Punjab

StateCommission

CC/931/2018

Rattan Lal - Complainant(s)

Versus

Magma Finance Corp. Ltd. - Opp.Party(s)

03 May 2019

ORDER

STATE CONSUMER DISPUTES REDRESSAL COMMISSION, PUNJAB, CHANDIGARH.

                   Consumer Complaint No.931 of 2018         

                                             Date of institution  :   29.11.2018

        Reserved on           :   08.04.2019

                                             Date of decision     :   03.05.2019

Rattan Lal Bhardwaj, aged 63 years son of Sh. Amar Nath, Resident of B-25/353/1 Ram Das Street, Sheranwala Gate, Patiala, Punjab.

….Complainant.

Versus

1.      Magma Financial Corporation Limited, Regd. Office 24, Park Street, Kolkata, West Bengal through its Director.

2.      Magma Financial Corporation Limited, Branch Office at 2^nd     Floor, Car Life Building, Opp. Head post Office, Patiala-      147001, Punjab through its Branch Manager.                                                                           .…Opposite Parties

Consumer Complaint under Section 17 of the Consumer Protection Act, 1986.

Quorum:- 

     Hon’ble Mr. Justice Paramjeet Singh Dhaliwal, President

                    Mrs. Kiran Sibal, Member.

Present:-

    For the complainant       :  Sh. Rajinder Singh, Advocate

    For the opposite parties  :  Sh. Tushar Arora, Advocate

MRS.KIRAN SIBAL, MEMBER

          The complainant has filed this complaint, under Section 17 of the Consumer Protection Act, 1986, (in short “C.P. Act”) seeking following directions to the opposite parties (in short “OPs”):-

i)        to recalculate the interest on the total amount of loan of Rs.61,70,000/- @ 9.50% per annum as agreed in the loan agreement dated 13.04.2006, reschedule the number of instalments and amount of EMI after adjusting the amount already paid by the complainant in his loan Account No.HFPC00000070 and furnish him the full detail regarding the increase/decrease in the rate of interest since the date of disbursement of loan till date as per directions/guidelines issued by the RBI. OP may also be directed to give discount of interest @ 1% than the market rate and the rate of interest being charged by the other bankers as per their commitment before sanctioning the loan.

ii)       to pay Rs.5,00,000/- as compensation due to mental agony, harassment, deficiency in service and unfair trade practices in the interest of justice.

iii)      to pay Rs.50,000/- as costs of litigation expenses.

iv)      Any other relief, which this Commission may deem fit.

2.      Brief facts, as set out in the complaint, are that complainant along with his brothers are the owner of property i.e. B-25/353/1, Ram Das Street, Sheranwala Gate, Patiala, along with shop situated at main Sheranwala Gate, Patiala. Complainant had taken a loan of Rs.57 lakh from ICICI Bank Limited. The officials of the “GE COUNTRYWIDE” Consumer Financial Services Limited came to know about this fact and they approached him and pressed to avail loan from their company on the ground that their company was charging less interest than that of ICICI Bank. They managed to convince him with clear cut understanding that the rate of interest would remain less @ 1% than market rate and rate of interest being charged by other bankers. They further assured the complainant that by opting for their company, he would be getting huge benefits and they would themselves take over the loan from ICICI Bank and would collect original title documents from the ICICI Bank. The complainant blindly and in good faith,   believed the versions of the said officials and agreed for the same. It was also assured that in case the complainant wanted to close the loan account before its final due payment, then their company would not charge any extra charges for closing the same. OPs-Company sanctioned housing loan of Rs.61,70,000/- to the complainant with interest @ 9.50% per annum with monthly instalment @ 64,429/- vide loan account No.HFPC00000070 recoverable in 180 (15 years) equated monthly instalments. The first instalment was to commence from 07.06.2006 as mentioned at Serial No.8 of the schedule of agreement dated 13.04.2006 executed between the parties. Complainant received an intimation from the OPs dated 28.07.2009 regarding extending the monthly instalments from 07.06.2006 to 07.06.2025 (19 years) in place of earlier EMIs starting from 07.06.2006 to 07.05.2021 with interest @ 11.66% per annum. Complainant demanded the statement of account from the OPs number of times in order to know about the rate of interest being charged on the loan amount but it was never supplied by the GE Money. Rather without informing the complainant and without his consent, the loan was sanctioned and his loan account was taken over by the OP Company without executing any agreement between them. He had been issuing the cheques of monthly instalment regularly and had visited the office of the OP many a times, for the supply of statement of account in order to know the actual rate of interest being charged but all in vain. The complainant has paid a sum of Rs.95,09,901/- to the OPs till date against the said housing loan and the loan account is to be closed in the year 2025. Complainant is praying for a direction to be issued to OPs to produce the record of loan of Rs.57 lakh of ICICI Bank Ltd by which the OPs had taken over the charge of housing loan, which would prove that the loan was transferred with condition to charge less interest from earlier interest of ICICI Bank as well it would show the actual loan amount paid to ICICI before transfer of said loan to OPs. As per RBI guidelines addressed to all the banks and NBFC (Non Banking Financial Corporation) on 02.01.2009 and 26.03.2012, it was incumbent upon them that the interest rate would be changed only annually. Even if interest rate is changed many times during the year, it only be informed on annual basis and in case of floating rate of interest, the consent of the borrower should be obtained. It was further directed that as per the said guidelines the change of interest rates and charges should be effected only prospectively but the OP changed the number of EMIs and rate of interest for repayment of loan taken by the complainant many a times unilaterally and arbitrarily without seeking the prior consent of the complainant as tabulated under:-

Further there are certain clauses in the loan agreement which were apparently not in conformity with the RBI guidelines.  The copy of RBI guidelines dated 02.01.2009 and 26.03.2012 have been placed on record as Ex.C-2 and Ex.C-3 and copies of intimation received from the OPs on various dates have been placed on record as Ex.C-4 to Ex.C-7. Complainant apprehended that GE Money and OPs-Company had charged higher rate of interest and increased the number of EMIs than agreed and even the assured discount of interest @ 1% had not been given to him. Complainant served a legal notice dated 08.03.2017 through his counsel through a registered post for demanding the statement of account but the OP instead of supplying the statement of account, sent a false and vague reply on 27.04.2017. OPs-Company had extended the period/tenure of loan from the year 2021 to 2025 as such the OPs shall be getting excess amount of Rs.30 lakh. As per the RBI guidelines the OPs are liable to recalculate the repayment schedule as per terms of agreement dated 13.04.2006 @ 9.5% per annum and further give discount of 1% per annum on interest than the rate of interest being charged by the nationalized bank in loan account No.HFPC00000070 for Rs.61,70,000/- as assured by the OPs at the time of sanction of loan and refund the extra amount charged along with interest. A Consumer Complaint was filed before the District Consumer Forum, Patiala earlier on 10.05.2017 but the same was dismissed due to pecuniary jurisdiction as the loan taken by the complainant from the OP was of Rs.61,70,000/-, keeping in view the judgment in the case of “Ambrish Kumar Shukla Vs. Ferrous Infrastructure Private Limited” with the liberty to approach the appropriate authority having pecuniary jurisdiction. The act and conduct of the OPs amounts to deficiency in service and unfair trade practice on the part of the OPs. Hence this complaint.

Defence of the Opposite Parties

3.      Upon notice, opposite parties appeared and filed reply to the complaint, raising certain preliminary objections that the complaint is barred by limitation as the loan was availed in 2006, the applicant had admittedly been aware in 2009 that the loan interest had been changed and had admittedly paid the dues in accordance with the new rate of interest. The present complaint filed in 2018 is barred by limitation. Last rate of interest was changed by GE Money in March, 2009 and new rate of interest was 11.66% per annum. Copy of the letter sent to customer informing him about the increase in rate of interest along with courier receipt is attached with the reply. The Hon’ble Delhi High Court in CS(OS) 101/2010 titled “Ram Gupta v ICICI Bank has held, following Khatri Hotels Pvt. Ltd. and Another vs Union of India” (2011) 9 SCC 126, Apex Court, that if a suit is based on legal cause of action the period of limitation will begin to run from the date when the right to sue first accrues and that successive violation of the right will not give rise to a fresh cause of action and the suit will be liable to be dismissed if it is beyond the period of limitation counted from the date when the right to sue first accrued. Complaint is liable to be dismissed on the ground of non-joining of necessary parties as all the co-applicants are not made party by the complainant.  It has been submitted that Amit Kumar, Varinder Kumar, Jaspal Bhardwaj, Rekha Sharma and Asha Rani are also co borrowers in the loan and had not been arrayed as party. Hon’ble National Consumer Disputes Redressal Commission had held in various judgments i.e. “ICICI Bank (Home Loan) Vs. Ganga Singh Shekhawat” (2015(3) C.P.J. 507), that Accounts cannot be settled under the C.P. Act that the Commission cannot enter into the realm of a case of rendition of accounts. Forum constituted under the C.P Act is not the proper forum for taking accounts and deciding the amount due to any of the parties and which is to be done only by the regular Civil Court of competent jurisdiction. Reliance has been placed in the case titled as “Bihar State Housing Board Vs. Chairman-cum-Managing Director and Ors I (1996) CPJ-228(NC), “Vishal Roadways vs Economic Traders (Gujarat) Ltd (1998)CPJ (NC)-539, “Heritage Education Society vs. Tata Motor Limited”, “R.Sethuraman & Anr. Vs The Manager, Overseas Bank & Anr”, (1996) CPJ- 58 (NC). It was submitted that the Agreement as produced by the complainant provides for a change of rate of interest at clause 2, 2.1 which specifically provide that a new rate of interest shall be fixed. Rate change was done by GE Money in January 2011 and new rate of interest was 11.66% per annum. Complainant also started paying as per the same but after 7 years he had chosen to challenge the same. The same was also as per the agreement itself. Complaint is not maintainable; intricate questions of law were involved which was to be tried before the Civil Courts and as such the complaint before this Commission is liable to dismissed with heavy costs. Complaint is liable to be dismissed on the ground that the loan was taken for a commercial purpose and hence, not covered under the provisions of C.P. Act. Complaint is liable to be dismissed on the ground of pecuniary jurisdiction. The loan amount was Rs.61,70,000/-  and even as per the case set up by the complainant, the amount to be paid was Rs.64429/- x 180 months= Rs.1,15,97,220/- which exceeds the pecuniary jurisdiction of this Commission. On merits, it was admitted that the home loan of Rs.61,70,000/- was sanctioned to the complainant and it started from 07.06.2006. The rate of interest even as per the agreement was to change and the intimation is a matter of record. It was further submitted that the statement of account could be taken by any customer from the office of the institution but the complainant is intentionally levelling the false allegations against the OP. Moreover, the deed of assignment entered into between GE Money and Magma Fincorp. Ltd whereby the assets and liabilities of GE Money were taken over by Magma Fincorp Ltd was brought to the notice of the complainant by issuing the proper notices to him, who after receiving and acknowledging the same, started making the payment to the OPs. The actual rate of interest being charged to the complainant was appraised by the representatives of the OPs, every time the complainant visited the office of OP. The statement of account was always available and copy of which could be taken by the complainant as per the procedure of OP, on payment of requisite charges. He is levelling false allegations to gain undue sympathy from the Commission. Moreover, copy of statement of account was supplied by the OPs. It was further submitted that the complainant was unduly pressurizing the OPs to accede to its un-genuine demands of cutting the interest rates by filing such types of frivolous complaints before the Commission. OPs have not increased the rate of interest after taking over the loan from GE Money. Last rate change was done by GE Money in January 2011 and new rate of interest was 11.66% per annum. Copy of the letter sent to customer informing him about increase in rate of interest was already on record. All other allegations of the complainant were denied and prayed for dismissal of the complaint.

Evidence of the Parties

4.      To prove his complaint, the complainant filed, along with the complaint, affidavit and documents Ex.C-1 to Ex.C-10.

5.      OPs along with the reply, filed affidavit of Sanjeev Kumar Rajput, Authorised Signatory along with documents Ex.R-1 to Ex.R-3.   

Contentions of the Parties

6.      We have heard learned counsel for the parties and have carefully gone through the record of the case.

7.      Learned counsel for the complainant vehemently contended that complainant took a loan of Rs.57 lakh from ICICI Bank Limited and officials of the “GE COUNTRYWIDE” Consumer Financial Services Limited came to know about this fact and they approached him and pressed him to avail loan from their company on the ground that their company was charging less interest than that of ICICI Bank. It was further argued that the OPs-Company sanctioned housing loan of Rs.61,70,000/- to the complainant with interest @ 9.50% per annum. The complainant received intimation from the OPs on 28.07.2009 regarding extending the monthly instalments period from 07.06.2006 to 07.06.2025 in place of earlier EMI schedule i.e. 07.06.2006 to 07.05.2021 with interest @ 11.66%. The complainant demanded the statement of account from the OPs number of times in order to know about the rate of interest being charged on the loan amount but it was never supplied by the GE money. Rather without informing the complainant and without his consent, the loan was sanctioned and granted by the GE money to him and his loan account was taken over by the OP Company without executing any agreement between them. Learned counsel for the complainant has drawn our attention towards the guidelines of RBI issued to NBFCs, change of rate of interest and EMIs in different years which are also stated in the written arguments submitted by the counsel for the complainant. The OPs-Company has extended the period of loan from the year 2021 to 2025. As such, the OPs shall be getting an excess amount of Rs.30,00,000/- approximately from the complainant. The complainant is being harassed as the OPs had taken unilateral and arbitrarily decision in extending the period of instalments and rate of interest without taking consent of the complainant. Learned counsel for the complainant prayed that OPs be directed to recalculate the repayment schedule as agreed between the parties and to refund the amount which had been charged extra along with interest and compensation. This act and conduct of the OPs amounts to deficiency in service, as a result of which the complainant suffered mental tension and harassment. Averring on similar lines as stated in the complaint, learned counsel for the complainant prayed for allowing the complaint.

8.      Learned counsel for the OPs had vehemently argued that complaint is bad for mis-joinder of necessary parties as the agreement Ex.C-1 was signed by the co-borrowers but the complainant has not impleaded the co-borrowers as a party in this case. The complaint is barred by limitation as the loan was availed in 2006, the applicant had admittedly been aware in 2009 that the loan interest had changed and had admittedly paid the dues in accordance with the new rate of interest. The complainant had not raised any objection regarding the change in interest rate at that time and he continued to pay the EMIs for more than seven years silently. Counsel for the OPs further argued that OPs duly informed the complainant regarding the change in rate of interest and increase in EMIs as per RBI circulars. Counsel for the OPs further contended that as per clause 2, 2.1 of the agreement executed between the parties the OPs rightly change the rate of interest and charged the EMIs from complainant. The rate of interest was changed by the GE Money in January 2011 and new rate of interest was 11.66% per annum and complainant paid the same and now after seven years he cannot challenge the same. Learned counsel for the OPs reiterated the stand taken in the preliminary objections and stated that the complainant himself opted for the loan from the OPs by signing the written loan agreement and understanding the term of the loan agreement. It was never mentioned or assured that the rate of interest will remain less at 1.5% than market rate. Counsel further contended that this Commission had no pecuniary jurisdiction. Averring on similar lines as stated in the written reply, learned counsel for the OPs prayed for dismissal of the complaint.       

Consideration of Contentions

9.      We have given our thoughtful consideration to the respective contentions raised by the counsel for the parties.

10.    We would first like to dispose of the preliminary objections taken by the OPs that this Commission does not have pecuniary jurisdiction to entertain this compliant. In this regard, it is relevant to mention that the loan amount was Rs.61,70,000/- and the loan period is for 07.06.2006 to 07.06.2025. The OPs have calculated the EMIs upto the year 2025, the value of which had been added for the purpose of determining the pecuniary jurisdiction. The instant complaint has been filed in 2018, as such only the accrued value of the EMIs (principal + interest) would be taken into consideration for the purpose of determining the pecuniary jurisdiction. In the instant matter, the loan amount of Rs.61,70,000/- was recoverable in 19 years in equated monthly instalments which is certainly less than Rs.1 crore. Hence, this plea that the complaint is not maintainable on the ground of pecuniary jurisdiction is rejected.

11.    Another objection raised by the OPs is that the complaint is barred by limitation as the loan was availed in 2006, the complainant had admittedly been aware in 2009 that the loan interest had changed and had admittedly paid the dues in accordance with the new rate of interest. The complainant had not raised any objection regarding the change in interest rate at that time and he continued to pay the EMIs for more than seven years silently. He filed the present complaint in 2018 which is barred by limitation. It is also the case of the complainant that he received intimation from the OPs on 28.07.2009 Ex.C-5 whereby the period of monthly instalments was increased from 07.06.2006 to 07.06.2025 (19 years) in place of earlier EMIs starting from 07.06.2006 to 07.05.2021. Since the loan agreement was signed between the parties on 13.04.2006 Ex.C-1 and the last instalment is payable in the year 2025, it is a recurring cause of action for the complainant till the loan tenure is completed. Accordingly, the plea of the OPs that the complaint is barred by limitation does not find merit with us.

12.    The OPs have also raised another objection that complaint is bad for mis-joinder of necessary parties. The complaint has been filed by the borrower Mr. Rattan Lal Bhardwaj and the remaining are co-borrowers in the loan agreement who have not been impleaded as party. Be that as it may, the complaint is maintainable even if co-borrowers in the loan agreement have not been arrayed as party as the issue of the interest rate has been raised by the first borrower i.e. complainant in this case. For redressal of his grievance, every consumer has a right to approach the competent authority and the provisions of C.P. Act, being summary in nature does not overlook the rights of a consumer on hyper technical grounds.

13.    Admittedly, an agreement was entered into between the parties dated 13.04.2006 Ex.C-1 under which the complainant was sanctioned a housing loan of Rs.61,70,000/- by the OPs-Company with interest @9.5% per annum. The amount of each EMI for the initial interest period stated as Rs.64,429/- vide loan account No. HFPC00000070 recoverable in 15 years, the date of first EMI was to commence from 07.06.2006. The description of the borrower under clause 2 of the schedule is in the name of Rattan Lal Bhardwaj; Amit Kumar; Varinder Kumar Bhardwaj; Jaspal Bhardwaj; Rekha Sharma; Asha Rani. The loan was availed by six co-borrowers and the instant complaint has been filed by Sh. Rattan Lal Bhardwaj i.e. borrower. The main grievance of the complainant is that he had blindly in good faith and believed the version of the officials of OPs-Company and had agreed to transfer his loan of Rs.57 lakh which he had taken from ICICI Bank Limited on the assurance that he would be charged lesser rate of interest @ 1% than market rate. It is also the case of the complainant that he received intimation from the OPs on 28.07.2009 Ex.C-5 whereby the period of monthly instalments was increased from 07.06.2006 to 07.06.2025 (19 years) in place of earlier EMIs starting from 07.06.2006 to 07.05.2021.

14.    As far as the plea of the complainant that the OPs had assured and promised him to transfer his loan at 1% less than the market rate is not tenable as there is no documentary evidence placed by the complainant which substantiates this claim of the complainant. Oral evidence cannot take precedence over documentary evidence is a settled principle of law. As such, this contention of the complainant is rejected.

15.    Now addressing the other contention raised by the complainant is regarding the rate of interest being charged by the OPs and whether the same was without the consent of the complainant. To address this contention, we have perused clause 2, 2.1 of the loan agreement Ex.C-1 and the relevant portion is reproduced as under:-

“2.    Rate of Interest

2.1    The Borrower shall pay the Company Interest         (“Interest”) on the Loan at the rates and in the manner mentioned below from the date of disbursement of the Loan till the repayment of the Loan in full:-

(i)      For such period from the date of disbursement of the      Loan is mentioned at Item No.(7) of the Schedule (“the       initial interest Period”) the Borrower shall pay interest         on the outstanding Loan amount at the rate mentioned           at Item No.(8) of the Schedule with monthly rests.

(ii)      For the balance period of the Loan after the expiry          of the Initial Interest Period, the Borrower shall pay      Interest on the outstanding Loan amount at the New Interest Rate (as defined in Clause [ (iii) ] below)     with   monthly rests in the manner mentioned      hereunder:

(a)     The Company shall determine the New Interest Rate which is to be applicable on and from the expiry of the Initial Interest Period. The Company shall thereafter apply the New Interest Rate to the principal amount of the Loan then outstanding and on the basis thereof, recompute amount and/or period of the EMIs (as defined in Clause [3.1] below] for the balance period in accordance with the Company’s norms for computing EMIs. The Company shall recompute the EMIs as per its norms in such manner that the amount of each EMI remains the same as the existing EMIs and the number of balance EMIs is decreased or Increased appropriately to account for the repayment of the       principal Loan amount and payment of Interest at      the New Interest Rate. Provided that if, on account of such recomputation as aforesaid, the   repayment period of the Loan and Interest extends beyond 11 years from the date of disbursement of the Loan or the retirement age for salaried or self-employed persons (as applicable to the Borrower) as per the Company’s norms prevailing at the relevant time then the amount of each EMI shall be increased appropriately such that the principal Loan amount and Interest at the New Interest Rate are repaid/paid to the Company within the 11 year period or before the retirement age mentioned above, whichever is earlier.

          (b)     The aforesaid recomputation and          determination will be done and communicated by        the Company to the Borrower three months prior to         the expiry of the Initial Interest Period, and shall be       binding on the Borrower.

(iii)     “New Interest Rate” shall mean the rate of Interest        which is equal to the GE Countrywide’s Home         Equity Published Rate of Interest prevailing three          months prior to the expiry of the Initial Interest         Period”.

The above stated clauses of the agreement produced by the complainant provide for a change of rate of interest. Clause 2.1(supra) specifically states that a new rate of interest shall be fixed after the expiry of the initial interest period. In this case, the rate changed was done by GE Money in January 2011 and the new rate of interest was 11.66% per annum which has been paid by the complainant duly for more than six years. The same was also a part of the agreement itself. The complainant himself placed on record the loan agreement Ex.C1 stating these terms and conditions and has also placed on record, various other exhibits in support of his contentions. However, a perusal of Ex.C-2 which is a Notification No.DNBS.204/CGM (ASR)-2009 dated January, 2009 issued by Reserve Bank of India states that Clause B and C reproduced as under;-

          “ b)    The rates of interest and the approach for gradation of risks shall also be made available on the web-site of    the companies or published in the relevant newspapers. The information published in the website or otherwise published should be updated whenever there is a change in the rates of interest.

          c)      The rate of interest should be annualised rates so that the borrower is aware of the exact rates that would be charged to the account”.

Ex.C-4 is the loan account ledger dated 19.03.2009 issued by GE Money for customer name Rattan Lal Bhardwaj in which all the details regarding the loan account No.HFPC00000070 have been categorically mentioned including the loan amount, original tenor, disbursal date, interest rate, principal amount, interest amount, future principal, future interest etc. Even in the final interest statement Ex.C-5, which has been duly acknowledged by the complainant that this intimation was sent to him on 28.07.2009, clearly gives the details of the finance availed by him against his loan account number. Furthermore, Ex.C-6 dated 30.08.2010 is another final interest statement of similar nature issued by GE Money to the complainant giving a breakup of the principal amount and interest amount and principal and interest realised in detail. Ex.C-7 placed on record by the complainant is the letter written by GE Money to the complainant with regard to the revision of terms and conditions of home equity loan account No. HFPC00000070 and the relevant portion regarding the rate changed and higher loan tenure is mentioned. The relevant portion is reproduced as under:-

“ It is our endeavour to keep you updated about your loan account at all times. Due to increase in cost of funds, benchmark floating reference rate for GE Money Financial Service Pvt. Ltd. has been increased by 0.75% with effect from 1^st of January 11, which will lead to an increment in your rate of interest resulting in higher loan tenure. This will be effective, February ’11 Equated Monthly Installment (EMI) onwards.

The Revised terms of your loan are mentioned as below:

New Interest Rate        11.66

New Tenure                 228”

The OPs have also placed on record Ex.R-1 along with the complaint which is the interest statement dated 09^th April, 2007, final interest statement dated 28.07.2009, interest statement for the period 01.04.2007 to 31.03.2008, account statement dated 30.08.2010 to rebut the contention of the complainant that he was never supplied with any account statement or information regarding any revision in tenure of the loan period modification in EMI. The OPs have also placed on record Ex.R-2 and Ex.R-3 which are the complete statement of account and amortisation schedule in respect of the said loan account wherein the complete break up of the interest and principal is given to support their contention. It has also been pleaded by the OPs that such statement of accounts could have also been taken by the complainant at any time on the payment of requisite charges if he so desired. From all the pleadings evidence and arguments raised before us, we are of the opinion that the complainant cannot take this plea at this stage that he was not informed by the OPs regarding the revision and modifications in his loan agreement.

16.    Sequel to the above discussions, the complaint filed by the complainant is hereby dismissed with no order as to costs.

                             (JUSTICE PARAMJEET SINGH DHALIWAL)

                                                                   PRESIDENT

                                                         (MRS. KIRAN SIBAL)

                                                                   MEMBER 

May  3, 2019.                                               

SK/-