First of all in fetching the entire instruction , we need :
No of memory references = (4 + 2 + 1 + 1 + 4 + 1)
= 13
But each memory reference takes 4 cycles , so no of cycles = 13 * 4 = 52
Now coming to memory reference in operand fetch and writeback , we have 3 such operands or result which are in direct addressing mode and 2 in indirect addressing mode..So
No of references here = 2*2 + 3 = 7
So no of cycles = 7 * 4 = 28 cycles
So total cycles required for program execution = 52 + 28 = 80 cycles..
There is no ALU operations involved if u go by meaning of the instruction given in the question although ADD etc have been used..
So time taken = 80 * 1 / (2 GHZ)
= 40 ns
Hence 40 ns should be the correct answer..So the options should be corrected..