[2025] EWHC 2501 (Ch)

Ground 1 - is that in paragraph 15 of a witness statement dated 10 October 2024, Mr Ginda (in responding to Sanman’s application of 8 October 2024) stated that: “The Final Payment under the [DMA] was received from Cortland on 30 September 2024. The final payment received is £10,289,910”. Sanman says that this statement is false, that the payment received from Cortland, by TGDM was £12,347,892 and Sanman asserts that, as sole director of TGDM, Mr Ginda knew that that statement was untrue. Sanman accepts that it has to apply for permission to commence contempt proceedings on this ground and it does so;

Ground 2 - is that, in a letter written by the Respondents’ then solicitors (Jury O’Shea) to Sanman’s solicitors on 7 November 2024 (in purported compliance with the requirement of the Freezing Order that the Respondents provide details of TGDM’s assets over £10,000) Jury Oshea said: “[TGDM’s] only asset is £9,315,733 in the Punjab National Bank”. Sanman says that that statement is false, in that, on 7 November 2024 the balance in TGDM’S bank account with Punjab National Bank (“PNB”) was £11,118,518.70 and that the Respondents knew that it was false. Sanman says that it does not need permission to commence contempt proceedings on this ground.

Ground 3 - is that in paragraph 10 of an affidavit sworn by Mr Ginda, on 12 November 2024 (in purported compliance with paragraph 9 of the Freezing Order, which required such an affidavit to be served) Mr Ginda said that: “[TGDM’s] only asset worldwide exceeding £10,000 in value is £9,315,733 in [TGDM’s] bank account with Punjab National Bank”. Sanman say that this statement was false, because the balance on TGDM’s bank account was £11,118,518.17, on 12 November 2024 and Mr Ginda knew it to be false. Sanman accepts that it needs permission, to commence contempt proceedings on this ground and seeks such permission;

Ground 4 - is that the false statement made in paragraph 10 of Mr Ginda’s affidavit of 12 November 2024 (see (c) above) was also a deliberate breach of paragraph 9 of the Freezing Order. Sanman says that it does not need permission to commence contempt proceedings on this ground; and

Ground 5 – is that, in paragraph 8 of Mr Ginda’s affidavit of 12 November 2024, Mr Ginda says that: “The final payment under the [DMA] was received from Cortland on 30 September 2024. The final payment was £10,289,910.” Sanman says that this statement is false in that the sum received by TGDM from Cortland, on 30 September 2024 was £12,347,892 and that Mr Ginda knew that that statement was false. Sanman accepts that it needs permission to bring contempt proceedings on this ground and seeks such permission.