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.