Voici La Réponse de Larsen & Toubro À La Suite D'une Plainte Déposée Par Des Habitants de La Rue Sir Virgil Naz. Le Leader de L'opposition A Déposé Ce Document À L'assemblée Nationale Ce Mardi.
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Voici la réponse de Larsen & Toubro à la suite d'une plainte déposée par des habitants de la rue Sir Virgil Naz. Le leader de l'opposition a déposé ce document à l'Assemblée nationale ce mardi.
Оригинальное название
Voici la réponse de Larsen & Toubro à la suite d'une plainte déposée par des habitants de la rue Sir Virgil Naz. Le leader de l'opposition a déposé ce document à l'Assemblée nationale ce mardi.
Voici la réponse de Larsen & Toubro à la suite d'une plainte déposée par des habitants de la rue Sir Virgil Naz. Le leader de l'opposition a déposé ce document à l'Assemblée nationale ce mardi.
0 оценок0% нашли этот документ полезным (0 голосов)
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Voici La Réponse de Larsen & Toubro À La Suite D'une Plainte Déposée Par Des Habitants de La Rue Sir Virgil Naz. Le Leader de L'opposition A Déposé Ce Document À L'assemblée Nationale Ce Mardi.
Voici la réponse de Larsen & Toubro à la suite d'une plainte déposée par des habitants de la rue Sir Virgil Naz. Le leader de l'opposition a déposé ce document à l'Assemblée nationale ce mardi.
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(At the suit, instance and request of LARSEN & TOUBRO LTD, electing its legal
(domicile in the office of the undersigned Attomey, of Unit 601, 5" floor, Chancery
(House, Lislet Geoffroy Street, Port-Louis
NOTICE IN REPLY FROM LARSEN & TOUBRO LTD TO THE NOTICE OF THE
HEREUNDER NAMED PARTIES, electing their legal domicile in the office of Me.
Naseebah A. Chataroo-Chumun situate at 7" Floor, Hennessy Tower, 23, Jules
Koenig Street, Port-Louis,
4. Larsen & Toubro LTD ("L&T") acknowledges receipt of the mise en demeure
served at the suit, request and instance of the hereunder named parties on the
15/11/2018 (the “Notice”).
2. L&T denies the allegations of negligence levelled against it in the Notice, denies
being responsible for the alleged prejudice, loss and damaged referred to in
paragraph 15 of the Notice, and denies being indebted to the hereunder named
parties in the sum claimed, or in any sum at all.
3. L&T's response to the Notice is set out below. Save and except as hereinafter
expressly admitted, all the averments of the Notice are traversed as though the
same were herein set out and traversed seriatim.
4, L&T takes note of paragraph 1 of the Notice.
L&T admits paragraph 2 of the Notice and states that it has been awarded a
contract by Metro Express Limited and the Government of Mauritius for
‘engineering, procurement and construction work for the Metro Express project in
=the Republic of the Mauritius.
6. L&T takes note of paragraph 3 of the Notice.
7. L&T makes no admission as to paragraphs 4 to 14 of the Notice, puts the
hereundernamed parties to the proof of each and every averment set out therein
and states:
7.1.On the 27/10/2018, construction work in respect of the Metro Express project
was on-going:
7.2.On the 28/10/2018 at or about 11am, it was noticed that three manholes on Sir
Virgil Naz Street, Rose Hill, were overflowing;
7.3.L&T immediately informed the Wastewater Management Authority ("WMA") of
the incident and L&T deployed a highly empowered quick response team to
deal with the situation;7.4.The identification of the pipe which was clogged and which was causing the
manholes to overflow was time consuming, and required L&T to carry out
certain excavation works. The entire operation of detection of the fault,
excavation of the pit, dismantling of the affected pipe and rectification works
were jointly carried out by engineers of WMA and L&T ina professional manner
and in accordance with engineering standards required for works of this nature;
7.5.On 30/10/2018, the process of identifying the clogged pipes and allowing the
water to flow downstream was completed;
7.6. Notwithstanding the process of identifying the causes of the overflowing
manholes, two sewage tankers were deployed as from 11:30 AM on
28/10/2018 to pump the sewerage, which was overflowing from the manholes.
These two sewage tankers worked throughout the day and night of 28/10/2018
to evacuate the waste water from the street. On 29/10/2018, six additional
tankers and two heavy duty dewatering pumps were mobilized to remove the
water overflowing from the manholes;
7.7.On 30/10/2018, after detecting and removing the blockage, the overflow of
water reduced and, by 10am on 31/10/2018, had completely stopped.
7.8.While these operations were ongoing, L&T engaged twelve sewage tankers
and heavy duty dewatering pumps to remove water from the overflowing
manhole chambers at Sir Virgil Naz Street and the excavated pits at the site.
Wastewater pumped from these manhole chambers and excavated pits was
discharged into the nearest sewer manhole, and not into Riviére Séche as
alleged;
7.9. After completely stopping the overflow of water on 31/10/2018, L&T mobilized
multiple teams to clear all the dirty water and slush from the affected areas as
a matter of priority. Arrangements were made to clean the roads and nearby
shops using jetting machines and fresh water tankers. Crusher run was spread
in front of the residential area after cleaning the slush. Specialised agencies
were deployed to disinfect the area, shops, car parking area, storm water
channels and the river. Cleaning and disinfection of shops and nearby
residences was ompleted by the evening of 31/10/2018. Specialised agencies
were deployed in order to spray air fresheners in the affected area and
distribute air freshener kits to shops in the affected area. The cleaning of
sludge from the river stream behind the CEB premises was continually done
to ensure there was no residual sludge in the river. Road cleaning and
disinfection of the locality was carried out each day to ensure a clean
environment.7.10. __Itis denied that WMA continued to pump waste water from Sir Virgil Naz
Street until 10/11/18. L&T stopped pumping out waste water from Sir Virgil
Naz Street on the 31/10/2018 when the blockage was cleared. As a measure
of abundant precaution, all the pipes and manholes in the vicinity were verified
by L&T and WMA during off peak timing at specific areas to make sure that
there were no blockages and that pipes were clear of any obstruction. Apart
from other technical surveys, a special investigation through camera was
carried out at night to find out the extent to which the pipe along Sir Virgil Naz
Street was obstructed.
7.41. On 13/11/2018 at about noon, there was heavy rainfall in Rose Hill which
caused an inflow of twigs, branches, leaves and debris into the pit excavated
to investigate the sewer line at Place Margéot. As a result, the mouth of the
sewer pipe got clogged. This caused the overfiow of a manhole at Sir Virgil
Naz Street for a short period of time. The overflowing is not related to sewer
pipe damage incident,
8. L&T denies paragraph 15 of the Notice generally and puts the hereunder named
parties to the proof thereof.
9. L&T denies paragraph 16 of the Notice and puts the hereunder named parties to
the proof thereof. L&T avers that it immediately took all remedial measures
following the overflow of sewerage along Sir Virgil Naz Street, Rose Hill on the
material date to minimise and/ or avoid any inconvenience and/ or damage and/or
prejudice to the inhabitants of Sir Virgil Naz Street.
10.In response to paragraph 17 of the Notice, L&T notes that no breakdown of the
sum claimed in respect of each of the claimants nor any particulars of the claim
have been provided. L&T denies the averments set out in paragraph 17 and denies
being indebted to the hereunder named parties in the sum claimed, or in any sum
atall.
14.L&T therefore will not comply with the requirements and exigencies of the Notice.
Under all legal reservations
Dated at Port-Louis, this 2; of November 2018 “i
wi
Of Unit 601, 5" floor, Chancer
ATTORNEY FOR LARSEN & TOUBRO LTD
GUJADHUR SA (ot m- Ba
House, Lislet Geoffroy Street, Port-Louis
a