PRAYER

Wherefore in the light of the issues raised, arguments advanced and authorities cited, it is
humbly requested that this Honourable Court may be pleased to:

DECLARE that

I. The Arbitral Tribunal has jurisdiction to hear the present dispute.

II. ‘Fraud’ as a subject matter will be arbitrable

ADJUDGE that

I. The claims based on the evidence by the defendants is not admissible.

III. Evidence produced by the defendants is inadmissible.

IV. Claimants are entitled to damages as a consequence of termination of contract.

And pass any such order or direction as the Honourable Tribunal deems fit in the interest of
justice and good conscience, and , for this the Claimant shall duty bound pray.

Date:

Place:

ALL OF WHICH IS RESPECTFULLY SUBMITTED

COUNSEL FOR THE CLAIMANTS