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.