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(i) The requests lack relevance and/or materiality.
(ii) The requests are mere "fishing and roving" exercise.
(iii)    The requests made lack specificity.

(iv)     The requests made are directed towards internal documents

(v)      The documents of which disclosure is sought are privileged as they

refer to the affairs of the State.

(vi)     That the documents of which disclosure is sought are privileged

inasmuch as they refer to intra-Governmental discussions.
OMP (COMM) No.44/2018 Pg. 10 of 46

24.2 Insofar as the aspect concerning the file notings was concerned, the Arbitral Tribunal observed that it could not, simply, in one-stroke dismiss OMP (COMM) No.44/2018 Pg. 13 of 46 the request for disclosure of file notings and internal documents only because they did not constitute the Government‟s final decision. Accordingly, the Arbitral Tribunal, while holding that the proportionality of each such request would have to be examined observed that it could not, based on a general objection raised against disclosure of file notings, not deny such a request. According to the Arbitral Tribunal, the UOI‟s submission in this behalf was erroneous as it had also sought a whole range of documents from the respondents/Contractors which may not have resulted in enabling them to reach a final decision in the given matter. In sum, the Arbitral Tribunal in respect of this aspect, in a sense, applied the adage what‟s sauce for the goose is sauce for the gander. 25 The bulwark of the majority reasoning was that given the provisions of Sections 18 and 19 of the 1996 Act while it is required to follow the principles of natural justice, it is not bound by the provisions of the Code of Civil Procedure, 1908 (hereafter referred to as „CPC‟) and/or the Evidence Act.

                                                                              disclosure      of       a   document
                                                                              commenting on the AIDP and
                                                                              arguably directly relevant to a central
                                                                              issue in this arbitration.
Request No. 2    (Amended request) Disclosure of                 Granted      - UOI consented to disclosing the
                 earlier versions of, or equivalent                           October 2017 procedure.
                 formal documentation dealing with,                           In deciding whether such consent
                 the subject-matter of the DGH's                              would extend to earlier versions of
                 published October 2017 "Standard                             the document, the AT held:
                 Operating Procedure for Declaration                          - Confidentiality cannot be a ground
                 of Commerciality" etc. (Standard                             for non-disclosure, especially when
                 Operating Procedure). (Documentation                         the claimants (Respondents herein)
                 dating from May 2004 to October                              successfully proved the following:
                 2013).                                                       i. Request is sufficiently specific.
                                                                              ii. Documentation relevant.
                 (List of custodians provided)                                - Therefore, fair disclosure must do
                                                                              justice to the contentions of both
                                                                              sides to the argument.
Request No. 3    (Amended request) - Disclosure of               Granted      - Relevant and admissible material
                 formal MoPNG or DGH guidelines or                            should be produced.
                 procedures concerning methodology or                         - If formally published guidelines are
                 criteria for estimation and approval of                      relevant, as they obviously are, the
                 OGIP/reserve estimates in proposed                           same response obtains for earlier
                 development plans or their revisions                         such material, even if not published.



             OMP (COMM) No.44/2018                                                               Pg. 22 of 46
                 (Documentation dating from May 2004                 - Hence, UOI's other contentions
                to October 2013). (List of custodians               rendered unpersuasive.
                provided)
Request No. 4   Disclosure of formal guidelines or Granted          Reasons for granting are same as in
                procedures of the MoPNG or DGH in                   Request no.3 as the UOI's stand is
                effect from January 2011 to May 2014                same as in Request no.3.
                governing decisions to approve, deny
                or revise proposed development well
                locations. (List of custodians provided)
Request No. 5   (Amended request) - Disclosure of the Granted       - Internal documents not immune
                UOI's documents dated between                       from disclosure just because they are
                28.8.2012 and 1.10.2013 concerning                  internal.
                (especially disputing, challenging or               - Disclosure is primarily aimed at the
                discussing) the decision of the UOI's               internal documents of the opposing
                representatives      on      the     MC             party which have NOT been shared
                (Management Committee) not to                       or disclosed. - Internal documents
                approve the RFDP at the meeting of                  cannot be free of the obligation to

As for the claim to privilege, the A.T. in general rejects it for the reasons and in the terms set out in the Introduction to this Disclosure Order.

Request No. 6 Documents, falling within the period Granted Reasons for granting are same as in of two years before the MC meeting of Request no.5 as the UOI's stand is 1.10.2013, which were sent, received same as in Request no.5. or created by the listed custodians and which went to the UOI representatives on the MC for the purpose of the meeting of 1.10.2013. (List of custodians provided) Request No. 7 The UOI's internal documents, sent, Granted - At the stage of disclosure, it is not received or created in the period from for the Parties to assume, or for the 1.10.2011 to October 2013 by A.T. to rule on, the Parties' custodians whose names have been individual pleaded contentions: that listed to aid a search, discussing the awaits their final award. position taken by the UOI's - The role of disclosure is to allow representatives at the MC meetings fair access to each other's documents held on 2.11.2011 and 7.8.2012, that to permit the several pleaded cases to additional drilling of development be fairly heard and adjudicated. wells was required.