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D. To the extent that the MOFS seeks to deal with the assets of the R.C. Jain (HUF), it is submitted that it required the assent of all members of the HUF, which it admittedly did not have.

E. The MOFS is an incomplete document, inasmuch as the schedules thereto were never agreed between the parties. It is pointed out that the purported schedules to the MOFS, which have been filed with the petition, are unsigned documents whereas each page of the MOFS bears the signature of the seven signatories. The respondents referred to various clauses of the MOFS to submit that the schedules were intended to be integral parts of the MOFS, without which it is rendered meaningless.