If i were representing EstrellaYour Honour,This matter is not simply a contractual disagreement or a clash between two mining entities. It is a clear case of legal entitlement and the enforcement of a mineral royalty that exists independently of the current operator's preferences or intentions.Estrella Resources Ltd holds a registered royalty interest over lithium within Tenement M15/87. That royalty exists whether the lithium is the primary target of extraction or not. The law is settled: if a co-existing ore body is disturbed, removed, or monetised in any way during mining operations, then the royalty holder is entitled to compensation — not at the convenience of the operator, but as a matter of legal right.The respondents — Auric Mining Ltd and its subsidiary — now seek to sidestep this obligation by suggesting that the lithium is of no value to them or that it may be discarded. But that is precisely the issue. They are not entitled to unilaterally determine the value, relevance, or treatment of a mineral over which they hold no unfettered rights.If lithium is disturbed in the course of mining gold, the operator becomes liable under the royalty arrangement. There is no ambiguity here. Any claim that they can simply shovel it aside or ignore it entirely is not supported by law, and if allowed to proceed unchecked, would set a dangerous precedent — one where mineral rights can be circumvented by convenience or corporate strategy.Estrella is not asking this court to award speculative damages. It seeks enforcement of a valid royalty agreement and recognition that any extraction or disturbance of lithium triggers a legal obligation to pay. It is a straightforward matter of title, obligation, and legal precedent.And so, Your Honour, the question before the court is not whether lithium is a priority for Auric — it is whether a party can mine a tenement, disturb a valuable resource, and deny the rightful royalty holder their due. If we allow that logic to stand, we effectively reduce mineral royalties to optional suggestions. That is not the law, and it cannot become the standard.We ask the court to uphold the rights that were granted, paid for, and recorded — and to send a clear message that such agreements are not only enforceable, but inviolable.
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