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.
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).
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.
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.
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.