An Anecdote of Arbitration in Recent Years

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Abstract

The huge growth in the number of business disputes over the last few decades has paralleled the enormous increase in economic development of nations. As a result, alternative conflict resolution methods such as arbitration have become increasingly important for companies doing business in India as well as those doing business with Indian companies. . This article is an attempt to objectively analyse arbitration in India as a legal institution, keeping in mind the broader exploration between the quality of legal performance and economic progress. Arbitration as a method of Alternative Dispute Resolution has grown in popularity in India in recent years. International Commercial Arbitration has become increasingly important since India has reduced trade barriers and opened up trade. Arbitration has become a buzzword in today’s commercial contracts. The law gives the parties the option of entering into commercial agreements knowing that if there is a dispute, they can refer it to this easy, quick, convenient, and cost-effective approach instead of going through the lengthy and complicated procedures of a court. Both domestic and international arbitration are covered by the Act. This article focuses on domestic issues that also apply to major aspects of international arbitration. This article discusses pronouncements that have irrevocably altered the way arbitration would be conducted in India. The Supreme Court of India issued a number of rulings relating to the 1996 Arbitration and Conciliation Act in 2020 and 2021. In this research paper, the most well-known legal cases are briefly discussed.

  • GOVERNMENT OF MAHARASHTRA (WATER RESOURCES DEPARTMENT) V. M/S BORSE BROTHERS ENGINEERS & CONTRACTORS PVT. LTD., CIVIL APPEAL NO. 995 OF 2021[1]

A DELAY BEYOND 90 DAYS, 30 DAYS OR 60 DAYS IS TO BE CONDONED BY WAY OF EXCEPTION AND NOT BY WAY OF RULE

Bench: Justices RF Nariman, BR Gavai and Hrishikesh Roy

Appearances: Sandeep Sudhakar Deshmukh, Senior Advocate Aishwarya Bhati (ASG), Amalpushp Shroti, Senior Advocate Vinay Navare, Manoj Chouhan, Dr.Amit George

The Supreme Court overturned its 2019 decision in the case M/s NV International vs State of Assam, which had rigorously declared that a delay of more than 120 days in submitting appeals under Section 37 of the Arbitration and Conciliation Act 1996 could not be excused.

The Supreme Court has now ruled that submitting appeals under Section 37 after 90, 60, or 30 days, depending on the venue, might be excused. However, the Court included a stipulation that such delays should be the exception rather than the rule, given the Arbitration Act’s goal of fast claim settlement.

Back Story

Orders issued under Sections 9, 34, 16, and 17 of the Arbitration Act can be appealed under Section 37 of the Act. Unlike Section 34, Section 37 does not provide a time limit for filing an appeal.

In the NV International case, a two-judge bench comprised of Justices RF Nariman and S Ravindra Bhat extended the time limit for filing an appeal from Section 34 (which governs appeals against arbitration awards) to Section 37. According to Clause 34(3), an appeal against an arbitration award must be lodged within three months of the date of the award; the section also provides a thirty-day grace period, up to which a delay might be excused if adequate cause is shown. To put it another way, the appeal must be filed within 120 days (90+30).

In the NV International Case, the 120-day appeal period for arbitration awards was applied to appeals against orders under Section 37. However, in the matter of Government of Maharashtra against Borse Brothers Engineers and Contractors Pvt Ltd and related matters, a three-judge bench comprising Justices RF Nariman, BR Gavai, and Hrishikesh Roy has recently rejected NV International’s verdict.

The three-judge panel considered how the Commercial Courts Act and the Arbitration Act interact. The Commercial Courts Act, Section 13(1), states that appeals must be filed within 60 days, with no time restriction for forgiveness of lateness (unlike Section 34 Sub-section (3). This term will apply to arbitration cases with a commercial worth greater than the specified amount (above Rupees 3 Lakhs).

The Court further emphasised that, depending on the forum, the Limitation Act of 1963 provides varied time restrictions for filing appeals against orders.

Consider the following example:

If the appeal is to a High Court, the time is 90 days under Article 116(a).

If the appeal is to a higher court, the term is 30 days from the date of the order, according to Article 116(b).

If the appeal is from a High Court to a higher bench of the same court, the term is 30 days under Article 117.

Arbitration claims with a commercial value of less than Rs 3 lakhs will be subject to the time limits set out in Articles 116 and 117. Such arbitration cases will be rare, according to the Court, and the majority will be controlled by the Commercial Courts Act.

By virtue of Section 43 of the Arbitration Act and Section 29(2) of the Limitation Act, the Court recognized that the power to excuse delay under Section 5 of the Limitation Act extends to all of the foregoing instances. The argument that the Commercial Courts Act’s design precludes the use of Section 5 of the Limitation Act was rejected.

NV International was overruled for the following reasons:

The following reasons for overruling NV International were cited in Justice Nariman’s judgement.

First, NV International failed to notice the provisions of the Commercial Courts Act and is so per in curium.

Second, because the Commercial Courts Act sets a limitation time of 60 days rather than 90 days for filing appeals, the formula of 90 days plus 30 days and not afterward indicated in section 34(3) of the Arbitration Act no longer applies.

Third, the “bodily lifting” of Section 34(3) to Section 37 is unjustified because Section 13 of the Commercial Court contains no provision limiting the condonation of a period of delay beyond a specific point.

Advocate Amalpush Shroti’s arguments in this regard were found to be sound, according to the ruling.

“For all of these reasons, and in light of the compelling arguments advanced in these appeals, we believe that N.V. International (supra) was incorrectly decided and is thus overruled,” the Court stated.

Both opinions were written by Justice RF Nariman, which is unusual.

To what extent may a delay be tolerated:

Not content with overruling NV International, the court moved on to consider what the utmost amount of delay that can be tolerated could be.

“On one hand, we have the N.V. International (above) decision, which states that delays of more than 30 days cannot be excused, and on the other hand, we have an open-ended provision that allows any amount of delay to be excused if adequate cause is demonstrated. We must navigate a moderate ground between these two extremes “, the court remarked.

In this regard, the Court emphasised that the purpose and intent of both the Arbitration Act and the Commercial Courts Act was to expedite the resolution of claims.

“Given the goal sought to be achieved by both the Arbitration Act and the Commercial Courts Act, namely, the prompt resolution of disputes,” the Court held, “the word “sufficient reason” is not elastic enough to cover extended delays beyond the timeframe given by the appeal provision itself.”

The following is the dictum as stated in the judgement:

“Given the foregoing and the goal of speedy resolution sought under both the Arbitration Act and the Commercial Courts Act, a delay of more than 90 days, 30 days, or 60 days, respectively, for appeals filed under section 37 of the Arbitration Act that are governed by Articles 116 and 117 of the Limitation Act or section 13(1A) of the Commercial Courts Act, has to be tolerated; not by a way of an exception but by way of rule.

In a suitable case in which a party has otherwise acted honestly and without negligence, a short delay beyond that period may be excused at the discretion of the court, always bearing in mind that the opposite party may have acquired both in equity and justice, what may now be lost due to the first party’s inaction, negligence, or laches.”

The Court also rejected the argument that because

Section 37 does not clearly define a limitation term, the uniform period of limitation under Article 137 of the Limitation Act (3 years) should apply. Article 137’s expression “applications” cannot be interpreted as “appeals,” it said.

Furthermore, the Court stated that even in the rare cases when the economic value of the arbitration case is less than Rs 3 lakh, the purpose of expeditious resolution of disputes will govern appeals covered by Articles 116 and 117 of the Limitation Act.

“Even in the unlikely event that an appeal under section 37 of the Arbitration Act is for a sum less than three lakh rupees; when applications under section 5 of the Limitation Act are filed to condone delays beyond 90 days and/or 30 days, depending on whether Article 116(a), 116(b), or 117 applies, the main object of the Arbitration Act requiring speedy resolution of disputes would be the most important principle to be applied when applications under section 5 of the Limitation Act are filed to condone delays beyond 90 days and/or 30 days,” the judgement stated.

CHINTELS INDIA LTD. V. BHAYANA BUILDERS PVT. LTD., CIVIL APPEAL NO. 4028 OF 2020.[2]

AN APPEAL UNDER SECTION 37(1) (C) OF THE ARBITRATION ACT, 1996 WOULD BE MAINTAINABLE AGAINST AN ORDER REFUSING TO CONDONE DELAY IN FILING AN APPLICATION UNDER SECTION 34 OF THE ARBITRATION ACT, 1996 TO SET ASIDE AN AWARD.

Bench : Justices RF Nariman, Navin Sinha and KM Joseph.

Appearances : Advocate Rajshekhar Rao appeared for the appellant. Senior Advocate Mukul Rohatgi appeared for the respondent.

The Supreme Court has ruled that a decision refusing to excuse a delay in filing an appeal under Section 34 of the Arbitration and Conciliation Act 1996 might be appealed under Section 37 of the Act.

“…the question of law is answered by stating that an appeal under section 37(1)(c) of the Arbitration Act, 1996 would be maintainable against an order refusing to condone delay in filing an application under section 34 of the Arbitration Act, 1996 to set aside an award,” a bench of Justices RF Nariman, Navin Sinha, and KM Joseph observed.

This significant decision, which clarified a widespread misunderstanding, came in the case of Chintels India Ltd v Bhayana Builders Pvt Ltd, which was an appeal stemming from a Delhi High Court ruling that such an appeal was not maintainable.

The High Court had issued permission for appeal to the Supreme Court under Articles 133 and 134A of the Indian Constitution, recognising the gravity of the legal issue.

It is vital to highlight, according to the Supreme Court, that the phrase “setting aside or refusing to set aside an arbitral judgement” does not stand alone. The expression must be interpreted in conjunction with the following term: “under section 34.” Section 34 does not apply only to grounds established by that sub-section (2).

“Clearly, a literal reading of the provision would demonstrate that a refusal to set aside an arbitral award because delay has not been excused under sub-section (3) of section 34 would clearly fall under section 37(1)(c),” the SC remarked.

The SC went on to say that the fact that a plea referred to in sub-section (2) or (3) of section 16 is accepted gives rise to an appeal under section 37(2)(a). This would illustrate that when the Legislature wanted to refer to a portion of a section rather than the complete section, it did so. The fact that an arbitral award might be rejected to be set aside for refusing to condone delay under section 34(3) is strengthened by the language of section 37(1)(c), where the word “under section 34” relates to the full section and not just section 34(2), noted the Court.

The Court rejected the contention that appeals against rulings refusing to condone delay should not be heard since the Arbitration Act allowed for minimum judicial intervention.

The Court stated that the court cannot limit the scope of a provision where the text of the provision allows for such appeals to be brought.

“Section 37 of the Arbitration Act of 1996, without a doubt, provides a limited right of appeal. However, given the language of the clause as construed by us herein, it is not the province or duty of this Court to further limit such right by rejecting appeals that are in reality provided for “, according to Justice RF Nariman’s decision.

The Court distinguished the decisions in BGS SGS Soma JV. v. NHPC Limited and State of Maharashtra and Anr. v. M/s Ramdas Construction Co. and Anr. and BGS SGS Soma JV. v. NHPC Limited and State of Maharashtra and Anr (2017).

The Supreme Court upheld the appeal, overturning the Division Bench’s decision, and remanding the case to a Division Bench of the High Court of Delhi to determine if the Single Judge’s refusal to condone delay was correct.

  • M/S. INOX RENEWABLES LTD. V. JAYESH ELECTRICALS LTD., CIVIL APPEAL NO. 1556 OF 2021.[3]

THE NEW VENUE BECOMES THE SEAT OF THE ARBITRATION WHEN PARTIES CHANGE THE VENUE OF ARBITRATION BY MUTUAL AGREEMENT.

Coram: Justice RF Nariman, Hrishikesh Roy

Appearances: Senior Advocate Sachin Dutta for appellant; Senior Advocate Purvish Jitendra Malkan for respondent

When parties agree to modify the ‘venue/place of arbitration,’ the new venue/place becomes the ‘seat of the arbitration,’ according to the Supreme Court.

As a result, the arbitral proceedings will be heard by the courts at the new venue/location of arbitration.

M/s Inox Renewables Ltd v Jayesh Electricals Ltd was decided by a bench consisting of Justices Rohinton Fali Nariman and Hrishikesh Roy. The court adopted the precedent set in BGS SGS Soma JV vs NHPC Ltd, which found that in the absence of a contrary intention on the part of the parties, the venue of arbitration will be the legal seat of arbitration.

Back- Story and Facts:

Gujarat Fluorochemicals Ltd [“GFL”] and Jayesh Electricals Ltd signed a power transformer manufacturing and supply deal. This agreement included an arbitration clause that established the arbitration site as Jaipur, Rajasthan, and provided Rajasthan courts exclusive jurisdiction over any issues resulting from the agreement.

GFL eventually sold the entire company to Inox Renewables Ltd. GFL and Inox’s business transfer agreement had an arbitration clause that set Vadodara, Gujarat, as the location and gave Vadodara’s courts exclusive jurisdiction.

When a disagreement emerged between Inox and Jayesh Electricals, the latter applied to the Gujarat High Court for the appointment of an arbitrator under Section 11 of the Arbitration and Conciliation Act, 1996. As an arbitrator, the High Court nominated a former HC judge.

Despite a stipulation in the agreement that specified Jaipur as the arbitration location, the parties consented in front of the arbitrator to have the arbitration held in Ahmedabad. The arbiter conducted the arbitration in Ahmedabad, documenting the parties’ willingness to hold the proceedings there.

Jayesh Electricals received a favourable decision from the arbitrator. Inox challenged this in Ahmedabad’s Commercial Court under Section 34 of the Act. The Ahmedabad Court dismissed the appeal, stating that the Vadodara Court has exclusive jurisdiction under the company transfer agreement.

Inox appealed the decision to the Gujarat High Court. The High Court upheld the Ahmedabad Court’s decision that it lacked jurisdiction to hear the case. The High Court, on the other hand, stated that the court in Jaipur, not the court in Vadodara, had jurisdiction.

Inox appealed the High Court verdict to the Supreme Court once more.

Supreme Court Arguments

Inox’s Senior Advocate Sachin Dutta contended that Ahmedabad had become the arbitral tribunal’s legal seat because the parties agreed to relocate the site there. As a result, he claimed, the Ahmedabad court will have jurisdiction, citing the precedent set in BGS SGS Soma.

For Jayesh Electricals, Senior Advocate Purvish Jitendra Malkan contended that the location of arbitration can only be altered by a written agreement. As a result, the continuance of proceedings in Ahmedabad had no bearing on the Jaipur court’s exclusive jurisdiction. He also argued that the arbitrator’s finding that the venue was shifted from Jaipur to Ahmedabad by mutual consent was based solely on Section 20(3) of the Arbitration and Conciliation Act, 1996, because Ahmedabad was in fact a convenient location for the arbitration to take place, with the arbitration’s seat remaining in Jaipur.

The Supreme Court’s Decisions

The Court initially rejected the claim that a formal agreement was required to change the arbitration site. The Court noted that the arbitrator had recorded the parties’ assent to relocate the venue to Ahmedabad, which had not been contested or questioned.

“…the parties may jointly agree on a seat of arbitration and may modify the seat of arbitration by mutual agreement, which is recorded by the arbitrator in his award to which no party challenges,” the Court noted.

In addition, citing BGS SGS Soma, the Court concluded that once Ahmedabad was chosen as the location, the Ahmedabad Courts gained exclusive jurisdiction as the arbitration’s seat.

“This case demonstrates that when Ahmedabad is chosen as the seat, it acts as an exclusive jurisdiction clause, giving the Ahmedabad courts exclusive jurisdiction over the arbitration….

…it is obvious that the parties have agreed, by mutual consent, to substitute Ahmedabad for Jaipur as the place/seat of arbitration under Section 20(1) of the Arbitration and Conciliation Act, 1996.”

The Court observed in Indus Mobile Distribution Private Limited vs. Datawind Innovations Private Limited, (2017) 7 SCC 678, that “the venue” being shifted from Jaipur to Ahmedabad is really a shifting of the venue/place of arbitration with reference to Section 20(1), and not with reference to Section 20(3) of the Arbitration and Conciliation Act, 1996; as it has been said, Jaipur will no longer be the seat of arbitration, and Ahmedabad will now be the seat specified by the parties, rather than a meeting location.”

“Once the seat of arbitration is replaced by mutual agreement to be in Ahmedabad, the Rajasthan Courts are no longer vested with jurisdiction, as exclusive jurisdiction is now vested in the Courts in Ahmedabad, given the change in the seat of arbitration,” the Supreme Court said. The appeal was approved, with the Ahmedabad Court ruling that it had jurisdiction over the Section 34 petition.

  • DAKSHIN HARYANA BIJLI VITRAN NIGAM LTD. V. M/S NAVIGANT TECHNOLOGIES PVT. LTD., CIVIL APPEAL NO. 791 OF 2021[4]

THE PERIOD OF LIMITATION FOR FILING OBJECTIONS STARTS TICKING FROM THE DATE ON WHICH A SIGNED COPY OF THE FINAL AWARD IS RECEIVED BY THE PARTIES

A bench of Justices Indu Malhotra and Ajay Rastogi decided that there is only one date recognised by law, namely the day on which the parties get a signed copy of the final award, from which the time limit for raising objections begins to run. The Bench stated that the award can have no finality until it is signed, as signing the award confers legal effect and finality on the award. In arbitration procedures under the Indian Arbitration and Conciliation Act, 1996, the date on which the signed award is delivered to the parties is critical. The period of 30 days for filing an application under Section 33 for correction and interpretation of the award, or for an additional award, begins on this date; the arbitral proceedings end as provided by Section 32(1) of the Act; and the period of limitation for filing objections to the award begins under Section 34.

  • PASL WIND SOLUTIONS PRIVATE LIMITED V. GE POWER CONVERSION INDIA PRIVATE LIMITED, CIVIL APPEAL NO. 1647 OF 2021[5]

THERE IS PARTY AUTONOMY IN DESIGNATING A SEAT OF ARBITRATION OUTSIDE INDIA EVEN WHEN BOTH PARTIES HAPPEN TO BE INDIAN NATIONALS

Even where both parties are Indian nationals, a bench of Justices Rohinton Fali Nariman, B.R. Gavai, and Hrishikesh Roy concluded that party autonomy in designating a seat of arbitration outside India remains unaffected. Under both Parts I and II of the Arbitration Act, section 10(1) of the Commercial Courts Act applies to foreign commercial arbitrations, as well as applications or appeals originating from them. The definition of “international commercial arbitration” in section 2(1)(f) of the Arbitration will govern when petitions or appeals arise out of such arbitrations under Part I, when the site of arbitration is in India. When it comes to Part II, “international commercial arbitration” refers to a site of arbitration that is international in the sense that it takes place outside of India. There is no conflict between section 10 of the Commercial Courts Act and the explanation to section 47 of the Arbitration Act, because an arbitration resulting in a foreign award, as defined under section 44 of the Arbitration Act, will only be enforceable in a High Court under section 10(1) of the Commercial Courts Act, and not in a district court under section 10(2) or sub-section 3 of the Commercial Courts Act 10.

BHARAT SANCHAR NIGAM LTD. & ANR. V. M/S NORTEL NETWORKS INDIA PVT. LTD., CIVIL APPEAL NOS. 843-844 OF 2021

THE PERIOD OF LIMITATION FOR FILING AN APPLICATION UNDER SECTION 11 OF THE ARBITRATION AND CONCILIATION ACT WOULD BE GOVERNED BY ARTICLE 137 OF THE FIRST SCHEDULE OF THE LIMITATION ACT, 1963.

The period of limitation for submitting an application under Section 11 of the Arbitration and Conciliation Act would be governed by Article 137 of the First Schedule of the Limitation Act, 1963, according to a bench of Justices Indu Malhotra and Ajay Rastogi. The statute of limitations will begin to run on the date that the arbitrator is not appointed. . The Court further proposed that Parliament alter Section 11 of the 1996 Act to include a time restriction for filing an application under this provision, which would be consistent with the goal of rapid resolution of arbitration proceedings. In rare and extraordinary instances, where the claims are presumptively time barred and it is clear that no disagreement exists; which the court may refuse to accept.

  • M/s. N.N. GLOBAL MERCANTILE PVT. LTD., V. M/s. INDO UNIQUE FLAME LTD. & OTHERS, CIVIL APPEAL NOS. 3802 – 3803/2020[6]

THE NON-PAYMENT OF STAMP DUTY ON THE COMMERCIAL CONTRACT WOULD INVALIDATE EVEN THE ARBITRATION AGREEMENT, AND RENDER IT NON-EXISTENT IN LAW, AND UN-ENFORCEABLE, IS NOT THE CORRECT POSITION IN LAW

The findings in SMS Tea Estates Pvt. Ltd. v. M/s. Chandmari Tea Co. Pvt. Ltd. and Garware Wall Ropes Limited v. Coastal Marine Constructions and Engineering Limited were upheld by a bench of Justices Dr Dhananjaya Y Chandrachud, Indu Malhotra, and Indira Banerjee; that failure to pay stamp duty on a business contract would render the arbitration agreement null and void in law, and hence unenforceable, is not the right legal position. The question before the Bench was whether the statutory bar in Section 35 of the Indian Stamp Act, 1899, which applies to documents chargeable with Stamp Duty under Section 3 read with the Act’s Schedule, would also render the arbitration agreement contained in such an instrument, ,……which is not chargeable to stamp duty payment, as being non-existent, unenforceable, or invalid, waiting stamp duty payment on the substantive contract instrument, to be authoritatively resolved by a Constitution bench of five Supreme Court judges.

  • BHAVEN CONSTRUCTION V. EXECUTIVE ENGINEER SARDAR SAROVAR NARMADA NIGAM LTD. & ANR., CIVIL APPEAL NO. 14665 OF 2015[7]

THE POWER OF THE HIGH COURTS UNDER ARTICLE 226 AND 227 OF THE CONSTITUTION OF INDIA TO INTERFERE WITH AN ARBITRATION PROCESS NEEDS TO BE EXERCISED IN EXCEPTIONAL RARITY

A three-judge panel led by Justices N.V. Ramana, Surya Kant, and Hrishikesh Roy concluded that it is advisable for a judge not to exercise discretion in allowing judicial intervention outside of the framework provided by an enactment. The Bench concluded that the High Court’s jurisdiction to intervene in an arbitration procedure under Articles 226 and 227 of the Indian Constitution should only be used in extreme circumstances, such as when one party is rendered helpless by the statute or when one of the parties acts in bad faith. The Court’s high bar is in line with the legislative objective to make arbitration fair and efficient. The Bench also overturned a Gujarat High Court decision by admitting a writ petition challenging the arbitrator’s jurisdiction.

  • UNITECH LIMITED & ORS. V. TELANGANA STATE INDUSTRIAL INFRASTRUCTURE CORPORATION (TSIIC) & ORS., CIVIL APPEAL NO. 317 OF 2021[8]

PRESENCE OF AN ARBITRATION CLAUSE DOES OUST THE JURISDICTION UNDER ARTICLE 226 IN ALL CASES

While exercising jurisdiction under Article 226, a bench of Justices led by Dr Dhananjaya Y Chandrachud and MR Shah observed that the Court is entitled to inquire whether the State’s or its instrumentalities’ behaviour is arbitrary or unjust, and therefore in violation of Article 14. Article 226 jurisdiction is an important constitutional safeguard against arbitrary use of state power or abuse of authority. The Court further stated that when deciding whether or not to exercise jurisdiction in a contractual dispute, the Court must avoid contested questions of fact that would require an evidentiary judgement requiring a trial. The jurisdiction of Article 226 cannot be revoked solely because the issue concerns a contractual matter. This is for the simple reason that the State and its instrumentalities are not free from the obligation to act honestly just because they have entered the sphere of contract in their economic activities. The Bench found that the presence of an arbitration provision did not obviate Article 226 jurisdiction in all situations; nonetheless, whether or not a public law remedy can be justified must be determined case by case.

  1. AMWAY INDIA ENTERPRISES PVT. LTD. V. RAVINDRANATH RAO SINDHIA & ANR., CIVIL APPEAL NO. 810 OF 2021[9]

IF ONE OF THE PARTIES IS EITHER A FOREIGN NATIONAL, OR HABITUALLY RESIDENT IN ANY OTHER COUNTRY, THE ARBITRATION BECOMES AN INTERNATIONAL COMMERCIAL ARBITRATION

Whatever the transaction between the parties is, if it is entered into between persons who are either foreign nationals or usually residing in any country other than India, a bench of Justices Rohinton Fali Nariman and B.R. Gavai held that it is void; regardless matter whether the individual, body corporate, or government of a foreign country conducts business in India through a business office in India, the arbitration becomes an international commercial arbitration.


[1] Government of Maharashtra vs Borse Brothers Engineers and Contractors Pvt Ltd LL 2021 SC 170

[2]CHINTELS INDIA LTD. V. BHAYANA BUILDERS PVT. LTD LL 2021 SC 77

[3] M/s Inox Renewables Ltd v Jayesh Electricals Ltd LL 2021 SC 219

[4] Dakshin Haryana Bijli Vitran Nigam Ltd. Vs M/S Navigant Technologies Pvt Ltd. LL 2021 SC 126

[5] PASL Wind Solutions Private Limited vs. GE Power Conversion India Private Limited LL 2021 SC 226

[6] N.N. Global Mercantile Pvt Ltd vs. Indo Unique Flame Ltd LL 2021 SC 13

[7] Bhaven Construction vs. Executive Engineer Sardar Sarovar Narmada Nigam Ltd LL 2021 SC 7

[8] UNITECH Limited vs. Telangana State Industrial Infrastructure Corporation LL 2021 SC 92

[9] Amway India Enterprise Pvt Ltd vs. Ravindranath Rao Sindhia and Anr. 2021 SCC SC 171

Author: Abhishek Bhardwaj, Amity Law School, Noida

Editor: Kanishka VaishSenior Editor, LexLife India.

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