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h. By notice dated 7 December 2000, original Plaintiffs through their constituted attorney requestioned meeting under Section 169 of the Companies Act for removing Defendant Nos.2, 8 and 9 as Directors and instead appointing Plaintiff No. 1, Defendant No.17 and Original Plaintiff No.2. Accordingly, a Meeting of Board was held on 8 December 2000 resolving to take proper legal advice on original Plaintiff No.1's requisition.

i. Original Plaintiffs also issued public notices in Times of India (17 December 2000) and Mumbai Samachar (18 December 2000) stating that they have 99.96% stakeholding in Defendant No.1-Company and requestioning of Extra-Ordinary General Meeting (EOGM) for removal of Defendant Nos.2, 8 and 9 as Directors. Defendant No.2 also issued public notice in Times of India (24 December 2000) contending that Original Plaintiffs' Notices were misleading. On 26 December 2000 an intimation was sent by Defendant No.1-Company to Defendant No.22-Registrar of Companies about cessation of original Plaintiff No.1 as Director of the Company. Also, a Notice dated 26 December 2000 convening the requisitioned meeting on 9 January 2001 by Defendant No.1-Company was received by Original Plaintiffs on 27 December 2000. By letter dated 4 January 2001, original Plaintiffs forwarded proxy forms appointing Plaintiff No.1 and Defendant No.17 as their proxies to vote in the AGM.