INews Guyana



IN THE HIGH COURT OF THE SUPREME COURT OF JUDICATURE OF GUYANA2020-HC-DEM-CIV-SOC-BETWEEN:MOHABIR ANIL NANDLALLClaimantAndJAIPAUL SHARMAJAMES BONDDefendantsJointly & SeverallySTATEMENT OF CLAIMTO THE DEFENDANTSA LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the Claimant. The claim made against you is set out in the following pages. IF YOU WISH TO DEFEND THIS PROCEEDING, you or an Attorney-at-Law acting for you must prepare a Defence in Form 10A prescribed by the Civil Procedure Rules 2016, serve it on the Claimant, and file it, with proof of service at a Registry, WITHIN TWENTY EIGHT DAYS after this statement of claim is served on you. IF YOU FAIL TO DEFEND THIS PROCEEDING, JUDGMENT MAY BE GIVEN AGAINST YOU IN YOUR ABSENCE AND WITHOUT FURTHER NOTICE TO YOU. IF YOU WISH TO DEFEND THIS PROCEEDING BUT ARE UNABLE TO PAY LEGAL FEES, LEGAL AID MAY BE AVAILABLE TO YOU BY CONTACTING A LOCAL LEGAL AID OFFICE. THIS STATEMENT OF CLAIM has no validity if it is not served within six months of the date below unless it is accompanied by an order extending that time. Date: November, 2020 ……………………………………Signature of RegistryIssued by:Law Courts, Georgetown, Demerara. TO: 1. JAIPAUL SHARMADiamond Housing SchemeEast Bank DemeraraGuyanaJAMES BONDSouth StreetLacytownGeorgetownCLAIMThe Claimant claims from the Defendants, jointly and severally:damages in excess of twenty-five million dollars ($25,000,000) against the First Named Defendant for each of libelous statements of and concerning the Claimant published by the First Named Defendant on his account on the social platform Facebook on the 17th day of November, 2020, located at Order that the First Named Defendant publish or cause to be published a suitable correction and apology on the Facebook account within seven (7) days of the date of the Court’s Order;an Order that the First Named Defendant publish the Court’s judgment (including the court’s declaration of falsity) on the Facebook account;a permanent injunction restraining the First Named Defendant, whether by himself, his representatives, agents or otherwise, from publishing or causing to be published the Posts or similar words defamatory of the Claimant;an Order requiring the First Named Defendant to remove or cause to be removed the posts published on the Facebook account and anywhere else;special damages against the First Named Defendant in excess of twenty-five million dollars ($25,000,000);aggravated and exemplary damages against the First Named Defendant in excess of twenty-five million dollars ($25,000,000);damages in excess of twenty-five million dollars ($25,000,000) against the Second Named Defendant for each of the libelous statements of and concerning the Claimant published by the Second Named Defendant on his account on the social platform Facebook on the 17th day of November, 2020, located at ; an Order that the Second Named Defendant publish or cause to be published a suitable correction and apology on the Facebook account within seven (7) days of the date of the Court’s Order;an Order that the Second Named Defendant publish the Court’s judgment (including the court’s declaration of falsity) on the Facebook account;a permanent injunction restraining the Second Named Defendant, whether by himself, his representatives, agents or otherwise, from publishing or causing to be published the Posts or similar words defamatory of the Claimant;an Order requiring the Second Named Defendant to remove or cause to be removed the posts published on the Facebook account and anywhere else;special damages against the Second Named Defendant in excess of twenty-five million dollars ($25,000,000);aggravated and exemplary damages against the Second Named Defendant in excess of twenty-five million dollars ($25,000,000);costs;(x)such further or other Order(s) as the Court may deem just and proper.The Claimant is and was at all material times an Attorney-at-law of over two decades standing, Senior Counsel and the Attorney General and Minister of Legal Affairs and Member of Parliament of the Co-operative Republic of Guyana.The Claimant is also a Central and Executive Member of the Peoples Progressive Party / Civic (PPP/C), the political party in Government in Guyana. The Claimant has been a Member of Parliament of Guyana since 2006 and also served as Attorney General from December 5th 2011 to May 11th 2015. The Claimant was also, prior to his appointment, the senior and managing partner of a law firm trading under the name and style of Mohabir A. Nandlall & Associates, Attorneys-at-law, of 217 South Street, Lacytown, Georgetown.The said law firm employs a number of Attorneys-at-law and has a large clientele throughout the Co-operative Republic of Guyana, the Caribbean, North America and Europe. This clientele includes individuals as well as large corporate organisations and other forms of commercial holdings. Under the Laws of Guyana, lawyers and law firms are prohibited from engaging in any form of advertisement or commercial promotion of its services and are also prohibited from any form of solicitation of business or professional work and rely largely upon the reputation, standing, competence and integrity to attract clientele. In the circumstances, reputation, standing and integrity are indispensable to the survival of a lawyer or a law firm. Facebook is a social media platform that is largely unregulated and unfortunately permits the publications of matters that may be libelous, defamatory, or in some instances, even criminal, without any reprimand or lawful sanction.This social media platform enjoys an active membership of over two billion users worldwide and is extremely popular in the jurisdiction of Guyana. The Claimant as well as the Defendants are all users of this platform. The Claimant has a following of in excess of fifty thousand (50,000) persons as his friends, followers or members on his Account and his Public Page.The First Named Defendant has over four thousand six hundred and sixty-seven (4667) friends on his Account. This means that at a minimum, four thousand six hundred and sixty-seven (4667) can view his posts. Each of these persons has an ability to share this post to their friends. By simple mathematics therefore, one post on Facebook can be seen by tens of thousands depending on the number of shares. The First Named Defendant Account bears his name and can be found at .The First Named Defendant is a former minister of the previous Government of Guyana and a Member of Parliament.The Second Named Defendant is an Attorney-at-law and a former Member of Parliament and a Member of the Peoples National Congress (PNC) a political party within the collation A Partnership for National Unity (APNU). A Partnership for National Unity (APNU) and the Alliance for Change (AFC), another political party coalesced and constituted the previous Government of Guyana. The Second Named Respondent has a Public Page on the social media platform Facebook which bears his name and his photograph, describing himself as a Politician and has over fifty thousand (50,000) followers/members.The current Government of Guyana is reviewing certain transactions in relation to State lands undertaken under the previous Government and the Second Named Defendant has been implicated in a material way in those transactions which are currently the subject of criminal investigations by the Guyana Police Force. On the 17th day of November, 2020, the First Named Defendant published on his Account of and concerning the Claimant in bold capital letters: “LET ME REMIND AG- MOHABIR THAT HIS LAW FIRM WAS INVOLVED IN SOME OF THESE LAND TRANSACTIONS IN WHICH A LARGE POLT WASS TRANSFERRED A FEW DAYS AFTER DAVID A. GRANGER SWORN IN AS PRESIDENT.” The post read in its entirety:The hypocritical PPP/c MOHAMMED/BADRAT government going after JAMES Bond and others for questionable land sales using the Attorney General MOHABIR while AG's office, Guyana Police Force and the DPP are filled with cases about questionable land sales and breach of land development contracts under the the previous PPP/c government and MOHABIR is doing nothing about it.LET ME REMIND AG - MOHABIR THAT HIS LAW FIRM WAS INVOLVED IN SOME OF THESE LAND TRANSACTIONS IN WHICH A LARGE POLT WAS TRANSFERRED A FEW DAYS AFTER DAVID A. GRANGER SWORN IN AS PRESIDENT.The CH&PA were telling the more than 25,0000 applicants, there are no lands remaining on the East Bank Demerara for distribution.Under the previous PPP/C administration, it appeared that thousands of acres of lands under the authority of CH&PA and former Minister of Housing, MOHAMMED Irfaan Ali, were given away for LITTLE OR NOTHING AND DEVELOPERS ONLY MADE PAYMENT.The more than 400 acres of lands that were sold under QUESTIONABLE ARRANGEMENTS to the private developers are all considered PRIME REAL ESTATE, worth BILLIONS OF DOLLARS at the current market rate.The decision to sell those lands to a number of developers was made IN THE LAST DAYS of the BADRAT Jagdeo administration with most of the deals consummated under former PRESIDENT DONALD Ramotar.There was no clear basis what methodology was used to determine the prices per acre-— some developers just paid more than others.The more-than 400 acres of land stretching from behind REPUBLIC PARK to LITTLE DIAMOND had ended up mainly in the hands of close friends of the previous administration.At least 16 private developers benefited from as early as 2011. Still another 11companies, as of July last year, were set to receive lands from CH&PA for areas in Little Diamond and Great Diamond.One company, Luxury Reality Inc., which has lands in Providence, has listed as its Director/Secretary, Roopnarine Ramcharitar, a right hand man for Dr. Ranjisinghi ‘BOBBY ’ Ramroop. Ramroop is the owner of New GPC, a company that was investigated by the Opposition for a number of questionable deals.He is the best friend of former President BADRAT Jagdeo.Hi Tech Construction Inc. is another Chinese company involved. Hi Tech has Su Zhi Rong listed as its Director while the Secretaries are Zhang Ling Ling and Ming Chen.The other companies that were allocated lands between Eccles and Mocha were QUEENSWAY DAX Contracting Service, NABI Construction Incorporated, BUDDY'S ’s Housing Development, CUMBERLAND Developers Inc., VIKAB Engineering Consultants, KISHAN Bacchus Construction, CARICOM General Insurance, NAVIGANT Builders and WINDSOR Gardens. QUEENSWAY has been allowed several acres in Golden Grove.As of July 2014, those that had applications at CH&PA for lands were Buddy Housing Development, Queensville Housing Development, A&R Jiwanram Printery, Raydan Housing Enterprise, Lakeview Executive Homes, Gentle P. Elias and Brian Chase, Chung’s Global Enterprise, Prembury Consultants T&T Limited and Romell Jagroop Construction.The Chinese owned Hi Tech Construction has also applied for lands in the Little Diamond/Great Diamond area.The words in paragraphs 20 and 21 above are complained of for their combined effect and meaning as alleged herein, with an emphasis on the words in bold.Upon reading the said post, the Claimant spoke to the First Named Defendant in person on cellular number (592) 651-1439 and the First Named Defendant confirmed that the said post is his. The Claimant further requested from the First Named Defendant the source of the aforesaid information and the First Named Defendant alleged that he read same in a Forensic Audit Report of the Ministry of Housing/ Central Housing and Planning Authority done by Mr. Christopher Ram, Chartered Accountant. Apparently, the only reference to the Claimant and his law firm in the said Forensic Audit Report is a paragraph which indicated that Navigant Builders Inc. a limited liability company was incorporated with a sole Director, Mr. Danny Sawh, has its listed address at South Road, Lacytown, Georgetown, “which is the office of Attorney-at-law and former Attorney General, Mr. Anil Nandlall. The law requires that Directors and Secretaries give their residential address and not their business address or the business address of their professional advisors”.The Claimant’s law firm incorporated the company Navigant Builders Inc. on the 21st day of June, 2011, with Mr. Danny Shaw being the Secretary and sole Director of the company in compliance with the Companies Act, Laws of Guyana. It is a regular practice in Guyana for companies to use their lawyer’s office address as their registered office and the address of their officers until the company locates an office. The said Forensic Audit Report does not connect or implicate the Claimant or his law firm in any other transaction in relation to the said company.Indeed, the Claimant and his law firm played no part or role whatsoever in the manner or form in which the company conducted its affairs or business endeavours, including but not limited to its acquisition of lands. Moreover, the Claimant and his law firm played no part or role whatsoever in the acquisition of state lands by any party.However, the Claimant will add that the said company has established one of the better housing schemes in Guyana. In consequence, the Claimant caused his Attorney-at-law to dispatch the hereunder set out letter to the First Named Defendant:“Mr. Jaipaul SharmaDiamond Housing SchemeEast Bank DemeraraGuyana17th November, 2020Dear Sir,Re:Proposed Legal ProceedingsI act on behalf of Mr. Mohabir Anil Nandlall, Attorney General and Minister of Legal Affairs and Member of Parliament of the Cooperative Republic of Guyana.My client has handed to me a post on your Facebook account which bears your name. My client has instructed me that on the 17th November, 2020, at 13:45 hours, he spoke to you in person on cellular number 651-1439 and you confirmed that the said post is yours. In that post, you wrote and published of and concerning my client the following defamatory remarks:“The hypocritical PPP/c MOHAMMED/BADRAT government going after JAMES Bond and others for questionable land sales using the Attorney General MOHABIR while AG’s office, Guyana Police Force and the DPP are filled with cases about questionable land sale and breach of land development contracts under the the previous PPP/c government and MOHABIR is doing nothing about it. LET ME REMIND AG – MOHABIR THAT HIS LAW FIRM WAS INVOLVED IN SOME OF THESE LAND TRANSACTIONS IN WHICH A LARGE POLT WAS TRANSFERRED A FEW DAYS AFTER DAVID A. GRANGER SWORN IN AS PRESIDENT”I am further instructed that my client spoke with you and requested the source of the information you published aforesaid and you informed him that read same in a Forensic Audit Report of the Ministry of Housing/Central Housing and Planning Authority done by Mr. Christopher Ram, Chartered Accountant. My client has already contacted Mr. Christopher Ram, Chartered Account. My client and our law firm have already contacted Mr. Christopher Ram and requested a copy of the said Forensic Audit Report. Further, Mr. Ram has informed my client that he cannot recall his Report containing any such or similar publication of and concerning my client or our law firm. I am to inform you that your publication of and concerning my client is not only libelous but is malicious and completely false and is causing damage to the office, standing and reputation of my client and our law firm. In the circumstances, I hereby demand that you retract that offensive publication forthwith and that you publish on your Facebook account with equal prominence, a post apologizing, unconditionally, to our client and our law firm. Our client and our firm reserves our right to institute legal proceedings against you. The apology requested may mitigate the quantum of compensation which our client will seek against you. Please be guided accordingly. Yours faithfully,….…..sgd.……..Rajendra JaigobinAttorney-at-lawMohabir A. Nandlall & Associates”Rather than publish the apology as requested, the First Named Defendant aggravated the libel by publishing another post reciting the Claimant’s conversation with him and asserting that the Forensic Reports in which he allegedly read the offensive passage is with “our Government at the Ministry of Finance”. He then further aggravated the libel by reposting the libellous post stating:A few minutes ago I just received a cell phone call from the Attorney General MOHABIR saying in annoying tone of voice that, it was brought to his attention that I said in a Facebook post that his law firm was involved in the TRANSFER OF LARGE POLTS OF LANDS.The AG MOHABIR said that I will have to explain before a JUDGE for my inaccurate and irresponsible post on Facebook and asked where I got that information from.I said that I read it in the FORENSIC AUDIT REPORT OF CH&PA DONE BY CHRISTOPHER RAM, Chartered Accountant and Attorney-at-law but the FORENSIC Reports are with our government at the Ministry of FinanceThe AG asked which other reports this information was in and I said that is it.The AG MOHABIR who appears to have been taking notes said ok he is going to call CHRISTOPHER RAM,This is what I had written in the Facebook post ME REMIND AG - MOHABIR THAT HIS LAW FIRM WAS INVOLVED IN SOME OF THESE LAND TRANSACTIONS IN WHICH A LARGE POLT WAS TRANSFERRED A FEW DAYS AFTER DAVID A. GRANGER SWORN IN AS PRESIDENT.To my Guyanese Brothers and Sisters I stand by my statement and I am now calling on your support and protection. AG MOHABIR is no ordinary person and his name was associated in many dreadful threats.Should I be fearful for MY LIFE for speaking the TRUTH???The words in bold in paragraph 34 above are complained of.The First Named Defendant made a third post:My fellow Guyanese Brothers and Sisters, today I received the shock of my life when I answer a call from a number +592 623 3785, the person on the cell phone said it was the Attorney General and Minister of Legal Affairs of Guyana MOHABIR NANDLALL and proceeded to threaten legal action against me. The Attorney General of Guyana requested that I apologise on Facebook for a Facebook post and yet reserved the right to institute legal proceedings against me. The Attorney General's threat was followed up by a legal letter from MOHABIR A. NANDLALL & ASSOCIATES of LOT 217, SOUTH STREET, LACYTOWN, GEORGETOWN sent on WhatsApp using +592 623 3785,I am now calling for the Attorney General and Minister of Legal Affairs of Guyana MOHABIR NANDLALL to explain to this Nation what is his relationship with the Director of NAVIGANT BUILDERS INC, Mr. DANNY SHAW whose company was allocated two (2) parcels of lands at PETERS Hall as follows 15 Acres at $9M per acre with date of sale stated as 15 May,, 201525 Acres at $4M per acre (the auditor was UNABLE to establish date of sale).If no response is received within reasonable time from the Attorney General and Minister of Legal Affairs of Guyana MOHABIR NANDLALL, WE THE PEOPLE MUST DEMAND HIS RESIGNATION.IT IS ABOUT TIME WE THE PEOPLE MAKE OUR LEADERS AND POLITICIANS ACCOUNTABLE AND ANSWERABLE.AND FOR THEM TO STOP THE BULLYISM AND THREATS AGAINST CITIZENS.TONIGHT I PRESENT AN EXTRACT OF THE FORENSIC REPORT ON CENTRAL HOUSING AND PLANNING AUTHORITY THAT WAS DONE BY CHRISTOPHER RAM MANAGING PARTNER OF RAM & MCRAE.As I was typing this Facebook post after 7 p.m a BLACK HEAVILY TINTED SUV STOP AT MY HOME AND A PERSON CAME OUT AND PUT SOMETHING AT MY GATE AND TOOK PICTURES OF MY HOME.The words in bold in paragraph 36 above are complained of, along with the combination and effect of all words published.Shortly after the First Named Defendant published the aforesaid offensive first post, the Second Named Defendant published the following libellous remarks:“Anil Numbskulls Chambers directly involved in land transfers check Jaipaul Sharma FB page for more info. I know for a fact Clients gave Numbskulls millions of US to facilitate transactions purchase land and equipment. This fool can't judge me. He can carry his MS once again.”Subsequently, the Second Named Defendant made another post in which he republished the letter sent by the Claimant’s Attorneys-at-law to the First Named Defendant with the following libellous caption of and concerning the Claimant:“I am afraid for Jaipaul Sharma. The Chatree likes to make threats and we know he can carry them out. If anything happen to Sharma know is Numbskulls Goadee. My people share this threat wide and far let the world know how weak and cowardly the Attorney General is. He slanders and libels me daily I have not once threatened him. But he jumps on Jaipaul Sharma because Sharma speaks the truth that his law firm was involved in shady land transactions and it is in an Audit Report.”The Second Named Defendant also reposted the First Named Defendant’s post as alleged in paragraph 36 above.At no time was the Claimant or his former law firm ever involved in any land transaction between Navigant Builders, Inc. and the state directly or indirectly, nor did the Claimant in any way threaten the health, safety or well-being of the First Defendant.At no time was the Claimant ever involved in the transfer of State lands to Navigant Builders Inc, or at all, after the David Granger administration took office in 2015.At no time was the Claimant given millions of United States dollars or at all to facilitate the purchase of lands and equipment.The natural and ordinary mean and or imputation of the aforesaid publications complained of made by the First Named Defendant of and concerning the Claimant is that:the Claimant is dishonest; the Claimant was engaged in some corrupt land deals;that the Claimant was engaged in some unlawful and/or criminal activity in relation to State lands;the First Named Defendant has evidence that the Claimant was engaged in some unlawful corrupt transactions involving State lands;the Claimant’s former law firm engages in dishonourable and unlawful activities;the Claimant’s law firm is corrupt and engages in corrupt transactions;the Claimant and his law firm are unprofessional and dishonest;The Claimant was involved in the transaction by which Navigant Builders, Inc. obtained lands from the State; andThe Claimant was involved in the transfer of State lands after the Granger administration took office in 2015.The natural and ordinary mean and or imputation of the aforesaid publications complained of, made by the Second Named Defendant of and concerning the Claimant is that:the Claimant is dishonest; the Claimant was engaged in some corrupt land deals;that the Claimant was engaged in some criminal activity in relation to State lands;the First Named Defendant has evidence that the Claimant was engaged in some unlawful corrupt transactions involving State lands;the Claimant’s former law firm engages in dishonourable and unlawful activities;the Claimant’s former law firm is corrupt and engages in corrupt transactions;the Claimant and his former law firm are unprofessional and dishonest;the Claimant is violent;the Claimant is capable of criminal violence;the Claimant has taken steps to threaten and intimidate the First Defendant;The Claimant obtained millions of United States dollars for the purchase of state lands;The Claimant was involved in the transaction by which Navigant Builders, Inc. obtained lands from the State; andThe Claimant was involved in the transfer of State lands after the Granger administration took office in 2015.None of the foregoing is true.The Claimant will rely on dozens of further libellous publications made of and concerning the Claimant, which the aforesaid postings generated on the social media platform Facebook’s comments under the said posting from persons who hardly know the Claimant and who are unknown to the Claimant.These derogatory and libellous comments of and concerning the Claimant are continuing and will continue to cause damage to the reputation of both the Claimant and the law firm Mohabir A. Nandlall & Associates which continues to operate under a different management. As a result of the publications complained of, the Claimant has also suffered public humiliation, ridicule, odium, anguish, which will be demonstrated at trial by the comments made under the posts complained of.As a result of the publications complained of, the Claimant and the law firm Mohabir A. Nandlall & Associates have also suffered irreparable financial loss and damage resulting from the damage to his and its reputation as pleaded in paragraphs 7 and 8 above, his and its good name and reputation being their sole currency as an attorney/s in Guyana, and also impact the Claimant’s ability to perform his duties as the State’s Attorney General.The defamatory statements irreversibly strike at the core of the reputation the Claimant has been building for over the last two decades in Guyana by investing time, money and energy into the Claimant’s education and career respectively.The Defendants published or caused to be published the all of the defamatory statements complained of knowing they were false or recklessly, not caring whether they were true or false.The words complained of in the defamatory statements complained of are malicious and calculated to disparage and injure the Claimant in his personal and professional life, to cause him loss and damage and to cause him emotional distress and embarrassment.The First Named Defendant acted with malice since the Claimant brought to his attention that his initial post was libelous, and despite his demand for an apology, the First Named Defendant proceeded to repost his defamatory statements.The Second Named Defendant acted with malice in making his post, since he had no factual basis to make the defamatory statements made, but instead alleged personal knowledge of the untrue and fictitious allegations, clearly designed to ruin the reputation and character of the Claimant. Unless restrained by this Honourable Court, the Defendants and each of them will further publish and caused to be published the said or similar words defamatory. The Claimant is deserving of a public apology in the manner demanded herein as well as for an order requiring the Defendant to immediately remove the defamatory statements aforesaid.An award of aggravated and exemplary damages in favour of the Claimant is just and appropriate in the circumstances for the reasons pleaded herein, the First and Second Defendants having no basis in fact to publish the defamatory statements, and continued to so act despite being requested to cease and desist by the Claimant.Dated at Georgetown, DemeraraThis 18th day of November, 2020................................................................ DEVINDRA KISSOONMANOJ NARAYAN, PRATESH SATRAMMRS. SASHA S. MAHADEO-NARAYANMR. RAJENDRA R. JAIGOBIN & AANURADHA DEODASINGH Attorneys-at-Law for the ClaimantLondon House ChambersA87 Issano Place WestBel Air ParkGeorgetown, Guyanadkissoon@Tel: 231-1882The Registry is located at The Law Courts Georgetown, Demerara. The office is open to the public between 8:30a.m. and 3:30 p.m. Mondays to Thursdays and 8:30 a.m. and 2:30 p.m. on Fridays, except holidays.IN THE HIGH COURT OF THE SUPREME COURT OF JUDICATURE OF GUYANA2020-HC-DEM-CIV-SOC-BETWEEN:MOHABIR ANIL NANDLALLClaimantAndJAIPAUL SHARMAJAMES BONDDefendantsJointly & SeverallySTATEMENT OF CLAIMMR. DEVINDRA KISSOONMANOJ NARAYAN, PRATESH SATRAMMRS. SASHA S. MAHADEO-NARAYANMR. RAJENDRA R. JAIGOBIN & AANURADHA DEODASINGHLondon House ChambersA87 Issano Place WestBel Air ParkGeorgetown, Guyanadkissoon@Tel: 231-1882IN THE HIGH COURT OF THE SUPREME COURT OF JUDICATURE OF GUYANA2020-HC-DEM-CIV-SOC-BETWEEN:MOHABIR ANIL NANDLALLClaimantAndJAIPAUL SHARMAJAMES BONDDefendantsJointly & SeverallyINFORMATION FOR COURT USEThis proceeding is commenced as a:[ √ ] Statement of Claim[] Fixed Date Application2. This proceeding falls under the High Court’s:[] Appellate Jurisdiction[] Admiralty Jurisdiction[ ] Commercial Jurisdiction[] Criminal Jurisdiction[] Family Jurisdiction[ √] Regular Jurisdiction3. The proceeding is a(n):[] Admiralty Proceeding in personam[] Admiralty Proceeding in rem[] Probate Proceeding[] Proceeding for Judicial Review[] Proceeding for relief under the Constitution[] Proceeding for other Administrative Order[] Proceeding commenced under (name of Act)[ √] Other Proceeding4. I certify that the above information is correct, to the best of my knowledge. Date: day of November, 2020 ……………………………………….DEVINDRA KISSOONMANOJ NARAYAN, PRATESH SATRAMMRS. SASHA S. MAHADEO-NARAYANMR. RAJENDRA R. JAIGOBIN & AANURADHA DEODASINGHAttorneys-at-LawLondon House ChambersA87 Issano Place WestBel Air ParkGeorgetown, Guyanadkissoon@Tel: 231-1882IN THE HIGH COURT OF THE SUPREME COURT OF JUDICATURE OF GUYANA2020-HC-DEM-CIV-SOC-BETWEEN:MOHABIR ANIL NANDLALLClaimantAndJAIPAUL SHARMAJAMES BONDDefendantsJointly & SeverallyINFORMATION FOR COURT USEMR. DEVINDRA KISSOONMANOJ NARAYAN, PRATESH SATRAMMRS. SASHA S. MAHADEO-NARAYANMR. RAJENDRA R. JAIGOBIN & AANURADHA DEODASINGHLondon House ChambersA87 Issano Place WestBel Air ParkGeorgetown, Guyanadkissoon@Tel: 231-1882 ................
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