Federated Mountain Clubs of New Zealand Incorporated v Griffin Creek Hydro Limited
[2023] NZHC 3746
•18 December 2023
IN THE HIGH COURT OF NEW ZEALAND AUCKLAND REGISTRY
I TE KŌTI MATUA O AOTEAROA TĀMAKI MAKAURAU ROHE
CIV-2022-404-001251
[2023] NZHC 3746
UNDER the Declaratory Judgments Act 1908 and Part 18 of the High Court Rules BETWEEN
THE FEDERATED MOUNTAIN CLUBS OF NEW ZEALAND INCORPORATED
Plaintiff
AND
GRIFFIN CREEK HYDRO LIMITED
First Defendant
THE MINISTER OF CONSERVATION
Second DefendantTHE DEPARTMENT OF CONSERVATION
Third Defendant
Hearing: On the papers Counsel:
M Smith for the Plaintiff
M Wright for the First Defendant
R Elvin and R Fistonich for the Second and Third DefendantsJudgment:
18 December 2023
JUDGMENT OF GORDON J
[As to costs]
This judgment was delivered by me on 18 December 2023 at 3.30 pm, pursuant to r 11.5 of the High Court Rules
Solicitors:
Crown Law, Wellington
Registrar/Deputy Registrar Date:
Gilbert Walker, Solicitors, Auckland Rout Milner Fitchett, Solicitors, Nelson
THE FEDERATED MOUNTAIN CLUBS OF NEW ZEALAND INC v GRIFFIN CREEK HYDRO LTD [2023] NZHC 3746 [18 December 2023]
Introduction
[1]This is a decision on an application for costs.
[2] In my judgment of 18 October 2023 (substantive judgment),1 I refused an application by the plaintiff, The Federated Mountains Clubs of New Zealand Inc (FMC), for a declaration under the Declaratory Judgments Act 1908 as to the interpretation of a concession granted by the second defendant, the Minister of Conservation (the Minister), to the first defendant company, Griffin Creek Hydro Ltd (GCHL).
[3] In 2011, the Minister, via her delegate, granted a concession under pt 3B of the Conservation Act 1987 (the Act) in the form of an easement in gross (Concession) to GCHL. The Concession permits GCHL to construct and operate a small, run-of-river, hydroelectric power scheme2 on conservation land3 in the Griffin Creek valley located on the West Coast of the South Island approximately 40 kilometres east of Hokitika. The scheme is not yet in operation. GCHL has constructed an access track but has not yet constructed the hydroelectric plant.
[4] FMC sought a declaration that the Concession limits the volume of water GCHL may extract from Griffin Creek to 1.2 cubic metres per second (cumecs). A second declaration was originally sought but was not pursued at the hearing as in their statements of defence, the defendants admitted that the Concession regulated the residual flow in the terms as expressed in the second declaration sought. There was, accordingly, no live dispute on that issue.4
[5]The three defendants opposed the declaration.
[6]The parties have not been able to agree costs and have filed memoranda.
1 The Federated Mountain Clubs of New Zealand Inc v Griffin Creek Hydro Ltd [2023] NZHC 2917 [substantive judgment].
2 With a “run-of-river” scheme there is no dam.
3 Conservation land is land held under the Conservation Act 1987 for conservation purposes.
4 Refer to fn 4 in substantive judgment.
Summary of parties’ positions on costs
[7] GCHL seeks costs on a 2B basis in the sum of $20,076.00 (up to and including the date of the hearing) plus an increase of 20 per cent applied to all steps up to and including the hearing. That is an additional $4,015.20. As well, GCHL seeks costs of
$1,434.00 for filing its application for costs. The total costs sought are $25,525.20 together with disbursements of $4,115.32. The total amount of costs and disbursements sought is $29,640.52. The schedule of costs filed with the submissions for GCHL is attached to this judgment as Annexure A.
[8] The Minister and the third defendant, the Department of Conservation (Department), which is the landholder and the administrator of the Concession, were jointly represented. Together they claim costs on a 2B basis of $16,132.50 and disbursements of $940.38, totalling $17,072.88. The schedule annexed to the submissions of counsel for the Minister and the Department is attached to this judgment as Annexure B.
[9] FMC’s position is that no costs award ought to be made against it as the proceeding concerned a matter of public interest and FMC acted reasonably in the conduct of the proceeding.5 Alternatively, FMC says any costs award should be substantially reduced. If the Court were to adopt FMC’s alternative position, FMC accepts an award of costs on a 2B basis is appropriate but says adjustments need to be made to the items in the two schedules for the defendants referred to above. FMC says there is no basis for increased costs.
[10] In response, GCHL says costs should be awarded as sought. The Minister and the Department similarly say no reduction in costs should be allowed and alternatively, if the Court finds a reduction in costs to be appropriate, any reduction should not be more than 10 per cent.
5 High Court Rules 2016, r 14.7(e).
Costs principles
[11] Although costs awards in the High Court are discretionary,6 as a general principle, the party who fails in a proceeding should pay costs to the party who succeeds.7 That general principle may be departed from, including to refuse or reduce costs if the proceeding concerned a matter of public interest, and the party opposing costs acted reasonably in the conduct of the proceeding.8
[12] For the “public interest” exception to apply, the proceeding must concern a matter of genuine public interest, have merit and be of general importance beyond the interests of the particular unsuccessful litigant.9
Public interest
[13] As to the first limb of r 14.7(e), Mr Smith, counsel for FMC, submits that the proceeding clearly concerned a matter of public interest. He says the case concerned infrastructure development in a previously pristine mountain valley. Mr Smith submits the protection of the environment is axiomatically in the public interest. He cites four cases which involved environmental challenges to development projects where there were no orders made as to costs and costs were to lie where they fell (in part in Environmental Defence Society Inc v The New Zealand King Salmon Company Ltd).10
[14] Mr Smith also submits that FMC did not act for personal gain, but as an advocate for nature. He refers to the affidavit of Neil Silverwood filed in the proceeding in which Mr Silverwood said FMC advocates for recreation broadly and the environment they recreate in, on behalf of 22,000 members in 100 clubs. Mr Smith submits the particular lens through which FMC approaches these issues – recreation –
6 Rule 14.1.
7 Rule 14.2(1)(a).
8 Rule 14.7(e).
9 Taylor v the District Court at North Shore (No 2) HC Auckland CIV-2009-404-2350, 13 October 2010 at [9] as cited in New Health New Zealand Inc v South Taranaki District Council [2014] NZHC 993, (2014) 21 PRNZ 766 at [10].
10 Save Kapiti Inc v New Zealand Transport Agency [2013] NZHC 3314; West Coast ENT Inc v Buller Coal Ltd [2013] NZSC 133; Environmental Defence Society Incorporated v The New Zealand King Salmon Company Ltd [2014] NZSC 167; and Lawyers for Climate Action NZ Inc v The Climate Change Commission [2023] NZHC 527.
is specifically recognised in the Act.11 Mr Smith submits that recreation is one of the primary lenses through which New Zealanders interact with nature.
[15]Mr Smith also submits the legal issue raised by the case was a novel one.
[16] I do not accept that the proceeding concerned a matter of public interest. The issue in the case was narrow. The application did not challenge the authorisation of the hydroelectric power scheme. The issue was simply: what is the correct approach for interpreting concessions under the Act. In more specific terms, the Court needed to decide whether the volume of water take referred to by GCHL in its application documents, but not imposed as a condition in the Concession as granted, nevertheless applied as a limit on the amount of water that could be taken.
[17] FMC argued that the Court should follow the approach that applies to the interpretation of a resource consent under the Resource Management Act 1991 when interpreting a concession. Following that approach would have meant the reference to the water take in the application documents operated as a limit on the water take under the Concession. I did not accept that argument and held that the Concession, being an easement, was to be interpreted using the principles of contractual interpretation. I considered that approach was supported by differences between the Act and the Resource Management Act.
[18] As noted above, Mr Smith makes the submission that the case concerned infrastructure development in a previously pristine mountain valley and the protection of the environment is axiomatically in the public interest. But that was not what the case was about. As already mentioned, the proceeding did not seek to overturn the authorisation of the scheme and accordingly, could not achieve the outcome Mr Smith refers to. The Court simply had to decide how the Concession document should be interpreted and whether using Resource Management Act interpretation principles was the correct approach.
11 Referring, for example, to the definition of “conservation” in s 2 and in the exemption for recreational activities from the concession regime under s 17O.
[19] I acknowledge that in a general sense FMC may seek to further public interest. However, that general interest was not a focus in this proceeding.
[20] In his affidavit, Mr Silverwood refers to the number of members on whose behalf they advocate. However, it is apparent that it would be only a small and select group of very experienced canyoners who would undertake the experience in Griffin Creek. In a letter annexed to Mr Silverwood’s affidavit written by the president of the NZ Canyoning Association, he refers to Griffin Creek as being a place very high on the list for advanced canyoners to visit. He refers to “technical challenges” and says “[t]here are only a few canyons so far explored at this level of difficulty…”. This does not suggest a broad interest in Griffin Creek.
[21] There was a news article published following the hearing which states: “Informing its members of the court action at the weekend, Federated Mountain Clubs said the case could have important implications for the place of recreation in interpreting such concessions.” That misstates what the case was about. The president of FMC is quoted as saying the Act requires that recreation be fostered. While that may be right, the proceeding before the Court did not involve a consideration of the role of recreation in decision-making under the Act.
[22] Mr Smith submits that the case raised the novel question of whether the scope of a concession activity is confined by the terms of an application, as is a resource consent under the Resource Management Act. He says this is an important question of law.12
[23] A matter that arises out of a private interest does not become a matter of public interest simply because the public benefits generally from its determination, such as settling the correct interpretation of a piece of legislation.13 Further, it arguably might be said that the narrow question the Court was required to decide was specific to the particular Concession.
12 Which he says was acknowledged by GCHL in its recent fast track memorandum in the Court of Appeal (FMC has appealed the substantive judgment).
13 Wong v Registrar of the Auckland High Court (2008) 19 PRNZ 32 (HC) at [18] as cited in
Belgiorno-Nettis v Auckland Unitary Plan Independent Hearings Panel [2018] NZHC 926 at [16].
[24] Even accepting Mr Smith’s submission that the decision is helpful beyond this case, the degree of helpfulness and the difficulty of the issue raised are not of the order as was found in the cases FMC relies on. For example, in Environmental Defence Society Inc v The New Zealand King Salmon Company Ltd, the Judges in the majority in the Supreme Court said:14
[44] We accept that there is force in the points made by SOS. The submissions it made in the EDS appeal were of assistance to the Court and are reflected in the Court’s analysis. The SOS appeal in relation to the three remaining salmon farms raised, as King Salmon acknowledged, issues of “major resource management significance“. The Court’s analysis will have a significant impact on decision-making under the RMA in the future. ...
[25]The minority Judges said:
[26] Although the appeal taken to this Court by SOS ultimately failed, the points raised by it were undoubtedly matters of significant public importance. The testing against the Act of the system of adaptive management of impacts on water quality and arguments advanced that a precautionary approach was required in cases of scientific uncertainty were important in themselves and the litigation provided principles of significance for future cases, even if in the end the Court concluded that they were not determinative of the present appeal on the facts.
…
[28] … The case, like West Coast ENT, was of real difficulty (as the division of opinion in this Court indicates) and the principles of interpretation applied had significance well beyond it. …
[26]Similarly, in West Coast ENT Inc v Buller Coal Ltd, the Supreme Court said:15
… As well, the underlying issue of law was difficult and its resolution had a significance which went well beyond the present case.
[27] The position in this case can also be contrasted with the position in Lawyers for Climate Action NZ Inc v The Climate Change Commission where the Court said:16
[7] In this case, I consider it is appropriate in the circumstances to depart from the general principle. Pursuant to the significant amendments to the Act that established the Commission, the Commission’s role is to provide periodic advice to the Minister and to review the Government’s progress towards emissions reduction and adaptation goals. LCANZ’s proceeding concerned
14 Environmental Defence Society Incorporated v The New Zealand King Salmon Company Ltd, above n 10.
15 West Coast ENT Inc v Buller Coal Ltd, above n 10, at [4].
16 Lawyers for Climate Action NZ Inc v The Climate Change Commission, above n 10.
the first occasion that the Commission advised the Minister pursuant to those amendments. It did so as a not-for-profit group formed for the purposes of promoting more ambitious climate change action in the face of the climate change emergency. It was not seeking a pecuniary or other direct benefit for itself. It was a group qualified and skilled to consider the legal issues on which the grounds of review were based. It advanced high-level principles and interpretation issues of general application rather than minor or narrow issues of limited significance. …
[8] … A similar point applies in the context of the Commission’s advice that has potentially such important impact on our future society in that, without the resources of a group such as LCANZ, no one person might be in a position to so thoroughly test whether the Commission’s advice, on the first occasion required of it, was in accordance with the task the legislature set for it.
[9] … As noted earlier, although it did not obtain relief, it succeeded on some points.
[28] This proceeding can be distinguished from the cases relied upon by FMC. FMC did not succeed on any points, nor were the issues finely balanced. The subject matter is also not a matter of general importance or significance going far beyond the present case. Here, the interests were of those of a select group of canyoners. The fact that the Court has determined how a concession is to be interpreted does not elevate the interests of a niche group into a matter of public interest.
[29] I do not consider the general principle that costs follow the event has been displaced.
Increased costs
[30] GCHL seeks increased costs. It says first, the application was entirely unmeritorious, being premised on the law of resource consents rather than the law of easements. GCHL also says the arguments it raised were not responded to in any meaningful way by FMC.
[31] Second, GCHL says the application relied on evidence in the affidavit of Mr Silverwood, which the Court ruled inadmissible. Ms Gepp, counsel for GCHL, says that necessitated the time and expense of filing a notice under r 9.11 of the High Court Rules and there was a need to address admissibility issues in legal submissions. Further, Ms Gepp says, as acknowledged in oral submissions by Mr Smith, the parts
of Mr Silverwood’s affidavits ruled inadmissible were not relevant to the legal issue before the Court.
[32] Next, Ms Gepp submits that the assertions in Mr Silverwood’s evidence as to the effects of the scheme on Griffin Creek required GCHL to file evidence from two expert witnesses in response.
[33] Lastly, Ms Gepp says FMC failed without reasonable justification to accept an offer of settlement prior to trial.
[34] Rule 14.6 of the High Court Rules sets out the circumstances in which a party may be awarded increased costs. Rule 14.6(3)(b) provides in relevant part:
14.6 Increased costs and indemnity costs
…
(3) The court may order a party to pay increased costs if—
…
(b)the party opposing costs has contributed unnecessarily to the time or expense of the proceeding or step in it by—
…
(ii) taking or pursuing an unnecessary step or an argument that lacks merit; or
…
(v) failing, without reasonable justification, to accept an offer of settlement whether in the form of an offer under rule 14.10 or some other offer to settle or dispose of the proceeding; or
…
[35] As regards settlement offers prior to trial (known as Calderbank offers), rr 14.10 and 14.11 respectively provide, in relevant part:
14.10Written offers without prejudice except as to costs
(1)A party to a proceeding may make a written offer to another party at any time that—
(a)is expressly stated to be without prejudice except as to costs; and
(b)relates to an issue in the proceeding.
…
14.11Effect on costs
(1)The effect (if any) that the making of an offer under rule 14.10 has on the question of costs is at the discretion of the court.
(2)Subclauses (3) and (4)—
(a)are subject to subclause (1); and
(b)do not limit rule 14.6 or 14.7; and
(c)apply to an offer made under rule 14.10 by a party to a proceeding (party A) to another party to it (party B).
(3)Party A is entitled to costs on the steps taken in the proceeding after the offer is made, if party A—
…
(b)makes an offer that would have been more beneficial to party B than the judgment obtained by party B against party A.
…
[36] The effect of a Calderbank offer on an award of costs is fully discretionary.17 Such an offer does not stand alone. All the surrounding circumstances must be considered.
[37] All of the grounds in r 14.6(3)(b) are predicated on actions by the losing party which increased the costs of a proceeding once issued. Leaving aside for the moment the affidavits of Mr Silverwood, I accept that the case for FMC was progressed responsibly. However, as against that, taking or pursuing an entire claim that lacks merit can warrant increased costs.
[38] Although FMC failed, it did raise a novel question of law. While Ms Gepp submits, and I agree, that FMC failed to apply the law relating to the interpretation of easements (the Concession being an easement), the Court reached its decision not only
17 McDonald v FAI (NZ) General Insurance Co Ltd (2002) 16 PRNZ 298 (HC) at [53] citing Health Waikato Ltd v van der Sluis (1997) 10 PRNZ 514 (CA).
by applying the law relating to easements but also by finding support in the differences between the regimes under the Act and the Resource Management Act. There was no explicit guidance from case law on such an analysis, as noted in the substantive judgment.18
[39] As far as Mr Silverwood’s evidence is concerned, any cost incurred by GCHL as a consequence of that evidence can be met by allowing in the scale costs award the cost of GCHL’s r 9.11 notice (as claimed by GCHL in its schedule), and by allowing the fees for GCHL’s two expert witnesses as disbursements (also as claimed in GCHL’s schedule).
[40] As regards the settlement proposal, counsel for GCHL sent a letter to the solicitors for FMC dated 16 December 2022 on a “without prejudice save as to costs” basis. The letter states in relevant part:
In the interests of resolving this litigation promptly and avoiding further costs, GCHL is prepared to offer a compromise. In exchange for FMC discontinuing the proceeding and not taking further action to challenge the take volume available under the concession, GCHL is prepared to offer to cease take up to “X” pre-arranged days per year, with the number of days and hours per day to be agreed between GCHL and FMC. On those days, canyoners would be able to use Griffin Creek for canyoning with the water at its natural full flow. This would be a significant betterment for FMC compared with the best outcome that could be achieved if FMC were successful in its declaration application.
[41] The issue of the reasonableness of rejecting an offer is to be assessed at the time the offer was made, not in light of the result.19
[42] As any effect on costs on a r 14.10 offer is at the Court’s discretion, it does not afford automatic protection from costs in the event of a lower recovery. An offer more favourable than the ultimate recovery must be considered.20 However, it is not the sole consideration.
[43] I do not consider it was unreasonable for FMC not to accept the settlement offer. First, FMC sought a year-round result in the proceeding. Further, as Mr Smith
18 At [106].
19 New Zealand Sports Merchandising Ltd v DSL Logistics Ltd HC Auckland CIV-2009-404-5548, 19 August 2010 at [35]–[36].
20 Warren Metals Ltd v Grant [2015] NZHC 2462 at [42].
points out, the proposal was uncertain with the key term, the number of days and hours of cessation, still to be negotiated. Leaving the fundamental part of the proposal uncertain means it is difficult to evaluate whether the compromise offered by GCHL would be, as Ms Gepp puts it, a “significant betterment” for FMC compared with the best outcome that could be achieved if FMC were successful in its application.
[44] Taken overall, I do not consider any of the matters raised by GCHL either on their own, or in combination, warrant an award of increased costs.
Quantification of GCHL’s 2B costs
[45] Mr Smith submits that five adjustments need to be made to GCHL’s costs claim in its schedule. The first of those also applies to the claim by the Minister and the Department.
[46] Mr Smith submits that no allowance should be made for item 2, commencement of defence. FMC’s proceeding as filed raised two issues with a declaration sought on each of those two issues. Mr Smith says this was based on the position of GCHL as set out in its solicitor’s letter of 20 November 2018. Mr Smith says that following the filing of proceedings, GCHL changed its position on the second issue (residual water flow).21 Mr Smith submits that costs on commencement of the proceeding ought to lie where they fall, reflecting each party’s success on one of the two matters initially in issue.
[47] I accept Ms Gepp’s submission that FMC’s present position is inconsistent with the parties’ agreement as to how this issue would be dealt with in terms of costs. In a letter dated 8 December 2022, the solicitors for FMC wrote to counsel for GCHL in the following terms:
FMC is pleased that GCHL, the Minister and the Department have admitted the Concession regulates residual flow in the manner described in the statement of claim. FMC is accordingly prepared to withdraw its application for the first declaration with costs on that aspect of the claim to lie where they fall.
21 See fn 4 in substantive judgment.
[48] Having regard to the above correspondence, which refers to “that aspect of the claim”, I consider it is proper to provide an allowance for item 2 (commencement of the defence) as it relates to the other declaration, for both GCHL and the Minister and the Department. I will allow this item as claimed.
[49] As a second adjustment, FMC says there should be no allowance for the first case management conference memorandum dated 19 January 2023. Mr Smith submits this was prepared by FMC.
[50] However, it is apparent from the memorandum on the Court file that it is a joint memorandum. Although the memorandum appears to have been filed by the solicitors for FMC, by its nature, a joint memorandum requires input from all counsel. I will allow this item claimed by GCHL.
[51] Third, Mr Smith submits the hearing time allowance should be 0.75 days reflecting, what Mr Smith submits was the actual time occupied by the hearing rather than the one day claimed by GCHL.
[52]I have examined the Court records. They indicate the hearing ended at
4.15 pm. In other words, the hearing continued after the afternoon adjournment and therefore went beyond the third quarter day into the fourth quarter. I will allow the one day allowance as claimed by GCHL.
[53] The fourth adjustment that FMC says should be made is that there should be no allowance for GCHL’s expert witness disbursements. As Mr Smith notes, under r 14.12, disbursements may be recovered where they are reasonably necessary for the conduct of the proceeding. Mr Smith submits GCHL’s expert fees were not necessary in circumstances where the evidence was relevant only to the potential implication of a term (in other words a limit in the Concession on the volume of water GCHL might extract from Griffin Creek) and FMC did not argue for the implication of a term.
[54] I do not accept Mr Smith’s submission. It was reasonably necessary for GCHL to file evidence from the two experts for two reasons. First, the evidence was in response to Mr Silverwood’s evidence. Although in the end the Court ruled that parts
of Mr Silverwood’s evidence purporting to give expert opinion were inadmissible, given that argument was not heard on that issue until trial, it was reasonable for GCHL to file expert evidence in response to Mr Silverwood’s purported expert opinion.
[55] Second, the evidence was relevant for the Court’s consideration of whether a term limiting water take should be read into the Concession as an implied (contractual) term. Given GCHL’s position that the Concession should be interpreted under the law of contract, GCHL needed to provide the Court with an evidential basis in order to submit that a term limiting water take should not be an implied term. The evidence was “reasonably necessary” for that purpose. I will allow the claim by GCHL for expert witness fees as disbursements.
[56] Finally, Mr Smith submits there should be no allowance for GCHL’s costs application.
[57] It is well established that costs may be awarded in respect of an application for costs.22 An application for costs is to be treated no differently for costs purposes from an ordinary interlocutory application. Costs may be awarded according to scale or on an increased or indemnity basis as appropriate.23 I will allow the claim in accordance with the scale.
Orders
[58] I make an order for costs against The Federated Mountain Clubs of New Zealand Inc (FMC) in favour of Griffin Creek Hydro Ltd in the sum of $21,510.00 plus disbursements of $4,115.32 together totalling $25,625.32.
[59] I make a further order for costs against FMC in favour of the Minister of Conservation and the Department of Conservation jointly in the sum of $16,132.50 plus disbursements of $940.38 together totalling $17,072.88.
Gordon J
22 Body Corporate Administration Ltd v Mehta (No 4) [2013] NZHC 213 at [85] citing for example,
Auckland Regional Council v Arrigato Investments Ltd (2002) 16 PRNZ 217 (HC).
23 Body Corporate Administration Ltd v Mehta (No 4), above n 21, at [85].
Annexure A
SCHEDULE OF COSTS
Schedule 3 HCR time allocations Allocated day or part day (B) Value based on daily recovery rate of $2,390 (for category 2
proceedings)
2: Commencement of defence by
defendant
2 $4,780.00 10: Preparation for first case management conference (including discussion about discovery) 0.4 $956.00 11: Filing memorandum for first or subsequent case management
conference or mentions hearing
0.4 $956.00 30: Preparation of affidavits, list of
issues or authorities; and agreeing common bundle.
2 $4,780.00 32 Preparation for hearing 2 $4,780.00 34 Appearance at hearing for
sole or principal counsel
1 $2,390.00 36 Other steps in proceeding not specifically mentioned [Notice in accordance with Rule 9.11
regarding admissibility of evidence]
0.6 [estimated to be the same as time allocation for filing an interlocutory
application]
$1,434.00 Sub-total $20,076.00 20% of sub-total $4,015.20 22: Filing interlocutory application [application for costs] 0.6 $1,434.00 Total - costs $25,525.20 Disbursements Court filing fee statement of
defence
$110.00 Affidavit of Mary Ann Mitchell $1,653.13 Affidavit of Monique Harvey $1,840.00 Printing and binding of pleadings
and evidence
$438.55 Delivery bundles from printers
(uber)
$21.53 Printing handup documents for
court
$24.15 Taxi to Court (Uber) $10.86 Taxi after Court $17.10 Total $29,640.52
Annexure B
1
10
0