Proposal and Justification for the Recognition of AMTOI as a Self-Regulatory Organisation (SRO) for Multimodal Transport Operators.

[Shantanu Bhadkamkar]

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Dear Members of the Managing Committee,

We are writing to share the draft regulatory submissions prepared for the Directorate General of Shipping. The primary purpose of these submissions is the "Proposal and Justification for the Recognition of AMTOI as a Self-Regulatory Organisation (SRO) for Multimodal Transport Operators."

Through this initiative, we intend to formally submit our comprehensive proposal and legal justification for the recognition of the Association of Multimodal Transport Operators of India (AMTOI) as an SRO to assist in the development of multimodal transport and the registration of Multimodal Transport Operators (MTOs).

Transitioning towards an SRO model is a vital strategic step for our industry, moving us from a purely compliance-oriented framework to a mature, professionally governed ecosystem that promotes technical competence, market discipline, and swift dispute resolution.

For your review and feedback, we are enclosing the four attachments that will form the complete submission package. This includes the draft covering letter addressed to the DG Shipping, along with the three core annexures that detail our strategic and legal rationale:

1. Draft Covering Letter to the DG Shipping: Outlining our philosophy and formally presenting the proposal.

2. Annexure A: Strategic Rationale for AMTOI SRO: Detailing the institutional framework, governance philosophy, and proposed SRO architecture.

3. Annexure B: Statutory Provisions and Rules Relied Upon: Verbatim text of the relevant sections of the MMTG Act, 1993.

4. MMTG Act 1993: Notes on Competent Authority, Registration, and Delegation: Our legal brief demonstrating the viability of delegating competent authority functions to AMTOI under the existing Act.

We request that you kindly review the enclosed documents. Your insights, feedback, and formal approval will be highly appreciated before we proceed with the final submission to the Directorate General of Shipping.

We look forward to discussing this at our upcoming meeting.

With warm regards,

Shantanu Bhadkamkar

President, AMTOI

Thanks & regards

Shantanu Bhadkamkar

ATC Global Logistics Pvt. Ltd.

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