ValkyaEditorial

Arbitration — 40 Valkya Editorial digests

Arbitration under the 1996 Act — arbitrability, the appointment of arbitrators under Section 11, the seat-versus-venue question, interim measures under Section 17, and the limited grounds to set aside or refuse enforcement of an award under Sections 34 and 37.

High CourtHigh Court of Bombay

Rashmi Realty Builders v. Pagariya (2024): a RERA dispute cannot be sent to arbitration

The Bombay High Court held that a dispute falling within the Real Estate (Regulation and Development) Act, 2016 is non-arbitrable, and that an arbitration clause in a builder-buyer arrangement cannot oust the jurisdiction of the Real Estate Regulatory Authority. Justice Madhav J. Jamdar applied the Booz Allen and Vidya Drolia non-arbitrability framework to a homebuyer's refund claim.

Valkya Editorial··6 min
Supreme CourtSupreme Court of India

Bhartia Infra Projects v. Vishwa Samudra Engineering (2026): an exclusive-jurisdiction clause prevails over a dual seat-venue choice in arbitration

The Supreme Court held that where an arbitration agreement names two possible seats or venues but also confers exclusive jurisdiction on a specific court, the exclusive-jurisdiction clause governs and forum non conveniens does not apply to displace the chosen court. A digest of the facts, the holding, and what it means for drafting arbitration clauses.

Valkya Editorial··7 min
High CourtHigh Court of Judicature at Bombay

Oil Field Instrumentation v. Xcalibur Multiphysics (2026): confidentiality cannot shield an alleged breach of JV exclusivity from scrutiny

The Bombay High Court set aside a Section 17 order that had excused a party from producing the very contract said to breach a joint-venture non-compete, holding that a confidentiality clause inside an allegedly offending agreement cannot immunise that agreement from disclosure. A digest of the facts, the holding on confidentiality versus court-directed disclosure, the Section 17 set-aside and remand, and what it means for arbitration practice.

Valkya Editorial··8 min
High CourtHigh Court of Kerala

Purushothaman Thitta v. Pothan Rajan (2026): why company restructuring and shareholder oppression are not arbitrable

The Kerala High Court held that a claim to restructure companies and divide their assets under a private MOU falls within the NCLT's exclusive jurisdiction under Sections 241–242 of the Companies Act, 2013, and is non-arbitrable. A digest of the facts, the Vidya Drolia / Booz Allen arbitrability test, and the Court's use of Article 227.

Valkya Editorial··8 min
High CourtHigh Court of Delhi

Black Gold Resources v. International Coal Ventures (2025): invoking an unconditional bank guarantee

A single judge of the Delhi High Court vacated an interim stay and refused to restrain the encashment of a USD 10.53 million unconditional performance bank guarantee, holding that a contractor's dispute over the legality of contract termination is no ground to injunct an autonomous guarantee. A digest of the facts, the Section 9 question, and the narrow fraud and special-equities exceptions restated in a cross-border India–Mozambique setting.

Valkya Editorial··7 min
Supreme CourtSupreme Court of India

DMRC v. DAMEPL: a curative petition unwinds a patently illegal award

On 10 April 2024, a three-judge bench allowed DMRC's curative petition and set aside an arbitral award that, with interest, had swelled to about ₹8,000 crore, holding that the Court's earlier interference had restored a patently illegal award and caused a miscarriage of justice.

Valkya Editorial··9 min
Weekly Report

Arbitration in May 2026: the post-Gayatri-Balasamy modification line, the stamping discipline, and the Section 9 reset

The May 2026 cycle in Indian arbitration law has produced three doctrinal threads running in parallel — the first substantial post-Gayatri Balasamy applications of the Section 34 limited-modification corridor (Bhupesh Bhayana, Gujarat Water Supply, Paramount Learning), the continuing stamping discipline post-In Re Interplay (Tarini Prasad Mohanty), and the Section 9 reset for the unsuccessful party at the post-award stage (Home Care Retail Marts). Read alongside the Section 12(5) appointment discipline (PTC Techno, Andhra Pradesh v. Dataevolve), the Cox & Kings group-of-companies extension (ASF Buildtech, Ocean View Properties), the limitation question (West Bengal v. B.B.M.), and the institutional developments (CIAC launch, IIAC empanelment suspension, pending 2024 Amendment Bill), the cycle discloses the operational architecture within which Indian arbitration practice now operates.

Valkya Editorial··14 min
LandmarkSupreme Court of India

BALCO v. Kaiser Aluminium: how the Constitution Bench severed Part I from foreign-seated arbitrations

On 6 September 2012, a five-judge Constitution Bench of the Supreme Court overruled Bhatia International and Venture Global and held that Part I of the Arbitration & Conciliation Act, 1996 applies only to arbitrations seated in India. The judgment prospectively rewrote the boundary between domestic-court supervision and party-chosen foreign seats, aligned Indian law with the UNCITRAL Model Law and the New York Convention, and laid the analytical scaffolding on which Indus Mobile, BGS SGS Soma JV and PASL Wind Solutions were later built.

Valkya Editorial··13 min
Supreme CourtSupreme Court of India

Booz Allen v. SBI Home Finance: the foundational taxonomy of arbitrability and its six-category illustrative list

On 15 April 2011, a two-judge bench of the Supreme Court — Justice R.V. Raveendran writing — supplied the first authoritative analytical framework for arbitrability under the 1996 Act. The judgment installed the in rem / in personam taxonomy, enumerated six classic non-arbitrable categories, and held that a suit for enforcement of a mortgage by sale under Section 67 of the Transfer of Property Act 1882 is non-arbitrable. Booz Allen is the foundational anchor on which Vidya Drolia's four-fold test and Cox & Kings's group-of-companies doctrine were later built.

Valkya Editorial··14 min
Supreme CourtSupreme Court of India

Centrotrade Minerals v. Hindustan Copper: how the Supreme Court settled the validity of two-tier arbitration in India

On 15 December 2016, a three-judge bench of the Supreme Court — Madan B. Lokur, J. (authoring), R.K. Agrawal, J. and Dr D.Y. Chandrachud, J. — held that a two-tier arbitration clause, providing for first-tier arbitration in India and an appellate second-tier ICC arbitration in London, is valid and permissible under the Arbitration and Conciliation Act 1996. The bench resolved a decade-long impasse left by a 2006 two-judge split between Sinha J. and Tarun Chatterjee J., and reaffirmed party autonomy as the lodestar of the 1996 Act. A close reading of the bench, the contract, the doctrinal contribution on appellate arbitration, and the post-judgment arc through Centrotrade III (June 2020) which held the resulting foreign award enforceable under Part II.

Valkya Editorial··14 min
LandmarkSupreme Court of India

Cox & Kings and the group-of-companies doctrine: a Constitution Bench re-anchors the law of non-signatories

On 6 December 2023 a five-judge Constitution Bench of the Supreme Court, in Cox & Kings Ltd v. SAP India Pvt Ltd, affirmed the group-of-companies doctrine as a valid and continuing part of Indian arbitration jurisprudence but re-anchored its legal foundation — moving it away from the textual hook of 'claiming through or under' in Sections 8 and 45, on which Chloro Controls had rested it, and into the consent-based definition of 'party' in Section 2(1)(h) read with Section 7. A close reading of CJI Chandrachud's judgment, the five-factor consent inquiry, the prima facie / final-call division of labour between referral court and tribunal, and what the doctrine looks like in post-Cox & Kings practice.

Valkya Editorial··14 min
Supreme CourtSupreme Court of India

Emaar MGF v. Aftab Singh: the arbitration clause does not displace the consumer forum

The Supreme Court's review judgment of 10 December 2018, authored by Justice Ashok Bhushan for a two-judge bench (Bhushan + U.U. Lalit JJ), holds that the 2015 amendment to Section 8 of the Arbitration and Conciliation Act 1996 — making reference to arbitration mandatory 'notwithstanding any judgment, decree or order' — does not displace the regime of special legislation that creates non-arbitrable in rem statutory remedies. An arbitration clause in a builder-allottee agreement does not oust the jurisdiction of the consumer forum; the consumer remedy is at the consumer's option. The NCDRC Larger Bench order of 13 July 2017 was approved. The reasoning has since travelled into the RERA-CPA interface through Imperia Structures (2020) and IREO Grace Realtech (2021), with HC divergence emerging in 2024-26.

Valkya Editorial··14 min
Supreme CourtSupreme Court of India

Hindustan Construction Company v. Union of India: how Section 87 fell and the no-automatic-stay regime was restored

On 27 November 2019, a three-judge bench of the Supreme Court — Rohinton Fali Nariman, J. (authoring), Surya Kant, J. and V. Ramasubramanian, J. — struck down Section 87 of the Arbitration and Conciliation Act 1996 (inserted by the 2019 Amendment) as manifestly arbitrary and violative of Article 14. The decision restored the no-automatic-stay regime built by the 2015 amendments and confirmed by BCCI v. Kochi Cricket (2018): a Section 34 challenge does not, of itself, stay the enforcement of an arbitral award; the award-debtor must apply separately for a stay under Section 36(3). A close reading of the architecture, the legislative-reversal pattern that brought Section 87 into being, the manifest-arbitrariness reasoning, and the practitioner discipline now stable on independent stay applications.

Valkya Editorial··16 min
Supreme CourtSupreme Court of India

Home Care Retail Marts v. Haresh N. Sanghavi: Section 9 interim relief is available to the unsuccessful party at the post-award stage

On 24 April 2026, the Supreme Court held that an unsuccessful party in arbitration can invoke Section 9 of the Arbitration and Conciliation Act 1996 for interim relief at the post-award stage, pending Section 34 proceedings. The Court rejected the 'fruits of the award' doctrine that had restricted Section 9 to successful parties, reading Section 9's text — 'any party to an arbitration agreement' — to authorise the unsuccessful party to seek interim measures, subject to 'care, caution and circumspection'. The ruling resolves a long-standing High Court conflict and recalibrates the post-award practitioner architecture.

Valkya Editorial··13 min
Supreme CourtSupreme Court of India

Indus Mobile v. Datawind Innovations: how the designation of a seat became an exclusive jurisdiction clause

On 19 April 2017, a two-judge bench of the Supreme Court held that the parties' designation of a seat of arbitration operates as an exclusive jurisdiction clause — vesting the courts at the seat with exclusive supervisory jurisdiction even where no cause of action arose there. The decision imported the international seat-as-jurisdiction principle into Indian domestic arbitration and supplied the analytic engine for the seat-versus-venue line in BGS SGS Soma JV, Mankastu Impex and Hardy Exploration.

Valkya Editorial··12 min
Supreme CourtSupreme Court of India

IREO Grace Realtech (P) Ltd v. Abhishek Khanna: the one-sided-clause doctrine in apartment buyer's agreements and unfair trade practice under Section 2(1)(r) CPA 1986

On 11 January 2021 a two-judge bench of the Supreme Court — Justices Indu Malhotra and Indira Banerjee — held that one-sided clauses in an apartment buyer's agreement, heavily favouring the developer through asymmetric cancellation, token delay compensation and restricted refund rights, constitute 'unfair trade practice' within Section 2(1)(r) of the Consumer Protection Act, 1986. The allottee is not bound by such clauses; the developer cannot enforce one-sided forfeiture; the consumer forum has jurisdiction to refuse enforcement; and where the developer fails to deliver possession, the allottee is entitled to refund with interest. The judgment formalises the 'one-sided clause' doctrine first articulated in Wing Cdr Arifur Rahman Khan v. DLF Southern Homes (August 2020) and aligns with Emaar MGF v. Aftab Singh (2018) on the preservation of statutory remedies against private contractual ouster.

Valkya Editorial··15 min
Supreme CourtSupreme Court of India

Larsen Air Conditioning v. Union of India: the Section 34 court has no power to modify an arbitral award

On 11 August 2023, a two-judge Bench of the Supreme Court restored an arbitrator's award of 18% compound interest after the Allahabad High Court had reduced it to 9% simple interest under Section 34 of the Arbitration and Conciliation Act 1996. The ruling reaffirms that the Section 34 court has no power to modify; it may only set aside. Two years on, the 5-judge Constitution Bench in Gayatri Balasamy v. ISG Novasoft has qualified — not overruled — the proposition. A close reading of the holding, its lineage from Associate Builders through M. Hakeem, and the narrow modification corridor that Gayatri Balasamy has opened.

Valkya Editorial··13 min
LandmarkSupreme Court of India

From N.N. Global to In Re Interplay: the eight-month doctrinal arc that restored Indian arbitration to its separability footing

On 25 April 2023, a five-judge Constitution Bench in N.N. Global Mercantile v. Indo Unique Flame held by 3:2 that an unstamped arbitration agreement could not be acted upon under Section 11 of the Arbitration and Conciliation Act 1996. Eight months later, on 13 December 2023, a seven-judge Constitution Bench in In Re Interplay overruled it unanimously — restoring separability, kompetenz-kompetenz and the prima facie referral standard, and confining stamping to a curable Section 35 admissibility question for the tribunal. A close reading of the architecture, the 3:2 split, the seven-judge overruling, what was decided, what was left for the tribunal, and how the arc from SMS Tea Estates (2011) to Tarini Mohanty (2026) now reads end-to-end.

Valkya Editorial··17 min
Supreme CourtSupreme Court of India

PASL Wind Solutions v. GE Power Conversion: party autonomy reaches its furthest point when two Indian parties choose a foreign seat

On 20 April 2021, a three-judge bench of the Supreme Court resolved a long-running circuit split and held that two Indian-incorporated parties may validly choose a foreign seat of arbitration. The resulting award is a foreign award enforceable under Part II of the 1996 Act, not a domestic award; and the Indian parties retain access to Section 9 interim relief through the proviso to Section 2(2). The judgment treats party autonomy as the dominant principle of Indian arbitration, even where the analytic invites attention to public-policy and contract-law objections.

Valkya Editorial··13 min
Supreme CourtSupreme Court of India

Perkins Eastman v. HSCC: the extension from ineligible-cannot-nominate to ineligible-cannot-unilaterally-appoint

On 26 November 2019 a two-judge bench of the Supreme Court, in Perkins Eastman Architects DPC v. HSCC (India) Ltd, extended TRF v. Energo from the narrow case of an ineligible MD nominating himself a substitute to the broader principle that a person who is himself statutorily ineligible by reason of interest in the dispute cannot — even where he does not appoint himself — be the unilateral appointing authority. The Court appointed an independent sole arbitrator under Section 11(6). A close reading of Justice Uday Umesh Lalit's judgment, the doctrinal architecture, and the recalibration by the Constitution Bench in Central Organisation for Railway Electrification (8 November 2024).

Valkya Editorial··14 min
Supreme CourtSupreme Court of India

Shayara Bano v. Union of India: how a five-judge Bench struck down instant triple talaq

On 22 August 2017, a Constitution Bench of five judges drawn from five faiths held by 3:2 that talaq-e-biddat — the practice of instant, irrevocable triple talaq — was unconstitutional. Justice Nariman and Justice Lalit struck it down as manifestly arbitrary under Article 14. Justice Kurian Joseph struck it down on Islamic theological grounds. Chief Justice Khehar and Justice Nazeer would have left the practice to legislative reform. A digest of the bench, the three operative positions, the doctrine on manifest arbitrariness, and the subsequent Muslim Women (Protection of Rights on Marriage) Act, 2019.

Valkya Editorial··9 min
Supreme CourtSupreme Court of India

TRF v. Energo: the Supreme Court's first articulation of ineligibility-cannot-nominate

On 3 July 2017 a three-judge bench of the Supreme Court, in TRF Ltd v. Energo Engineering Projects Ltd, held that where an arbitration clause authorises the Managing Director of a party to act as sole arbitrator or to nominate one, and that MD is statutorily ineligible under Section 12(5) read with the Seventh Schedule of the Arbitration & Conciliation Act, 1996, the MD cannot act as arbitrator and equally cannot nominate a substitute — 'once the infrastructure collapses, the superstructure is bound to collapse.' A close reading of Justice Dipak Misra's judgment, the doctrinal architecture, the 2015 Amendment background and what the holding seeded for Perkins Eastman and Central Organisation for Railway Electrification.

Valkya Editorial··14 min
Supreme CourtSupreme Court of India

Vidya Drolia and the four-fold test: the Supreme Court reorders the law of arbitrability

On 14 December 2020 a three-judge bench of the Supreme Court, in Vidya Drolia v. Durga Trading Corporation, restated and tightened the in rem / in personam taxonomy of Booz Allen into a structured four-fold test for non-arbitrability, held tenancy disputes under the Transfer of Property Act arbitrable, overruled N. Radhakrishnan on the arbitrability of fraud, and recalibrated the standard of judicial review under Sections 8 and 11 in favour of competence-competence. A close reading of Justice Sanjiv Khanna's lead judgment, Justice Ramana's concurring opinion, the doctrinal architecture and what the bar should plead in the post-Vidya Drolia world.

Valkya Editorial··15 min
Supreme CourtSupreme Court of India

Vodafone International Holdings v. Union of India: how an offshore share transfer fell outside Section 9(1)(i), and what Parliament did next

On 20 January 2012, a three-judge bench of the Supreme Court — S.H. Kapadia C.J., K.S. Radhakrishnan J. and Swatanter Kumar J. — unanimously held that the transfer of a single share in a Cayman Islands holding company (CGP) between two non-residents did not give rise to capital gains taxable in India under Section 9(1)(i) of the Income-tax Act, 1961, even though the share's value was rooted in the Hutch–Vodafone Indian telecom chain; the look-at test was adopted, and the Revenue's USD 2.2 billion demand was quashed. Parliament responded with the Finance Act 2012 retrospective amendment to Section 9(1)(i); Vodafone then commenced a treaty arbitration under the India–Netherlands BIT and prevailed; the Taxation Laws (Amendment) Act 2021 ultimately rolled back the retrospective amendment. A digest of the judgment, its statutory architecture, and the doctrinal arc that has followed.

Valkya Editorial··13 min
Supreme CourtSupreme Court of India

Section 11(6) and Order 23 Rule 1: how the Supreme Court closed the door on a second arbitrator-appointment application

On 2 April 2026, a Supreme Court bench of Justices P.S. Narasimha and Alok Aradhe held in Rajiv Gaddh v. Subodh Parkash that a subsequent application under Section 11(6) of the Arbitration and Conciliation Act, 1996 — based on the same cause of action as one already abandoned — is barred on the principles contained in Order 23 Rule 1 of the Code of Civil Procedure. A digest of the ruling, the facts that drove it, the doctrinal extension into the appointment stage, and what it tells practitioners about strategy and abandonment.

Valkya Editorial··8 min
Supreme CourtSupreme Court of India

Silence is consent: the Supreme Court's reading of Section 29A waiver in arbitration

On 26 May 2026, the Supreme Court held that a party who participates in arbitral proceedings after the arbitrator's mandate has expired — without objection — cannot later challenge the award on the ground of expired mandate. A close reading of the doctrine, its interaction with the Court's earlier 2026 rulings on Section 29A, and what it means for the practitioner advising on tribunal continuity.

Valkya Editorial··9 min
High CourtBombay High Court

Section 9, Section 47, and the foreign award: Justice Sundaresan's intervention in Osterreichischer Lloyd

On 10 March 2026, a learned single judge of the Bombay High Court closed a gap that had quietly opened up in Indian arbitration practice: whether a foreign award-creditor who has filed an enforcement petition under Part II loses access to interim relief under Section 9. The judgment is short, the holding is precise, and the practitioner's takeaway is operational.

Valkya Editorial··8 min