Notice of Arbitration

Gold exploration and development company Panthera Resources Plc (AIM: PAT), with assets in West Africa and India, is pleased to announce that the Company's Australian subsidiary, Indo Gold Pty Ltd ("IGPL") has formally issued a Notice of Arbitration ("NoA") 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").

On 2 January 2024, the Company announced that its Australian subsidiary, Indo Gold Pty Ltd ("IGPL"), formally issued a Notice of Dispute to India in relation to the Bhukia project. As the parties have not reached an amicable settlement, IGPL has delivered the NoA to the Government of India. Under the Treaty, an arbitral tribunal is to be constituted within two months of delivery of the notice of arbitration.

While the statement of claim inclusive of the quantum of damages will be issued in due course, the Company refers to its announcement on 2 January 2024 which noted that on 30 September 2023 the Times of India reported that, based on information from the Geological Survey of India ("GSI") and the Additional Chief Secretary of Mines, the gold deposit at the site could be worth over US$1 billion.

In addition, the Company notes that the preferred bidder in the auction of the Bhuki-jagpura block by the Government of Rajasthan ("GoR") ("Auction") was selected with a 'Highest Final Price Offer' of 65.3%. In effect, the auction process binds the preferred bidder to a future payment schedule to the GoR of 65.3% of the value of mine production over the life of mine. We also note that the GSI has reported a mineral resource of 7.2 Moz of gold with a calculated inground value of US$16.7 billion based on the closing gold price of US$2,329/ounce on 24 June 2024. In addition to the Highest Final Price Offer, an upfront payment and a performance security of approximately ₹1000 (~US$120 million) must be provided by the preferred bidder on or before the completion of the Auction. Further details in this respect were announced by the Company's on 26 June 2024.

The Company will provide further updates as appropriate.

IGPL's Treaty Claims

The Company made its initial investment in Bhukia (through IGPL) in or around 2004. IGPL provided substantial 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 GoR. The Prospecting Licence Application over Bhukia was rejected by the GoR again in August 2018, despite an agreement and the GoR's promise to grant the Prospecting Licence, on various spurious and legally untenable grounds.

The acts and omissions by the GoR and India, culminating in the enactment of MMDR2021 and the dismissal in September 2023 of MMI's writ petition, amount to breaches by India of its obligations under the Treaty, including but not limited to, Article 3 (Promotion and Protection of Investments), Article 4 (Treatment of Investments) and Article 7 (Expropriation and Nationalisation). IGPL will be seeking damages from India.

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

Bhukia Background

The GSI published a report in 2014 after the completion of over 150 drill holes (Bulletin Series A (April 2014)), wherein it reported an indicated and inferred resource estimate of 6.7 Moz gold (excluding additional resources subsequently found through additional drilling by the GSI). The estimate was reportedly prepared according to the UNFC code. More recently, Rajasthan issued a gazette notification containing an updated resource estimate of 113.52 Mt at 1.96 g/t and 0.14% Cu, which amounts to 7.2 Moz of gold plus copper with accessory nickel and cobalt. It is not reported what code was followed in preparing the updated estimate.

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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