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Claim No. CFI 060/2020

THE DUBAI INTERNATIONAL FINANCIAL CENTRE COURTS

IN THE COURT OF FIRST INSTANCE

BETWEEN

(1) AL AHLI BANK OF KUWAIT K.S.C.P.
(2) MASHREQ BANK PSC
(3) ARAB BANKING CORPORATION (B.S.C.)
(4) NATIONAL BANK OF OMAN (S.A.O.G.)
(5) STATE BANK OF INDIA
(6) REGERA S.A. R.L.

Claimants

and

(1) EMIRATES HOSPITALS GROUP LLC
(2) KHALEEFA BUTTI OMAIR YOUSIF AHMED AL MUHAIRI
(3) H.E. SAEED MOHAMMED BUTTI MOHAMMED KHALFAN AL QEBAISI
(4) EMIRATES HEALTHCARE L.L.C.
(5) EMIRATES HOSPITAL L.L.C.
(6) EMIRATES SPECIALITY HOSPITAL FZ-LLC
(7) EMIRATES HOSPITALS & CLINICS L.L.C.
(8) EMIRATES HOSPITALS REHABILITATION AND HOMECARE SERVICES L.L.C.
(9) EXCEL HEALTHCARE L.L.C.
(10) EMIRATES PHARMACY L.L.C.
(11) COSMESURGE AND EMIRATES HOSPITAL PHARMACY L.L.C.
(12) VEINCUE CLINIC DMCC
(13) EMIRATES HOSPITAL DAY SURGERY & MEDICAL CENTRE L.L.C.
(14) EMIRATES HOSPITALS CLINICS BUSINESS BAY L.L.C
(15) KLINKA MAHARLIKA L.L.C.
(16) AL SABAH MEDICAL CENTRE L.L.C.
(17) COSMOPOLITAN MEDICAL CENTRE L.L.C.
(18) EMIRATES STAR MEDICAL CENTRE L.L.C.

Defendants

and

(1) CREDIT SUISSE AG
(2) AHLI UNITED BANK B.S.C. (DIFC BRANCH)
(3) NATIONAL BANK OF OMAN (S.A.O.G.), DUBAI BRANCH

Additional Defendants to the Counterclaim of the First and Fourth to Eighteenth Defendants

REASONS OF JUSTICE WAYNE MARTIN FOR ORDERS MADE ON 6 DECEMBER 2021

SCHEDULE OF REASONS

Introduction

1. On 30 November 2021, at the conclusion of the hearing of Application no. CFI-060-2020/7 by the Claimants for immediate judgment, I ordered that:

for reasons to be published. Ancillary orders were also made relating to the continuation of the Claimants’ claims against the Third Defendant and with respect to the costs of the proceedings as between the Claimants and the First, Second and Fourth - Eighteenth Defendants.

2. These are the reasons for the orders which I made.

Procedural History

3. On 27 July 2020, the Claimant banks commenced proceedings in this Court against the Principal Borrower of funds from the Claimants (the First Defendant), two personal guarantors of the debt created by the advances made by the Claimants (the Second and Third Defendants) and fifteen corporate guarantors of the debt (the Fourth - Eighteenth Defendants).

4. The First Defendant and the Fourth - Eighteenth Defendants filed an Acknowledgement of Service indicating an intention to defend the claim. No challenge to the jurisdiction of the Court was foreshadowed by those Defendants. Further, in due course, those Defendants filed Defences in which they admitted the allegations made by the Claimants in their Particulars of Claim relating to provisions in the relevant Facility Agreements and/or the Guarantees empowering the Claimants to give notice requiring any dispute arising under those documents to be litigated, and in the event such notice is given, conferring exclusive jurisdiction on the Dubai International Financial Centre Courts (the “DIFC Courts”) to settle any dispute the subject of such notice. Those Defendants admit that such notices were served, and that this Court therefore has exclusive jurisdiction with respect to both the Claimants claims against them, and their counterclaims against the Claimants.

5. However, the Second and Third Defendants filed an Acknowledgement of Service indicating an intention to challenge the jurisdiction of the DIFC Courts, and on 28 September 2020, the Second and Third Defendants filed a challenge to the jurisdiction of this Court in which they asserted that they did not sign the guarantees upon which the Claimants rely.

The Dubai Proceedings

6. On 5 October 2020, the Second and Third Defendants commenced proceedings in the Dubai Court of First Instance against the Claimants, naming the First Defendant and the Fourth - Eighteenth Defendants as defendants in those proceedings, although without claiming any relief as against those Defendants. In those proceedings, the Second and Third Defendants sought relief requiring the Claimants to submit originals of the Guarantees and Facility Agreements alleged to have been signed by the Second and Third Defendants to the Court for analysis and for the Court to determine whether the signatures of the Second and Third Defendants on those documents were forged.

7. Following the commencement of the proceedings in the onshore Courts of Dubai, the Second and Third Defendants made an application to the Joint Judicial Committee (the “JJC”) established pursuant to Dubai Decree no. 19 of 2016 (the “Decree”) on the basis of a conflict between the jurisdiction of the Dubai Courts, which they had invoked, and the jurisdiction of the DIFC Courts, which the Claimants had invoked.

8. The Second and Third Defendants then advised the Registry of this Court of the commencement of the proceedings in the onshore Dubai Courts and the JJC. In that correspondence they asserted that the Court was obliged to order the stay of these proceedings pursuant to the operation of Article 5 of the Decree. The Claimants were provided with an opportunity to respond to those assertions, which they did by an email to the Registry of the Court.

9. The emails from the parties and various other materials were placed before me, and in accordance with what was then standard practice, I granted a stay of proceedings in this Court by order issued on 3 November 2020.

10. Following publication of the decision of the Court of Appeal in Lakhan v Lamia¹ (“Lakhan”) the Claimants applied for an order revoking the stay of proceedings which I had previously granted. For reasons published on 9 August 2021 I granted that application and the stay was set aside.

The Abu Dhabi Proceedings

11. The Second Defendant commenced bankruptcy proceedings in the Abu Dhabi court of First Instance, joining 29 additional parties as “Joined Litigants” to those proceedings, including the Third Defendant. The Joined Litigants include some but not all of the Defendants to these proceedings. Only one of the Defendants to these proceedings who is a Joined Litigant in the Abu Dhabi proceedings is incorporated in Abu Dhabi. The remainder of the corporate Defendants in these proceedings who are also Joined Litigants in the Abu Dhabi proceedings are not registered in Abu Dhabi.²

12. On 27 July 2021, the Abu Dhabi Court of First Instance issued a ruling in which it ordered the appointment of a Trustee in Bankruptcy, together with various and ancillary orders including the stay of judicial proceedings against the Second Defendant and the Joined Litigants.³

13. Following the Bankruptcy Order, the Abu Dhabi Court of First Instance issued a document described as a “to whom it may concern” certificate referring to the Bankruptcy Order and the stay made as part of that order. The Abu Dhabi Court of First Instance also sent a letter to the President of the Dubai Court of First Instance referring to the decision in the bankruptcy proceedings and inviting the President of that Court to address the DIFC Courts in relation the stay of proceedings. The Dubai Civil Court of First Instance passed that communication to the Chief Justice of the DIFC Courts. Further, the Abu Dhabi Court of First Instance also wrote directly to this Court drawing attention to the stay orders which had been issued.

14. The Defendants relied upon these communications for the proposition that these proceedings should be stayed by reason of the Abu Dhabi Bankruptcy Order. After hearing argument on that issue, for reasons published on 20 October 2021, I concluded that no stay should be granted unless and until an application had been made for recognition of the Abu Dhabi proceedings and for a stay based upon such recognition.

15. Such an application was made by the Trustee in Bankruptcy by proceedings commenced pursuant to Part 8 of the RDC.⁴ However, those proceedings are contested and have not yet been determined. No interim order has been made in those proceedings staying these proceedings. Although there is an application in those proceedings for a stay of these proceedings and others, that application has not been brought on for hearing, on either an interim or permanent basis. Nor has the Trustee or Trustees in Bankruptcy made any application in these proceedings for the grant of an interim stay based upon the application for recognition of the Abu Dhabi Bankruptcy Order.

16. Essentially for the reasons I gave on 20 October 2021, unless and until an interim or permanent order is made staying these proceedings, they must continue. Accordingly, I concluded that the various applications brought by the Claimants should be heard and determined on their merits, notwithstanding the bankruptcy proceedings in Abu Dhabi. The lawyers representing the Defendants advised the Court and the Claimants that, given the Abu Dhabi Bankruptcy Order, they did not propose to appear in opposition to the Claimants’ applications. At the commencement of the hearing, I noted that position, and noted that in the absence of any application by the Trustee or Trustees in Bankruptcy to take over the conduct of the defence in these proceedings from the lawyers currently representing the Defendants, or an order staying these proceedings, the proceedings should continue, and the Claimants’ applications should be heard and determined.

The Jurisdictional Challenge

17. As noted, only the Second and Third Defendants have challenged the jurisdiction of this Court. Their sole ground of challenge is their assertion that they did not sign the Personal Guarantees or the Facility Agreement. Each of those Defendants supported their challenge to the jurisdiction of the Court with witness statements in substantially identical terms in which they assert that they did not sign either of the Personal Guarantees and have never met the person who is said to have witnessed their signatures on those Guarantees. Each assert that the first time they became aware of the existence of the Guarantees was when they were shown the documents by their lawyers in connection with these proceedings. Each also assert that at the time when these documents are said to have been signed, they had no involvement with the management of the Emirates Hospital Group (which is the group of corporate Defendants in these proceedings). Each assert that they were “extremely surprised” to sight the Guarantees. Each of the Second and Third Defendants has also filed a further witness statement in substantially similar terms in which each denies having signed a number of other related documents, including certificates relating to the provision of independent legal advice with respect to the Guarantees, and various other documents. Each assert that they have never met, nor received any advice from Mr. James Chesterman, a lawyer who has signed a certificate to the effect that he provided each of the Second and Third Defendants with independent legal advice with respect to the Guarantees.

18. In the case of the Third Defendant, two reports have been provided from a handwriting expert, Mr. J P Osborn, in which he affirms that it is probable that a number of the signatures on documents examined by him purporting to be the signature of the Third Defendant were “non genuine”.

19. The Claimants accept that Mr. Osborn’s reports raise an issue apt for trial in respect of their substantive claim against the Third Defendant. Accordingly, they do not press for immediate judgment against that Defendant. However, they assert that the Third Defendant’s challenge to jurisdiction should nevertheless be dismissed, as on the current state of the evidence, the Claimants have established a “good arguable case” to the effect that the DIFC Courts have jurisdiction with respect to the claims against the Second and Third Defendants. For the reasons which follow, I accepted that submission.

20. The Claimants rely upon two alternative gateways to the jurisdiction of this Court; the first is pursuant to Article 5(2) of the Judicial Authority Law (the “JAL”).⁵ That Article provides:

“The Court of First Instance may hear and determine any civil or commercial claims or actions where the parties agree in writing to file such claim or action with it whether before or after the dispute arises, provided that such agreement is made pursuant to specific, clear and express provisions.”

21. The evidence establishes that each Personal Guarantee contained, as clause 23.4, a provision pursuant to which Credit Suisse as Global Facility Agent for the lending Claimants could give notice in writing requiring that all disputes or any specific dispute be litigated, in which event the DIFC Courts have exclusive jurisdiction, and all parties agree to submit to the exclusive jurisdiction of those Courts. The evidence established that Credit Suisse gave written notice under that clause to the Second and Third Defendants by notice dated 17 July 2020.

22. As noted, the Second and Third Defendants challenge the availability of this gateway to jurisdiction on the ground that they did not sign the Personal Guarantees.

23. Previous decisions of this Court establish that when a challenge is made to a jurisdiction, the claimant carries the onus of establishing a good arguable case to the effect that one or other of the gateways to jurisdiction is satisfied.⁶ Previous decisions in this Court also establish that where the question upon which jurisdiction turns is solely a question of law, or of contractual construction, it will generally be appropriate for the Court to determine the issue definitively in order to decide the objection to jurisdiction. However, it is also established that where the outcome of the objection to jurisdiction turns upon disputed issues of fact, if the claimant establishes a good arguable case on those issues they will be determined as part of the substantive determination of the case rather than upon an interlocutory hearing of a challenge to jurisdiction, which is not an appropriate forum for contested issues of fact.⁷

24. More recent English cases have amplified the approach properly taken when a challenge to jurisdiction turns upon disputed questions of fact.⁸ Those cases establish a three-stage process, namely:

25. This approach has been adopted in at least one decision in this Court⁹ and I see no reason why this approach should not be adopted generally.

26. On this basis the question becomes whether the Claimants have established a plausible evidential basis for their assertion that the Second and Third Defendants signed the Guarantees, notwithstanding their denial of that assertion.

27. In this regard, the Claimants rely upon the following matters, all of which are established on the evidence before the Court:

28. These matters establish an entirely plausible evidential basis for the Claimants’ assertion that each of the Second and Third Defendants signed the Guarantees upon which the Claimants sue. Consistent with the authorities to which I have referred, it follows that the Claimants have established a good arguable case for jurisdiction under Article 5(A)(2) of the JAL.

29. In the alternative, the Claimants rely upon the gateways to jurisdiction provided by Articles 5(A)(1)(a) and/or 5(A)(1)(c) of the JAL because the Fifth Claimant is a DIFC establishment within the meaning of the JAL and at all times acted through its DIFC branch. The evidence establishes both of those matters, with the consequence that proceedings involving the Fifth Claimants fall within the exclusive jurisdiction of the DIFC Courts. As the Claimants proceed against all Defendants jointly, pursuant to both the Facility Agreements and the Guarantees, it follows that the other Claimants are appropriately joined as parties to these proceedings pursuant to RDC 20.7, read with Article 5(A)(1)I of the JAL, and all claims are within the exclusive jurisdiction of the DIFC Courts.

30. Accordingly, the evidence establishes this alternative gateway to the jurisdiction of the Court, which does not depend upon the outcome of any contested issue with respect to execution of the Guarantees.

31. For these reasons the Claimants satisfied me that they had a good arguable case to the effect that the Court has jurisdiction to entertain their claims and the objections to jurisdiction by the Second and Third Defendants were dismissed.

The Immediate Judgment Application

32. RDC 24.1 provides:

33. This Court has generally adopted the principles enunciated by Simon J in JSCVT Bank v Skurikhin¹⁰ in relation to the exercise of the power conferred by RDC 24.1.¹¹

34. In short, the Court must consider whether the Defendant has a “realistic” as opposed to a fanciful prospect of success. A realistic prospect of success is one that carries some degree of conviction and not one that is merely arguable.

35. The Claimants have adduced cogent evidence to establish all the material facts alleged in their Particulars of Claim and upon which their cause of action depends.

36. In particular, the evidence establishes that by a Conventional Facility Agreement dated 10 April 2018, the Claimants made a credit facility available to the First Defendant in the amount of USD 250 million. The terms of that Facility were further documented in a Common Terms Agreement bearing the same date. Both Agreements are governed by English law. Under the Common Terms Agreement, each corporate guarantor irrevocably, unconditionally, jointly, and severally guaranteed punctual performance by the First Defendant of its obligations under the finance documents as Principal Obligor.¹²

37. Also on 10 April 2018, a Guarantee was apparently signed by each of the Second and Third Defendants jointly and severally guaranteeing the punctual performance by the First Defendant of its obligations under the Conventional Facility Agreement, the Common Terms Agreement and other related finance documents. That Guarantee was also governed by English law. On the same date, Mr. Chesterman issued certificates to Credit Suisse confirming that he had provided independent legal advice to each of the Second and Third Defendants in respect of their entry into the Guarantee.

38. On 24 February 2018, the Claimants entered into an Additional Conventional Facility Agreement with the First Defendant pursuant to which a further credit facility in the amount of USD 50 million was made available. On the same date, each of the Second and Third Defendants apparently executed a second Guarantee under which they jointly and severally guaranteed the increased obligations of the First Defendant. This Guarantee was also governed by English law. On the same date, Mr. Chesterman issued further certificates to Credit Suisse confirming that he had provided independent legal advice to the Second and Third Defendants in respect of their entry into the second Guarantee.

39. Pursuant to the Common Terms Agreement the First Defendant undertook to pay, within ten business days of demand, any costs and expenses incurred by the Lenders as a consequence of any event of default, and an event of default entitled Credit Suisse to accelerate the Facility making all loans and interest and any other amount accrued immediately due and payable. The Common Terms Agreement also contained a provision¹³ pursuant to which in any litigation in connection with the finance documents, any certificate or determination by a finance party of a rate or amount due under any finance document is conclusive evidence of the matter to which it relates in the absence of manifest error.

40. Pursuant to these agreements, on 11 April and 29 May 2018 respectively, advances in the sum of USD 250 million and USD 50 million were made to the First Defendant.

41. Events of default occurred under the Finance Agreements on each of 5 January 2020 and 10 January 2020, when the First Defendant did not pay sums due. On 14 January 2020, Credit Suisse gave notice to the First Defendant of the occurrence of the events of default.

42. On 3 February 2020, Credit Suisse gave notice in writing to the Second and Third Defendants of the occurrence of the events of default and demanded immediate payment of the overdue amounts together with interest. Those Defendants failed to make any payment pursuant to this demand, which constituted a further event of default under the Common Terms Agreement.

43. By letter dated 3 March 2020, the First Defendant was given notice of the further event of default, together with notice that unless certain conditions were met the Claimants intended to exercise their rights to accelerate repayment under clause 23.19 of the Common Terms Agreement.

44. On 17 March 2020, as a result of non-compliance with the conditions specified in the letter of 3 March 2020, Credit Suisse sent a Notice of Acceleration to the First Defendant, copied to each of the other Defendants. The Notice of Acceleration declared that all loans together with accrued interest and all other amounts due were immediately due and payable, and made formal demand for immediate repayment of the sum of USD 301,222,331.70.

45. The following day Credit Suisse notified all guarantors that it had served the Notice of Acceleration the previous day and demanded payment from each guarantor of the amount due.

46. On 26 March 2020, one of the Claimants gave notice that it would exercise its right to set off sums owing to it from the First Defendant in partial reduction of the First Defendant’s debt.

47. The Claimants adduced in evidence a certificate issued pursuant to the provisions of the Common Terms Agreement showing the amount due under the finance facilities as at a date some months prior to the hearing of the immediate judgment application. A spreadsheet was also provided showing the amount due as at the date of hearing, based upon the application of interest to the amount the subject of the certificate. That spreadsheet showed the total amount due as at the date of the hearing as USD 329,213,755.91. There is no reason to doubt the accuracy of the calculations shown on the spreadsheet.

48. As the evidence adduced by the Claimants establishes a strong prima facie case in support of their claim, the question becomes whether the Defendants, or any of them (other than the Third Defendant) have established a realistic and not fanciful defence to the claim. As the position adopted by the Second Defendant is quite different to the position of the other Defendants, it is convenient to separate that Defendant from the other Defendants when addressing this question.

The Second Defendant

49. The only defence suggested by the Second Defendant is his assertion that he did not sign either of the Guarantees. That assertion is not substantiated by any other evidence. The assertion is contradicted by the various matters to which I have referred above in the consideration of the Second and Third Defendant’s challenge to jurisdiction. Components of the evidence relating to those matters are particularly cogent, including the Second Defendant’s express reliance upon his execution of the Guarantees for the purposes of the proceedings he commenced in Abu Dhabi, the report of the company of which the Second Defendant was a director which adopted accounts which refer to the Second Defendant’s guarantee of the debt the subject of these proceedings, and the certificates of independent legal advice provided by Mr. Chesterman. I also accept that the Second Defendant’s unsubstantiated and uncorroborated assertions of forgery are inherently implausible, for the reasons given by the Claimants.

50. In these circumstances I accept the Claimants’ submission that this case is on all fours with Saif Saeed Sulaiman Mohammad Al Mazrouei v Bankmed (Sal)¹⁴ where the Court of Appeal upheld the first instance decision to grant immediate judgment against a guarantor who had alleged that his signature had been forged. Chief Justice Zaki Azmi¹⁵ held that something more than a bare assertion of forgery was required to establish a defence with a realistic prospect of success – citing the obvious capacity to produce expert handwriting evidence to substantiate the allegation of forgery.

51. In the present case, the Second Defendant has had well over a year in which to adduce expert evidence on the subject of forgery. Unlike the Third Defendant, he has failed to take that opportunity. The absence of such evidence, or indeed any evidence to corroborate or substantiate the bare assertions of the Second Defendant on this topic, viewed in the context of the various matters upon which the Claimants rely caused me to conclude that the Second Defendant had failed to establish any realistic prospect of defending the claim against him, and immediate judgment was entered for that reason.

51. In the present case, the Second Defendant has had well over a year in which to adduce expert evidence on the subject of forgery. Unlike the Third Defendant, he has failed to take that opportunity. The absence of such evidence, or indeed any evidence to corroborate or substantiate the bare assertions of the Second Defendant on this topic, viewed in the context of the various matters upon which the Claimants rely caused me to conclude that the Second Defendant had failed to establish any realistic prospect of defending the claim against him, and immediate judgment was entered for that reason.

The First and Fourth-Eighteenth Defendants

52. The First Defendant (the Principal Borrower) and the Fourth-Eighteenth Defendants (the Corporate Guarantors) filed a Defence and Counterclaim in 2020 before the proceedings were stayed. It is a singular feature of that pleading that none of the Defendants deny that the funds alleged by the Claimants were advanced pursuant to the terms of the Finance Agreements upon which the Claimants rely, nor do any of the Defendants assert that all or any part of those funds were repaid. This is an inauspicious start to the consideration of whether any of those Defendants have established a realistic prospect of successfully defending the claim against them.

53. It is fair to characterise the various matters to which these Defendants refer in their Defence and Counterclaim as technical in character. All are without substance, for the following reasons.

54. First, these Defendants put the Claimants to proof of the issue and service of the notices required in order for the Amended and Restated Common Terms Agreement to take effect under its clause 2(b). The evidence adduced by the Claimants satisfies that obligation. By clause 42.5 of the Amended and Restated Common Terms Agreement any communication in relation to the finance documents could be provided by email and the address for the First Defendant for these purposes set out in clause 42.2(b). On 20 September 2019, Credit Suisse sent an email to that address and others stating that the Amended and Restated Common Terms Agreement was now effective and lawyers acting on behalf of these Defendants replied to that message some days later.

55. Next, these Defendants assert that by mistake interest was calculated and paid at a margin of 4.5% above the specified rate rather than 3.5%. However, the additional margin of 1% was specifically agreed to be payable as an arrangement fee payable to Credit Suisse in the fee letters dated 10 April 2018 and 24 May 2018 respectively. There is no substance in this line of defence.

56. Next, these Defendants rely upon a typographical error in the original Particulars of Claim referring to the amount not paid, and which gave rise to the second event of default. That error was corrected in Amended Particulars of Claim, but the defence has not been amended in response to that correction. Significantly, as I have noted, there is no assertion that the amount due, or indeed any amount was paid to the Claimants.

57. Next, these Defendants assert that the Claimants failed to make available to them credit in the amount of USD 4,320,894.86 to which they were entitled. However, the evidence establishes that by agreement between the Claimants and the First Defendant, that sum was deducted from the proceeds of the credit facility in order to place the funds in the Finance Service Reserve Account. There is no substance in this line of defence.

58. Next, these Defendants take a technical pleading point by asserting that the Claimants failed to plead that they had 10 days within which to remedy the first event of default. This omission was addressed in the Amended Particulars of Claim to which the Defendants have not responded. However, the significant fact is that none of these Defendants have ever asserted that either event of default was remedied and it is clear that the First Defendant remained in default two months later when the Notice of Acceleration was issued. There is no substance in this line of defence.

59. Finally, these Defendants assert that the Notice of Acceleration was ineffective because it was not given to Mr. Jagannath Rout. However, the evidence adduced by the Claimants establishes otherwise and in particular establishes that the Notice of Acceleration was sent to Mr. Rout’s email address, which was the address specified for service in the Common Terms Agreement for notices to be given to the First Defendant. There is no substance in this line of defence.

60. For these reasons, as the First and Fourth-Eighteenth Defendants had failed to establish any defence with any realistic prospect of success, judgment was entered against them.

The Counterclaims

61. The Counterclaims brought by the First and Fourth-Eighteenth Defendants were based entirely upon some (but not all) of the matters identified in their Defence. As those matters are all without substance, there is no substance in any of the Counterclaims, and immediate judgment was entered dismissing those claims.

Costs

62. There was no reason why costs should not follow the event, and the Claimants had filed Particulars of the costs sought. Those costs were substantial, but related to the entirety of the proceedings, which took a number of procedural turns, as I have noted already. I ordered that the Defendants against whom judgment was entered should pay the Claimants’ costs in the amount claimed, but as those Defendants were not represented at the hearing, I granted them liberty to apply for an assessment of those costs within 28 days of the date of the hearing.

Issued by:
Nour Hineidi
Registrar
Date of issue: 20 December 2021
Time: 10.30am