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).