BEFORE SHRI S.S.

BARVE, THE SOLE ARBITRATOR

IN RE
M/s Bee Jay Contractors …CLAIMANT
Vs
M/s Indian Oil Corporation Ltd. …RESPONDENT

INDEX

NO. PARTICULARS PAGE NOS.

1. Petition with Affidavit
2. List of documents
3. Vakalatnama
4. Address Form

NEW DELHI Verma & Associates

Advocates for the Plaintiff
Dated:

BEFORE THE SOLE ARBITRATOR SHRI S.S. BARVE

 IN RE
M/s Bee Jay Contractors,
BG-6/251A,Paschim Vihar
New Delhi-110063
Though their partner …CLAIMANT
Vs

M/s Indian Oil Corporation Ltd.

Plot no.3A,Madhya Marg,
Chandigarh.
Through The Chief Engineering
Manager …RESPONDENT

PETITION FOR CLAIM OF RS..... PERTAINING TO

RECOVERY OF DUES FOR WORK ORDER NO
…………………….PERTAINING TO REMODELLING
MANN MOTORS BHATINDA

The Claimant most respectfully showeth:-

1. That Claimant is a Partnership concern, duly

registered with the Registrar of Partnership and
carrying its business from BG-6/251A,Paschim Vihar
New Delhi-110063.Sh.Anil Dheer, who is instituting
the petition has signed and verified the Petition. He is
 fully conversant with the facts and circumstances and
has been personally dealing with the matter out of
which the present claim has arisen.

2. That the Respondent is The Chief Engineering

Manager(PSO) Indian Oil Corporation Ltd,Plot no-
3A,Madhya Marg,Chandigarh. Vaneet Bansal
,Dy.Manager (E) who is Chief Engineering Manager.

3. That the Claimant was given the work order for

remodelling of………………After successfully finishing the
work and after tallying the contractual payments ,it
was Observed that deductions that Rs.4,96,375.00
and the amount of extra work of Rs. 10,90,818.00
thereby making a total amount of Rs.15,87,193.00
was pending at defendant’s

4. That claimant have written various letters to which no

reply has been received till date.

5. That claimant Due to your arbitrary deductions,

requested vide their letter ref no. BJC/F-270/4677
Dt.14.04.2010 to refer the matter to the arbitrator as
of the dispute.

6. That the defendant however failed to make the

 payments till date, needless to mention that Claimant
had been requesting the Respondent many a times to
release the outstanding dues. But Respondent failed
to honour their commitments and withheld the
amount, in spite of Claimant satisfactorily finishing
the work for remodelling of Mann Motors, Bhatinda.

7. That since the Respondent has failed to pay the above

mentioned amount in spite of the demands; under
following circumstances Respondent is liable to pay
the amount in favour of Claimant along with the
interest as stated in the Invoice.

PRAYER

It is therefore prayed that this Hon’ble Court be

pleased to:-
1. Pass a decree in favour of the Claimant and

against the Respondent in the Sum of Rupees

…………………………….only.
2. Award pendent lite interest @ 18 %per annum,

till the date of realisation,

3. Allow Costs of the Suit in favour of the Claimant

and against the Respondent,

4. Allow/Grant any other relief which the Hon’ble

Court may deem fit and proper in the

 Circumstances of the case.

Claimant/Applicant
DELHI

Date: THROUGH

VERMA AND ASSOCIATES

ADVOCATES

VERIFICATION:-

Verified at New Delhi this ………… that the contents of

Paras ………..of the above Plaint are true and correct to
my knowledge and those of Paras ……………are true
upon information/advice received and believed to be
correct and the last Para is Prayer to this honourable
Court

Claimant
BEFORE THE SOLE ARBITRATOR SHRI S.S. BARVE
SUIT NO. ----------OF 2009
IN RE
M/s Bee Jay Contractors …CLAIMANT
Vs
M/s Indian Oil Corporation Ltd.…RESPONDENT

Affidavit
I, Anil Dheer, , Director, M/s Bee Jay Contractors BG-
6/251A,Paschim Vihar New Delhi-110063 do hereby
solemnly affirm and declare as under:-
1. That I am the Director/Partner of the Claimant
Company. I am well conversant with the Facts
and circumstances of this matter. I am
competent to swear this Affidavit.

2. That accompanying Suit for Recovery against the

Respondent has been drafted by my Counsel
 under my instructions, the Contents of which
have been read and understood by me. The
same are not repeated here for the sake of
brevity.

3. The same may be read as part of this affidavit

4. The same are true to my knowledge.

DEPONENT
VERIFICATION
Verified at Delhi on this Day of January, 2011on
Solemn Affirmation that the Contents of this
Affidavit are true and nothing material has been
concealed there from.
DEPONENT
BEFORE THE SOLE ARBITRATOR SHRI S.S. BARVE

SUIT NO. ----------OF 2009

IN RE
M/s Bee Jay Contractors …CLAIMANT
Vs
M/s Indian Oil Corporation Ltd.…RESPONDENT

ADDRESS FORM
 M/s Bee Jay Contractors. … CLAIMANT
Versus
M/s Indian Oil Corporation Ltd.…RESPONDENT

ADDRESS FORM

Suit for ______________ Date of Hearing:

__________

The address of Plaintiff is as under:

Name Cast Resident Post Tehsil Distt. Remarks
with e of Office
Father’s
Name

Sir,
 All the summons, notices orders etc. in connection
with the above suit be sent to me at the address given
above.
In case of any change in address the same shall be
communicated you with full particulars and details.

(Signature)