Grounds 6.1 and 6.2 :

6.1.That, the letter of termination dated 18.01.2023 sent by the  Respondent No. 2 and the subsequent letter dated 22.09.2023 for encashment of Bank guarantees sent by Respondent No 2 to Respondent No. 4 is arbitrary, illegal, unjustified and uncalled for and hence, deserves to be interfered by this Hon’ble Court.

6.2.That Bank Guarantees are being invoked wrongfully and fraudulently by Respondent Nos. 2 and 3, contrary to the conditions and terms set out in the contract and without any breach of performance or default on part of the Petitioner in performing its obligations. As evident from the facts stated above, the Respondent No 1, 2 and 3 have neither any subsisting valid and/or legal money claim against the Petitioner nor is the Petitioner in default of performance of any kind or any of its obligations under the Agreement.