Bhukia Update

Gold exploration and development company Panthera Resources Plc (AIM: PAT), with assets in West Africa and India, provides the following update on the dispute with the Republic of India ("India") over the latter's breaches of its obligations under the 1999 Agreement between the Government of Australia and the Government of the Republic of India on the Promotion and Protection of Investments (the "Treaty").

As stated in the Company's announcement on 27 September 2023, the Company is focused on pursuing a claim against India under the Treaty. Accordingly, with the unconditional funding facility from LCM Funding SG Pty Ltd ("LCM Funding" or the "Funder") to support the claim under the Treaty secured, we are pleased to announce that the Company's Australian subsidiary, Indo Gold Pty Ltd ("IGPL") is now preparing to deliver a notice of dispute to the Government of India. This notice is anticipated to be delivered to the Government of India in the fourth quarter of 2023.

Following the delivery of the notice of dispute and in the absence of any meaningful correspondence in relation to this matter from the Government of India or if no amicable settlement is reached, IGPL will subsequently deliver a notice of arbitration to the Government of India. Any such notice of arbitration is anticipated to be delivered to the Government of India in the first quarter of 2024. Under the Treaty, an arbitral tribunal is to be constituted within two months of delivery of the notice of arbitration.

The Company is aware that on 30 September 2023 the Times of India reported that, based on information from the Geological Survey of India and the Additional Chief Secretary of Mines, the gold deposit at the site could be worth over US$1 billion. This valuation has not been independently verified by the Company. Accordingly, while at this stage the Company is not able to make any comments in relation to the potential quantum of damages that IGPL will claim from India, the Company will in due course, announce the actual quantum of damages that IGPL will claim from India when available. This quantum may differ from that reported by third parties, including but not limited to, the Times of India.

IGPL's Treaty Claims

The Company made its initial investment in Bhukia (through IGPL) in January 2005. IGPL provided all of the funding and managed the joint venture exploration programmes. The work programmes were carried out in accordance with government rules and regulations and reported on time and in a professional manner.

IGPL's right to be granted a Prospecting Licence over Bhukia, through its joint venture holding, has been consistently frustrated over an extended period by the Government of Rajasthan ("Rajasthan"). The Prospecting Licence Application over Bhukia was rejected by Rajasthan again in August 2018 on various spurious and legally untenable grounds.

IGPL's investment in Bhukia was expropriated by the actions of Rajasthan and India through multiple acts culminating in the enactment of MMDR2021 and the recent dismissal of MMI's writ petition, contrary to Article 7(1) of the Treaty. India has also breached the obligation to accord fair and equitable treatment to IGPL and its investment under Article 3 of the Treaty. IGPL will be seeking damages from India.

There can be no certainty as to the outcome of IGPL's Treaty claims.

Bhukia Background

The Geological Survey of India, an agency of the Government of India, published a report in 2014 after the completion of over 150 drill holes (Bulletin Series A (April 2014)), wherein it reported reserve/resource estimates of 6.7 Moz gold.

LCM Litigation Financing

On 25 August 2023, the Company announced that IGPL had secured up to US$13.6 million in litigation financing ("Facility") with LCM Funding SG Pty Ltd ("LCM Funding" or the "Funder"). LCM Funding is a subsidiary of Litigation Capital Management Limited ("LCM"), a firm quoted on the AIM Market of the London Stock Exchange. LCM is a leading global disputes funder with significant expertise in international arbitration and cross-border disputes, including bilateral investment treaty claims over mineral resource assets.

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