One can love it or hate it, but we respect science & technology, we love numbers, we believe in numbers and reciprocate what numbers say.

1. Page 1 of 16
WITHOUT PREJUDICE
Dated 27th June 2019
BY COURIER / E-MAIL
del2infinity Energy Consulting Pvt. Ltd.
(An accurate solution for Wind Power & Solar Power
Forecasting & Scheduling)
To
1. R. P. Thanebala
Advocate
Thanevala Terrace, 163 R.N.T. Marg
Indore 452001, Ph. 2527618
18/3/9 Kumud Ghosal Road,
Kolkata – 700057, West Bengal, India
Email: contact@del2infinity.xyz
Website: www.del2infinity.xyz;
Phone: 7760989341 || 9891770702 || 9990433149
2. RECONNECT Energy Solutions Pvt Ltd.
173, A Sector, Scheme No. 54 Indore
Indore MP 452010
3. RECONNECT Energy Solutions Pvt Ltd.
Krishik Sarvodaya Foundation 1st Floor, No
15, Golf View Road,Off Old Airport Road,
Kodihalli, Bangalore – 560008 Karnataka,
India Ph - 080 50473388 / 99
Sub: Reply to your legal notice dated June 12, 2019 (‘Notice’) sent on
behalf of your client M/s RECONNECT Energy Solutions Pvt Ltd.
(‘RECONNECT’)
Dear Sir,
We are in receipt of the above referenced Notice, the content of which are incorrect, riddled
with factual errors, patent absurdities, unsubstantiated allegations and damaging
imputations, misrepresentation of facts and a blatant attempt to coerce del2infinity to
wrongfully eliminating competition and appear either motivated by ignorance of the facts,
malice or worse.
At the outset, we, del2infinity, deny each and every allegation and statement made by you or
your client RECONNECT in your Notice and we hereby contest the content of Notice, as
being totally false, fabricated, concocted and a baseless threat on behalf of RECONNECT
exhibiting your devious malicious intentions of coercing and arm-twisting del2infinity for
eliminating competition, extracting additional business profit.
Without prejudice to del2infinity’s rights, available under the applicable laws, including
initiating any appropriate legal action against RECONNECT for an attempt to malign the
reputation and image of del2infinity, we hereby state the chain of events as below:

2. Page 2 of 16
1. We, would like to state that we have shared the following table to many of our clients:
RAJASTHAN DSM Penalties (RE Forecasting & Scheduling Penalties)
QCA Jun-18 Jul-18 Aug-18 Sep-18 Total (INR)
1 STATKRAFT -32,74,693 -23,03,847 -9,89,645 -15,62,253 -81,30,438
2 RECONNECT -35,47,42,813 -21,60,95,490 -17,45,99,282 -9,51,96,786 -84,06,34,371
3 MANIKARAN -2,92,96,007 -1,07,23,141 -6,44,24,876 -1,80,97,427 -12,25,41,451
Total (INR) -38,73,13,513 -22,91,22,478 -24,00,13,803 -11,48,56,466 -97,13,06,260
as per Rajasthan SLDC Website
We would like to state that the above table shows the RE Forecasting & Scheduling
penalties of 3 (three) QCAs at Rajasthan SLDC. It is a simple comparative study on the
techno-economic viability of the QCAs acting at Rajasthan SLDC.
Please also take note that this table does not show how much aggregate amount payable
by the renewable energy generators for the deviation in energy generated and forecasted.
This table only shows how much liability each QCA have at Rajasthan SLDC since as per
the present F&S regulation, the penalty amount is to be settled by the QCA only.
The purpose of the table is to understand the present techno-economic status of QCAs at
RJ-SLDC, to research on the comparative analysis of QCAs and to understand the
viabilities of QCAs.
We would like to state herein that renewable energy industry is very small. We are also
working with many of the renewable energy companies, who are again may be
RECONNECT’s client’s too, so there is no arrangement of exclusivity or non-compete
arrangement between RECONNECT and del2infinity. Please take note that we are
already in touch with around 90% of the renewable energy companies and IPPs and we
are closely working with them since 2015 onwards not only in forecasting & scheduling
services but in different verticals of renewable energy and energy analytics. We would like
to state that one has to provide the following 3 points to prove defamation:
A. Firstly, we would like to state that in order to constitute the legal wrong of
defamation, you need to prove that the statements made by us necessarily
lowered the reputation of your client RECONNECT in the eyes of a
“reasonable” public.
B. Secondly, even if the said statements lowered the reputation of your
esteemed client, RECONNECT, they are exempt from legal liability, if it can
be shown that they encapsulate the truth or amount to a fair
comment/opinion.

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C. Thirdly, the public interest factor plays an important role in all of this and
any fair reportage on matters of public interest are generally exempt.
Please take note that the table presented by del2infinity, has nothing to do with the
reputation of RECONNECT before reasonable public. It is a comparative study which
depicts the truth and an amount of fair comment/ opinion. Last but not the least; the
comparative study is for public interest to make them understand the total liability of the
leading QCAs. It is pertinent to mention that all the 3 leading QCAs are under huge
financial stress:
QCA Name Rajasthan1 M.P.2 AP3 Total DSM (INR)
MANIKARAN 12,25,41,451 3,54,86,758 9,74,810 15,90,03,019
REONNECT 84,06,34,371 23,44,00,145 19,57,581 1,07,69,92,097
STATKRAFT 81,30,438 1,04,35,867 26,63,026 2,12,29,331
Please take note that we have not identified RECONNECT’s penalty alone, we have
analyzed the total DSM penal liability of the 3 leading QCAs in 3 states ie. Rajasthan,
Madhya Pradesh & Andhra Pradesh.
2. Please also take note that del2infinity has also published a comparative study of all the 6
QCAs working at M.P. Detailed study is as following:
Madhya Pradesh DSM Penalty (RE Forecasting & Scheduling penalty)
MW Aug-18 Sep-18 Oct-18
Avg
Penalty/MW
Nov-18
Avg
Penalty/MW
Dec-18
Avg
Penalty/MW
Manikaran 1059.63
₹
1,72,41,679
₹ 98,35,024 ₹ 40,02,770 ₹ 3,778 ₹ 12,61,452 ₹ 1,190 ₹ 31,45,833 ₹ 2,969
Reconnect 1825
₹
9,08,62,257
₹
7,08,89,117
₹ 2,45,07,632 ₹ 13,429
₹
1,36,14,040
₹ 7,460
₹
3,45,27,099
₹ 18,919
Statkraft 330.5 ₹ 28,07,912 ₹ 15,04,989 ₹ 21,31,918 ₹ 6,451 ₹ 22,68,031 ₹ 6,862 ₹ 17,23,017 ₹ 5,213
Regent Climate 12 ₹ 1,51,661 ₹ 50,291 ₹ 10,831 ₹ 903 ₹ 13,301 ₹ 1,108 ₹ 16,118 ₹ 1,343
Vedanjay Power 10 ₹ 4,00,176 ₹ 43,427 ₹ 4,343 ₹ 10,754 ₹ 1,075 ₹ 28,925 ₹ 2,893
del2infinity 20 ₹ 2,00,353 ₹ 3,01,555 ₹ 6,239 ₹ 312 ₹ 4,579 ₹ 229 ₹ 4,076 ₹ 204
as per MP SLDC Website:http://www.sldcmpindia.com/
3. In response to para 5 of your Notice, we would like to state that the table represents the
RE forecasting & scheduling penalties of three QCAs at Rajasthan SLDC. It is simple
comparative study on the techno-economic viability of the QCAs acting at Rajasthan
SLDC. This table contains the information for academics, research in techno-economics
and business studies for renewable energy sectors. The table contains the information
1
Penalty for the month of June, July, August & September 2018
2
Penalty for the month of August, September, October, November & December 2018
3
Penalty for the month of July 2018

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which is in public domains and can be useful for all renewable energy stakeholders in
public interest, grid-stability, grid-discipline. Please also take note that Surekha Realty
has also shown its interest to appoint del2infinity as its forecasting agency. We have
necessary emails in this reference, which we can produce in appropriate time and forum.
Please also take note that we have many of the renewable energy companies and IPPs
who has not received the DSM penalties published by state SLDC. They have enquired
for the DSM penalty and we have shared the DSM penalty as published by SLDC. We
are surprised, why RECONNECT has not shared such SLDC published DSM penalty
details to all the IPPs transparently showing the QCA’s liabilities.
4. In response to para 5 of your Notice, we would like to state that the table shows the total
penalty of each QCA at Rajasthan. As per the regulation, this amount is payable by QCA
to SLDC on behalf of IPPs, hence for research purpose, the economic viability and
financial capability of each QCA can be studied whether these leading QCAs are in a
position to pay this amount of DSM penalty or not. Hence this study also focuses on the
requirement of QCA regulations in future to meet the sustainable energy goal, grid-
stability, grid-discipline.
This table is prepared and compile with the DSM penalty data available in public space,
uses public or openly available information and is useful for all renewable energy
stakeholders, not only the customers of your clients.
5. The information at the Table are correct and can be checked at RJ-SLDC site, if your
client had misinterpreted any of the information to its customers, then this table can be a
threat to RECONNET’s reputation, otherwise this table is a simple representation of the
status of QCAs penalties at RJ-SLDC.
Please take note that all the 3 leading QCA has following DSM penalty which QCA has to
deposit to the SLDC on behalf of IPP:
QCA Name Rajasthan4
M.P.5
AP6
Total DSM (INR)
MANIKARAN 12,25,41,451 3,54,86,758 9,74,810 15,90,03,019
REONNECT 84,06,34,371 23,44,00,145 19,57,581 1,07,69,92,097
STATKRAFT 81,30,438 1,04,35,867 26,63,026 2,12,29,331
Please also take note that all the QCAs have also submitted Bank-Guarantee with
various SLDCs to register itself as a QCA. Generally, for registering as QCA at
Karnataka, A.P., Telangana SLDC, BG for a substantial amount for wind & for solar has
to be deposited. Submission and extension of this BG shall also stress the financial
capabilities of the QCA.
4
Penalty for the month of June, July, August & September 2018
5
Penalty for the month of August, September, October, November & December 2018
6
Penalty for the month of July 2018

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State Solar Wind
Karnataka 10,600/- per MW 43,200/- per MW
Andhra Pradesh 22,500/- per MW 45,000/- per MW
Rajasthan 10,000/- per MW 40,000/- per MW
Madhya Pradesh 110% of average weekly liability
Telangana Generator shall furnish PSM directly to SLDC
Please also take note that all the state forecasting & scheduling company has stated that,
Regulation 6(f) of the impugned regulations states that the net worth of the QCA shall be
at least Rs. 1.50 Crores in the previous financial year which shall reflect from the audited
accounts duly verified by the chartered accountant. Hence QCAs may be in default to
comply with the financial net-worth criteria, as they are already under huge financial
stress. The forecasting regulation states that the financial strength of the QCA must be
such that it should be in a position to handle the risk of penalties due to deviation charges
applicable to generator. From the following analysis it is evident that del2infinity’s claim
regarding financial strength of the QCA in this matter is true:
QCA Name Rajasthan7
M.P.8
AP9
Total DSM (INR)
MANIKARAN 12,25,41,451 3,54,86,758 9,74,810 15,90,03,019
REONNECT 84,06,34,371 23,44,00,145 19,57,581 1,07,69,92,097
STATKRAFT 81,30,438 1,04,35,867 26,63,026 2,12,29,331
6. Here again, we fail to understand how any reasonable reader would have arrived at such
a fanciful conclusion. We believe there are several robust online publications around
these days, should you wish to take one of them. Most important of all however,
del2infinity’s post was based entirely on RAJ-SLDC published revised DSM results.
We’ve queried the Rajasthan SLDC, and apparently, you’ve not sent RAJ-SLDC any
notice as yet nor have you filed any case or raised any dispute against Rajasthan-SLDC
against such DSM penalty.
7. Again, we assume that as a reasonable person, you are well aware of the distinction
between an opinion and a fact. This is a fair comment/opinion expressed by del2infinity
predicated on sound facts i.e. the fact that a dispute (‘grid discipline’ and ‘grid stability’)
that prolonged for more than 8-9 years would certainly qualify as a “problem” and an
“obstacle” for any sane person and transmission-company or SLDC, least of all a
business entity that relies on some level of legal certainty for its investments.
If your client, RECONNECT has a different take on this, we welcome it. In fact, we’d be
more than happy to run it on our website and our pages. We’re great fans of the
7
Penalty for the month of June, July, August & September 2018
8
Penalty for the month of August, September, October, November & December 2018
9
Penalty for the month of July 2018, as per RTI reply

6. Page 6 of 16
inimitable Voltaire who reputedly quipped: “I disapprove what you say, but I will defend to
the death your right to say it.”
8. The allegations of bias and false reporting made in point 6 & 7 of your Notice are
preposterous, to say the least. If you had the patience to read the table carefully, you
would have noticed that del2infinity merely restated factual aspects of the legal
proceedings pertaining to IWPA (Rajasthan State Council) application. Your Notice, in
fact, acknowledges that a similar case is pending before the High Court of Rajasthan.
One fails to understand as to how such a narration amounts to false reporting and bias.
Clearly the man on the Clapham omnibus must have knocked his head hard, if this were
to qualify as a “reasonable” construction!
9. Your allegations made in point 6,7 & 8 of the Notice are again misplaced. del2infinity’s
remarks on the performance of leading 3 QCAs are based on the comments of leading
senior counsel for Indian Wind Power Association, as reported in the Judgment of 1.
Indian Wind Power Association (Rajasthan state council) vs. RERC10, 2. M/s Tanot
Wind Power Ventures Pvt. Ltd. Vs. RERC & Ors.11
and 3. M/s. Ramgad Minerals and
Mining Limited Vs. State OF Rajasthan and Ors.12
has been quoted as saying:
“14. While questioning the legality and propriety of the Regulations
of 2017, learned counsel for the petitioner-Association submitted that the
respondents have restricted the choice of selection of QCAs from
amongst four agencies and have compelled the members to choose one
of them. It has been contended that none of the QCAs suggested by
the respondents is technically competent. A grievance has been
raised that the respondents have given more weightage to the financial
capacity than their technical expertise, while selecting QCAs and none of
them have any expertise of forecasting 500 MW for a year. Work of QCA
become more daunting in a terrain like Western Rajasthan, where climatic
conditions are more unpredictable than other parts as the desert areas
witness many sand storms and the wind velocity in this part is also highly
variable making it almost impossible to predict.
18. Counsel for the petitioner pointed out that though scheduling part is
to be done by the generators, but the same is totally dependent upon the
forecasting to be provided by the QCA. If the input for scheduling i.e.
forecasting about the wind is improper or inaccurate, the scheduling or
the forecasting of the generation given by the generator is bound to go
wrong. According to the learned counsel for the petitioner, the
members of the petitioner Association are sought to be penalized
10
[CW / 18587 / 2018]
11
[CW / 3662 / 2018]
12
[CW / 2623 / 2018]

7. Page 7 of 16
for the fault of QCA in not being able to correctly forecast the
weather or wind.
19. Highlighting the problems and lack of expertise/experience of
the QCA, learned counsel for the petitioner submitted that none of
the QCAs are having experts or expertise to predict or forecast the
weather with accuracy. He submitted that their estimation or
forecasting of weather is only a hypothesis. He repeatedly and rhetorically
asserted that no instrument or technique is available, with which a proper
forecasting of the wind can be made, particularly in a terrain like Western
Rajasthan.
27. Mr. Ravi Bhansali, learned Senior Counsel appearing on behalf of
the other petitioner, Tanot Wind Power Ventures Pvt. Ltd. invited
attention of the Court towards para No.23 of his writ petition, wherein a
comparative chart has been given showing the revenue as per earlier
mechanism vis-à-vis a revenue as per the new mechanism. With the help
of comparison given in the said table, he contended that after coming into
force of the new Regulations, per unit revenue or price payable to the
generator will be substantially reduced as against the rates already fixed,
i.e. Rs.5/- per unit. He submitted that Regulation 18 of the Regulations is
a subterfuge to generate revenue for the RRVPNL or to curtail the rightful
entitlement of the generators. Learned
Senior Counsel submitted that the petitioner had ventured to install a wind
farm and invested a huge amount keeping in mind the assured rate of
Rs.5/- per unit, without anticipating that the respondents would bring in
the impugned legislation, substantially reducing the amount payable to it.
Rajasthan was an electricity scarce State, when the petitioner had
installed its wind farm and the respondents were inviting
entrepreneurs to establish wind farms, and when there is sufficient
generation of electricity, now taken a U-turn. Finding the rates fixed in the
power purchase agreement unprofitable, they have deviced a way to
reduce the rates under the guise of deviation charges. He also echoed
the Association’s voice that the petitioner has to depend upon the
QCA for weather forecasting and that for the fault of the QCA, an
agency thrusted upon it, the petitioner cannot be saddled with heavy
penalty under the garb of deviation charges. He argued that
Regulation 5 of the Regulations provides that the price to be paid by
DISCOM shall be net of all GoR and local taxes and duties as leviable on
generation and/or sale of electricity and the same shall be based on the
tariff attached as Annexure-B to the Regulations. Taking the Court
through the tariff contained therein, he argued that neither the Regulation
5 envisages deviation charges leviable under Regulation 18 nor does the
tariff shown in Annexure-B of the Regulation takes into account the
deviation charges. As such, the deviation charges levied under
Regulation

8. Page 8 of 16
29. At the outset, he submitted that there are three factors; first
forecasting, second scheduling and third deviation, as far as the
Regulations of 2017 are concerned and the generator has control over
none. Inviting attention towards Regulation 6 of the Regulation he
submitted that the same provides for methodology for scheduling of the
energy by the generators connected to the State grid so also the
methodology of handling deviation of such wind and solar energy
generators, but it does not provide any mechanism for forecasting. By
virtue of such provision, the respondents have conveniently passed on
the SLDC’s burden of forecasting to the QCAs and/or to the generators,
whereas the same is an essential function, rather obligation of the SLDC.
He submitted that Regulation 7 of the Regulations mandates SLDC to
undertake forecasting of the power, i.e. expected to be injected into the
State Grid with an objective of ensuring secure grid operation by planning
for the requisite balancing of resources. He pointed out that the said
Regulation 7 of the Regulations of 2017 provides the QCA or wind and
solar generators will have the option of accepting the SLDC’s forecasting
for preparing its schedule or carry out their own forecasting for preparing
schedule to be given to the SLDC, but by dint of these Regulations, the
respondents have not only shifted the onus of forecasting upon the
QCAs but in a way have compelled the generators to engage one out of
the four QCAs registered with the respondents. According to him,
regardless of the fact that the Regulation mandates the SLDC to carry out
forecasting, the respondents have forced the petitioner and other power
generators to enter into an agreement with the QCA, realizing that the
SLDC, which is one of its arms, is not in a position to carry out forecasting
accurately.
31. We were then navigated through “Procedure for Implementation of the
Framework of Forecasting and Scheduling for renewable energy (RE)
Generating Stations (wind and solar)”, (hereinafter referred to as ‘the
framework’). It was contended that Clauses (8) and (9) of the framework
do not prescribe any penalty or fine upon the QCA, if such QCA mis-
judge or go wrong in the forecasting. He raised grievance qua Clause
8(2) of the framework by saying that it is totally tilted in favour of the
QCAs, so much so that in case of non-performance of function by QCA, it
provides that the generator shall not, in any manner, be absolved from
meeting its responsibilities under the Regulations.
46. Learned Advocate General contended that much has been said
about the lack of technical expertise and infrastructure, including non-
availability of equipment’s with the QCAs and consequential financial
implication upon the members of the petitioner Association on the
failure of such QCAs’, but all such allegations have been hurled at
their back. The petitioners have not chosen to implead the QCAs as a
party respondent. The petitioners’ allegation that the QCAs do not have

9. Page 9 of 16
equipment’s or expertise to forecast the wind velocity, cannot be gone
into or considered in absence of the QCAs. He pointed out that all the
members of the petitioner Association, and so also the other writ
petitioner Tanot Wind Power Ventures Pvt. Ltd. have chosen one QCA
out of the four QCAs, registered with the RERC and have entered into
agreements, yet none of them (QCAs) is before this Court to respond to
the allegations about their incompetence. According to Mr. Singhvi, the
petitioners’ writ petitions are liable to be rejected for non-joinder of
necessary parties.
57. Reiterating the petitioners’ grievance, he submitted in other words
that the cost in the form of deviation charges cannot be saddled on the
petitioners for someone else’s fault. Elaborating his argument further, he
submitted that a generator will have to depend upon the forecasting done
by other agency, namely, QCA, if the forecasting done by the QCA turns
out to be wrong because of the wageries of the nature, a generator
cannot be burden with the deviation charges. As such, Regulation 18 of
the Regulation is arbitrary and violative of Articles 14 and 19(1) (g) of the
Constitution of India, emphatically argued learned counsel.
58. Thereafter, learned counsel for the petitioner pointed out numerous
other grievances of the petitioner, which were all procedural and
operational hassels, such as; (i) choice of QCA is not in petitioner’s
domain, (ii) no mechanism for registration has been provided, (iii) no
recording of metering is carried out, (iv) there is no mechanism of be-
pooling etc.
Here again, we’re guessing that you’ve shied away from sending a legal notice to
Advocate Mr Ravi Chirania (representing Indian Wind Power Association), Advocate
Mr. Ravi Bhansali (representing Tanot Wind Power Ventures Pvt. Ltd. i.e. Greenko
Group company), Mr M.S. Sangvi, Advocate General (representing RAJ-SLDC), widely
acknowledged as a leading legal luminary and heavyweight.
10. You chose instead to vent your animosity and target an innocent del2infinity who penned
his piece in good faith and backed it up with very credible sources, including the views of
legal stalwarts. We are particularly amused at your allegation that del2infinity caused
“irreparable injury” and “loss of reputation” to a powerful energy F&S house like
RECONNECT ENRGY by highlighting a highly technical dispute of public importance,
grid-discipline, grid-stability, loss to transmission companies and reflecting on the
protracted nature of the litigation. Continue to amuse us, and we may begin to
reciprocate.
11. Please also take note that your client, RECONNECT has represented before the
“TECHNICAL COMMITTEE FOR IMPLEMENTATION OF FRAMEWORK ON
RENEWABLES AT THE STATE LEVEL” held at CERC on 17th
July 2018 recorded in the
minutes, available as public document, about the very high accuracy of your clients
system; but that DSM penalty published by RAJ-SLDC and other state DSM do not

10. Page 10 of 16
support such accuracy claim of your client. Hence the table is also useful for the policy
research and the research and development of new guidelines and regulations for QCAs,
grid-stability, grid-discipline.
12. Please take note that forecasting and scheduling cannot be 100% accurate but can be
reach more than 99% accuracy as claimed by your client only at the “TECHNICAL
COMMITTEE FOR IMPLEMENTATION OF FRAMEWORK ON RENEWABLES AT THE
STATE LEVEL” held at CERC on 17th
July 2018.
13. The information of the table is complete and shows a comparative study of 3 QCAs
registered with RJ-SLDC. The information is not malicious as the information can be
checked at RJ-SLDC website as public document. The table shows no charges of the
customers of your client as the regulation states that this DSM amount of penalty is
payable by QCAs on behalf of IPPs/ Generators.
14. With regards to point 8,9 in your Notice, the table nowhere portrays RECONNECT as a
hapless victim. It is surprising how you’ve twisted simple sentences to reach this fanciful
conclusion.
15. Your averments in point 9, 10 of the Notice are again baseless. It has nothing to do with
your client, omnipotent and omnipresent as they maybe. Given the sheer time and
money spent on litigation, any reasonable person would have opined the same way. But
here again, the qualifier is “reasonable”.
16. To conclude, we strongly and staunchly deny all your puerile claims. We take strong
exception to your imputation of bad faith to del2infinity’s writings, articles on the website,
LinkedIn or Facebook publication have always reflected the highest values of journalistic
integrity and passion towards grid-integrity, grid-discipline. If your client continues with
this character assassination and threaten us any further, we will be constrained to initiate
legal proceedings against your client.
17. In view of the above observation, it is evident that DSM penalties in relation to renewable
energy forecasting and scheduing has been subject to the judicial scrutinity. It is
expected that SLDC and all its QCAs shall also maintain such standard or care and
transperancy while calculating the DSM penalties.
18. It is also to be noted that all the leading QCAs have faced hudge penalty in the state of
Rajasthan and M.P. It is also to be noted that IWPA being an organisation representing
majority of the wind IPPs have stated before the High Court of Rajasthan in their pentition
that none of the QCAs suggested by the Rajasthan SLDC is technically competent. A
grievance has been raised that the Rajasthan SLDC has given more weightage to the
financial capacity than their technical expertise, while selecting QCAs and none of them
have any expertise of forecasting 500 MW for a year.
19. Counsel representing IWPA also pointed out that though scheduling part is to be done by
the generators, but the same is totally dependent upon the forecasting to be provided by

11. Page 11 of 16
the QCAs. If the input for scheduling i.e. forecasting about the wind is improper or
inaccurate, the scheduling or the forecasting of the generation given by the generator is
bound to go wrong. According to the learned counsel for IWPA, the members of the
IWPA are sought to be penalized for the fault of QCA in not being able to correctly
forecast the weather or wind.
20. Highlighting the problems and lack of expertise/experience of the QCA, learned counsel
for the IWPA submitted that none of the QCAs are having experts or expertise to predict
or forecast the weather with accuracy.
21. In view of the above statement made by lawyer representing IWPA before the Hon’ble
High Court of Rajasthan, it is evident that the leading 4 QCAs have miserably failed to
perform its duty of wind & solar energy forecasting and scheduling.
22. Since there is no valid reasoning of the Notice, the Notice is illegal and intentional
probably due to the following facts: the RECONNECT is not interested in the law in the
interest of state-grid, grid-discipline, national-grid and grid-security. Further,
RECONNECT wants to illegally refrain or stop del2infinity to raise a voice for requirement
of grid-stability, grid-discipline, balance between grid-discipline and DSM penalty and to
ensure the IPPs stable growth in long run; and also throw out del2infinity out of the
competition to ensure its illegal profits and unjust enrichment.
23. Further, from the acts and deeds of RECONNECT, it sends a strong signal that
RECONNECT has become scared of transparent techno-economic analysis of data
available on SLDC website or public domain and would like to threat del2infinity to stop
any such analysis which would actually prove that RECONNECT has probably failed to
act as a QCA as well as forecasting agency and /or RECONNECT’s forecasting accuracy
is not as per acceptable limit. This is clearly an illegal and unscrupulous tactics of
RECONNECT to eliminate all kind of fair competition. However, in case RECONNECT
still tries to drag del2infinity in any unwarranted litigation, it shall be to RECONNECT’s
risk and cost and RECONNECT shall be solely liable to indemnify del2infinity for any
actual or threatened claims, losses, cost, damages etc. in this regard.
24. It is apparent that RECONNECT intends to take undue advantage and create monopoly
and to extract financial and other gains or unjust enrichment from IPPs on account of
IPPs being a bona fide law-abiding company. The mala fide and dishonest intentions of
RECONNECT are strongly evident in your Notice wherein despite del2infinity having
published public information as openly available, RECONNECT wish to stop all such
public information. In fact, the content of the said Notice is blatantly false and a deliberate
attempt to conceal your fallacies for the unjustified demands and hence exposes the
illegal intention of RECONNECT. While del2infinity vehemently denies each and every
allegation as alleged by RECONNECT in your Notice, del2infinity hereby cautions that
RECONNECT shall be held responsible for every malicious action initiated by
RECONNECT against del2infinity, that any such action shall be to RECONNECT’s risk
and cost and RECONNECT shall be solely liable to indemnify del2infinity for any claims,
losses, cost, damages etc. in this regard.

12. Page 12 of 16
25. In light of the abovementioned facts, it is humbly submitted that the Notice is nothing but
a device to unlawfully gain at the cost of del2infinity by exerting pressure on del2infinity to
raise its voice. It is vehemently stated that RECONNECT has been ill advised to issue
the Notice to del2infinity and is hereby advised to immediately withdraw the Notice.
26. In your entire Notice, you have consistently failed to highlight a single inaccuracy in any
report/ table that del2infinity has published, which is entirely based upon the SLDC’s
DSM report that were released on SLDC’s website, for which there is a strong public
interest in publication since the SLDC is a statutory body and moreover grid-discipline,
grid-stability is the necessary for public at large as pointed out in various Judgement by
Hon’ble Supreme Court.
You should also be aware that truth is an absolute defence to civil defamation.
In criminal defamation, you may like to remind yourself that there are several strong defences
available under section 499 of the IPC that would clearly apply in this case, such as:
a. an exception in the “conduct of any person touching any public question” (“It is
not defamation to express in good faith any opinion whatever respecting the conduct
of any person touching any public question, and respecting his character, so far as
his character appears in that conduct, and no further”),
b. “Imputation made in good faith by person for protection of his or other's
interests —It is not defamation to make an imputation on the character of another
provided that the imputation be made in good faith for the protection of the interests
of the person making it, or of any other person, or for the public good.”
c. Caution intended for good of person to whom conveyed or for public good.—It
is not defamation to convey a caution, in good faith, to one person against another,
provided that such caution be intended for the good of the person to whom it is
conveyed, or of some person in whom that person is interested, or for the public
good.
27. Additionally, for the offence of criminal defamation, an active mens rea, i.e., an intention
to defame an individual /entity must be established beyond reasonable doubt. It is an
established legal principle that a statutory public body such as the SLDC or it’s result or
SLDC appointed QCAs are open to fair criticism and scrutiny by members of the general
public.
28. Your attention is drawn to various judgments of the Supreme Court regarding the
governance of public bodies and their criticism. Additionally, the SC has even extended
the right of the general public at large to fairly criticise entities performing public functions
such as the SLDC or it’s result or SLDC appointed QCAs.
Your attention is also drawn to the plethora of judgments by the Supreme Court on the
freedom of the press and the fundamental rights relating to freedom of expression.

13. Page 13 of 16
29. A reading of the recent judgment of the SC in Shreya Singhal v. UOI establishes the
expansive freedom provided to the public media and general public in reporting fairly and
expressing an unhindered opinion. The present scenario clearly demonstrates a factually
supported table carried by a reputed research organization such as del2infinity. The team
members of del2infinity have already produced different technical and techno-economical
articles for academic and research purposes. Circulating or publishing any part or whole
of the article is only for academic and research purpose to understand the present
scenarios of renewable energy sector. The dissemination of techno-economic analysis
for renewable energy stakeholders should be judged in scientific and technical space.
The article list of del2infinity, related solar and wind energy, is attached here for your
understanding as Annex - A.
30. Merely because the RECONNECT or SLDC does not wish to be criticized regarding its
opaque manner of functioning, the laws governing defamation cannot be utilized to arm
twist the report, research article to refrain from expressing a justified opinion.
31. On top of the above, your client has absolutely failed to show any malice or motivation in
del2infinity's report / table / research article, other than del2infinity's intention to report /
table / research article the facts in a balanced manner and bring transparency to the
functioning SLDC or SLDC appointed QCAs, grid-stability, grid-discipline, and DSM
penalties, as set out above.
In light of the above, you have therefore completely failed to show any of the elements required
for defamation, either criminal or civil.
Nothing in this Notice shall prejudice any of del2infinity’s rights, entitlements or remedies and
shall not act as any express or implied, permanent or temporary waiver of any such rights or
remedies that may be available to us under the law, equity or otherwise, whether now or in
future, each of which are hereby expressly reserved. We further reserve our right to issue any
additional response or further amend the contents of this response or any other subsequent
notice, Notice, email, correspondence, etc. issued by us to you, at an appropriate juncture.
For the avoidance of doubt, this response will be published on the del2infinity’s website,
Linkedin, Facebook and del2infinity reserves the right to circulate this response
Most unapologetically yours
Thanking you,
Yours Faithfully,
For M/s del2infinity Energy Consulting Pvt. Ltd.
Abhik Kumar Das
Director

14. Page 14 of 16
Schedule – A
LIST OF PUBLICATION
Journal Publications:
1. “An analytical model for ratio-based analysis of wind power ramp events”, Abhik Kumar
Das, Sustainable Energy Technology and Assessments, Elsevier vol. 9, pp.49-54, March
2015
2. “An Empirical Model for Ramp Analysis of Utility-Scale Solar PV Power”, Bishal Madhab
Mazumdar, Md. Saquib, Abhik Kumar Das, Solar Energy, Elsevier, vol. 107, pp. 44-49,
September 2014
3. “Quantifying photovoltaic power variability using Lorenz curve”, Abhik Kumar Das,
Journal of Renewable and Sustainable Energy, AIP, vol.6 (3), June 2014
4. “Analytical derivation of equivalent functional form of explicit J–V model of an illuminated
solar cell from physics based implicit model”, Abhik Kumar Das, Solar Energy, Elsevier,
vol. 103, pp. 411-416, May 2014
5. “An Empirical Model of Power Curve of a Wind Turbine”, Abhik Kumar Das, Energy
Systems vol. 5(3), pp. 507-518, March 2014
6. “An Explicit J–V Model of a Solar Cell using Equivalent Rational Function Form for
Simple Estimation of Maximum Power Point Voltage”, Abhik Kumar Das, Solar Energy,
Elsevier, vol. 98(C), pp. 400-403, December 2013
7. “A Statistical Model for Wind Power on the Basis of Ramp Analysis”, Abhik Kumar Das &
Bishal Madhab Majumder. International Journal of Green Energy, 2013
8. “Analytical Expression of the Physical parameters of an Illuminated Solar Cell using
Explicit J-V Model”, Abhik Kumar Das, Renewable Energy, Elsevier vol. 52, issue 1, pp
95-98, April 2013
9. "Analytical Derivation of Explicit J–V Model of a Solar Cell from Physics based Implicit
Model", Abhik Kumar Das, Solar Energy, Elsevier, vol. 86, issue 1, pp 26-30, January
2012
10. "An Explicit J–V Model of a Solar Cell for Simple Fill Factor Calculation", Abhik Kumar
Das, Solar Energy, Elsevier, vol. 85, issue 9, pp 1906-1909, September 2011
11. "Analytical investigation of parabolic trough receiver performance with outer Vacuum
Shell",Premjit Daniel, Yashavant Joshi, Abhik K Das,Solar Energy, Elsevier, vol. 85,
issue 9, pp 1910-1914, September 2011

15. Page 15 of 16
12. "Analytical Derivation of the Closed-form Power Law J-V Model of an lluminated Solar
Cell from the Physics Based Implicit Model", Abhik Kumar Das and Shreepad Karmalkar,
IEEE Transactions on Electron Devices, vol. 58, No 4, pp 1176-1181, April 2011
Conference Proceedings:
1. “A Simple Functional Relationship of Error distribution of Day-Ahead Power Generation
Forecast and the Variability of Power Generation’’, 1st International Conference on
"Large-Scale Grid Integration of Renewable Energy in India endorsed by the Indian
Ministry of New and Renewable Energy as well as the Indian Ministry of Power and
organized by Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ), United
States Agency for International Development (USAID) and Energynautics, Germany,
2017
2. ‘Probability based Scenario Analysis and Ramping Correction Factor in Wind Power
Generation Forecasting’, Windergy 2017, New Delhi
3. ‘Higher Efficiency in O&M (Monitoring, forecasting and data management solutions)’,
India Solar Conference, April 6th & 7th-2017, BIEC, Bangalore”
4. 'Applicability of Error Limit in Forecasting & Scheduling of Wind & Solar Power in India’ ,
Compendium of Technical Papers Indian Smart Grid Week 2017, India Smart Grid Forum
& Government of India, Manekshaw Centre, New Delhi, 2017.
5. 'Forecasting and Scheduling of Wind and Solar Power generation in India' Abhik Kumar
Das, NTPC's Third International Technology Summit ‘Global Energy Technology Summit’
2016. [http://www.ntpcgets.com/abstract/finalpapers/619.pdf]
6. “A neural network based approach to predict high voltage Li-ion battery cathode
materials”, T Sarkar, A Sharma, A K Das, D Deodhare, M D Bharadwaj, , IEEE
International Conference on Devices, Circuits & Systems, (IEEE-ICDCS-14), March 2014
7. “A Simple Method for Determination of the Series Resistance of an Illuminated Solar Cell
from Experimental Data”, Abhik Kumar Das, IEEE 4th International Conference on
Electronics Computer Technology, (IEEE-ICECT-12), April 2012
8. "Determination of the Peak Power Voltage Using Explicit PLM of an Illuminated Solar
Cell", Abhik Kumar Das, IEEE International Conference on Devices, Circuits & Systems,
(IEEE-ICDCS-12), March 2012
Other Articles:
1. ‘Inability to Forecast is not the Disability of Regulation’, Saur Energy International June,
2019

16. Page 16 of 16
2. ‘Normalized parametric model for wind turbine power curve’, Indian Wind Power, vol. 3,
issue 1, April-May 2019
3. ‘Forecasting of Wind and Solar Power under Litmus Test’, Saur Energy International, vol
3 Issue 6, Feb 2019.
4. ‘Forecasting to mitigate backdown’, Saur Energy International, Feb, 2018
5. ‘Gaming or Forecasting’, Climate Samurai, January 2018
6. ‘Game of Forecast or Gaming in Forecast’, Saur Energy International, Dec 2017
7. 'Submitting Forecast & Schedule of Solar Power generation: Communication with SLDC’'
Saur Energy International, 2017
8. 'Generation Forecasting for the remaining life of WTG’’, WindPro-IWPA Magazine-May
2017
9. ‘Forecasting Daily Power Generation of Solar Plant’, Council of Power Utilities INDIA
POWER, Vol XXV No 2, Pg. 12, April - June 2017
10. 'Forecasting Solar Power Generation: Revise the Forecast when it requires', EQ
International Magazine, April 2017
11. ‘Applicability of Error Limit in Forecasting & Scheduling of Wind & Solar Power in India’'
has published in WINDPRO, IWPA Journal, March 2017
12. 'Forecasting Solar Power Generation in India: A Path of Unnecessary Revisions'
SaurEnergy, March 2017
13. 'Wind Power Forecasting in India' Abhik Kumar Das, WINDINSIDER, January 2017
14. 'Forecasting Solar Power Generation: Variability vs. Predictability' Abhik Kumar Das,
SolarQuarter, 6th February 2017.
15. 'Solar Power: Forecasting in India' Abhik Kumar Das, Saur Energy, December 2016.