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.