Panthera Resources

Panthera Resources Plc (“Panthera” or the “Company”) is a London-listed natural resources company whose principal asset is a USD 1.58bn arbitration claim against the Republic of India (“India”) filed by the Company’s Australian subsidiary Indo Gold Pty Ltd (“IGPL”). The claim is filed under the Australia-India Bilateral Investment Treaty (“BIT”) and concerns the Bhukia gold deposit in Rajasthan, where India withheld the Company’s prospecting licence for around 15 years before auctioning the deposit to a domestic buyer in 2024.

On 26 October 2026, the Company announced that India had filed its Rejoinder on 23 October 2026, the final written submission in Phase One of the arbitration, the phase that decides whether India is liable and on what principles any compensation is to be calculated. The announcement follows an equity raise of approximately GBP 2.69m in September 2026, the refinancing of the Company’s litigation funder, Litigation Capital Management (“LCM”), and a maiden Exploration Target at the Bido gold project in Burkina Faso in October 2026.

Developments Since the Initial Equity Research Report

• Written phase of Phase One completed on schedule
• Phase One Hearing confirmed for 14–19 December 2026
• GBP 2.69m equity raise narrows the modelled funding gap
• LCM refinanced through 2030, removing a funding risk
• Exploration Target of 0.7–1.6 Moz defined at Bido

Summary

The period since Analyst Group’s equity research report on 16 July 2026 has delivered the two procedural steps that remained before the Phase One Hearing, with Panthera’s Reply filed on 17 July 2026 and India’s Rejoinder on 23 October 2026, both in line with the procedural calendar set in October 2025. The hearing at the Peace Palace on 14–19 December 2026 and the oral closing submissions on 11 January 2027 are therefore confirmed, and the timeline underpinning Analyst Group’s Base scenario, with a liability decision estimated for August 2027, remains intact.

The hearing is the principal near-term catalyst in Analyst Group’s investment case. It is the first time the two sides argue the case in person before the three-member tribunal, after a process conducted entirely on paper, where a favourable ruling would confirm liability and set the framework for the award, with the amount itself determined in a second, shorter phase. In parallel, the two funding uncertainties flagged in July have both been addressed. The Company raised approximately GBP 2.69m in equity in September 2026. LCM’s lender extended and increased its facility to December 2030, which secures the non-recourse funding of the claim through and beyond the assumed cash collection date in July 2029.

Taken together, Analyst Group sees no reason to revise the inputs of the Base scenario, which values the claim as a probability-weighted present value and, together with the West African assets, gives an equity value of USD 302m, or approximately GBp 82 per share (July 2026: USD 287m and GBp 81.9). The increase reflects the shorter time to the assumed cash collection date, which offsets the dilution from the September placing.

At the latest closing price of GBp 21.8, Panthera’s market capitalisation of approximately USD 80m corresponds to 5% of the USD 1.58bn claim and 27% of the Base scenario equity value, a discount that Analyst Group considers unwarranted given the strength of the case and expects the discrepancy to narrow as the hearing approaches.

Beyond the arbitration there is a set of smaller catalysts: the exploration target at Bido, the pending Kalaka licence renewal and the intended restructure of the West African portfolio, which the Company has communicated it will pursue assuming that the Kalaka licence is renewed. In Analyst Group’s view, November 2026 to January 2027, with the Phase One Hearing at its centre, is the most eventful period for the investment case since the claim was filed in May 2025.

Written Phase Completed on Schedule Ahead of the December Hearing

India filed its Rejoinder on the Merits and Principles of Compensation on 23 October 2026, the final written submission of Phase One, in line with the procedural calendar announced by the Company on 29 October 2025. Both parties have met every deadline set by the tribunal since October 2025, and the remaining steps in Phase One are the hearing on jurisdiction, the merits and the principles of compensation at the Peace Palace in The Hague on 14–19 December 2026, followed by oral closing submissions on 11 January 2027. Precise quantum calculations are reserved for Phase Two, should IGPL prevail in Phase One. In Analyst Group’s view, the completion of the written phase removes the main near-term timing risk to the Base scenario, which estimates a liability decision in August 2027, a quantum award in July 2028 and cash collection in July 2029.

IGPL’s claim is that India engaged in unfair and arbitrary treatment of its investment and indirectly expropriated Bhukia. Having invested in and co-ventured with the original explorer of the deposit, IGPL secured a right to the prospecting licence, which India left undecided for around 15 years. A 2021 amendment to the national mining law extinguished that right and required compensation, which India did not pay. The State then auctioned the deposit to a domestic buyer in June 2024. IGPL argues that this breached the BIT’s fair and equitable treatment standard and amounted to expropriation without compensation at fair market value. The quantum of USD 1.58bn was set by independent mining and damages experts, anchored on India’s own auction in 2024, in which the buyer committed to USD 120m in upfront and guaranteed payments plus a 65.3% royalty on all future production from a deposit that the Geological Survey of India estimates at 7.2 Moz, equivalent to approximately USD 29bn of gold in the ground at the current gold price.

We believe that India’s defence will primarily focus on two threads. The first is centred on Indian law and holds that the licence application was flawed from the outset, such that IGPL and its co-venturer never held protected prospecting and mining licence rights. Besides rebutting this argument under Indian law, Panthera also has responsive arguments based on international law, which protects it from arbitrary, unfair and non-transparent treatment brought about by the vagaries in Indian law. India’s second general argument is that, even if a right existed, the project was early stage and therefore of little compensable value. Panthera’s position is that the value was tangible and considerable despite its early stage, as India’s own auction demonstrated, and that India should not profit from the value of such a significant asset that India’s own breach created.

In Analyst Group’s assessment, the auction is the decisive piece of evidence on quantum. It established a market price for the deposit irrespective of its development stage, and because the block was auctioned together with a mining licence, India can hardly argue that social or regulatory obstacles would have prevented development.

The claim of USD 1.58bn corresponds to approximately 5% of the in-ground value of the deposit at the current gold price, which Analyst Group regards as a conservative starting point. Analyst Group does not, however, assume that the full claim is awarded. Tribunals rarely award the full amount claimed, and the Base scenario applies a 40.4% recovery rate, derived from investor-state precedent, India’s prior adverse treaty awards and market-based cases to the claim including interest. On that basis, a favourable ruling may imply gross proceeds of approximately USD 780m, of which approximately USD 570m is estimated to accrue to shareholders after the funder’s entitlement and other deductions. Weighted at the 72.5% probability of success and discounted to today, this is the USD 281m that the arbitration contributes to the Base scenario equity value of USD 302m. The arguments disclosed to date fall within this framework, and Analyst Group leaves both the probability of success and the recovery rate unchanged.

Equity Raise Secures Funding and Independence Through the Hearing

On 3 September 2026, Panthera raised approximately GBP 2.69m before expenses through an oversubscribed placing and subscription of 15,362,780 new shares at GBp 17.5, a discount of approximately 16.7% to the closing price of GBp 21.0 on 2 September 2026. The proceeds are earmarked for corporate overheads, legal and advisory costs and general working capital, including arbitration costs if required. The dilution of approximately 5.6% is, in Analyst Group’s view, a modest price for carrying the claim through the hearing without a further raise. Furthermore, with the time to estimated cash collection nearing, the accretion in the present value of the claim since July has more than offset the dilution.

The raise also directly addresses the funding gap identified in Analyst Group’s equity research report. Cash stood at USD 2.1m on 31 March 2026, and the annual burn was slightly above the USD 2.0m assumed in the initiation. Including the net placing proceeds, Analyst Group estimates cash of approximately USD 4.6m on 30 September 2026, which is estimated to fund the Company until the start of 2029 and reduces the remaining gap to the assumed July 2029 cash collection date to under USD 1m, before any potential proceeds from the West African restructure. The Company does not intend to return to the equity market before a decision by the tribunal, and has stated that the raise complements, rather than replaces, the non-recourse LCM facility, whose uncertainty earlier in 2026 has since been resolved, as discussed below.

LCM Refinancing Removes the Funder Risk Flagged in July

In our equity research report, we flagged that LCM, which funds IGPL’s legal costs through a non-recourse facility of USD 13.6m, was in a strategic review and operating on covenant waivers from its lender, Northleaf. That uncertainty has since been resolved, as Northleaf has extended its credit facility to LCM to December 2030 and increased it from USD 100m to USD 125m. LCM’s existing cases, including Panthera’s, are funded to conclusion, no new investments are made, and realised proceeds repay Northleaf.

In Analyst Group’s view, the refinancing is positive for Panthera. The extension to December 2030 covers the entire assumed award path, including Analyst Group’s estimated July 2029 cash collection date. LCM is incentivised to see remaining cases through, and the terms of IGPL’s facility, and therefore LCM’s estimated entitlement in the Base scenario, are unchanged.

Bido Moves From Optionality Toward a Tangible Asset

On 8 October 2026, Panthera reported drilling results from the 80%-owned Bido permit in Burkina Faso, where the best intersection to date returned 56 m at 1.16 g/t gold, including 28 m at 2.04 g/t. On the back of these results, the Company has defined a maiden Exploration Target of 0.7 to 1.6 Moz of gold. In our equity research report, we treated Bido as optionality outside the sum-of-the-parts valuation due to the early-stage nature of the asset, and the Exploration Target does not change that treatment.

However, at an assumed USD 5/oz valuation, half the multiple applied to Kalaka’s inferred resource by Analyst Group, Panthera’s 80% share of the target range gives USD 3m to 6m, which indicates the scale of that optionality. The next phase, infill drilling in 2027 toward a JORC-compliant resource, is intended to be funded by a partner. In Analyst Group’s view, the main significance of the results is that a drill-defined target is a materially more marketable asset in partner discussions.

West African Restructure Pending Kalaka Licence Renewal

The intended restructure of the West African assets, noted in our initial equity research report, has progressed to active discussions with a number of interested parties. The portfolio comprises the Cascades and Bido projects in Burkina Faso and the Kalaka and Bassala projects in Mali. Of all the projects, Cascades and Kalaka carry a combined USD 20.4m in Analyst Group’s valuation, while all four incur ongoing holding costs. The gating item is the renewal of the Kalaka exploration licence in Mali, which is still pending. Analyst Group’s valuation of Kalaka at USD 6.4m assumes renewal. A refusal would reduce the asset to a distressed value, but at approximately 2% of Base scenario equity value, the overall impact would be limited.

Rather than a farm-out, where a partner earns a share of a project by funding exploration, the Company’s preferred outcome is to transfer the West African assets to another listed company in exchange for shares in that company. In Analyst Group’s view, this structure would lower the annual burn, keep Panthera’s exposure to the assets, and give Panthera a holding the Company can sell in parts. Analyst Group estimates that the Company is funded to the start of 2029, but the assumed cash collection date is July 2029. Any delay in the award or enforcement would thus extend the period to be funded. A liquid holding would therefore serve as a buffer against that risk without the need to issue new shares, in line with the capital need flagged in Analyst Group’s equity research report.