unit at these premises was to be made functional, Mr. Atul Beri
                              had to be paid a sum of INR 7.50 crores in tranches for that purpose under
                              Clause 5 of the MoU. He was also to be paid a sum of INR 1 crore under
                              Clause 15 of the MoU to compensate for the difference in valuation of the
                              assets allocated to him and his brother.



                             v.     In the light of these agreements, Mr. Nagrath proceeded to
                             issue certain directions by way of an award dated 02.08.2016
                             incorporating all the three settlement agreements, along with some
                             additional directions which he felt were essential to effect the terms
                             and conditions of the family settlement.

                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                       Page 8 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                              vi. A week later, on 10.08.2016, Mr. Deepak Beri instituted a
                             petition under Section 9 of the Act, being OMP(I) COMM 326/16
                             (captioned herein) before this Court seeking inter alia directions to
                             restrain his brother and father from derogating the terms of the
                             agreements and to take all necessary steps to ensure smooth
                             functioning of all the units. This Section 9 petition filed in 2016 also
                             sought appointment of a receiver to take charge of the account
                             books of the four business entities, their stock registers, their email
                             services and their domain names etc., as also the record of orders
                             placed on them, along with details of any unsold stock lying in the
                             concerned premises. In August 2016 itself, when this petition was
                             pending consideration, Mr. S.K. Beri and Mr. Atul Beri assailed the
                             award dated 02.08.2016 by preferring petitions under Section 34 of
                             the Act, being OMP(COMM) 382/2016 and 396/2016. Thereafter,
                             on 09.02.2017, Mr. Atul Beri also filed a petition under Section 9 of
                             the Act, being OMP (I) COMM 72/17 (captioned herein) seeking
                             inter alia a direction to Mr. Deepak Beri to refrain from diverting
                             any business, customers, receipts stock manpower material etc. of
                             any of the four business entities to any other private concern. In this
                             petition, for the very first time, a specific reference was made to M/s
                             Marvel Engineering and Trade Pvt. Ltd. and M/s DB Engineering
                             solutions LLP, allegedly run by Mr. Deepak Beri and his family
                             members, insofar as a direction was sought to restrain them from
                             carrying on business in these names.
                             vii. In the meanwhile, when the Section 34 petitions were taken up
                             by this Court, Mr. S.K. Beri contended that although he was not a
                             party to the arbitration proceedings, the award included certain
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                 Page 9 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                              directions against him which were wholly unwarranted and
                             surpassed the terms of the settlement agreements executed between
                             the parties. Similarly, Mr. Atul Beri opposed the award as well by
                             challenging the decision of the learned Arbitrator to issue directions
                             which travelled beyond the parameters of the family settlement
                             agreements and did not follow a due process of law. On 31.05.2018,
                             a Coordinate bench of this Court partly allowed the two Section 34
                             petitions by upholding the award insofar as it adhered to the family
                             settlement agreements. The Court, after observing that these family
                             settlement agreements had been voluntarily entered into between
                             Mr. S.K. Beri, Mr. Deepak Beri and Mr. Atul Beri, proceeded to set
                             aside all directions issued by the learned Arbitrator which exceeded
                             the terms of the agreements. Since the judgment dated 31.05.2018
                             was not assailed by any of the parties, it has attained finality as on
                             date and the award stands modified to such extent as directed.
                             viii. Shortly after the award attained finality in its modified form, on
                             08.08.2018, Mr. Deepak Beri filed the captioned enforcement
                             petition OMP(Enf)(Comm) 187/2018 wherein, besides praying for
                             appointment of an Observer to effect implementation of the
                             remaining terms of the settlement agreement, he sought appointment
                             Receiver to take complete charge of all aspects of the businesses
                             which fell in his brother Atul's share, viz. DBEPL and BMGL, and
                             a forensic audit into the funds and assets thereof. A further prayer
                             was sought to restrain Mr. Atul Beri and Mr. SK Beri from acting in
                             contravention of the three settlement agreements. A month later,
                             Mr. Atul Beri preferred a Section 9 petition on 27.09.2018, being
                             OMP(I) COMM 396/18 (captioned herein), primarily seeking
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                 Page 10 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                              injunctions against Mr. Deepak Beri from acting on behalf of
                             DBEPL and BMGL, the companies which fell in his share, as also
                             against certain employees, who were allegedly employed by Mr.
                             Deepak Beri, from claiming any wages from and/or initiating any
                             legal proceedings against Mr. Atul Beri's DBEPL before any Court
                             or Tribunal on the ground of non-payment of salaries. Finally, on
                             16.07.2019, Mr. Atul Beri also moved his own enforcement petition
                             OMP(Enf)(Comm) seeking enforcement of the award dated
                             02.08.2016, as modified by the judgment dated 31.05.2018. Thus, in
                             these proceedings, both parties are seeking execution of the award
                             as it stands modified by way of the judgment dated 31.05.2018
                             which only calls for enforcement of the terms of the three settlement
                             agreements.
                             ix. These two enforcement petitions under Section 36 of the Act,
                             along with the three Section 9 petitions, have remained pending
                             before this Court for the last several years, during the course
                             whereof certain interim orders have been passed from time to time.
                             One of these interim directions were issued on 03.01.2017 by this
                             Court, in response to the grievance of Mr. Deepak Beri that while
                             the enforcement was still pending adjudication, Mr. Atul Beri had
                             opened new bank accounts in the names of DBEPL without
                             informing him in his capacity as a Director thereof and had also
                             proceeded to transfer some amounts to his personal accounts and
                             those of his son. Accordingly, this Court appointed a Court
                             Commissioner and a Chartered Accountant to inspect and file a
                             report on all the premises owned by the four family concerns as also
                             the LLP privately owned by Mr. Deepak Beri. The Court
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                               Page 11 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                              Commissioner initially filed interim reports on 17.01.2017,
                             14.04.2017, 25.04.201, which were followed by a comprehensive
                             final report filed on 15.05.2017, setting out the status of inter alia
                             accounts, records pertaining to statutory liabilities, inventory of
                             pending orders, stocks, plants & machineries, raw materials,
                             employees in the different businesses and the premises as well. The
                             data in this report was to include a separate list of machines which
                             were earmarked to be transferred to the other units/entities in terms
                             of the settlement agreements. Notwithstanding the submission of
                             these reports, the matter remained pending and on 01.11.2018, this
                             Court once again observed that the best way to proceed further in
                             the matter was to ensure division of assets in terms of the award.
                             Apparently, barring the inspections carried out in the years 2017 and
                             2018, the premises of these four business entities have never been
                             inspected. Therefore, today, the parties remain at the same position
                             as they were at the time of filing of these enforcement petitions.
                      3.    In support of his case that the separation of the assets and businesses
                      is yet to take place in terms of the settlement agreements, learned senior
                      counsel for Mr. Deepak Beri, Mr. Sandeep Sethi has made the following
                      submissions -
                             i.     With passage of time, Mr. Deepak Beri realised that Mr. Atul
                              Beri was siphoning off assets of the family businesses. This led to
                              friction between the brothers and they could no longer carry on the
                              family businesses together. As a result, they were constrained to
                              contemplate partition of the family concerns and, to that effect,
                              executed the arbitration agreement on 20.01.2016. This brought in
                              Mr. Nagrath to mediate the disputes between them, which led to the
                    OMP(I)(COMM)326-2016 & connect. matters
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DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                               execution of the three agreements forming the family settlement
                              today. These three agreements, undoubtedly, contemplated division
                              of the assets, which division was then to be followed by a complete
                              separation, to be effected as per the steps postulated in the
                              agreements and preceded the separation. These agreements also
                              display that the intent of the parties was to pool the assets of the
                              family business and then divide them equally between the two
                              brothers, while the father remained equal shareholder/partner in all
                              the business entities. When the parties were drawing up the MoU
                              and      minutes       of meeting   on   17.02.2016   and    14.03.2016
                              respectively, they fixed dates for effecting various steps towards
                              separation including preparation of inventory of raw material, stock
                              and machinery, division of employees and logos etc., as they were
                              hopeful that by the time the final document, i.e., the deed was
                              executed on 30.04.2016, the division would have taken place and a
                              smooth separation would thereafter follow. Unfortunately, by the
                              time the Deed was signed on 30.04.2016, the parties had realised
                              that it was not possible to adhere to the dates agreed upon, which
                              then inspired the final clause (34) in the Deed which states that this
                              date was variable. However, the parties were always ad idem that
                              till division takes place according to the various steps envisaged in
                              the three agreements, there was no question of any separation
                              between them. This common intent of the parties can be easily
                              gleaned from the language of the three settlement agreements.
                              Further, in the light of the decisions in Bhavan Vaja & Ors. Vs.
                              Solanki Hanuji Khodaji Mansang & Anr. (1973) 2 SCC 40 and
                              Deep Chand & Ors. Vs. Mohan Lal (2000) 6 SCC 259, it is settled
                    OMP(I)(COMM)326-2016 & connect. matters
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DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                               that this Court, as an executing court, has to consider the true effect
                              of the three agreements in the light of all surrounding
                              circumstances rather than arriving upon its decision on mere
                              technicalities. Moreover, considering the decisions in Kale & Ors.
                              Vs. Deputy Director of Consolidation & Ors. (1976) 3 SCC 119
                              and Hari Shankar Singhania Vs. Gaur Hari Singhania & Ors.
                              (2006) 4 SCC 658, one has to bear in mind that these agreements
                              are essentially family settlements which are placed on a far
                              different footing than commercial agreements. Thus, rather than
                              adopting a hypertechnical consideration while regarding them,
                              these agreements and the terms thereof should be given effect to in
                              letter as well as spirit. On doing so, it would become apparent that
                              the parties had agreed to first divide and separate the businesses,
                              following which they would recognise and appoint a date of
                              separation. Thus, they had always intended to undertake physical
                              division of the businesses first and follow it up by agreeing upon a
                              Date of Separation. This implies that despite the date of 30.06.2016
                              being mentioned in all the three settlement agreements, this was
                              purely a tentative date. The prayer of Mr. Atul Beri seeking for a
                              declaration from this Court that the Date of Separation had been set
                              out as 30.06.2016 under the agreements is in blatant contravention
                              of the terms of the settlement agreed upon between the parties. The
                              settlement agreements contemplate a separation in presenti and not
                              in relation back to a purportedly agreed Date of Separation. If this
                              Court were to adopt the interpretation supported by Mr. Atul Beri
                              and hold that the agreements contemplate a Date of Separation to
                              be fixed first, which would then be followed by distribution and
                    OMP(I)(COMM)326-2016 & connect. matters
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                               separation of assets with reference to an earlier date, the same
                              would be at divergence with the settlement sought to be enforced in
                              these proceedings.
                           ii.      Contrary to the submissions of Mr Atul Beri and Mr. S.K. Beri,
                              no division has taken place since the parties have not even
                              completed the major steps required to be taken towards separation.
                              The three agreements are self-explanatory in that each of them
                              requires the parties to complete certain steps by certain dates, all of
                              which are much prior to 30.06.2016. However, since a majority of
                              these steps have not been effected, there is no question of a Date of
                              Separation coming into play. Even an affidavit filed by Mr. Atul
                              Beri in the Section 9 petition state that most of the steps required to
                              be taken for the division have not yet taken place and, thus, even he
                              has admitted that no separation has taken place. The fact that no
                              separation has taken place is also evident from the various orders
                              passed by this Court during the hearing of the present petitions. To
                              begin with, on 15.12.2016, not only had the Court asked the parties
                              to suggest steps which were yet to be carried out to effectuate the
                              division, but it had also appointed a Court Commissioner and
                              Chartered Accountant on 03.01.2017 in order to prepare a complete
                              inventory of the raw materials, stocks, employees, logos, etc;
                              however, in none of these orders did the Court direct any of the
                              processes to be effected keeping in mind the Date of Separation as
                              30.06.2016, yet Mr. Atul Beri did not assail these orders on that
                              ground. Next, the report eventually filed by the Court
                              Commissioner on 15.05.2017 shows that Mr. Atul Beri had tried to
                              obstruct the Court Commissioner and, clandestinely, shifted goods
                    OMP(I)(COMM)326-2016 & connect. matters
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                               and machinery for his benefit from one business premises to
                              another. That apart, this report also happened to be the most
                              comprehensive exercise with respect to the businesses in question
                              and also showed that the division is yet to take place. In fact, when
                              the parties were unsuccessful in their original intent to separate by
                              30.06.2016, they were hit by a deluge of litigations instituted by
                              Mr. Atul Beri before this Court against the award dated 02.08.2016
                              [OMP(COMM.) 396/2016], which further delayed implementation
                              of the award and the formal partition of the family businesses. As
                              on date, post-award, Mr. Deepak Beri has only received 10% of the
                              assets falling in his share under the settlement while Mr. Atul Beri
                              has been using the remaining assets, which has caused irreparable
                              loss to Mr. Deepak Beri. Thus, if this Court were to pay heed to the
                              steps effected by the parties so far, it would be evident that Mr.
                              Deepak Beri has not even received his half of the share in the
                              family businesses. Any claims of Mr. Atul Beri to the effect that
                              most of the steps towards separation have been carried out are
                              completely baseless, unsubstantiated and devoid of material proof.
                              To make matters worse, over the past four years, Mr. Atul Beri has
                              made huge profits by using the assets, more particularly, the
                              machinery and premises which were to come to Mr. Deepak Beri's
                              share and moved some of this machinery to his personal entities.
                              Owing to the unrestrained scheming of Mr. Atul Beri, Mr. Deepak
                              Beri has suffered an estimated loss in profits/business to an
                              approximate tune of Rs.64 crores, which ought to be recovered
                              from Mr. Atul Beri after directing him to hand over 50% of family
                              assets to Mr Deepak Beri in accordance with the family settlement
                    OMP(I)(COMM)326-2016 & connect. matters
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                               arrangement, the value whereof should be approximately Rs.130
                              crores. Having wrongfully continued to hold on and profit from
                              assets of the family businesses which were never his and deprived
                              Mr. Deepak Beri of his share thereto for the last four years, it is not
                              open for Mr. Atul Beri to now contend that the division has already
                              taken place from a backdated Date of Separation. Rather, the award
                              ought to be executed immediately since Mr. Atul Beri is continuing
                              to enjoy the assets which fell in the share of Mr. Deepak Beri as per
                              the terms of the three family settlements. For all these reasons, this
                              Court must appoint a Court Commissioner in order to freshly
                              ascertain the status of assets of the family concerns and draft a plan
                              to divide them in terms of the agreements between the parties.
                              Considering the large scale siphoning off of funds and assets by
                              Mr. Atul Beri, it is further prayed that this Court be pleased to
                              direct a forensic audit to be conducted into the finances and assets
                              of the family businesses, as they existed on 30.06.2016.
                      4.    On the other hand, Mr.Arun Kathpalia, learned senior counsel
                      appearing for Mr. Atul Beri has made the following submissions:
                             i.     A cumulative reading of the three settlement agreements shows
                              that the process of separation which began with the MoU on
                              17.02.2016 was to end on 30.06.2016 with a final separation of all
                              business, whereafter the businesses would retain independent
                              existence. The very first document, i.e., the MoU refers to the date
                              of separation as 30.06.2016 during the course of the document.
                              Although the Minutes contemplated a separation by March-April
                              2016, when this could not come to pass, the Deed stepped in to
                              provide the last date of separation as 30.06.2016. This date of
                    OMP(I)(COMM)326-2016 & connect. matters
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                               30.06.2016 has been referred to as a 'fixed' date of separation in
                              the Deed, which meant that it could never be changed, except at the
                              instance of the arbitrator, Mr. Nagrath. Based on these terms, when
                              the award was finally passed on 02.08.2016 by the learned
                              Arbitrator, he also did not bother to change the date of separation in
                              his award, which meant that the date had become binding on the
                              parties with immediate effect. By relying on the decision in M/s
                              Creative Travels Pvt. Ltd. Vs. Joginder Singh Palta 1994 (28)
                              DRJ (DB), it is submitted that the consent of the parties on the
                              aspect of this date of separation, as gleaned from the settlement
                              agreements, assumes primacy and cements its binding nature. That
                              was only strengthened further by the award passed by the learned
                              Arbitrator. Therefore, at this stage, when the parties are merely
                              seeking enforcement of the family settlement agreements, this
                              Court cannot deviate from the general consensus of the parties
                              contained in those agreements. Reliance has been placed on the
                              decisions in C.F. Angadi Vs. Y.S. Hirannayya (1972) 1 SCC 1914,
                              Gurdev Singh Vs. Narain Singh (2007) 14 SCC 173, Deepa
                              Bhargava Vs. Mahesh Bhargava (2009) 2 SCC 294, and State of
                              Punjab vs. Krishan Dayal Sharma (2011) 11 SCC 212, to submit
                              that once the deed of arrangement clearly demarcated 30.06.2016
                              as the date of separation, or any other date to be decided by the
                              learned Arbitrator, an executing Court cannot embark on the
                              process of fixing a new cut-off date. In fact, as per an express
                              stipulation contained in the Deed, the only way for the parties to
                              alter this date was by approaching the learned Arbitrator who was
                              the only entity empowered under the settlement agreement to make
                    OMP(I)(COMM)326-2016 & connect. matters
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                               a 'decision' and set down further terms and conditions on this
                              aspect. Thus, it was incumbent upon Mr. Deepak Beri, who was
                              under the purported belief that separation had not taken place, to
                              approach the learned Arbitrator at any time before the award was
                              passed on 02.08.2016 to have a date of separation fixed. In the
                              alternative, when this Court was dealing with the Section 34
                              petitions, Mr. Deepak Beri ought to have sought remittance of the
                              award to the learned Arbitrator for fixing of a fresh cut-off date by
                              moving an appropriate application under Section 34(4) of the Act.
                              However, Mr. Deepak Beri neither moved an application seeking
                              change of date before the learned arbitrator before or after the
                              passing of the award nor has he challenged the award on this
                              ground till date. By placing reliance on the decision in Barkat Ali
                              & Anr. Vs. Badrinarain (Dead) by LRs (2008) 4 SCC 615), it is
                              submitted that since Mr. Deepak Beri had made no such plea either
                              before the learned Arbitrator or before the Court, he cannot now
                              deny that that the separation did not take place on 30.06.2016 or
                              that the date of separation was not sacrosanct. Be that as it may, it
                              is a fact that Mr. Deepak Beri has categorically admitted in
                              Paragraph 7 of his Section 9 petition OMP(I)(COMM)326/2016
                              filed before this Court that as per the memorandum of
                              understanding, the date of separation was to be 30.06.2016.
                              Rather, all pleadings of Mr. Deepak Beri reveal that even as per his
                              understanding, the date of separation was 30.06.2016. This, in
                              itself, is further proof of the fact that the Date of Separation was
                              always 30.06.2016.


                    OMP(I)(COMM)326-2016 & connect. matters
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                            ii.      Not only did the parties agree upon 30.06.2016 as the date of
                              separation but they also effectively separated on this date, albeit
                              they left a few minor steps to complete the process. The brothers'
                              reason for executing the memorandum of understanding on
                              17.02.2016 was to facilitate a peaceful separation of the businesses
                              by envisaging seamless division of the following major business
                              components:
                                          A.       immovable and movable assets, including plant,
                                                   machineries and the eight premises.
                                          B.       employees
                                          C.       customers/orders
                                          D.       intellectual property, including software and logos
                              Thus, on 17.02.2016 itself, they were conscious that the businesses
                              sought to be divided were live businesses with various long
                              standing customers and, therefore, the separation had to be carried
                              out delicately to ensure that no harm would be caused to any of the
                              concerns. On 14.03.2016 when the minutes of the meeting were
                              recorded, it was resolved to divide the plants, machineries, staff,
                              logos, and pending orders amongst the two brothers. It was also
                              resolved to send a common e-mail to all customers about the
                              impending separation, which was carried out. Ultimately, they were
                              hoping that all these steps and efforts they were taking would result
                              in a peaceful separation by 30.04.2016. When this did not come to
                              pass, they executed the Deed on 30.04.2016 which exclusively
                              catered to the transition period, i.e., the short intervening period of
                              two months between 01.05.2016 and 30.06.2016. They were
                              hoping to spend this period finalising and completing the steps
                    OMP(I)(COMM)326-2016 & connect. matters
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                               required for eventual separation and had placed an embargo on
                              themselves from engaging in negative marketing with respect to
                              any business entity falling in the share of either brother or inform
                              the clients of the impending separation at that stage. Both brothers
                              were given independence in operation during this period insofar as
                              the orders and marketing was concerned, however since they were
                              sharing the available raw material till 30.06.2016, they were
                              obligated to share all documents in this respect and maintain
                              transparency in their records with respect to the orders received
                              from the period between 01.05.2016 and 30.06.2016. To further
                              their independent operations, the brothers also divided all serving
                              employees            between    them   w.e.f.   01.05.2016.   Pursuant         to
                              30.06.2016, since both brothers have been carrying out their
                              businesses not only independently, but also in competition with
                              each other, the separation can be regarded as already having taken
                              place. However, the following minor steps in this regard have been
                              left incomplete on account of the non-cooperation of Mr. Deepak
                              Beri:
                                             (i)      Formal documentation has not been completed
                                             (ii)     Small component of assets which are left to be
                                                       divided
                                             (iii)    Account statements have not been drawn up.
                              Thus, merely because some minor steps remained incomplete or
                              because Mr. Deepak Beri had refused to comply with his
                              obligations under the settlement, cannot be a ground to deny the
                              established fact that the parties had agreed to treat 30.06.2016 as
                              the official date of separation.
                    OMP(I)(COMM)326-2016 & connect. matters
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                           iii.      In furtherance of the aforesaid contention, it is submitted that
                              the separation was not only envisaged, but has also been mostly
                              effected with a few minor steps remaining in the process to
                              conclude their settlement. The brothers have indeed been operating
                              their businesses independently of each other, in accordance with
                              the three agreements, which is evident from the following facts:
                            A.     Being a practice which began during the transition period, the
                                   brothers have not had visibility with respect to each others'
                                   businesses          and    have   been   handling      clients      and
                                   executing/seeking orders independently of each other. After
                                   crossing the mark of 30.06.2016, their businesses have gone
                                   their separate ways, are no longer transparent to each other and,
                                   rather, are in competition as on date. Even the sales and
                                   marketing teams of the business entities stood divided between
                                   the brothers and operate separately as on date.
                             B.     An important stipulation under the settlement was that Mr.
                                    Deepak Beri was prohibited from using the brand 'Atlas
                                    Knives' for a period of two years from the date of separation,
                                    which he did and has now admittedly begun using the brand
                                    once again, which is tacit proof of the separation.
                             C.     The white collar employees were divided in accordance with
                                    the terms of the settlement by giving them an option to choose
                                    whether they wanted to work for Mr. Atul Beri or Mr. Deepak
                                    Beri. Consequently, the employees stood divided and were sent
                                    to work in the entities run by the brother of their choice. This is
                                    evident from the fact that erstwhile DBEPL employees, who
                                    opted to work in the businesses falling in the share of Mr.
                    OMP(I)(COMM)326-2016 & connect. matters
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Signing Date:25.12.2020
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                                     Deepak Beri, viz. Mr. Rohit Bakshi, Mr. Raman Raina and five
                                    other persons, have been sending email correspondences on
                                    behalf of M/s. Marvel Interiors and Traders Pvt. Ltd., an
                                    independent business entity run by Mr. Deepak Beri.
                             D. Although the settlement granted Mr. Atul Beri a sum of Rs.7.5
                                    crores to set up a functional unit in BMGL, this amount has not
                                    been paid and, therefore, even though the premises at Sector-64
                                    which were to go to the share of Mr. Deepak Beri has not been
                                    handed over to him, he has been carrying out independent
                                    business in other three premises i.e. A-99, Okhla Industrial
                                    Area, Sector-6, Noida, Section-59, Noida. Mr. Deepak Beri is
                                    not only carrying out the business of SKB and DBC, but he is
                                    also heading the businesses being run by his son in the very
                                    same premises.
                             E.     Further, from a reading of clauses 1, 3, 4, 5, 7 to 9, 13 to 17, 19
                                    to 28, 34, 35 and 38 of the MoU, it is evident that the parties
                                    had envisaged that in the transition period preceding
                                    30.06.2016, all transactions carried out by any of the family
                                    businesses were to be recorded in the books of accounts of the
                                    concerned entity with the approval of all the four parties i.e. the
                                    two brothers, their father and the Arbitrator. It is also evident
                                    that the parties agreed to share all expenses, profits and assets
                                    till they were jointly conducting the businesses, whereafter they
                                    would carry out the businesses separately. Today, the brothers
                                    neither share the expenses of their respective businesses nor
                                    record the transactions in the arrangement as set out by them.


                    OMP(I)(COMM)326-2016 & connect. matters
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                                 Thus, since most of the steps towards separation as set down by the
                                agreements have been effected, the separation is in effect for all
                                intent and purposes. In this regard, reliance has been placed on the
                                decisions in Re: Cumana Ltd.[1986] BCLC 430, Scottish
                                Wholesale Cooperative Society Vs. Meyer & Anr. [1959]A.C.324.
                                Even though, the assets stand largely divided, there is one major
                                step which still needs to be carried out as on date, i.e., for the
                                parties to draw up accounts as on 30.06.2016. Mr. Atul Beri has
                                prayed for the appointment of a Court Receiver to draw up the
                                accounts of all the business entities as they existed on 30.06.2016,
                                by using the admitted accounts available with the parties for the
                                FYs 2015-16 as also the four reports of the Court Commissioner.
                      5.    Ms. Priya Kumar learned counsel appearing on behalf of Mr. S.K.
                      Beri, while adopting the arguments made by Mr. Kathpalia, has also made
                      submissions which are best summarised in the following manner:
                           i.    At the time of executing the three documents of separation, Mr.
                                 S.K. Beri had hoped that the division of assets would be smooth,
                                 rather than bitter, which is what it is today amidst the slew of
                                 litigations      between     the   parties.   The   memorandum           of
                                 understanding entered into between the brothers on 17.02.2016
                                 laid the foundation as to how the separation was to be carried out.
                                 Once this foundation was laid, the parties acted in accordance
                                 therewith, but there was always an emphatic and unanimous
                                 agreement upon the fact that 30.06.2016 would be considered as
                                 the cut-off date for separation. It is a matter of record that the
                                 parties have effected most of the steps in terms of the settlement
                                 agreement. This is especially true for Mr. Deepak Beri who has,
                    OMP(I)(COMM)326-2016 & connect. matters
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                                 in the last four years, engaged in transferring the flow of business
                                from SKB and DBC to businesses being run by his own family
                                members, the basis of which transfer lies in the separation itself.
                                In fact, it is a matter of record that the premises of SKB and DBC
                                are being used by him and his son to run their private ventures. It
                                would be deeply egregious to permit Mr. Deepak Beri to continue
                                denying the separation when has actively enriched himself in the
                                last few years on the grounds of this separation. His prayer to
                                move the cut-off date forward had been made with the malafide
                                intent to pool the resources of the family concerns as they stand
                                today, to ease off the liabilities accumulated by his privately run
                                businesses since 30.06.2016. Were the cut-off date to be moved
                                from 30.06.2016, it would further dilute the value of the assets as
                                they stood on that date owing to the liabilities accumulated by the
                                parties since then, in their private capacity. In this regard, reliance
                                has also been placed on the decision dated 13.02.2020 passed by
                                the Supreme Court in Vijay Karia & Ors. Vs. Prysmian Cavi E
                                Sistemi SRL & Ors. (C.A. No. 1544/2020) in support of the plea
                                that the Court cannot overstep the confines of the award; any
                                shifting of the cut-off date from 30.06.2016 would amount to
                                adding or subtracting from the award, which cannot be done by
                                an executing court.
                          ii.   If Mr. Deepak Beri did have any grievance regarding the date of
                                separation, he was required to, and would have most definitely,
                                raised this issue before the learned Arbitrator after the award had
                                been pronounced to seek a change in this date. He neither
                                approached the learned arbitrator, nor adopted this plea before the
                    OMP(I)(COMM)326-2016 & connect. matters
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                                 Court dealing with the Section 34 petition that the Date of
                                Separation was not 30.06.2016. It also cannot be ignored that
                                previously, in the Section 34 petition instituted by Mr. S.K. Beri
                                he had contended that the three settlement agreements were not
                                conclusive, but his argument was rejected in favour of Mr.
                                Deepak Beri's submission that every aspect of the separation
                                stood finalised by these agreements. A necessary corollary thereof
                                is that Mr. Deepak Beri found these agreements to be conclusive
                                even on the aspect of the fixed date of separation. Thus, having
                                taken recourse in this stance in the past to obtain an order in his
                                favour, Mr. Deepak Beri is now estopped from denying that the
                                date of separation was not 30.06.2016 since the division of assets
                                is yet to take place. Mr. Deepak Beri's prayer for fresh fixing of
                                the cut-off date is anyway unsustainable considering all the steps
                                which have been effected so far as also the legal position,
                                summarised in the decision of the Supreme Court in Marshall
                                Sons & Co. (India) Ltd. Vs. Income Tax Officer (1997) 2 SCC
                                302, that cut-off dates in cases involving accounting and division
                                of businesses, are always a date in the past.
                      6.    I have heard learned counsel for the parties and perused the record.
                      Before dealing with the rival contentions of the parties and the issues which
                      arise for consideration, it would be apposite to first note the following
                      aspects on which the parties are ad idem.
                           i.   Disputes had begun cropping up between the parties which
                                resulted in their decision to separate the businesses. For that
                                purpose, the parties appointed an arbitrator on 20.01.2016, under
                                whose initiative, the three agreements, namely the MoU dated
                    OMP(I)(COMM)326-2016 & connect. matters
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                                   17.02.2016, the Minutes dated 14.03.2016 and the Deed dated
                                  30.04.2016 were executed by them, all for the purpose of
                                  finalizing the division of businesses.
                            ii.   Pursuant to these agreements, the parties have taken steps
                                  towards separation, although separation has not been fully
                                  effected.
                           iii.   Neither of the parties ever approached the learned arbitrator,
                                  either before he passed the award on 02.08.2016 or thereafter, or
                                  the Section 34 Court with any requests for clarification with
                                  respect to the Date of Separation.
                      7.     Against this admitted position, I now proceed to note the issues on
                      which the parties are at divergence today. The parties primarily disagree on
                      whether the date of separation was agreed between the parties and fixed as
                      30.06.2016 and what are the consequences of such an agreement. In fact, in
                      the light of the position adopted by both sides that complete separation has
                      not taken place in terms of the settlement agreements and this Court has
                      been approached by both sides by way of the enforcement petitions to get
                      the separation enforced as agreed between the parties, this issue is pivotal in
                      order to proceed any further in these execution proceedings. In fact, even
                      during the course of making their extensive arguments, both sides, including
                      Mr. S.K. Beri, insisted that the issue revolving around the Date of
                      Separation ought be decided first, before any directions pertaining to the
                      separation of businesses are passed.
                      8.     The question, therefore, which needs to be determined before any
                      directions are passed is whether there is already a pre-determined date of
                      separation in these settlement agreement and if yes, what is it? In the


                    OMP(I)(COMM)326-2016 & connect. matters
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                       alternative, if these agreements have not fixed any such date, what should
                      the date be?
                      9.    Before delving into the questions raised in these petitions, I consider
                      it appropriate to briefly revisit the powers of an executing court from the
                      plethora of judgments placed on record by the parties on this aspect.
                                   (i) In Brakewel Automotive Components (India) (P) Ltd. v. P.R.
                            Selvam Alagappan (2017) 5 SCC 371, this Court held as under:

                                     "20. It is no longer res integra that an executing court can neither
                                     travel behind the decree nor sit in appeal over the same or pass any
                                     order jeopardising the rights of the parties thereunder. It is only in the
                                     limited cases where the decree is by a court lacking inherent
                                     jurisdiction or is a nullity that the same is rendered non est and is thus
                                     unexecutable. An erroneous decree cannot be equalled with one which
                                     is a nullity. There are no intervening developments as well to render
                                     the decree unexecutable.

                                     21. As it is, Section 47 of the Code mandates determination by an
                                     executing court, questions arising between the parties or their
                                     representatives relating to the execution, discharge or satisfaction of
                                     the decree and does not contemplate any adjudication beyond the
                                     same. A decree of court of law being sacrosanct in nature, the
                                     execution thereof ought not to be thwarted on mere asking and on
                                     untenable and purported grounds having no bearing on the validity or
                                     the executability thereof." (emphasis supplied)

                            (ii)     In Deepa Bhargava Vs. Mahesh Bhargava (2009) 2 SCC
                            294, the Hon'ble Supreme Court held as under:
                                     "9. There is no doubt or dispute as regards interpretation or
                                     application of the said consent terms. It is also not in dispute that the
                                     respondent judgment-debtors did not act in terms thereof. An
                                     executing court, it is well known, cannot go behind the decree. It has
                                     no jurisdiction to modify a decree. It must execute the decree as it is. A
                                     default clause contained in a compromise decree even otherwise
                                     would not be considered to be penal in nature so as to attract the
                                     provisions of Section 74 of the Contract Act." (emphasis supplied)

                      10.   Thus, to put it simply, an executing court has a very limited function
                      of ensuring that the decree sought to be enforced is executed as it exists. In
                    OMP(I)(COMM)326-2016 & connect. matters
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                       the present case, the modified award forming the subject matter of these
                      proceedings comprises of the three family settlement agreements. All parties
                      herein are ad idem that the terms of these agreements are binding and,
                      therefore, the directions of this Court have to necessarily be within the
                      parameters of their mutual intent set out in these agreements. This gives rise
                      to the question, did the parties envisage a date of separation at the time of
                      their initial talks and incorporate the same in the settlement agreements?
                      Reading this with the fact that both sides have adopted varying
                      interpretations of the three agreements re. the cut-off date, it is necessary for
                      this Court to first determine the date, if any, agreed upon by the parties in
                      the agreements executed between them. If they did, the directions which are
                      to be issued shall depend entirely on this date of separation emerging from
                      these documents. For this reason, it is incumbent for this Court to refer to
                      the terms of these agreements in some detail. Only thereafter can I
                      contemplate issuing any consequential directions to carry out complete
                      separation of the businesses and assets, which both sides agree has not taken
                      place.
                      11.      To begin with, the settlement between the parties was initiated under
                      the canopy of the Memorandum of Understanding executed on 17.02.2016.

                                               Memorandum dated 17.02.2016
                                     "1. Deepak Beri is going to carry on the business under the
                                     name and style of D.B. Engineering Company (DBC) or any
                                     other name, which he may so decide, other than Atlas
                                     Knives, for a period of two years from the date of separation
                                     given hereunder in this MOU.

                                     xxx


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                                     3.    Atul Beri is going to carry on the business in the name
                                    of D.B. Engineering Pvt. Ltd. (DBE), Banaras Marbles and
                                    Granites Ltd., or any other name, which he may so decide.

                                    xxx

                                    5.     In addition to the above, Atul Beri will get a sum of
                                    Rs. 7.5 Crore towards construction and getting the unit
                                    functional situated at Phase II, Noida, which would be paid
                                    to Atul Beri in tranches in consultation with SKB and MN
                                    and they would decide as to how much money would be
                                    given to Atul out of Rs. 7.5 crore each time subject to its
                                    entire disbursement by the date of separation.

                                    xxx

                                    7. Deepak Beri and Atul Beri will share all the statutory and
                                    other liabilities of DBE and all other companies/entities in
                                    which the joint business had been carried on-till the date the
                                    business is being carried on jointly equally and similarly the
                                    profits would also be shared equally. The assets at any
                                    location of the business and in any entity would also be the
                                    property of the Parties till the date of division.
                                    8. Deepak Beri and Atul Beri will also equally share the
                                    following:
                                           a. All intangible assets.
                                           b. All tangible assets including plant and machinery
                                    and inventory and consumables lying at all units.
                                    xxx
                                    16. That prior to 30th June 2016 which is taken to be the
                                    effective date of separation, Sector 59 and Sector 64 will
                                    need to be transferred to DBC or any other entity in which
                                    Deepak would carry on the business subject to the fact that
                                    in such an entity, Deepak Beri & Atul Beri will hold equal
                                    share. At the time of separation on or before 30th June
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                                     2016, shares held by Atul Beri in this entity shall be
                                    transferred to Deepak. This transfer of properties to
                                    Deepak shall be done at the earliest possible date so that
                                    Deepak can proceed with the Bank limits, which he would
                                    have to take afresh.

                                    17. That on the date of separation, all the business entities
                                    would be transferred between Deepak and Atul as decided in
                                    this MoU and for this purpose they shall execute all such
                                    documents then or if need arises thereafter to give effect to
                                    the transfer.

                                    xxx

                                    19. That from this date to the date of separation, all the
                                    transactions will be recorded in the books of account with
                                    the approval of both Deepak Beri & Atul Beri. SKB and MN
                                    taking the cut off date as March 31, 2016, would map the
                                    Debtors and the Creditors till the date of separation.

                                    xxx

                                    24. The employees of DBE will be given an option to remain
                                    in DBE or to move to DBC and their decision will be final.
                                    In case Deepak Beri and Atul Beri jointly wish to terminate
                                    the employment of certain employees of DBE, DBC, SKB &
                                    Bros. they will do so at the earliest, not later than the end of
                                    this month.

                                    25. The compensation payable to the employees who move
                                    from DBE, SKB & Bros. to DBC will be paid by DBE.
                                    Similarly, the compensation due to the employees retained in
                                    DBE will be determined and adjusted as a liability accruing
                                    in DBE to be shared by both Deepak and Atul.

                    OMP(I)(COMM)326-2016 & connect. matters
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                                     26. The issue of transfer of employees has to be handed
                                    sensitively so that they continue to carry on their
                                    employment with DBE and/or DBE. In case there is a
                                    possibility to transfer the employment to DBC without any
                                    compensation on undertaking/other documentation given by
                                    DBC, they will take care to pay the compensation and
                                    employees agreeing to this arrangement, then in such a case
                                    this method will be followed subject to that it is legally
                                    compliant in all respects.

                                    27. All intangible assets i.e. computer software etc., will be
                                    divided equally between the two, Deepak and Atul, and it
                                    there is any cost attached to the transfer of the same to
                                    Deepak or to Atul, then it will be paid by DBE.

                                    xxx

                                    34. That post signing/initialing this document, the nitti
                                    gritties of this broad understanding would be worked out so
                                    that the division of business can effectively take place by 30th
                                    June 2016 or any other date as may be decided mutually by
                                    the two in consultation with Mr. S.K. Beri and Mr. Manoj
                                    Nagrath."

                      12.   The Memorandum dated 17.02.2016 which was the first document
                      executed between the parties pursuant to the mediation/arbitration
                      agreement executed on 20.01.2016 contemplated the division and clearly
                      specified which businesses and assets were to fall in the share of which
                      brother. The said Memorandum served to facilitate a peaceful separation of
                      the businesses by envisaging seamless division of the broad business
                      components, viz., (i) Employees (ii) customers/orders, (iii) intellectual
                      properties including logos and software.

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                       13.   It also emerges that the parties, being conscious that they were
                      seeking to separate businesses which were live, did not wish to separate the
                      businesses abruptly since that would have risked incurring significant harm
                      to these entities. Therefore, while broadly crystallising the steps for
                      separation in the Memorandum, the parties set down 30.06.2016 as the
                      tentative date of separation to provide the parties a transition period for
                      completing the separation. For this reason, it was also agreed that neither of
                      the brothers would engage in any negative marketing with respect to the
                      businesses falling in the share of the other brother nor would either party
                      inform their clientele of the impending separation at that stage. However,
                      this Memorandum clearly indicates that the parties had, on 17.02.2016
                      itself, desired to effect the separation by 30.06.2016, unless the date was
                      changed in consultation with Mr. S.K. Beri and the learned arbitrator.
                      14.   Now coming to the second document, i.e. the Minutes of Meeting
                      dated 14.03.2016, which reads as under:
                                                      Minutes dated 14.03.2016
                                "Name

                                As decided in the MoU, Deepak can use DB Engineering Solutions LLP as an
                                entity to carry on his business and he shall not use the name Atlas Knives as
                                the company name, LLP name, Partnership Firm, Proprietorship Firm,
                                Proprietorship concern or in any manner and also the Domain Name Atlas
                                Knives. This instruction of not using Atlas Knives would be for a period of
                                two years from the date of separation.
                                Plant & Machinery

                                    1. List of Plant & Machinery to be compiled. Deepak & Atul would take
                                       the responsibility of making the list of their respective units and the
                                       task to be finished by 16th March, 2016.
                                    2. Verification of the item of Plant & Machinery to be done by Deepak
                                       and Atul by 17th and 18th March, 2016 positively. Deepak and Atul to
                                       sit with SKB and MN on 19.02.2016 and finalise the distribution of
                                       the plan and machinery.
                    OMP(I)(COMM)326-2016 & connect. matters
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                                     3. The modus operandi would be that two sets as similar as possible
                                       would be made by Deepak (other than the unique items) and they
                                       would be decided by lots/toss.
                                    4. The unique list will be discussed between the two and finalized in all
                                       respects on 19.03.2016. Value to be determined by each one and
                                       highest bidder will take it.
                                    5. Date of dismantling of P & M and commencement of physical transfer
                                       of the same is 21.03.2016 onwards. 21st to 25th AB to take out P & M
                                       and DB from 26th to 31st. The date can be reasonably extended in
                                       case it is practically not possible to do so.
                             Staff
                                 1. List of staff and workers to be finalized by 16.3.2016.
                                 2. Deepak & Atul to jointly identify the Employees whom none
                                    wants on 17.3.2016.
                                 3. Staff at each location would be given and option to opt for
                                    either Deepak or Atul for which they would be called one by
                                    one and made to sign in the Register in front of representative
                                    of MN. This would be done on 18 & 19.3.2016. Workers
                                    would remain in same factory where they are now working
                                    and if they wish to go the other, they would be allowed to go.
                                 4. Compensation to be immediately calculated after the above
                                    exercise is over and to be paid to the Employees, to the extent
                                    possible by 31.3.2016.
                                 5. All the Employees who are to be transferred within different
                                    units would be done at the date of separation.
                             Logo
                           1. Logos to be divided as per MoU on 16th of March, 2016.

                                Orders

                           1. List of Orders in hand to be made available on 15th March 2016.
                              Customer whose orders can be changed from one entity to another
                              to be ascertained by Deepak.
                           2. The distribution would be made in such a way that each party gets
                              approximately equal orders.
                           3. In case of the difference being there, 20% of the value of the Order
                              to be considered as profits and distributed between Deepak & Atul.
                              The share of the said money would be paid upon execution of the
                              Order by the respective entity.
                           4. Customers to be informed on a date decided by SKB/MN regarding
                              the split by way of a common mail to be approved by MN.
                              xxx
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                                  Miscellaneous
                            1.   The endeavour of both Deepak & Atul would be to effect the
                                 separation by 31.3.2016 and if it is not possible to do the same due
                                 to any reason, the separation has to take place at the earliest
                                 possible date but not later than 30.04.2016 and for this purpose,
                                 both Deepak & Atul would work positively to achieve the target
                                 date. The process of transfer of Ownership, drafting of documents,
                                 minutes, deeds etc. shall commence immediately and both Deepak &
                                 Atul shall give their full support so that the documentation is
                                 completed at the earliest.
                            2.   Specific audits of stocks, consumables and other related issues
                                 would be carried out by the team of MN with immediate effect.
                            3.   No material/goods would be withheld by either Deepak or Atul in
                                 their respective premises and the same would be cleared from time
                                 to time, so that the businesses do not suffer during this intervening
                                 period in any respect.
                            4.   The net current assets available in DBE after the DOF has to be
                                 distributed equally between the two after clearing of the liabilities.
                                 A mechanism will be drawn by SKB & MN to ensure that the money
                                 is available for distribution.
                            5.   D&A would make all efforts to get their statutory audits for the year
                                 ended 31.3.2016 finalised by 30.4.2016. Potential past liabilities
                                 upto the date of DOS would be determined with the assistance of
                                 both.
                            6.   A lump sum amount of Rs. 40,00,000/- would be payable to Atul
                                 towards shifting of Plant & Machinery, taking on rent new premises
                                 etc. This amount has to be paid by DB."


                      15.   These Minutes show that, by that time, the brothers had come to the
                      realisation that in order to fully effectuate the separation it was necessary to
                      lay down the roadmap for it by specifically setting down the steps required
                      to be taken. In fact, this document shows that on 14.03.2016, since the
                      parties had already started taking steps towards separation, they were
                      hopeful that the separation may take place even prior to 30.06.2016, for
                      which reason they were intending to prepare the list of plants and machinery
                      by 16.03.2016, subject to the verification thereof by each brother. As noted
                    OMP(I)(COMM)326-2016 & connect. matters
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                       previously, the Minutes provided that the customers would be informed
                      about the split by way of a common e-mail, approved by the learned
                      Arbitrator. Moreover, the staff were to be permitted to exercise their options
                      as to which brother's business they wanted to continue their employment in,
                      while the logos were also to be separated. Notably, the Minutes provided
                      that the parties would endeavour to get their statutory audits for the FY
                      ending on 31.03.2016 by 30.04.2016.
                      16.     Finally, the Deed of Arrangement executed on 30.04.2016 was the
                      third and final document which was executed by the parties and the relevant
                      clauses thereof read as under:
                                               Deed of Arrangement dated 30.04.2016
                              "This deed of arrangement is being made amongst Mr. Deepak Beri
                              (DB), Mr. Atul Beri (AB), and Mr. S.K. Beri (SKB) is to give effect to the
                              understanding reached by the parties in terms of MoU entered into by
                              them on February 17, 2016 relating to the division of business of DBE
                              and SKB.
                              That it is agreed amongst all that the entire division exercise will be
                              executed in terms of the MoU and this interim arrangement as agreed
                              upon to facilitate the final division.
                              xxx
                              That to manage the period from the date of this arrangement to the Date
                              of Separation (DoS) which is June 30, 2016, it has been agreed that DB,
                              AB and/or any of their family members (except SKB) shall not visit any of
                              the premises where the production of the companies is being carried on
                              and the meetings, if any, amongst the parties shall be held at the place
                              and time decided by MN.
                              xxx
                              Orders
                              Existing Orders as on 30th April, 2016
                             All orders in DBE or SKB as on April 30, 2016 shall be kept as it is.
                             Since it takes approximately 2 months for processing of orders, therefore,
                              by June 14, 2016 such orders will be in either of the following phases:
                              o       Finished stock;
                              o       Debtor;
                    OMP(I)(COMM)326-2016 & connect. matters
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                               o      Cash;
                              o      WIP, pending final processing
                              o      Existing orders shall be processed before new orders as per
                              FIFO method.
                              o      Pending orders will be distributed as per the MoU as on DoS or
                              any other prior date as decided by MN.
                              xxx
                              Staff
                             Increment due in April 2016 is to be maintained at 8% p.a. as an interim
                              increment and to be paid prior to the DoS out of the common funds.
                              List of Employees/Workers
                             List of employees/workers (unit wise) to be taken as on April 30, 2016
                              which will be updated on daily basis in case of any change with complete
                              details.

                              Intimation to Employees/Workers
                             Employees/workers (if required) will be intimated about the new date of
                              separation. Till that date no employee/worker will be retrenched unless
                              the employee/worker wants to leave voluntarily.
                              White Collar Employees (i.e. Employees)
                             White Collar employees at each location will be given an option to opt to
                              work either with DBE or SKB, for which they will be called one by one
                              and made to sign the register in front of MN. Said option will be
                              executed on May 31, 2016. However physical movement of such
                              employees will take place on/after DoS.
                              xxx
                             If an employee/worker wants to voluntarily leave prior to the DoS, such
                              employee worker shall not be re-appointed by AB/DB up to a period of 6
                              months from the DoS. Any violation of the same on the part of AB or DB
                              will attract a penalty amounting to 5 times the actual CTC in which such
                              employee/staff is re-appointed, payable to DB or AB respectively.
                             Compensation policy i.e. Full and Final settlement of employees/workers
                              will be decided by MN considering the trend of previous two years i.e.,
                              2013-14 and 2014-15.

                              xxx
                              Raw Material
                              Purchase Orders
                             Any order of raw material, tools or consumables has to be placed post
                              discussion and on prior approval of respective Plant heads. Such plant
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                               heads shall be nominated by AB/DB as on April 30, 2016 and intimated
                              to MN. If there is any conflict regarding this, then decision of MN will
                              prevail.
                             A weekly update shall be given to AB/DB by respective plant heads.
                              Maintenance of Records
                             Proper records for in, out, scrap generated, consumption and closing
                              stock of raw material shall be maintained for the period from May 01,
                              2016 through June 30, 2016.
                             The above mentioned records shall be circulated to AB, DB and MN on
                              weekly basis.
                              Stock of Raw Material/WIP/Finished Products
                             Physical stock taking and its distributions to be done for all units, as will
                              be decided by MN in consultation with AB and DB on the date of its
                              physical movement.
                             Work in progress to be distributed as per the MoU.
                             Physical shifting of stock shall commence after June 15, 2016.
                              Production
                             Production to be done upto June 15, 2016.
                             Entire DBE & SKB shall be run as a single unit in terms of production.
                             The production will be carried out in full swing and no material will be
                              held at one premise without any justified reason. In case production is
                              withheld for any reason, MN shall be intimated immediately.
                              xxx

                              Books of Accounts
                             All sales, purchases and expenses will be recorded in the books of
                              accounts at Okhla and a representative of AB will assist the staff at
                              Okhla for the same.
                             Random weekly checks may be conducted by MN in order to validate the
                              BNG and its rehabilitee(sic).
                             Balance sheet of DBE and SKB as on June 30, 2016 to be finalized by
                              July 15, 2016 by the staff of DBE and SKB Group.
                             The representative appointed by AB and DB in the field of Accounts and
                              Finance shall be responsible for maintaining and delivering books of
                              accounts to MN including the financial statements, statutory records for
                              past 8 years i.e. from F.Y. 2007-08 to F.Y. 2015-16 and other Legal and
                              Secretarial records, since the date of Incorporation.
                              xxx

                            Independent Manufacturing and Purchases
                           All purchases, sales and manufacturing to be restricted to SKB and DBE
                            only. No private entity shall undertake any business activity.
                    OMP(I)(COMM)326-2016 & connect. matters
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                            Only commonly owned machinery to be run.
                           Expenses of privately (independently) owned machinery and labour
                            charges on such machinery, not to be shared among DBE and SKB.

                              Plant and Machinery
                              Key Machinery
                             List of Key Machinery to be provided by the respective plant heads of AB
                              and DB by May 01, 2016 and division of the aforementioned key
                              machinery to be done by MN based on written down value as on March
                              31, 2016.


                              Other Machinery
                             List of Plant and Machinery to be compiled. AB and DB to take the
                              responsibility of making the list of their respective units by April 30,
                              2016.
                             Distribution of Plant and Machinery on paper to be finalized by MN upto
                              May 31, 2016 and physical distribution to commence after June 15,
                              2016.
                             The modus operandi would be that the two sets are as similar as
                              possible.
                              xxx
                              Miscellaneous
                             Endeavour of both AB and DB would be to effect the separation by June
                              30, 2016 and if it is not possible to do the same due to any reason, the
                              separation has to take place at the date and conditions as decided by
                              MN. The process of transfer of ownership, drafting of documents,
                              minutes, deeds etc, shall commence immediately and both AB and DB
                              shall give their full support so that the documentation is completed at the
                              earliest.
                             Specific audit of stocks, consumables, raw material and other expenses
                              related issues would be carried out by the team of MN with immediate
                              effect and that has to be completed by May 15, 2016. Appropriate
                              adjustments will be made in the account of AB and DB before DoS.
                             Expenses incurred by AB on C-1 will be paid to him after complete due
                              diligence and specific approval of MN only.
                             AB and DB would make all efforts to get their statutory audits for the
                              year ended March 31, 2016 be finalized by June 30, 2016. Potential past
                              liabilities upto the DoS would be determined with assistance of both AB
                              and DB."



                    OMP(I)(COMM)326-2016 & connect. matters
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                       17.   This Deed is generally distinguishable from the other two documents
                      since it reflects their acceptance of the fact that they were fast approaching
                      complete separation and is posed as a record of the arrangement which they
                      had finally arrived upon. It is the last and final document executed between
                      the parties towards separation of businesses and begins by requiring them to
                      follow the terms therein as also in the MoU, in letter and in spirit. It
                      explicitly refers to the date of 30.06.2016 as the final date of separation and
                      then goes on to mention this date close to 7-8 times in its body. It is clear
                      that the parties were seeking to take care of any unfinished business by
                      ensuring completion of all pending orders, resolving to determine potential
                      past liabilities up to 30.06.2016 and furnishing books of account to the
                      learned arbitrator, including financial statements and statutory records, for
                      the eight preceding years, i.e., from FY-2007-08 till F.Y.2015-16. This
                      document also sets aside a period, which began with its execution and ended
                      on 30.06.2016 and is now known as a 'transition period' for all practical
                      purposes, to help the parties ease into their independent commercial
                      identities. During the transition period, the delivery time for completion of
                      orders stood extended and, in the spirit of encouraging complete
                      transparency in the process, (i) the two brothers and their respective families
                      were proscribed from visiting the premises of any production units of the
                      businesses, (ii) it was decided that the books of accounts of the businesses
                      belonging to each other were subject to inspection by the learned arbitrator,
                      (iii) all parties were encouraged to share complete details of any hidden
                      orders of DBEPL and SKB, (iv) they were stripped of the power to
                      introduce any changes in the BNG system (which was the common software
                      used to record the orders placed), without the approval of the learned
                      Arbitrator, and (v) the two brothers were to be given all updates on the raw
                    OMP(I)(COMM)326-2016 & connect. matters
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                       materials purchased. All production could be carried on unhindered only till
                      15.06.2016, whereafter the physical shifting of the stock, viz. raw material,
                      work in progress and finished goods, was to be effected on a date fixed by
                      the learned Arbitrator. The Deed ended with the Miscellaneous clause
                      which generally addressed any major steps which were yet to be taken by
                      inter alia resolving to take care of any pending specific audits by
                      15.05.2016 and statutory audit by 30.06.2016.
                      18.   Reverting to the submissions made at the Bar, as per Mr. Atul Beri
                      and Mr. S.K. Beri, the parties had mutually agreed to fix the date of
                      separation as 30.06.2016, which was not only reflected in the three
                      documents executed by them but also the manner in which they conducted
                      their business and themselves pursuant thereto. On the other hand, Mr.
                      Deepak Beri has contended that the date of separation should be reckoned
                      by the Court as on date, rather than myopically relying on the tentative date
                      of separation set out in the documents executed by the parties. Mr. Deepak
                      Beri has taken the unrelenting position that he never consented to
                      30.06.2016 as the official date of separation and, in actuality, that date was
                      an effective date envisaged by the parties to finalise the division, but since
                      most of the steps under the settlement remained ineffectual on that date, it
                      was automatically rendered null and void and thus, never crystallised into a
                      final date of separation.
                      19.   As can be observed from the terms of these agreements, prima facie,
                      this date of 30.06.2016 found mention in the very first document executed
                      between the parties in February 2016, when the parties had just embarked
                      on their journey of partition. Evidently, this was not a date which was
                      suddenly conceived on 30.04.2016 at the time of executing the Deed, which
                      was the final settlement agreement rather, it was the farthest deadline
                    OMP(I)(COMM)326-2016 & connect. matters
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                       present within the initially executed document of the MoU for effecting one
                      of the steps towards final separation of the businesses. Undoubtedly, the
                      MoU was referring to this date as the 'effective date' of separation, just as
                      Mr. Deepak Beri is contending. Therefore, notwithstanding the fact that the
                      Minutes recorded on 14.03.2016 reflect the parties' hope to conclude the
                      separation before 30.06.2016, it is evident that from the very get go, the date
                      of 30.06.2016 appeared to, in spirit, capture their desire to finish this entire
                      saga of partitioning the businesses by the end of June 2016. This, of course,
                      on its own is not conclusive of anything and must be appreciated in the
                      context of the steps taken by the parties towards division.
                      20.   The parties had also made exhaustive submissions on whether or not
                      they had taken steps to separate prior to 30.06.2016 and, while they agreed
                      that certain steps had already been taken to effect the separation, they
                      differed on how much separation had truly been effected. As per Mr. Atul
                      Beri, a majority or 90% of the steps have already taken place, whereas Mr
                      Deepak Beri is seeking to contend that a majority of the steps for effecting
                      the separation remain pending as on date. To achieve any clarity on this
                      aspect, it may be useful to note the steps towards separation which both
                      sides have admitted to taking thus far. The steps admitted by Mr. Deepak
                      Beri, as extracted from paragraph 48 of his enforcement petition
                      [OMP(Enf)(Comm) 187/2018], have been reproduced in entirety as Table I
                      in the Addendum to this decision. The steps admitted by Mr. Atul Beri have
                      been reproduced in entirety as Table II in the Addendum, extracted from his
                      enforcement petition OMP(Enf)(Comm) 117/2019 as also the written
                      submissions filed by him in November 2019. To avoid prolixity, the
                      relevant extracts of the steps towards separation which have been admittedly
                      effected, are being culled out hereinbelow in a tabular form:
                    OMP(I)(COMM)326-2016 & connect. matters
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                       S. No.   Description         As per Mr. Atul Beri   As per Mr. Deepak Beri
                               Names      in Done.                        Done.
                               which each
                               party carries
                               their         Have been carrying out       Have been carrying out
                               businesses    business in the name of      business in the name of
                                             M/s     DBEPL      and       M/s DBEC, SKB or any
                                             BMGL                         other name.
                               Properties to Done.                    Done.
                               be received
                               by AB
                                             Currently in possession
                                             of     the    properties
                                             situated in Sector 68,
                                             Sector 11, NOIDA and
                                             that owned by BMGL
                                             in Phase-II, NOIDA.
                               Properties to Done, except:                Done.
                               be received
                               by DB.
                                             - Sector 64 has not          Currently in possession of
                                               been handed over,          Sector 6, 59 and A-119
                                               since compensation         Okhla            properties.
                                               of INR 7.50 crores         However, DB is yet to
                                               has not been given         receive possession of
                                               yet.                       Sector 64, NOIDA, which
                                             - Title transference of
                                                                          is being illegally retained
                                               property situated at
                                                                          by AB.
                                               C-27, Sector 59,
                                               Noida belonging to
                                               DBEPL        and   in
                                               possession         of      In addition, the transfer of
                                               Deepak Beri yet to         title of the other premises
                                               be effected.               is also pending. Bank has
                                                                          ordered       release     of
                                                                          hypothecated documents
                                                                          of Sector 59 and Sector 64,
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                   Page 43 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                                                                            which only needs to be
                                                                           collected from the bank by
                                                                           signing the register by all
                                                                           three parties.
                             Division and Done.                            Done.
                             transfer  of
                             Employees
                             under Clause As per MoM dated                 The division of employees
                             24, MOU      14.03.2016, employees            in terms of the agreed
                                          have exercised their             documents has already
                                          option of choosing               taken place, and the
                                          which brother they               employees who have opted
                                          wish to work for. This           by DB and AB were
                                          was      done       in           identified and a list was
                                          March/April 2016.                circulated on 07.07.2016.
                                                   This was completed
                                                   with    effect     from
                                                                            Further, in terms of the
                                                   07.07.2016.
                                                                            agreed documents, an 8%
                                                                            increment has been given
                                                                            to the employees, which is
                                                   However,             the
                                                                            an admitted fact.
                                                   employees working at
                                                   the units of DBEPL,
                                                   under the control of
                                                   Deepak, need to be
                                                   formally transferred to
                                                   SKB.
                             Division of Done             w.e.f.           Done.
                             logos under 23.03.2016.
                             Clause   9,
                             MOU                                           This is done by a Coin
                                         Logos of the business             Toss on 23.03.2016 duly
                                         entities were divided             recorded and signed by
                                         amongst the parties on            nominees of AB and DB in
                                         23.03.2016 and parties            the presence of the Ld.
                                         have since then, been             Arbitrator and SKB, who
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                   Page 44 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                                                    using their respective also signed the said paper.
                                                   logos, in furtherance of
                                                   their       independent
                                                   business activities.
                             Accounting            Done for Mr. Deepak Done.
                             Software              Beri.

                                                                           SKB (the concern falling
                                                   Ever since Mr. Deepak   to the share of DB)
                                                   Beri caused SKB to      purchased its own ERP
                                                   purchase ERB software   Software so as to facilitate
                                                   to keep its accounting  the division process.
                                                   separated        from
                                                   DBEPL. Thus, the
                                                   accounting softwares A sum of Rs. 9,73,248/-
                                                   are separate.          was spent by SK Beri &
                                                                          Bros towards the same.


                                                                           The underlying objective
                                                                           was to have separate and
                                                                           distinct ERP Softwares
                                                                           between DBEPL and SKB,
                                                                           as part of the division.
                             Division of Done.                             Done.
                             servers,
                             Email IDs,
                             domain      Separate servers have             In pursuance of the
                             names, and been purchased by                  division process, separate
                             websites    SKB, so as to de-link             servers       have    been
                                         itself from DBEPL.                purchased by SKB so as to
                                         The two entities now              de-link itself from DBEPL.
                                         have separate email
                                         id's, domain names and
                                         websites, so as to                As part of the division
                                         function independently            process, SKB have also
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                    Page 45 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                                                    from each other.           created new email ID's
                                                                              with       the     domain
                                                                              'skberi.com'   and    has
                                                                              engaged technicians to
                                                                              develop its independent
                                                                              website.


                                                                              DB and his staff were
                                                                              earlier using the domain
                                                                              name "atlasknives.com",
                                                                              which were disabled at the
                                                                              instance of AB. This fact
                                                                              also shows implementation
                                                                              of the division process.
                             Intimation to Done.                              Done.
                             Customers

                                                   Customers          were    As agreed, the parties have
                                                   intimated about the        jointly sent various letters
                                                   division in around the     to customers regarding the
                                                   first week of May          division between the AB
                                                   2016,       and     thus   Group and the DB Group.
                                                   customers have taken
                                                   their business to an
                                                   entity controlled by
                                                   Atul      or    Deepak,
                                                   depending on which
                                                   brother they wanted to
                                                   continue        business
                                                   relations           with
                                                   Pertinently, as per
                                                   clause 38 of the MoU,
                                                   this step was to take
                                                   place only after the
                                                   effective     date    of

                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                       Page 46 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                                                    separation.
                             Working               Done.                       Done.
                             Capital
                             Sanctions
                                                                               As part of the agreed
                                                                               documents,            more
                                                   Fresh working capital
                                                                               particularly in terms of
                                                   sanctions have been
                                                                               Clause 32 of the MOU,
                                                   applied      for     and
                                                                               DB applied for Working
                                                   obtained by Deepak
                                                                               Capital loan and sanction
                                                   Beri, in the name of
                                                                               of Credit Facilities in the
                                                   SKB. As of date, the
                                                                               SKB with Canara Bank,
                                                   two businesses have
                                                                               Okhla       Branch       in
                                                   been sanctioned loans
                                                                               April2016.
                                                   separately and, thus,
                                                   have separate liabilities
                                                   in this respect.
                                                                               On the basis of the
                                                                               aforesaid application, the
                                                                               Credit Facilities were
                                                                               approved     by     Canara
                                                                               Bank vide its letter dated
                                                                               04.06.2016.


                                                                               DB was also authorized by
                                                                               DBEPL vide its letter
                                                                               dated 03.06.2016 (signed
                                                                               by SKB, AB, DB and
                                                                               Ramesh Beri) to collect the
                                                                               original property papers
                                                                               for the premises which
                                                                               were to fall to DB's share.


                                                                               The term loan availed by
                                                                               DBEPL has paid off in full
                                                                               under the orders of this
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                       Page 47 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                                                                               Hon'ble Court dated 22nd
                                                                              March, 2018 and the
                                                                              original documents of all
                                                                              properties are currently
                                                                              deposited      with    the
                                                                              Registrar General, Delhi
                                                                              High Court in terms of the
                                                                              aforesaid order.
                             Telephone             Done.                      Done.
                             connections

                                                   Separate      telephone    As part of the division, an
                                                   connections have been      application was made on
                                                   obtained           w.e.f   17.06.2016 to Airtel for
                                                   07.06.2016, so that        transferring     telephone
                                                   entities controlled by     connections in the name of
                                                   Deepak and Atul have       SKB from DBEPL.
                                                   separate telephones.
                             Division        of Done.                         Pursuant to the division
                             Orders                                           process,    orders    were
                                                                              booked in SKB, which was
                                                   From February, 2016,       hitherto done in the name
                                                   orders which would         of DBEPL. A perusal of
                                                   have     earlier  been     the Monthly Sales Order
                                                   booked in the name of      details shows a sudden
                                                   DBEPL, were being          jump in the value of orders
                                                   booked (by Deepak          in SKB for the months of
                                                   Beri) in the name of       February, March, April,
                                                   SKB. He has thereafter     May, June and July 2016.
                                                   stopped booking orders
                                                   in SKB and started
                                                   booking them in other
                                                   entities to defeat the
                                                   interest of the father
                                                   who continues to retain
                                                   his share in SKB after
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                      Page 48 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                                                    30.06.2018.
                             Deployment Done with effect from Done.
                             of Security May 2016.
                             Services
                             under Clause                     In terms of the agreed
                             21, MOU                          documents, the parties
                                                              were to employ ·security
                                                              services for the respective
                                                              units. Acting upon the
                                                              understanding, the services
                                                              of G4S Secure Solutions
                                                              (India) P. Ltd. were
                                                              availed by DBEPL.
                             Application  Done.                         Done.
                             of Licences/
                             Permits
                                                                        DBC has applied for EEPC
                                                                        and other licenses for the
                                                                        purposes of export in the
                                                                        name of SKB, post the
                                                                        division process. Similarly,
                                                                        license for import has also
                                                                        been applied for.


                      21.   A cumulative reading of the stand taken by both brothers, as noted
                      hereinabove, makes it clear that the business entities falling under the shares
                      of Messrs. Atul and Deepak Beri are operating in separate names under
                      identities which are distinct from each other. Mr. Atul Beri has admitted to
                      the position that he has been carrying on business in the names of DBEPL
                      and BMGL with effect from 30.06.2016. Similarly, even though Mr.
                      Deepak Beri is aggrieved by the fact that he is being denied access to the
                      business of DBEPL, he has also admitted that he has been carrying on

                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                  Page 49 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                       business in the name of DBC and SKB, apart from his own privately run
                      family businesses from 30.06.2016. Neither brother uses the identity of the
                      businesses falling in the share of the other. In a similar vein, they have also
                      been allocated completely different logos for their respective business w.e.f.
                      23.03.2016. These businesses are operating on separate premises as on date,
                      though the title deeds of some of these properties are yet to be executed in
                      the names of the persons entitled thereto under the settlement agreements.
                      That being said, it is admitted that the premises at Sector-64, falling in the
                      share of Mr. Deepak Beri, has not been transferred to him. In this regard,
                      Mr. Atul Beri has sought to contend that he has withheld transferring these
                      premises to his brother since the latter has not only failed to resign from the
                      directorship and transfer shareholding of the companies falling in Atul's
                      share, but he has also failed to pay the amounts due to Atul under Clause 15
                      of the MoU, namely a sum of INR 7.50 crores towards cost of construction
                      of a functional unit for BMGL in Phase-II, NOIDA and an additional sum of
                      INR 1 crore to make up the difference in value of the properties falling in
                      his share. As per Mr. Deepak Beri, this amount stands paid to Mr. Atul Beri
                      who, in turn, denies such payment vehemently. Rather, Mr. Atul Beri claims
                      that he is due a further sum of INR 9.30 crores under Clauses 4, 5, 14 (a) of
                      MoU, r/w clause 6 (under miscellaneous) of the MoM dated 14.03.2016.
                      This is one of the primary disputes arising out of the steps for separation of
                      properties. At the same time, it is admitted that Mr. Deepak Beri has been
                      carrying out independent business in the other three premises situated at A-
                      99, Okhla Industrial Area, Sector-6, Noida and Section-59, Noida. In fact,
                      Mr.Deepak Beri is not only carrying out the businesses of SKB and DBC,
                      but has also admittedly permitted his son to run other businesses of like
                      nature in these very premises. Thus, barring this aspect of the Sector 64
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                  Page 50 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                       property and outstanding payments claimed by both brothers, the parties
                      have in unison stated that they are in possession of the premises accruing to
                      each of them under the settlement agreements. They have engaged different
                      security services to guard their premises as well.
                      22.   Furthermore, even as per the recorded averments of Mr. Deepak Beri
                      in his enforcement petition, both the brothers divided their white collar
                      employees, based on their preferences, and gave them increments as well
                      pursuant to these agreements. At this stage, it is pertinent to note that Mr.
                      Deepak Beri had sought to contend at the time of arguments that even
                      though the list of employees who were to go to the share of each brother
                      stood finalised on 16.03.2016, no further steps were taken in this direction.
                      He sought to contend that this implied that no division of employees had
                      taken place in the manner intended. However, in the light of his admission
                      in the enforcement petition, there is no reason to disbelieve the versions of
                      Mr. Atul Beri and Mr. S.K. Beri that each brother (Atul/Deepak) has had his
                      independent sets of employees, working only for him and from units
                      controlled exclusively by him. It, however, is undisputed that the sales and
                      marketing teams of the business entities were divided between the brothers
                      and operate separately as on date. Even the accounting software, telephone
                      connections, servers, email IDs, domain names and websites used by the
                      brothers are separate and, thus, there is no jointness even in these minute
                      aspects. In terms of the settlement agreements, they even sent
                      correspondences to their clients about their separation and distinct business
                      identities and each business entities have been handling their respective
                      clients, completely independent of each other, ever since then.
                      23.   With respect to the orders being placed by clients w.e.f 01.07.2016,
                      the same are recorded separately for the businesses falling under the shares
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                  Page 51 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                       of Mr. Atul Beri and Mr. Deepak Beri. Mr. Atul Beri has contended this to
                      be the position since February, 2016, however Mr. Deepak Beri denies this,
                      even though he has accepted that the orders for SKB have been recorded
                      separately by him since February 2016 and the numbers thereafter appear to
                      have increased. However, the parties are ad idem that certainly with effect
                      from 01.05.2016, there has been absolutely no transparency between them
                      with respect to the orders received by the business concerns falling in their
                      share. Further, from a reading of clauses 1, 3, 4, 5, 7 to 9, 13 to 17, 19 to 28,
                      34, 35 and 38 of the MoU, it is evident that the parties had envisaged that in
                      the transition period preceding 30.06.2016, all transactions carried out by
                      any of the family businesses were to be recorded in the books of accounts of
                      the concerned entity with the approval of all the four parties i.e. the two
                      brothers, their father and the Arbitrator. It is also evident that the parties
                      agreed to share all expenses, profits and assets till they were jointly
                      conducting the businesses, whereafter they would carry out the businesses
                      separately. Today, the brothers neither share the expenses of their respective
                      businesses nor record the transactions in the arrangement as set out by them.
                      Finally, with effect from 30.06.2016, both the brothers have been taking
                      business loans and applying for licenses and permits independently. There is
                      no overlap or joint operations in these aspects for over four years.
                      24.   Against this background, one may consider the steps which are
                      admittedly left to be taken as on date. Mr. Atul Beri has produced a table in
                      paragraph 30 of his enforcement petition enumerating the steps to be taken
                      to completely discharge all obligations of the parties under the settlement
                      agreements. Similarly, Mr Deepak Beri had submitted a tabulation of the
                      steps left to be taken, in his reply to Mr. Atul Beri's enforcement petition
                      [OMP(Enf)(Comm)117/2019]. Although, in his post-hearing written
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                   Page 52 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                       submissions, Mr. Deepak Beri has submitted comprehensive tabular
                      representations which cull out additional steps which he claims are left to be
                      taken against each step contemplated in the Memorandum, Minutes and the
                      Deed, the same are not being referred to at this stage since they are not only
                      at some variance with his own broad stance in his enforcement petition, but
                      also because Messrs. Atul and S.K. Beri did not have an opportunity to
                      rebut the same. For the sake of convenience, the chart produced by Mr. Atul
                      Beri is reproduced as Table III in the Addendum whereas the chart produced
                      by Mr. Deepak Beri is reproduced as Table IV in the Addendum. However,
                      the gist of their respective positions may be summed up as follows:
                               i.   Both Messrs. Deepak and Atul Beri need to formally transfer
                                    their shareholding and ownership interests and that of their
                                    family's from the businesses falling in the share of the brother.
                                    Consequently, Mr. Deepak Beri needs to resign as Director of
                                    DBEPL and BMGL and transfer his and his family's share
                                    certificates therein to Mr. Atul Beri. Mr. Atul Beri, in turn,
                                    needs to do the same in SKB and DBC, in favour of Mr.
                                    Deepak Beri.
                              ii.   The brothers need to transfer the title to the properties in the
                                    names of the person in whose share the same falls as per the
                                    settlement agreements.
                             iii.   All documents pertaining to DBEPL and BMGL in the
                                    possession of Mr. Deepak Beri and those pertaining to SKB
                                    and DBC in the possession of Mr. Atul Beri, including but not
                                    limited to Customs shipping bills, Customs certified invoices,
                                    import/export books, DGFT licenses, need to be returned to the
                                    rightful owner of the respective businesses.
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                  Page 53 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                              iv.    The orders as they stood on 30.06.2016 have not been
                                    completely divided between the parties in terms of the
                                    settlement.
                              v.    The parties are yet to share the profits and liabilities of the
                                    business entities as they stood on 30.06.2016. Furthermore,
                                    accounting and auditing exercises have only been conducted
                                    partially.
                             vi.    The division of stocks, plant and machinery was not fully
                                    effected as they stood before 01.07.2016.
                      25.   When one considers the steps which are left to be taken, viz. the
                      numerous steps that have been completed so far, one can begin saying with
                      some certainty that the parties in most respects were operating distinctly
                      from each other. Their businesses have been, in spirit, divorced from each
                      other and do not share any jointness. Undisputedly, the original intent of the
                      parties was a more complete form of this separation, rather than the partial,
                      unfinished shape that it has assumed today. This tangled state of affairs is
                      solely attributable to the parties' contradictory stands with respect to the
                      date of separation.
                      26.   In the light of this position, this Court must assess whether the
                      agreements signed between the parties actually culled out a separation date
                      and whether this date was expressly stipulated as 30.06.2016. In this regard,
                      reference may be made to Paragraph 20 of the decision rendered by the
                      Hon'ble Supreme Court in Bhavan Vaja (supra) which reads as under:
                               "20. It is true that an executing court cannot go behind the decree under
                               execution. But that does not mean that it has no duty to find out the true
                               effect of that decree. For construing a decree it can and in appropriate
                               cases, it ought to take into consideration the pleadings as well as the
                               proceedings leading up to the decree. In order to find out the meaning of
                               the words employed in a decree the court, often has to ascertain the

                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                         Page 54 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                                circumstances under which those words came to be used. That is the
                               plain duty of the execution court and if that court fails to discharge that
                               duty it has plainly failed to exercise the jurisdiction vested in it. Evidently
                               the execution court in this case thought that its jurisdiction began &
                               ended with merely looking at the decree as it was finally drafted. Despite
                               the fact that the pleadings as well as the earlier judgments rendered by
                               the Board as well as by the appellate court had been placed before it, the
                               execution court does not appear to have considered those documents. If
                               one reads the order of that court, it is clear that it failed to construe the
                               decree though it purported to have construed the decree. In its order
                               there is no reference to the documents to which we have made reference
                               earlier. It appears to have been unduly influenced by the words of the
                               decree under execution. The appellate court fell into the same error.
                               When the matter was taken up in revision to the High Court, the High
                               Court declined to go into the question of the construction of the decree
                               on the ground that a wrong construction of a decree merely raises a
                               question of law and it involves no question of jurisdiction to bring the
                               case within Section 115, Civil Procedure Code. As seen earlier in this
                               case the executing court and the appellate court had not construed the
                               decree at all. They had not even referred to the relevant documents. They
                               had merely gone by the words used in the decree under execution. It is
                               clear that they had failed to construe the decree. Their omission to
                               construe the decree is really an omission to exercise the jurisdiction
                               vested in them."

                      27.   Evidently, it is not enough in every case for an executing court to
                      simply read and interpret the words of a decree, especially in a case such as
                      this where the execution pertains to a settlement bearing clauses which are
                      being differently interpreted. In fact, in such cases the Court is called upon
                      to pay due regard to the surrounding circumstances as well as the letter of
                      the decree in order to truly deliver justice in its powers of execution,. While
                      bearing in mind these principles which sculpt the powers of an executing
                      court, I revert to the facts of the present case. As observed previously, the
                      MoU deemed 30.06.2016 as an 'effective date of separation', which implied
                      that the date was not set in stone at the time and was envisaged as a mere
                      distant deadline to the parties, to provide them with a general sense of when
                      they were expected to conclude the process of partition. The Minutes

                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                              Page 55 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                       recorded on 14.03.2016 do not materially digress from this position, rather it
                      appears to capture the optimism of the parties in their perception of the pace
                      at which the partition was proceeding and their collective belief that they
                      might actually be able to pull the partition off before June 2016. The Deed
                      executed more than a month later on 30.04.2016 signals that the optimism
                      contained in the Minutes began wearing off in the days after it was
                      executed. It becomes apparent that the reality of partition and the numerous
                      nitty-gritty of it had become obvious to the parties and the learned arbitrator,
                      who had finally accepted that the partition was going to be a tedious and
                      mammoth task, incapable of being effected within the short period of time
                      envisaged in the Minutes. Nevertheless, since most steps were either already
                      underway or stood completed, the parties mutually agreed to follow through
                      with the partition by agreeing upon a deadline and, in that context, agreed
                      upon the following stipulation in the Deed:
                                    " That to manage the period from the date of this arrangement to
                                    the Date of Separation (DoS) which is June 30, 2016, it has been
                                    agreed that DB, AB and/or any of their family members (except
                                    SKB) shall not visit any of the premises where the production of
                                    the companies is being carried on and the meetings, if any,
                                    amongst the parties shall be held at the place and time decided by
                                    MN." (emphasis supplied)


                      28.   In my view, this is the turning point of the agreements and the point
                      wherein lies the answer to the primary question raised in these enforcement
                      proceedings. The parties explicitly referred to 30.06.2016 as the Date of
                      Separation. Following this stipulation, the Deed went on to cement the
                      importance of 30.06.2016 as the date of separation, by mentioning it as a
                      deadline for several other steps thereunder. While the CTC of the employees
                      and workers on transfer was to be determined as it stood on 30.06.2016, the
                      record of all in, out, scrap generated, consumption and closing stock of raw
                    OMP(I)(COMM)326-2016 & connect. matters
Signature Not Verified                                                                         Page 56 of 100
DigitallySigned
By:MANJU BHATT
Signing Date:25.12.2020
09:21:00
                       material was to be mandatorily maintained from 01.05.2016 till 30.06.2016.
                      All production at the manufacturing units of the family concerns was to be
                      carried out together till 15.06.2016 whereafter the physical shifting of the
                      stocks, plants and machinery was to take place on a date fixed by the
                      learned Arbitrator. In fact, even the balance sheets of DBEPL and SKB
                      were to be finalised as they stood on 30.06.2016 and the funds transferrable
                      to Mr. Deepak Beri, in case he failed to acquire the requisite working capital
                      loan by 30.06.2016, were to be apportioned out of the funds available with
                      the family businesses as on 30.06.2016. In closing, the Deed incorporated
                      the Miscellaneous clause which not only sought to tie any loose ends in the
                      separation process by mandating that all auditing exercise of stocks be
                      completed by 15.05.2016 and all statutory audit for the financial year ending
                      on 31.03.2016 be finalised by 30.06.2016, it also stated:
                            "Endeavour of both AB and DB would be to effect the separation by June
                            30, 2016 and if it is not possible to do the same due to any reason, the
                            separation has to take place at the date and conditions as decided by
                            MN."


                      29.   Therefore, notwithstanding the fact that the tenor of all the
                      agreements regarded 30.06.2016 as a deadline of sorts, the Deed finally and
                      unambiguously set down that the date of separation was going to be, after
                      all, 30.06.2016. Considering all the steps that the parties were concurrently
                      taking to make this happen, it appears quite obvious that the parties intended
                      to and did, ultimately, demarcate 30.06.2016 as the date of separation of the
                      businesses.
                      30.   Now, it is apparent that Mr. Deepak Beri has argued vehemently
                      against this position since he believes that 30.06.2016 was merely a
                      tentative date of separation, as reflected in Clauses 16 and 34 of the MoU,

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                       rather than a final date of separation set in stone. He is of the opinion that
                      the date was proposed, not ultimately accepted. The crux of his contention
                      is that the settlement agreements envisaged a certain order in which the
                      partition was to be carried out, first the parties would effectuate all the steps
                      set out in the three agreements, and once all of them were complete, they
                      would pronounce an appropriate date of separation which would be
                      backdated. Thus, he has urged that the steps and their completion were to
                      compulsorily precede any fixing of date of separation, and the entire
                      exercise of first pronouncing a date of separation is contrary to the tenor of
                      the agreements. I have carefully considered this aspect vehemently urged by
                      Mr. Deepak Beri and find that there is absolutely no stipulation in the
                      agreements which backs this interpretation. In fact, neither the language of
                      the agreements nor the circumstances surrounding the execution thereof
                      support this line of argument. Rather, the tenor of the agreements appears to
                      be starkly in favour of finalising a date of separation and correspondingly
                      working towards it at the earliest possible date, rather than waiting for the
                      parties to follow through with the steps as a preliminary requirement of
                      finalising the partition date. Express stipulation in the Deed to the effect that
                      the auditing of stocks, consumables and related issues were to be concluded
                      by 15.05.2016, the statutory audits were to be carried out by 30.06.2016,
                      and that Mr. Deepak Beri was granted time till 30.06.2016 to arrange for
                      working capital on his own as also fixing of travelling budget of sales
                      personnel only till June 2016 show that 30.06.2016 was to act as a point of
                      reference, a cut-off date. Ultimately, as mentioned above, this Court cannot
                      step out of the confines of the settlement and render a finding on fiction, and
                      this submission of Mr. Deepak Beri that the completion of steps would


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                       precede fixing of a date of Separation does not appear to be based on a
                      proper interpretation of the settlement at all.
                      31.   Mr. Deepak Beri has also sought to place reliance on several orders
                      passed by this Court in order to contend that this Court had taken judicial
                      cognisance of the position that the Date of Separation was not 30.06.2016.
                      He has further urged that since Mr. Atul Beri failed to object to this
                      conclusion in each of these orders at the relevant time, he has tacitly
                      consented to the position that separation has not taken place. He has urged
                      that in the order dated 15.12.2016, this Court had signified its intent to
                      appoint an Escrow Agent to implement the steps towards separation, but Mr.
                      Atul Beri did not agitate at that time that any court-monitored separation
                      ought to be carried out by keeping 30.06.2016 in mind as the Date of
                      Separation. He has contended that the next order passed on 03.01.2017
                      directed a physical audit of the stock, plant and machinery, receivables,
                      books of accounts, statutory and other records as on that date, which was
                      again never assailed by Mr. Atul Beri who has been presently urging that all
                      like audits should be carried out as on the date of 30.06.2016. Finally, by
                      placing reliance on the order dated 01.11.2018, he contends that even then
                      the Court was trying to find a way for the parties to move forward, which
                      implied that separation had not taken place. I have carefully taken this point
                      into consideration and perused the orders which Mr. Deepak Beri has sought
                      to rely on. To begin with, there is no quarrel with the position that complete
                      separation has not taken place. In fact, paragraphs 2,3 and 8 of the order
                      dated 01.11.2018, on which such heavy reliance has been placed, only
                      records that the assets must be divided in accordance with the award and,
                      clearly, this order neither makes any mention of the date of separation nor
                      does it proceed on the assumption that no such date has been fixed. Even the
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                       order dated 03.01.2017 does not contain any determinative finding on the
                      issue which is being dealt with by this Court, i.e. the stipulation of a cut-off
                      date. Rather, all the orders sought to be relied upon show an earnest attempt
                      of the Court to arrive upon some interim arrangement till these enforcement
                      petitions were finally decided.
                      32.   In view of my discussion thus far, while I am already of the
                      considered opinion that Mr. Deepak Beri's contention that 30.06.2016 was
                      not the Date of Separation is not tenable, there is another reason to reject
                      this plea. A glimpse at the extract from the Deed reproduced in paragraph
                      25 above shows that if either of the parties wanted to change the date of
                      separation, which had been fixed as 30.06.2016, a mechanism had been
                      provided therein to address the dispute by designating the learned Arbitrator
                      as the final deciding authority. In the light of this provision and the fact that
                      the learned Arbitrator had not altered the date of 30.06.2016 in his award or
                      fixed another date of Separation, it is manifest that the date of 30.06.2016 is
                      the final date of separation. In any event, it was also open to Mr. Deepak
                      Beri to move an application before the learned Arbitrator to seek a change
                      or clarification of this date which, as per the admitted position, he did not
                      elect to do. In fact, as has been brought to the notice of this Court by his
                      father and brother, even when their Section 34 petitions against the Award
                      was being considered, Mr. Deepak Beri did not claim a change in the date of
                      separation. Furthermore, it is also interesting to note that Mr. Deepak Beri
                      has previously, in the Section 9 petition filed by him in August 2016, stated
                      in no uncertain terms that the date of separation stipulated in the settlement
                      agreements was 30.06.2016. An extract of this paragraph reads as under:
                            "That a perusal of the aforesaid MOU shows that detailed terms were
                            agreed upon between the parties as to the division of the assets. In fact, it
                            was also agreed in the aforesaid MOU that the effective date of separation
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                             would be June 30, 2016 and in the interim a working arrangement would
                            be put in place, as detailed in the MOU."


                      33.   Thus, any attempt by Mr. Deepak Beri to feign innocence of the Date
                      of Separation or the factum of having agreed to it in the settlement
                      agreements executed by him, cannot hold ground. I am fortified in this view
                      since the same adheres to the dicta of the Hon'ble Supreme Court in Hari
                      Shankar Singhania (supra) and Kale (supra), relied upon Mr. Deepak Beri,
                      insofar as it is the best course to effectuate the settlement agreements and
                      fulfil the intentions of the family. Both the brothers are admittedly in favour
                      of ending this dispute once and for all and ultimately want this Court to
                      adopt an interpretation which is not only correct in law but also unhindered
                      by technical objections. This is obvious from the prayers in these
                      enforcement petitions, Mr. Deepak Beri has prayed for the following reliefs:
                                   "a.       Order(s) enforcing the Award dated 02.08.2016 passed by
                                             the Arbitrator;
                                   b.        Appointment of an Observer to oversee the implementation
                                             of the division process using the aid and assistance of such
                                             persons as may be deemed fit;
                                   c.        Restraining the parties from acting contrary to the Award
                                             and the settlement document;
                                   d.        Conducting a special / forensic audit for the family concerns
                                             to examine the extent of siphoning by Mr. Atul Beri; and
                                   e.        Appointment of a receiver to take charge of all assets and
                                             take over the affairs of the family concerns during the
                                             pendency of the division process."


                      34.   On the other hand, Mr. Atul Beri has prayed for the following reliefs
                      in his enforcement petition:
                                    "i)     Pass an order enforcing the Award dated 02.08.2016, to the
                                            extent upheld by judgment of this Hon'ble Court dated
                                            31.05.2018, in O.M.P. (Comm.) 396/2016 and O.M.P.
                                            (Comm.) 382/2016, taking into account details of the
                                            remaining steps required to be taken for such enforcement,
                                            as detailed by the Petitioner/ Award Holder hereinabove;

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                                     (ii)    Pass an order restraining the Judgment Debtors or any other
                                             person from acting contrary to the terms of the Award dated
                                             02.08.2016.
                                    (iii)   Pass any other such order as this Hon'ble Court may deem fit
                                             and proper in the facts and circumstances of the case."

                      35.   Thus, the reliefs sought in the petitions preferred by the brothers also
                      show their common intent to ensure that the family businesses, which are as
                      a matter of fact operating independently from each other, are formally and
                      completely separated in law. These parties have been in litigation for over
                      four years now, which has not done any favour to the bitterness and
                      acrimony between them which was the very reason for beginning the
                      process of partition in the first place. Their well-intended decision to
                      appoint Mr. Nagrath to mediate and arbitrate their disputes and execute the
                      three settlement agreements together may have resulted in an immediate
                      backfiring due to a few differences in their opinions, which is expected in
                      intimate familial disputes, but the same cannot be permitted to mushroom
                      any further into even more complicated cycles of litigation. When the
                      parties have made their mutual wish to achieve a quietus in this matter
                      known, there is no reason for their disputes to languish any further before
                      this Court without resolution. For this reason, it was always a matter of the
                      utmost importance to ensure that both parties are duly heard and all their
                      pleadings are thoroughly perused to mete justice to everyone concerned.
                      Thus, even though the agreements, especially the Deed dated 30.04.2016,
                      had clearly set out a date of separation, this Court felt the necessity to go
                      further and examine the steps that the parties had taken during the period of
                      executing these agreements and thereafter. Considering that a number of
                      major steps towards separation stood accomplished, barring those which
                      were dependent on certain accounting and auditing exercises, and the

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                       brothers have continued to operate their businesses separately and
                      independently of each other since 30.06.2016, I have no hesitation in
                      holding that the date of separation of businesses of the family concerns of
                      the Beri family among Messrs. Atul and Deepak Beri, as per the settlement
                      agreements executed by them on 17.02.2016, 14.03.2016 and 30.04.2016,
                      was 30.06.2016.
                      36.   Thus, it is clear that after 01.07.2016, neither does Mr. Deepak Beri
                      have any right or access to DBEPL and BMGL nor does Mr. Atul Beri have
                      any right or access to DBC and SKB. For this reason, the prayers made by
                      both Messrs Atul and Deepak Beri in their Section 9 petitions seeking right
                      of access to the premises or records of, inter alia books of accounts, bank
                      accounts, stock registers of raw materials, plant & machinery, ERP software
                      systems, e-mail addresses, domain names, tax records, etc., of the
                      businesses which are not falling in their share cannot be granted.
                      37.   In the light of this conclusion, it is now time to chart a course for the
                      future by determining how the assets need to be partitioned with reference
                      to the Date of Separation being 30.06.2016. Since it is the common case of
                      the parties that complete separation had not taken place by 30.06.2016 and
                      some steps still need to be taken, they have placed voluminous pleadings on
                      record to suggest further steps which are required to be taken to complete
                      the remaining steps of separation as also to substantiate their claims of the
                      outstanding sums accruing to them. With respect to the latter, they are ad
                      idem that the accounts for all the businesses as on 30.06.2016, which were
                      required to be drawn up, were not. However, they also agree that accounts
                      for the years till 31.03.2015 are available with them, as also the Local
                      Commissioner's report on this aspect till 15.05.2017 which records the
                      position of the assets, salaries, etc, as on that date. Thus, in my view, there is
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                       considerable material available today to draw out the relevant accounting
                      records for 30.06.2016.
                      38.   As can be seen from the tables reproduced in the Addendum, which
                      are a small fraction of the suggestions received from Deepak Beri, Atul Beri
                      and Mr. S.K. Beri, there are a few nitty-gritty left to be taken care of, not to
                      mention the significant aspect of drawing up the accounts. However, having
                      regard to the nature and complexity of the accounts which need to be drawn
                      up and the steps left to be taken to seal the separation by using 30.06.2016
                      as the Date of Separation, I am of the view that it would be necessary to
                      appoint a Court Commissioner and a Chartered Accountant, to assist him,
                      and obtain a report from them before proceeding to issue any further
                      directions.
                      39.   The Court Commissioner shall call for and examine the records of all
                      the four businesses pertaining to (i) statutory liabilities and profits, (ii)
                      tangible assets including employee transfers, raw materials, plants and
                      machinery, consumables as existing on 30.06.2016, (iii) intangible assets
                      including software, salaries, bank liabilities, pending orders as they stood on
                      30.06.2016. While dealing with these aspects, the Court Commissioner shall
                      take into consideration the list of plants and machineries prepared by the
                      learned Arbitrator on 10.06.2016 and the four reports furnished by the
                      previous Court Commissioner appointed by this Court on 03.01.2017. Once
                      this exercise is complete, the Court Commissioner shall reconcile the data
                      pertaining to the tangible and intangible assets, as they existed on
                      30.06.2016 with the help of the Chartered Accountant, and furnish a
                      detailed report bearing their valuation of the intangible and tangible assets
                      which stand divided thus far. While doing so, the Court Commissioner shall
                      include the following aspects:
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                                i.   The quantum of amount spent by either parties in pursuance of
                                    court orders or otherwise, as payments to each other or to
                                    discharge the liabilities of the businesses which were not
                                    falling in their share, including all payments made towards
                                    disbursement of salaries, increments, statutory dues, etc.
                              ii.   The valuation of the machineries which stood transferred to
                                    both the parties on 30.06.2016.
                             iii.   The steps which are left to be taken, after obtaining due
                                    suggestions from both the parties in this regard.
                             iv.    Whether there is any need to conduct a forensic audit in this
                                    matter or whether the existing records are sufficient to
                                    determine the value of all assets belonging to DBEPL, BMGL,
                                    DBC and SKB, as they stood on 30.06.2016. On this aspect, the
                                    Court Commissioner shall rely on the professional and
                                    technical expertise of the Chartered Accountant, who will give
                                    his specific recommendations thereon.
                      40.   Accordingly, Mr. Sudhanshu Batra, Sr. Adv. (+91 9811035392) is
                      appointed as the Court Commissioner. Further, Ravi Rajan & Co. LLP (+91
                      9810033815) with its office at 505A, 5th floor, Rectangle 1, 4D Saket
                      District Centre, Saket, New Delhi 110017 is appointed as the Chartered
                      Accountant. The Court Commissioner will furnish his report, along with the
                      report of the Chartered Accountant, before this Court by 10.03.2021.
                      Copies thereof shall also be provided to all parties herein. The Court
                      Commissioner and the Chartered Accountant shall be paid sums of INR 7.5
                      lakh each, to be borne equally by Messrs. Deepak and Atul Beri. This
                      remuneration may be subject to revision, if found necessary, at a later stage.
                      It will be open for the Court Commissioner and the Chartered Accountant to
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                       call for any other details from the parties, as required. The payment of fee to
                      the Court Commissioner and Chartered Accountant as also the submission
                      of documents to them to be effected within a period of two weeks.
                      41.   Before I conclude, I must observe that even though some of the reliefs
                      sought in the Section 9 petitions have been rendered infructuous, as
                      mentioned previously, there are a few important issues raised therein which
                      can be decided only once the reports of the Court Commissioner and
                      Chartered Accountant are received by this Court. One of these issues
                      pertains to the transfer of property situated at Sector-64, Noida to Mr.
                      Deepak Beri, who is its rightful owner under the settlement, and
                      compensation due to him, if any, on account of being deprived of its
                      possession since 01.07.2016. Similarly, for the time being, this Court is not
                      inclined to pass any directions regarding the conduct of forensic audit of the
                      family concerns as on 30.06.2016. In the light of the discussion thus far, it
                      would be appropriate to pass comprehensive directions in respect of all the
                      remaining steps towards separation, only after receiving the detailed report
                      from the Court Commissioner and the Chartered Accountant.
                      42.   Once the report, as sought hereinabove, is filed before this Court by
                      10.03.2021, the matter shall be listed for further directions on 21.03.2021.




                                                                               REKHA PALLI, J.

DECEMBER 24, 2020 OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 66 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 ADDENDUM TABLE I: Steps admitted to having been taken by Mr. Deepak Beri in paragraph 48 of OMP(Enf)(Comm) 187/2018.

S.No. Agreement between the How acted upon parties

1. Shri Deepak Beri (DB) to The parties have accepted the carry on business in the respective names in which they are to name of M/s DB carry on future business. Engineering Co. (DBEC) or any other name. Shri Atul Beri (AB) to carry on business in the name of M/s DB Engineering Pvt. Ltd.

(DBE) and M/s Benaras Marble & Granite Ltd.

(BMG)

2. DB to get the premises DB is in possession of Sector 6, 59 situated in Sectors 6, 59 and A-119 Okhla properties. However, and 64, NOIDA (U.P.) DB is yet to receive possession of owned by DBC, DBE and premises in Sector 64, NOIDA, which property No.A-119, Okhla is being illegally retained by AB. which is owned by M/s S. In addition, the transfer of title of the K. Beri& Bros. (SKB&B) other premises is also pending. Bank has ordered release of hypothecated documents of Sector 59 and Sector 64, which only needs to be collected from the bank by signing the register by all three parties.

3. AB to get property situated Admittedly, AB is in exclusive in Sector 68, Sector 11, possession of these three properties. NOIDA as well as property OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 67 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 owned by BMG in Phase-

II, NOIDA

4. AB was to be paid Rs. 7.50 These amounts stand already paid to crores towards cost of AB by transferring a total amount of construction of a functional Rs. 11,32,00,000/- (Rupees Eleven unit in Phase-II, NOIDA Crores Thirty Two Lacs only) from and an additional 1 crore in the account of DBE to BMG. terms of Clauses 15 of the The aforesaid amounts have been MOU utilized by AB for construction of the unit at Phase-II, NOIDA. This fact can be clearly ascertained from the email of AB to the Ld. Arbitrator dated 29.02.2016 wherein he requested for release of Rs. 2.5 crores for payment to the Building contractor. Pertinently, on the same day payment of Rs. 2.5 crores was made to BMG by DBE vide Cheque No. 858576.

On the strength of the payments made, AB has been able to construct an entire unit on a barren land.

5. Division of Logos This is done by a Coin Toss on 23.03.2016 duly recorded and signed by nominees of AB and DB in the presence of the Ld. Arbitrator and SKB, who also signed the said paper.

6. Division of ERP Systems SK Beri& Bros (the concern falling to the share of DB) purchased its own ERP Software so as to facilitate the division process.

A sum of Rs. 9,73,248/- was spent by SK Beri& Bros towards the same. The underlying objective was to have OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 68 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 separate and distinct ERP Softwares between DBE and SK Beri& Bros, as part of the division.

7. Employees The division of employees in terms of the agreed documents has already taken place, and the employees who have opted by DB and AB were identified and a list was circulated on 07.07.2016.

Further, in terms of the agreed documents, an 8% increment has been given to the employees, which is an admitted fact.

8. Servers Emails & Website In pursuance of the division process, separate servers have been purchased by SK Beri & Bros so as to de-link itself from DBE.

As part of the division process, SK Beri & Bros have also created new email ID's with the domain 'skberi.com' and has engaged technicians to develop its independent website.

DB and his staff were earlier using the domain name "atlasknives.com", which were disabled at the instance of AB. This fact also shows implementation of the division process.

9. Copying & Scanning of With a view to facilitate the division, Books of Accounts it was agreed that records / data would be retained by DB and AB. As part of the said understanding, the records of DBE were digitalized and retained. OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 69 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00

10. Intimation of Customers As agreed, the parties have jointly sent various letters to customers regarding the division between the AB Group and the DB Group.

It may be pertinent to mention here that AB has also been writing emails to customers claiming that the division process has taken place.

11. Working Capital and Bank As part of the agreed documents, more Limits particularly in terms of Clause 32 of the MOU, DB applied for Working Capital loan and sanction of Credit Facilities in the SK Beri& Bros with Canara Bank, Okhla Branch in April2016.

On the basis of the aforesaid application, the Credit Facilities were approved by Canara Bank vide its letter dated 04.06.2016.

DB was also authorized by DBE vide its letter dated 03.06.2016 (signed by SKB, AB, DB and Ramesh Beri) to collect the original property papers for the premises which were to fall to DB's share.

The term loan availed by DBE has paid off in full under the orders of this Hon'ble Court dated 22nd March, 2018 and the original documents of all properties are currently deposited with the Registrar General, Delhi High Court in terms of the aforesaid order.

12. Telephone Connections As part of the division, an application was made on 17.06.2016 to Airtel for OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 70 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 transferring telephone connections in the name of SK Beri & Bros from DBE.

13. Booking of Orders Pursuant to the division process, orders were booked in SK Beri & Bros, which was hitherto done in the name of DBE. A perusal of the Monthly Sales Order details shows a sudden jump in the value of orders in SK Beri & Bros for the months of February, March, April, May, June and July 2016.

14. Deployment of Security In terms of the agreed documents, the Services parties were to employ ·security services for the respective units. Acting upon the understanding, the services of G4S Secure Solutions (India) P. Ltd. were availed by DBE.

15. Application of Licences/ DB has applied for EEPC and other Permits licenses for the purposes of export in the name of SK Beri& Bros, post the division process. Similarly, license for import has also been applied for.

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 71 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 TABLE II: Steps admitted to having been taken by Mr. Atul Beri in his OMP(Enf)(Comm) 117/2019 as also his written submissions filed in November 2019.

Sr. Obligation Clause Mode/Status of No. No. implementation & comments MOU dated 17.02.2016

1. Property at B-113, 114, 2 This plot has been in the 115, 131, 132, Sector 6, exclusive possession of Noida (Owned by DBC, Deepak Beri and he is running to go to Deepak Beri). his LLP from here.

Plot is owned by DBC, which is a 50-50 partnership between Deepak Beri and Anuja Beri (Atul's wife).

Anuja may resign from DBC, leaving the firm and property to go to the share of Deepak.

2. Property at C-27, Sector 2&16 Property has been in the 59 Noida, (belonging to exclusive possession of DBEPL, to go to Deepak Beri. DBEPL used to Deepak Beri/SK Beri & run its Heat treatment plant Bros) from here. This was the mother unit to all other units. Deepak's exclusive possession of this property has severely hurt the family business.

Atul shall cause DBEPL to execute the requisite transfer documents, to transfer this property to SKB, simultaneously with Deepak OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 72 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 (and his wife/children) transferring their shareholding in DBEPL and BMGL to Atul, and resigning his Directorship in these Companies.

3. Property at A-32, Sector 2&16 Atul shall cause DBEPL to 64, Noida (belonging to handover possession and DBEPL, to go to execute the requisite transfer Deepak Beri/ SK Beri & documents, in favour of SKB, Bros) simultaneously with Deepak (and his wife/children) transferring their shareholding in DBEPL and BMGL to Atul, and resigning his Dictatorship in these Companies.

4. Property at A-119, 2 This property is in possession Okhla Phase-II of Deepak Beri. He is (belonging to SKB, to supposedly running S.K Beri remain with and Bros from the same, but SKB/Deepak) actually he is clandestinely running his LLP.

Since SKB goes to Deepak Beri, no transfer documents are required to be executed.

5. Property at B-1, Sector 4 In possession of DBEPL. No 68, Noida (belonging to execution of title documents DBEPL, to go to Atul) required.

As per the MoU, One-Time Lease Rent was to be borne by DBE and AB-50/50. This has not happened, and has to be accounted for, while computing final adjustment of accounts.

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 73 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00

6. Property at F-61, Sector 4 In possession of DBEPL/Atul.

11, Noida (belonging to No execution of title DBEPL, to go to Atul) documents required.

7. Property at C-57, Phase 4 In possession of BMG/Atul.

II, Noida (belonging to No execution of title BMG, to go to Atul) documents required.

Deepak to resign as Director from BMG and hand over shareholding.

8. Plot at C-12 Ecotech-11, 4 Possession awaited by Greater Noida, to go to DBEPL. Deepak Beri be Atul directed to handover requisite documents of allotment.

9. Rs. 7.5 Cr. to be paid to 5&14a Not done/pending.

Atul Beri for Phase II Has to be accounted for, while BMG Unit.

computing final adjustment of accounts.

10. Transfer charges 6&14b Will be paid by DBEPL at the payable by DBEPL. time of execution of title documents.

11. Refund of electricity 6 When DBEPL receives this security deposit for from UPPCL, it will be shared Sector 59 and 64. between Deepak and Atul (50-

50).

12. Equal sharing of 7 Has to be accounted for, while statutory liabilities/profit computing final adjustment of (till date of division i.e. accounts. 30.06.2016)

13. Division of tangible 8 For machinery, there was a list assets including Plant prepared by Mr. Nagrath dated 13 and machinery, 10.06.2016, as per MoM dated Inventory, and 14.03.2016.

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 74 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 Consumables Division and physical shifting of machinery as per the Nagrath list started immediately and continued till about 30.06.2016 but could not be completed because Deepak Beri did not co-

operate and started raising disputes.

Division of machinery can continue and be completed as per the Nagrath List.

Some Inventory and consumable have been consumed with passage of time, they can be divided physically to the extent possible and if required their value as on 30.06.2016 can be divided, as per the statutory records.

14. Software 27 New accounting software has been purchased by Deepak Beri using common funds (from SKB, prior to 30.06.2016).

Atul Beri also need to buy new software from common funds, since the old licenses have expired. The cost of new licenses may be accounted for while computing final adjustment of accounts.

15. Division of logo 9 Done & implemented (on OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 75 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 23.03.2016)

16. Separation of original 10 Pending, as in Deepak's data and documents control.

Deepak claims to have digitized the record, for which money from common funds was used. The same needs to be supplied to Atul.

17. Transfer of domain 11 Pending as in Deepak's www.atlasknives.com control.

Deepak be directed to transfer the domain name to Atul.

18. Bank Liabilities 14c All liabilities cleared from DBE. Extra interest paid by DBE may be accounted for, while computing final adjustment of accounts.

19. Change in constitution 14d The same will be taken into of companies/cost account while computing final adjustment of accounts.

20. Rs. 1 Cr. to AB for 15 Not done.

getting lesser properties May be accounted for, while computing final adjustment of accounts.

21. Documents for effecting 16 Pending, can be done at the separation time Deepak and Atul exit from each other's entities.

22. Transfer of Ever Sharp 18 Pending, to be done by Knives to the highest executing Court. bidder and closure of IE.

23. New Security 21 Done, with effect from May OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 76 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 2016.

24. Accounts and I.T 22 Deepak has been refusing to Department at Okhla. share. Access to be shared with May be directed to do so. AB by DB

25. Employee transfer 24 As per MoM of 14.03.2016, employees have exercised their option of choosing which brother they wish to work for. This was done in March/April 2016.

However, from 30.06.2016 to 28.02.2018, workers who had chosen to be with Deepak Beri, but remained on the official rolls of DBE, were paid by DBE. Deepak has to compensate DBE for the same.

                                                                        This may be accounted for
                                                                        while      computing    final
                                                                        adjustment of accounts.
                      26.    Compensation                     to   25   Full and final settlement upto
                             employees                                  30.06.2016, may be accounted

for, while computing final adjustment of accounts.

27. Division of Net Current 31  The Net current assets of Assets DBEPL as on 30.06.2016 were Rs. 13.35 Crores (share of S.K Beri @ 40%).

 The Net current assets of BMGL as on 30.06.2016 were Rs (-) 19..5 (share of S.K Beri @ 33%).

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 77 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00  The Net current assets of SKB as on 30.06.2016 were Rs. 19.10 crores (share of S.K Beri @ 50%).

 The Net current assets of DBC as on 30.06.2016 were Rs. 0.15 crores (no share of S.K Beri).

 Thus, total NCA of the entities stood at Rs. 13.45 crores, after exclusing Mr. S.K Beri's share of Rs.

8.57 Crores, as on 30.06.2016, the same stood at Rs. 4.88 crores.

 Thus, Atul and Deepak's share in the NCA is Rs.

2.441 crores each.

 Deepak has to bring back a sum of Rs. 13.4 crores, representing the salaries and other dues paid for his employees (working at his units), and other statutory dues pertaining to his units, paid post 30.06.2016, by DBEPL.

 Thus, from division of NCA, the sum receivable by Atul is Rs. 1.22 crores and the sum payable by Deepak is (Rs. 13.40- 1.22) = Rs.12.18 crores.

28. Division of loans 32 Not required since loans paid off. Extra interest has to be accounted for, while computing final adjustment of OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 78 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 accounts.

29. SKB to give his portion 33 No comments on behalf of ultimately Atul Beri.

30. Proposed family 34 Parents alone can decide.

settlement to be made as per parents wishes MOM dated 14.03.2016

31. Plant and Machinery 5 Division of machinery can Division take place as per the Nagrath List.

32. Compensation for 4 See above.

Employees

33. Logos 1 Done

34. Order Division Done

35. Stock Division of stocks as on 30.06.2016 can be done as per statutory records.

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 79 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 TABLE III: The table produced by Mr. Atul Beri in paragraph 30 of OMP(Enf)(Comm.) 117/2019 filed by him, which states the remaining steps to be taken towards separation, according to him:

Step Suggested Steps No.
1. Mutual transfer of shareholding and ownership interests/ resignation from Directorship.

• Share certificates of Deepak and his family in DBEPL and BMGL to be transferred to Atul.

• Deepak to resign as Director of DBEPL and BMGL • Atul and his family to transfer their ownership interests in SKB and DBC to Deepak.

2. @Clause 7, 8, 13 & 31 of the MOU: Equal sharing of profits and liabilities till 30.06.2016, Division of tangible assets including Plant and machinery, Inventory, and Consumables and Division of Net Current Assets (NCA), as on 30.06.2016. • The Net current assets of DBEPL as on 30.06.2016 were Rs. 13.35 Crores (share of S.K Beri@ 40%). • The Net current assets of BMGL as on 30.06.2016 were Rs. (-) 19.15 (share of S.K Beri@ 33%). • The Net current assets of SKB as on 30.06.2016 were Rs. 19.10 crores (share of S.K Beri@ 50%). • The Net current assets of DBC as on 30.06.2016 were Rs. 0.15 crores (no share of S.K Beri). • Thus, total NCA of the entities stood at Rs. 13.45 crores, after excluding Mr. S.K. Beri's share of Rs 8.57 Crores, as on 30.06.2016, the same stood at Rs. 4.88 crores. • Thus, Atul and Deepak's share in the NCA is Rs. 2.441 crores each. • Deepak has to bring back a sum of Rs. 13.4 crores, representing the OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 80 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 salaries and other dues paid for his employees (working at his units), and other statutory dues pertaining to his units, paid post 30.06.2016, by DBEPL.

• Thus, from division of NCA, the sum receivable by Atul is Rs. 1.22 crores and the sum payable by Deepak is (Rs. 13 .40-1.22) =Rs. 12.18 crores.

The financial documents of the companies concerned, and the relevant calculation sheets in this regard are being filed with the List of Documents.

• In so far as machinery is concerned, there was a list prepared by Mr. Nagrath dated 10.06.2016, as per the MoM dated 14.03.2016. Division and physical shifting of machinery as per the Nagrath list started immediately and continued till about 30.06.2016, but could not be completed because Deepak did not co-operate and started raising disputes.

• Division of machinery can continue and be completed as per the Nagrath List.

3. @Clause 27, MOU: Software • New accounting software has been purchased by Deepak using common funds (from SKB, prior to 30.06.2016). • Atul also needs to buy new software from common funds, since the old licenses have expired. The cost of new licenses may be accounted for while computing final adjustment of accounts.

4. @Clause 9, MOU: Division of logo • Done and implemented, w.e.f. 23.03.2016.

5. @Clause 10, MOU: Separation of original data and documents • Deepak claims to have digitized the record, for which money from common funds was used. The same needs to be supplied to Atul.

6. @Clause 11, MOU: Transfer of domain www.atlasknives.com • Deepak be directed to transfer the domain name to Atul.

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 81 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00

7. @Clause 14c), MOU: Bank Liabilities • All liabilities cleared for DBEPL. Extra interest paid by DBEPL, may be accounted for, while computing final adjustment of accounts.

8. @Clause 14d, MOU: Change in constitution of companies/cost • The same will be taken into account while computing final adjustment of accounts.

9. @Clause 15, MOU: Rs. 1 Cr. To AB for getting lesser properties.

• Yet to be done.

10. @Clause 16, MOU:Deepak to hand-over all documents pertaining to DBEPL in his possession, including but not limited to Customs shipping bills, Customs certified invoices, import/export books, DGFT licenses (90 in number).

11. @Clause 18, MOU: Transfer of Ever Sharp Knives to the highest bidder and closure of IE Trading. • Pending, to be done by the executing Court.

12. @Clause 21, MOU: New Security • Done, with effect from May 2016.

13. @Clause 22, MOU: Accounts and I.T Department at Okhla.

• Access to be shared with Atul by Deepak, but Deepak has been refusing to do so.

• Deepak may be directed to share access.

14. @Clause 24, MOU: Transfer of Employees • The employees working at the units of DBEPL, under the control of Deepak, to be transferred to SKB. • As admitted by Deepak in para 48(7) of his Execution Petition, division of employees between Deepak and Atul took place in February 2016.

• Thereafter, Deepak's employees have been working exclusively at the units under his control, which admittedly contribute no revenue OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 82 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 to DBEPL.

• Thus, only a formal transfer of employees from one entity to the other is pending, which should be done as there can be no dispute that the employees working at Deepak's units have to move to SKB. • Deepak has to compensate DBEPL for the salaries, PF dues and other charges paid for his employees and/or Units, post 30.06.2016. As on date, the amount payable by Deepak under this head is Rs. 13.4 crores (approx.).

15. @Clause 25, MOU: Compensation to Employees • May be accounted for, while computing final adjustment of accounts.1

16. @Clause 32, MOU: Division of loans • Not required since loans paid off. Extra interest has to be accounted for, while computing final adjustment of accounts.

17. Withdrawal of complaints and Indemnity by Deepak.

• Deepak has filed complaints against DBEPL before various authorities, including Income Tax, GST, PF, TDS, SFIO related complaints.

• Deepak must withdraw all such complaints and undertake not to file further complaints.

• Deepak must provide an indemnity to Atul that he shall share in any tax or other statutory liability, if imposed prior to the cut-off date.

• All liabilities have to be shared prior to the cut-off date. Thus, if any tax or statutory liability is imposed prior to the cut-off date, especially as a result of complaints initiated by Deepak, he must bear his share of the same.

18. Deepak to give details of all liabilities created by him, in the name of DBEPL, post 30.06.2016, and discharge the same • Deepak has been in possession of DBEPL's Unit at C-27, Sector 59 OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 83 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 Noida.

• He must give details of all liabilities created in the name of DBEPL, with respect to this unit, since 30.06.2016, discharge the same, and indemnify against any claims raised upon DBEPL, pertaining to this unit.

19. Clauses 4, 5, 14 (a) of MoU, r/w clause 6 (under miscellaneous) of the MoMdt. 14.03.2016:Rs. 9.30 Cr. To be paid to AtulBeri. Not done /pending.

Has to be accounted for, while computing final adjustment of accounts, or at the time of exchange of properties, whichever happens first.

20. Exchange of properties: -

Property/Company Mode of Implementation @Clause 2, MOU:Property at •This plot has been in the B-113, 114, 115, 131, 132, exclusive possession of Deepak Sector 6, Noida, (Owned by Beri and he is running his DBC, to go to Deepak Beri). private LLP from here.
•This plot is owned by DBC, which is a 50-50 partnership between Deepak Beri and Anuja Beri (Atul's wife). Anuja may resign from DBC, leaving the firm and property to go to the share of Deepak.
@Clause 2 & 16, MOU: • Property has been in the Property at C-27, Sector 59 exclusive possession of Deepak Noida, (belonging to DBEPL, to Beri. DBEPL used to run its go to Deepak Beri/SK Beri & heat treatment plant from here. Bros) This was the mother unit to all other units. Deepak's exclusive possession of this property has severely hurt the family OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 84 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 businesses.

• Atul shall cause DBEPL to execute the requisite transfer documents, to transfer this property to SKB, simultaneously with Deepak (and his wife/children) transferring their shareholding in DBEPL and BMG to Atul, and resigning his Directorship in these Companies.

@Clause 2 & 16, MOU: • Out of the Units in Atul's Property at A-32, Sector 64, possession at the time of Noida, (belonging to DBEPL, to execution of the agreements, the be given to Deepak Beri /S.K Unit @ Sector 64 Noida, had to Beri & Bros). be handed over to Deepak as per the MOU.

• Correspondingly, as per Clauses 4, 5, 14 (a) of MoU, r/w clause 6 (under miscellaneous) of the MoM dt. 14.03.2016, Atul is to receive a total sum of Rs. 9.30 crores.

• The crystallised monetary sum(s) receivable by Atul were provided for (a) in view of the difference in property values, and (b) to compensate him, since he was losing, and Deepak was gaining an additional unit. • Accordingly, possession and/or title of this unit can be handed over to Deepak, upon Atul receiving the sum of Rs. 9.30 crores, as per Clauses 4, 5, OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 85 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 14 (a) of MoU, r/w clause 6 (under miscellaneous) of the MoM dt. 14.03.2016, as compensation @Clause 2, MOU: Property at Since SKB goes to Deepak Beri, A-119, Okhla Phase-II, no transfer documents are belonging to SKB to remain required to be executed. with SKB/Deepak.

@Clause 4, MOU: Property at In possession of DBEPL. No B-1, Sector 68, Noida execution of title documents (belonging to DBE, to go to required. Atul) However, as per the MoU, One- Time Lease Rent was to be done by Deepak and Atul- 50-50.

This has not happened, and has to be accounted for, while computing final adjustment of accounts.

@Clause 4, MOU: Property at In possession of DBEPL/Atul. F-61, Sector 11, Noida No execution of title documents (belonging to DBE, to go to required. Atul) @Clause 4, MOU: Plot at C-57, In possession of BMG/Atul. No Phase II, Noida (belonging to execution of title documents BMG, to go to Atul) required.

Deepak to resign as Director from BMG and hand over shareholding.

@Clause 4, MOU: Plot at C-12, Possession awaited by DBEPL. Ecotech-11 Greater Noida, to go Deepak Beri be directed to to Atul.

handover requisite documents of allotment.

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 86 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00

21. @Clause 6, MOU: Refund of electricity security deposit for Sector 59 and 64.

When DBEPL receives this from UPPCL, it will be shared between Deepak and Atul (50-50)/

22. Ad hoc loan of Rs. 40,00,000/-, by DBEPL to SK Beri and Brothers in terms of Order dated 1.11.2018 needs to be returned to DBEPL.

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 87 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 TABLE IV: The table produced by Mr. Deepak Beri in his reply to OMP(Enf)(Comm) 117/2019, which states the remaining steps to be taken towards separation, according to him:

Status as on 24.07.2018 S.No. DOA Person Required Implementation Required Steps/Action
1. Existing Auditor/Receiver List out all orders Distribute orders Order that are equally or share available/pending percentage of
2. Additional Auditor/Receiver in value profit.
Orders
3. Hidden Auditor/Receiver Orders
4. Payment to Auditor/Receiver Over 20 Cr. Calculate Vendors Already paid by liability and then both, now share equally.
                                                                 therefore      get      Pay if Bank
                                                                 forensic     audit      Balance
                                                                 done, list out          available after
                                                                 those that are          splitting         or
                                                                 correct on date.        account for in
                                                                                         the          current
                                                                                         assets          and
                                                                                         liabilities.
                      5.     Staff     (No Auditor/Receiver Make list of all Pay from DBE
                             retrenchment,                  those    leaving account.
                             no soliciting,                 DBE, make full
                             full and final                 and         final

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 88 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 payment and settlement upto clear) date.

6. Raw Material Auditor Receiver Forensic audit to Distribute final POs to be be done since figure equally. signed by this step was not Compensate both parties followed. each other for then entered. difference, if any.

7. WIP, RM, Auditor/Receiver Forensic Audit to Distribute final Finished be done to arrive figure equally.

                            Goods                         at correct figure.
                      8.    Production to Receiver            Receiver takes        All audit and
                            be caried out                     over and fixes up     paper work to be
                                                              a     date     till   completed and
                                                              separation.           then distribute
                                                                                    equally.
                      9.    Managing       Receiver           Receiver takes Handover      to
                            Plant/all                         over,    appoint individual
                            departments                       new Security Co. Group on fixed
                            were to be                                         date.
                            done      with
                            intimation by
                            MN also
                      10.   Security     Receiver             Receiver takes Hands over to
                            Independent                       over,   appoints individual group
                            Security to                       new Security Co. on DOS.
                            be appointed
                            and       no
                            movement
                            without
                            approval.
                      11.   Books      of Auditor/Receiver Get      forensic Divide the final
                            Account                        audit done along equally.
                            Everything to                  with      regular

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 89 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 be recorded Audit and and checked finalise accounts Balance sheet to be made given books of last 3 years to Auditor.

12. IT Separate, Auditor/Receiver List out all that is Distribute B & G and there make 2 equally by Toss.

                            other                         equal list.
                            software
                      13.   Travelling
                      14.   Independent           Auditor/Receiver List out all the Hand them back
                            Unit                                   independent         on DOS.
                                                                   units. Clear them
                            running not
                                                                   or take them
                            allowed                                within         the
                                                                   company        till
                                                                   DOS.
                      15.   P&M List to Auditor/Receiver Appoint           Distribute
                            be                           Chartered         equally by Toss.
                                                         Engineer to value
                            made and
                                                         machine as per
                            distributed.                 CC list and make
                                                         2 equal lists.
                      16.   Intangible            Auditor/Receiver List out all that is Then distribute
                            Mainly                                 owned by the equally by Toss.
                            software                               company        after
                                                                   Forensic      Audi
                                                                   available, make 2
                                                                   equal lists.
                      17.   Working                                 Approach
                            Capital                                 Bankers

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 90 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 independently.

18. The Receiver Fix up future Handover to 30.06.2016 date of DOS, all each group.

                            was the DOS                             accounts        upto
                            or any other                            DOS to be made,
                            date as per                             documents made
                            MN,        all                          of      ownership
                            documents to                            transfer     assets
                            be made by                              and      liabilities.
                            DOS.                                    Keep            with
                                                                    Escrow
                      19.   Specific     Auditor/Receiver Appoint Forensic              Adjust whatever
                            Audit    and                  Auditor for this.             is the difference
                            adjust    in                                                in           each
                            DB/AB                                                       unit/group.
                            Account
                      20.   Expenses of Auditor/Receiver Not      required
                            C1                           since the date
                                                         31.03.2016 did
                                                         not work out.
                      21.   Efforts    to Auditor/Receiver Fix new date for             Sign     Balance
                            finalise                       finalisation   of            Sheet and file
                            account by                     Forensic Audit as            with    different
                            30.06.2016                     well as Statutory            Authorities.
                            and        all                 Audit.
                            accounts to
                            be finalized
                            by then.



                                                         Terms of the MOU

                      S.No MOU                          Person        Required       Implementation

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 91 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 . Required 1-2 What Deepak will Auditor/ Handover Transfer get Receiver possession properties in the of 64 to correct name and Deepak keep it escrow with share transfer certificate from Deepak.

                                                                                  Handover       on
                                                                                  DOS.
                      3-4   What Atul will Receiver                Pay            Handover/exchan
                            get                                    onetime        ge    documents
                                                                   lease rent     when everything
                                                                   for 68         is complete and
                                                                                  approved     by
                                                                                  Court on DOS
                                                                                  until then in
                                                                                  Escrow.
                      5.    Atul to get 7.5 Cr. Auditor/           Audit          Pay or get back
                                                Receiver           Accounts       as the case may
                                                                                  be      anything
                                                                                  above 7.5 Cr.
                                                                                  include     Cash
                                                                                  Payment of 2.5
                                                                                  Cr.
                      6.    Transfer of 59/64 Receiver             Handover       Transfer
                            to Deepak                              possession     properties in the
                                                                   to Deepak      Correct name and
                                                                   get      all   exchange       on
                                                                   ownership      DOS.
                                                                   documents
                                                                   made and
                                                                   kept      in

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 92 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 Escrow.

7. Statutory assets Auditor/ Get Pay all the dues and liabilities to Receiver forensic of all companies be equal audit done and file all and returns.

complete account upto DOS.

8. All tangible and Auditor/ Get Divide by Toss intangible assets Receiver forensic and handover the to be divided audit done each person at his also units.

chartered engineers to make 2 equal lists.

9. Atlas logo to be Auditor/ Get Board Handover to divided Receiver Resolution Deepak on DOS.

                                                              made by
                                                              DB
                                                              Engg(P)
                                                              Ltd       for
                                                              transfer.
                      10.   Date         & Auditor/           Make a list Hand        over         to
                            Documents to be Receiver          of all that DOS.
                            exchanged.                        is required
                                                              for    each
                                                              other
                                                              including
                                                              DB
                                                              Engg(P)
                                                              Ltd. Board
                                                              Resolution
                      11    Atlas          domain Receiver    Make      all Handover               on

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 93 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 name the papers DOS required 12 Deepak can use Receiver Undertakin Hand over on atlas knives after g from DOS 2 years Deepak to this effect 13 Machine List Auditor/ List of Toss for which Receiver CC's is list to where and authentic, then shift to each get other unit before Chartered DOS Engineers to value, make two equal groups

14. Money for Auditor/ Keep 10- Use whatever is separation Receiver 12 Cr in required? Balance Escrow to be distributed on DOS.

15. Atul to be paid 1 Auditor/ Get Audit Pay or get back Cr Receiver done as required

16. 30.06.16 as cut Receiver Decide Finish everything off date new date by then possibly 60 days ahead

17. Documents to be Auditor/ Make all Exchange on made Receiver documents DOS get them signed, keep in Escrow OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 94 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00

18. IE & Eversharp to Auditor/ IE Handover on be distribute Receiver insolveme DOS nt for Eversharp toss or bid and make papers for transfer.

19. Entries in Books Auditor/ Get Make adjustment with approval of Receiver forensic on group account both Audit done as required.

and account for everything

21. Common Security Auditor/ Appoint Handover unit on Receiver independe DOS nt security in all units

22. IT Personal & Auditor/ List out Handover unit to Hardware Receiver whatever each group is not done

23. Representative to Receiver Receiver is Hand back be run units i.e. appointed, everything on other than family he is not DOS family

24. Employees to be Auditor/ Make list Pay & Clear given an option Receiver and before DOS amount due for those who decided to move from DBE 25 & Compensation to Auditor/ Make list Pay & Clear OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 95 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 26 be given and full Receiver and before DOS & final amount due for those who will move.

                      27    Intangible Assets Auditor/         Make list Distribute                on
                            like software     Receiver         two equal DOS
                                                               if      not
                                                               possible
                                                               buy     and
                                                               make
                                                               equal    or
                                                               compensat
                                                               e        in
                                                               money.
                      28.   To have           equal Receiver   Will     be
                            share                              done once
                                                               everything
                                                               is achieved
                      29.   Restriction            of          Nothing
                            Business                           needs to be
                                                               done.
                      30.   Accounts to be Auditor/            Get        Books and final
                            prepared/maintain Receiver         forensic   account to be
                            ed till date with                  Audit done made upto DOS
                            knowledge of all                              finalized      and
                                                                          signed by all.
                      31.   Current assets to Auditor/         Get        Divide equally
                            be divided        Receiver         Forensic
                                                               Audit done
                                                               arrive at
                                                               correct
                                                               figure
                      32    Will         approach              No    limit Both       can          do

OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 96 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00 bank for working now individually after capital DOS 33 SK Beri holds his Auditor/ Take Get papers made share Receiver average for his share, also share in all papers for his companies shares finally arrive at going to Deepak his and Atul.

percentage of ownership 34 Nitting Gritting to Receiver Receiver Receiver to be worked out to decide decide 35 Code of Conduct Receiver Receiver Receiver to to decide decide 36 GK JB other Court Oral Get it in writing family properties settlement and approved by done Court

37. All assets and Auditor/Receiv Get Distribute equally liabilities of DBE er Forensic on DOS and other to be Audit finalized and Done shared equally

38. No email to be Receiver Receiver Receiver to sent to decide decide

39. MOU Binding Court Court has given its order on 31.05.2018 OMP(I)(COMM)326-2016 & connect. matters Signature Not Verified Page 97 of 100 DigitallySigned By:MANJU BHATT Signing Date:25.12.2020 09:21:00