G. The proposed demerger will cause irreparable damage to the rights of the Litigant appearing as Party in Person and to other genuine creditors of Core Healthcare Ltd as the demerger will enable the banks (Oriental Bank of Commerce and Global Trust Bank Ltd) , and the directors of Core Healthcare to go scot free . Such proposed demerger will render the pending litigations also redundant thereby rendering injustice not only to the present Petitioner but also other shareholders and genuine creditors of said Core Healthcare Ltd.

H. I believe that a charge of Rs. Eleven Crore created by Core Healthcare Ltd prior to August 1998 and hence, there was no reason for Jatin Jalundhwala to create a fresh charge of Rs Twelve and half crores subsequently in 1999 on the assets of M/s Rupmangalam Investment Pvt Ltd , M/s Flovin Plastics Pvt Ltd, M/s Dhanyushya. Financial Ltd.. This shows that this was done in collusion with the concerned officers as well as the management of Global Trust Bank Limited to Core HealthCare Limited to dilute the security and / or let the responsible directors of Core HealthCare Limited and Dhanyushaya Financial Limited to avoid facing huge liabilities. I had called for from the management of Oriental Bank of Commerce to furnish a copy of notarized affidavit either confirming that the cgarge of Rs. Eleven crores was created prior to August 1998 on assets of Core Healthcare Limited. I had called for detailed replies from OrientalBank of Commerce by sending several e-mails and they have evaded to give such detailed replies and findings and their silence shows that there is collusion between Core Healthcare management and the management of Oriental Bank of Commerce.

I. The demerger route would have enabled Nirma Ltd to enjoy enormous tax benefit to Nirma Ltd at the cost of shareholders of Core HealthCare Ltd and the management of Core Healthcare Ltd as a shrewd businessman would have done everything to see that they would have negotiated far better offer from Nirma Ltd for the benefit of the shareholders of Core HealthCare Ltd and the amount of the deal shows that they have not done hard bargaining or it seems possibly there is private arrangement. In the wider interest of all concerned shareholders and society ,such practice needs to be curbed by first lifting the corporate veil of Core Healthcare Ltd and its various group companies in totality.

J. In this way, the demerger scheme is not in the interest of share holders of Core Healthcare Ltd as it camouflages the misleading conduct ,acts , omissions , intentions of Core Healthcare Ltd's promoters, their agents and professional advisers.

K. I have come to understand recently that Mrs. Swati Soparkar , practicing advocate of Gujarat High Court of Core HealthCare Limited on 25-10-2005 , Mrs. Swati Soparkar, (as such advocate ) filed Company Application 358 of 2005(ANNEXURE K) on behalf of Nirma Ltd and filed Company Application 383 of 2005 (ANNEXURE L) on behalf of Core Healthcare Limited on 25-11-2005. I believe that Mrs. Swati Soparkar was in conflict of interest of situation where she filed the above application. I further believe, she has misled the said Court.

L. I have drawn attention of Dena Bank by emails to some of the issues raised by me to Oriental Bank of Commerce so hta they can necessary action and copy of email to Dena Bank is annexed as per Annexure M.

M. I do understand and verily believe that Core HealthCare Ltd's name has also surfaced in the Volcker Report and being investigated by relevant authorities.

N. I have reason to believe that Core Healthcare Ltd has acquired major shareholding of Span Medicals Ltd and where in Technology Finance Ltd ( once upon a time subsidiary of Core HealthCare Ltd) , Dhanyushaya Financial Ltd, Rupmanglam Investment Pvt Ltd, Flovin Plastics Pvt Ltd, etc have been amalagamated into Span Medicals by misleading and suppressing material facts as Core Health care management in collusion of Jatin Jalundhwala and others are deliberately not disclosing the facts so as to deny my rights and timely justice.

O. I may be allowed to add, amend , alter , modify ,rectify , grounds as and when necessary depending on the circumstances.

4. I most humbly appeal to your Lordships that I shall be allowed to furnish additional background information at future date.

5. I may be permitted to add , modify, alter, application at a future date depending on the circumstances.

6. I humbly and respectfully pray to the Honorable court would be pleased to :-

I. The Petitioner appearing as Party In Person humbly prays to your Lordship that on account of narrations as referred above, the proposed demerger should not be allowed by Core Healthcare Ltd and/or all connected agencies, and/or deferred until compliance of various pending suits and inquiry :-

a. The statements on oath of the present and past management of Core Healthcare Limited , their agents, the professional advisers and their bankers ( in particular Oriental Bank of Commerce and Global Trust Bank Limited) be recorded in this Honorable Court and/or in Sessions Court Inquiry No 1 of 2005 and in Civil Suit 5827/2001 pending in Bhadra Court.

b. That various documentary evidences to be submitted to this Honorable Court by the management of Core Healthcare Ltd as regards what is stated by me in above Paragraphs and as to what is referred in the proceedings of civil suit 5827 of 2001.

c. finally they be cross examined thereon letter in this Honorable Court or alternatively in the Sessions Court in Inquiry Number 1 of 2005 pending against promoters of Core Healthcare Ltd and their bankers.

II. The shares of Core Healthcare Limited as well as their various rights in the company are prohibited for being transferred or used in any manner by Nirma Ltd or any other agencies pending further investigation findings.

III. Core Healthcare Ltd would be given directions as to why charge was created by Core Healthcare on its assets prior to August 1998 by Global Trust Bank or not and what was the specific reason to obtain a fresh charge on the immoveable property of Rupmanglam Investment Pvt Ltd,Flovin Plastics Pvt Ltd in August 1998 and March 1998. Core Healthcare would be called upon to obtain detailed reply from Oriental Bank of Commerce.

IV. Core Healthcare Ltd management would take all necessary action against Handa family and Jatin Jalundwala to recover the loss suffered by the company especially when there is heavy loss in realization on proposed demerger as Nirma Limited at distress value.

V. Core Healthcare Ltd management along with Sushil Hand is called upon to take legal action against all the concerned agencied and bankers whoi have given consent to propose sale of assets at distress value to Nirma Limited and make them reimburse to Core Healthcare Ltd such loss on account of dpletion suffered by Core Healthcare Limited.

VI. Be pleased to grant such other and further reliefs as may be deemed just and proper in the facts and circumstances of the case.

AND FOR THIS ACT OF KINDNESS AND JUSTICE THE
PETTITONER AS IN DUTY BOUND SHALL EVER PRAY
PLACE : AHMEDABAD
DATE:- 12-2005

PANKAJ S MODY PARTY IN PERSON

I , Pankaj Sureshchandra Mody, aged 58 , adult residing at 2nd Floor , Janmangal Apartment , 40 Brahman Mitra Mandal Society , Paldi , Ahmedabad 380 006 , joining as Party In Person herein do hereby solemnly affirms and state on oath that what is stated herein above are true to best of my knowledge , information and belief and I believe the same to be true and correct.
Solemnly , affirmed at Ahmedabad on this day of December 2005
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DEPONENT
PARTY IN PERSON