A. The Defendant is the founder of the B market (hereinafter “instant market”), and the Plaintiff is a wholesale market corporation designated to wholesale or purchase goods of the instant market by listing them by being entrusted by the Defendant from the shipper.

B. On March 16, 2018, the Defendant notified the Plaintiff of an administrative disposition regarding the Plaintiff’s violation of the Act on Distribution and Price Stabilization of Agricultural and Fishery Products (hereinafter “Agricultural and Fishery Products Distribution Act”) and relevant regulations as a result of the business inspection conducted in March 16, 2017, and imposed a penalty surcharge of KRW 19,800,000 on the Plaintiff on April 17, 2018, as indicated in the attached disposition details.

(hereinafter referred to as the "disposition of this case" and specified each disposition of a warning as the "disposition of a warning") / [based on recognition] without dispute, each entry in the evidence Nos. 1 and 2, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) The imposition of a penalty surcharge among the instant disposition is that the payment was not made in part due to the deviation from the individual of the certified auctioneer under his jurisdiction, and the Plaintiff is the Seoul Metropolitan Government Agricultural and Fishery Food Corporation (hereinafter “Agricultural and Fishery Food Corporation”).

(2) The Plaintiff was not aware of the fact that the shipper was not aware of the fact that the payment was made partially before the direction, and the Plaintiff was unable to expect the performance of the obligation, or there is a justifiable reason for not being able to criticize the violation of the legal obligation, and even if not, there is no increase in the Plaintiff and there are many grounds for reduction, the Enforcement Rule of the Agricultural and Fishery Marketing Act (hereinafter

(2) The warning disposition No. 1 does not exist by the Defendant, which is the premise of the disposition, and the Plaintiff entered all the matters to be stated in the sales ledger as required by the management guidelines of the sales slip, and the brand name in the sales ledger.