Enforcing Foreign Arbitral Awards in India: Part II, Section 48 and Interim Relief in Foreign-Seated Arbitrations

By Bhaskar Subramanian, Partner, S&S Co. Advocates & Solicitors and Adv. Anupam, Senior Associate, S&S Co. Advocates & Solicitors

Published 24 October 2026 · Law stated as on 22 October 2026 · Informational content, not legal advice: see our disclaimer

A party that wins an arbitration seated outside India still has to clear a second contest before it sees any money: getting an Indian court to treat the award as a decree against assets here. Part II of the Arbitration and Conciliation Act, 1996 makes that path deliberately narrow, and a run of 2025-2026 rulings on limitation, issue estoppel and interim protection has sharpened exactly how narrow it now is, in both directions.

Two tracks, and why the distinction matters from day one

The Arbitration and Conciliation Act, 1996 keeps two separate regimes for taking an award to execution in India, and confusing them at the drafting stage can cost a party years. Part I of the Act governs arbitrations seated in India: an award made there is enforced directly as a decree under Section 36 once the time to challenge it under Section 34 has passed or that challenge has failed. Part II, Chapter I, Sections 44 to 52, gives domestic effect to the New York Convention and governs a different animal entirely, a 'foreign award' made in the territory of another Convention state, in a dispute the parties agreed in writing to arbitrate and that is treated as commercial under Indian law.

A sting in Section 44's threshold definition catches unwary parties: the award must come not merely from a country that has ratified the New York Convention, but from a country the Government of India has specifically notified, by order in the Official Gazette, as a reciprocating territory to which the Convention applies. India has notified a list running to a few dozen countries, but the list is not exhaustive of every Convention signatory, and commentary has flagged gaps, the United Arab Emirates being a frequently cited example: the UAE acceded to the Convention in 2006 and has been notified for enforcing civil and commercial court judgments under the Code of Civil Procedure, but had not, as far as published commentary in early 2025 indicated, been separately gazetted for Section 44 arbitration purposes. A party drafting a contract today should check the current gazette notification for its counterparty's seat before assuming Part II will even apply, rather than relying on the seat country's Convention membership alone.

Part II, Chapter II, Sections 53 to 60 carries a second, now largely historical regime implementing the older 1927 Geneva Convention, relevant only to the small number of countries that are Geneva signatories but never joined the New York Convention. For almost every contemporary commercial arbitration, the New York Convention chapter is the one that matters, and the rest of this piece addresses that chapter alone.

The enforcement procedure: one proceeding, not two

A persistent early uncertainty under the 1996 Act was whether a party had to first obtain a judicial declaration that an award was enforceable, and only then file a separate execution application, effectively doubling the litigation. The Supreme Court settled this in M/s. Fuerst Day Lawson Ltd. v. Jindal Exports Ltd., holding that enforcement of a foreign award is a single, composite proceeding: the court examines the Section 48 grounds for refusal and, if satisfied none applies, treats the award as a decree of that court in the same proceeding, without requiring the applicant to first secure a separate declaration of enforceability before moving to execute.

In practical terms, the applicant files a petition before the High Court having jurisdiction, ordinarily the High Court within whose territorial jurisdiction the award debtor's assets are situated, since the point of enforcement is almost always to reach those assets rather than the seat of any underlying business. Section 47 sets out the documentary package the applicant must produce: the original award or a duly authenticated copy, the original arbitration agreement or a certified copy, and, where the award or agreement is in a foreign language, a translation certified by a diplomatic or consular agent or otherwise certified as correct in the manner the Act permits.

Once those documents are in order, the burden shifts to the award debtor to make out one of the Section 48 grounds for refusal, discussed in detail below; the applicant does not have to affirmatively prove the absence of every ground. If the court is satisfied that no ground is established, Section 49 directs it to treat the award, to that extent, as a decree of that court, at which point ordinary execution procedure under the Code of Civil Procedure takes over: attachment of assets, sale, garnishee proceedings and the rest of the executing court's ordinary toolkit. The practical lesson from this structure is that an award-holder should identify where the debtor's attachable assets actually sit in India before filing, since that choice of court is not merely a convenience but fixes where execution will in fact have to run.

Limitation: three years, and when the clock starts

For years, High Courts split over how long an award-holder had to bring an enforcement petition, some applying the twelve-year period under Article 136 of the Limitation Act on the theory that a foreign award, once it clears the Section 48 gauntlet, becomes a decree and should carry a decree's limitation period. The Supreme Court closed that debate in Government of India v. Vedanta Ltd., decided on 16 September 2020, holding that a foreign award never becomes a foreign decree at any stage; it remains an award throughout, and Sections 47 and 49 together create a composite procedure for enforcement rather than a two-step conversion into a decree followed by execution of that decree. On that reasoning, the twelve-year decree period in Article 136 has no application, and the applicable period is the residual three years under Article 137 of the Limitation Act, running from the date the right to apply accrues.

The Court left genuinely open, and commentary has flagged this as a real gap, precisely when the right to apply 'accrues' in every scenario: whether it is the date of the award itself, the date any challenge to the award in the seat court is finally rejected, or some other triggering event where the award debtor has sought to resist the award abroad before the enforcement petition is filed in India. Award-holders who wait to see out a seat-court challenge before filing in India should not assume the Indian limitation clock paused during that foreign proceeding; the safer course, given the uncertainty, is to file the Indian enforcement petition promptly and, if a seat-court challenge is still pending, seek a stay of the Indian proceeding rather than simply waiting out the three years on the assumption that the clock has not started.

Vedanta also confirmed that Section 5 of the Limitation Act, which allows condonation of delay on sufficient cause, applies to enforcement petitions, since the general bar on condonation under Section 29(2) read with the Limitation Act applies only to execution applications under the Code of Civil Procedure and not to this composite proceeding. A party that has missed the three-year window by a modest margin, particularly where the delay traces to the genuine uncertainty that existed before Vedanta settled which article applied, has a real argument for condonation, though that argument weakens with every year of additional delay and should not be treated as a routine safety net.

Section 48: the grounds, and how narrowly courts read them

Section 48 gives an award debtor exactly five categories of objection, and Indian courts have, with the occasional controversial exception, insisted that these grounds be read narrowly and that an enforcement proceeding never become a re-hearing of the arbitration's merits. The grounds are: incapacity of a party or invalidity of the arbitration agreement; lack of proper notice of the arbitrator's appointment or the arbitral proceedings, or a party otherwise being unable to present its case; the award dealing with a dispute not contemplated by or falling outside the submission to arbitration; an irregularity in the composition of the tribunal or the arbitral procedure, measured against the parties' agreement or, failing that, the law of the seat; the award not yet having become binding, or having been set aside or suspended by a competent authority of the seat country; and, separately, that the subject matter was not capable of settlement by arbitration under Indian law, or that enforcement would be contrary to the public policy of India.

The public policy ground has generated by far the most litigation and the sharpest judicial disagreement. The Supreme Court's foundational statement in Renusagar Power Co. v. General Electric Co., decided under the predecessor 1961 Act, confined public policy under this chapter to three categories: enforcement being contrary to the fundamental policy of Indian law, contrary to the interests of India, or contrary to justice or morality. Shri Lal Mahal Pvt. Ltd. v. Progetto Grano Spa, decided by a three-judge bench in 2013, reaffirmed and narrowed this further, expressly rejecting any suggestion that the wider 'patent illegality' ground available for domestic awards under Section 34 could be imported into a Section 48 public policy analysis, and holding squarely that a court enforcing a foreign award does not sit in appeal over the arbitrator's findings on the merits.

Vijay Karia v. Prysmian Cavi e Sistemi Srl, decided by the Supreme Court in 2020, pushed the narrow reading further still, enforcing a London-seated LCIA award that directed a discounted share transfer which the award debtor argued contravened Indian foreign exchange law. The Court held that mere inconsistency with a regulatory statute like FEMA does not, without more, defeat enforcement on fundamental-policy grounds, following the Delhi High Court's earlier reasoning in Cruz City, and that courts retain limited discretion to refuse enforcement on several of the Section 48 grounds but effectively no discretion to enforce an award that genuinely falls foul of fraud, corruption, the fundamental policy of Indian law, or basic notions of justice and morality: those grounds, once made out, leave no room for discretionary leniency either way.

Set against that trend, NAFED v. Alimenta S.A., decided only weeks after Vijay Karia in 2020, refused enforcement of a roughly ₹450 crore award against a government-owned cooperative on the footing that performing the underlying groundnut export contract, once the Government had refused the export sanction the contract's own terms made a condition, would have required NAFED to act contrary to Indian export-control policy, which the Court treated as a species of fundamental policy of Indian law. Commentators have pointed out the tension between NAFED and Vijay Karia, decided by the same Court within two months of each other, and some argue NAFED's contract-law reasoning, essentially revisiting whether the underlying contract was discharged on frustration grounds, strayed closer to a merits review than Section 48 is supposed to permit. Both decisions remain good law, and an award debtor relying on a regulatory or statutory inconsistency to resist enforcement should expect a court to ask, closely following Vijay Karia rather than NAFED's narrower facts, whether the regulatory breach genuinely implicates a fundamental policy rather than merely a technical non-compliance the arbitrator has already weighed.

Binding non-signatories and the limits of resisting enforcement

A separate line of attack award debtors have tried is to argue that a foreign award cannot be enforced against a person or entity that never signed the underlying arbitration agreement. The Supreme Court closed that door firmly in Gemini Bay Transcription Pvt. Ltd. v. Integrated Sales Service Ltd., enforcing a United States-seated award against parties who had been brought into the arbitration on an alter ego theory despite never having signed the agreement themselves. The Court read Section 46, which provides that a foreign award is binding 'for all purposes on the persons as between whom it was made', as deliberately using the word 'persons' rather than 'parties', and held that this language permits enforcement against a non-signatory where the tribunal has itself found that person bound, typically through doctrines like alter ego or group-of-companies reasoning developed in the arbitration itself. The Court reiterated, in the same judgment, that the Section 48 grounds are to be read narrowly rather than expansively, and that a bare objection that the award runs against a non-signatory is not, by itself, a recognised ground for refusing enforcement.

Still, a newer and developing doctrine narrows the award debtor's room to relitigate issues a second time in India, where the seat court has already ruled on them. In Nagaraj V. Mylandla v. PI Opportunities Fund-I, the Supreme Court addressed a case where a Singapore-seated award had already survived a challenge before the Singapore High Court, the seat court, before the award-holder moved the Madras High Court for enforcement in India. The promoters resisting enforcement sought to reargue, under the banner of Section 48 public policy, factual and contractual issues the Singapore court had already finally decided between the same parties. The Supreme Court held that where a seat court has conclusively decided a forum-neutral factual or contractual issue, the Indian enforcement court will not reopen that same issue merely because the objection is recast in the language of Indian public policy, a doctrine the Court and subsequent commentary have called transnational issue estoppel. The Court was careful to cabin the doctrine: it does not displace the statutory public policy ground under Section 48(2)(b) itself, which an Indian court may still independently examine, and the ruling does not purport to define the doctrine's full boundaries. The practical effect, for a party that has already lost a seat-court challenge abroad, is that raising the same substantive arguments again in an Indian enforcement proceeding, dressed up as a public policy objection, is now a materially weaker strategy than it may have looked before 2026.

Interim relief while the foreign-seated arbitration is still running

A party does not have to wait for a foreign award before it can ask an Indian court for protection, a point that matters enormously where assets or evidence in India are at risk while a foreign-seated arbitration is still in progress. The Supreme Court's Constitution Bench ruling in Bharat Aluminium Co. v. Kaiser Aluminium Technical Services, known as BALCO, overruled the earlier and more expansive Bhatia International v. Bulk Trading position and held, with prospective effect only, that Part I of the Act, including Section 9 interim relief, does not apply to arbitrations seated outside India, since the seat determines which curial law governs the proceeding and Indian courts have no supervisory role over a foreign seat's own arbitral process.

Parliament reversed that result for interim relief specifically through the 2015 amendment, which inserted a proviso to Section 2(2) making Sections 9, 27, 37(1)(a) and 37(3) applicable to international commercial arbitrations even where the seat is outside India, unless the parties have agreed otherwise. The Delhi High Court applied this proviso in Raffles Design International India Pvt. Ltd. v. Educomp Professional Development Institute Pvt. Ltd., decided 7 October 2016, in a Singapore-seated SIAC arbitration where the petitioner had already obtained a confirmed emergency arbitrator's award. The Court held that choosing a foreign seat, foreign governing law or a foreign institution's rules does not, by itself, amount to an implied exclusion of Section 9, and that an emergency arbitrator's order from a foreign-seated arbitration cannot itself be directly enforced in India as such, but a party can achieve the equivalent protection indirectly by applying to an Indian court under Section 9 for the same interim relief the emergency arbitrator has already granted.

The Karnataka High Court's 2026 ruling in Aroha Labs Pte. Ltd. v. Prem Dharmani reinforced the same principle in a dispute arising from a Singapore-seated SIAC arbitration, holding that excluding Indian courts' Section 9 jurisdiction requires an express agreement to that effect, and that the mere choice of a foreign place of arbitration cannot itself be read as such an exclusion. The Court granted a partial restraint against former consultants and entities it found prima facie to be their alter egos from dealing with certain disputed business applications pending the arbitration, while declining at the interim stage to order the immediate return of company property, leaving that question for fuller consideration. The ruling also illustrates how non-signatory and alter ego reasoning, familiar from the enforcement context in Gemini Bay, surfaces equally at the interim relief stage when a party restructures through separate entities during a live dispute.

A further wrinkle, addressed by the Bombay High Court in Osterreichischer Lloyd v. Victore Ships on 10 March 2026, is whether an award-holder loses the right to seek Section 9 protective relief once it has already filed a Part II enforcement petition for the same foreign award. The Court held it does not: filing an enforcement petition under Part II does not by itself extinguish the separate right to seek interim protective measures under Section 9, at least for so long as the award has not yet been recognised as an enforceable decree under Section 49. Commentary following the ruling has flagged that it leaves open whether Section 9 relief remains available once the award has cleared Section 48 and become a decree, during the execution stage itself, a question High Courts have not yet uniformly resolved and that may eventually need the Supreme Court's own ruling.

Drafting lessons for cross-border contracts

Most of the uncertainty traced in this piece can be reduced, though never eliminated, at the drafting stage, long before any dispute arises. A contracting party that expects to need Indian enforcement one day should confirm, when the contract is being negotiated rather than after a dispute erupts, that the proposed seat sits on India's current Section 44(b) gazette list, and should raise the point with counsel if the counterparty insists on a seat whose notified status is unclear, since the alternative, enforcing an un-notified award through an ordinary civil suit on the award as a fresh cause of action, is markedly slower and loses the summary procedural advantages Part II provides.

A party that wants to preserve Indian courts' Section 9 jurisdiction over a foreign-seated arbitration should say so expressly in the contract rather than relying on silence, since the proviso to Section 2(2) already supplies that result by default, but an express clause removes any later argument that some other term of the agreement, a foreign governing law clause or an institutional rule referring generally to court assistance, was intended as an implied exclusion. Conversely, a party that genuinely wants to exclude Indian courts' interim jurisdiction, for instance because it expects all relevant assets to sit outside India, should use clear express language to that effect, because Aroha Labs and Raffles Design both confirm that Indian courts will not infer exclusion from an ambiguous clause or from the seat choice alone.

Stamp duty deserves a specific mention because it has caused confusion by analogy with domestic arbitration agreements. The seven-judge Constitution Bench ruling that an unstamped domestic arbitration agreement is not void, only inadmissible until the duty is paid and the defect cured, has sometimes been assumed to carry over to foreign award enforcement, but at least one High Court, in Narayan Trading Co. v. Abcom Trading, has held there is no provision in the Act requiring stamp duty on a foreign award itself, and the Supreme Court has rejected an argument that non-payment of stamp duty on a foreign award falls within the Section 48(2)(b) public policy ground. A party should still ensure the underlying arbitration agreement is properly stamped if it is governed by Indian stamp law and might separately need to be relied on in Indian court proceedings, but should not expect a stamping objection, by itself, to defeat enforcement of the award proper.

Finally, where a dispute is likely to touch a regulated sector, foreign exchange, export controls, or a similarly sensitive area of Indian policy, a careful drafter builds the governing law and compliance obligations into the substantive contract terms themselves, addressed and argued before the tribunal during the arbitration, rather than leaving the regulatory question to be raised for the first time as a public policy defence at the enforcement stage. Vijay Karia shows that an Indian court enforcing a foreign award will generally defer to the tribunal's own treatment of regulatory compliance; a party that wants a regulatory point taken seriously should make sure the arbitrator actually considered it, since NAFED's contrary outcome turned on a Government export prohibition the contract's own terms had already made a condition of performance, not on a point raised only in resistance to enforcement.

A step-by-step guide for the award-holder

Begin well before the award is even rendered: confirm that the seat country appears on India's current Section 44(b) gazette notification of reciprocating territories, since an award from a country India has not notified, whatever its own Convention membership, sits outside Part II entirely and would have to be enforced, if at all, through an ordinary civil suit on the award as a cause of action, a materially slower and more uncertain route. If there is any doubt about a particular jurisdiction, the India-UAE gap discussed earlier shows this is not a merely theoretical risk.

Once the award is in hand, identify where the award debtor holds attachable assets in India, since that, rather than any formal connection to the dispute, is what should drive the choice of High Court for the enforcement petition. Assemble the Section 47 documentary package promptly: the original award or an authenticated copy, the original or certified arbitration agreement, and certified translations of either document if they are not in English, since an incomplete filing invites early procedural objections that cost time without advancing the substance of the dispute.

File within three years of the right to apply accruing, treating the date of the award itself as the safer anchor for that period rather than waiting out any parallel challenge in the seat court, and if a seat-court challenge is genuinely still live, seek an explicit stay of the Indian proceeding rather than simply deferring the filing. Where delay is unavoidable, be ready to plead and evidence sufficient cause for condonation under Section 5 of the Limitation Act from the outset, rather than raising it only once the debtor objects on limitation grounds.

If the debtor has already contested the award, or the underlying contractual and factual issues, before the seat court and lost, plead that history affirmatively and invoke the transnational issue estoppel line of reasoning from the PI Opportunities Fund ruling to pre-empt a second round of merits argument dressed as a public policy objection. If assets are at risk of dissipation while the Part II petition is pending, move a parallel Section 9 application rather than assuming enforcement alone will be fast enough to protect the position, bearing in mind the Bombay High Court's confirmation that the two remedies can run together.

A step-by-step guide for the award debtor resisting enforcement

An award debtor's realistic options are narrower than many resisting parties initially assume, and the first task is to discard arguments the courts have already closed off. A bare objection that the award runs against a non-signatory will not succeed after Gemini Bay unless there is a genuine, separately arguable basis to say the tribunal's alter ego or group-of-companies finding was itself procured without a fair hearing, which would have to be framed as a due process objection under Section 48(1)(b) rather than as a standalone non-signatory defence.

A debtor that has already litigated the substance of its objections before the seat court and lost should not expect to relitigate those same issues in India under the public policy label; the realistic path, after the transnational issue estoppel ruling, is to identify a genuinely distinct public policy concern, something the seat court was never asked to decide, such as a specific Indian statutory or regulatory conflict, rather than repackaging the arguments the seat court already rejected.

Where the underlying dispute does implicate Indian regulatory policy, whether in foreign exchange control, as in Vijay Karia, or export policy, as in NAFED, the debtor's strongest framing follows the NAFED pattern of showing that performance would require actually contravening a specific government prohibition still in force, rather than merely showing some general regulatory friction, since the Vijay Karia line will otherwise treat mere inconsistency with a regulatory statute as insufficient. A debtor should also scrutinise the notice and composition grounds under Section 48(1)(b) and (d) closely and early, since these are the grounds most amenable to documentary proof, for instance showing the tribunal was not constituted in accordance with the parties' agreed procedure, and are correspondingly the grounds courts have been most willing to uphold without being accused of reopening the merits.

Finally, a debtor facing a parallel Section 9 application should not assume that resisting the underlying enforcement petition on the merits is enough; the Osterreichischer Lloyd ruling confirms that interim protective relief can proceed on its own track regardless of how the Part II petition is faring, so a debtor genuinely contesting enforcement should address the Section 9 application's own three-part test, prima facie case, balance of convenience and irreparable harm, on its own terms rather than treating it as a formality that will fall away once the main enforcement objection succeeds.

What remains unsettled

Several questions in this area are genuinely open rather than settled, and a party building a strategy around any of them should treat the current position as provisional. The precise moment the Article 137 limitation clock starts running, whether at the date of the award, at the conclusion of any seat-court challenge, or at some other point, was left unresolved in Vedanta itself and has not since been authoritatively fixed by the Supreme Court; parties relying on a later accrual date to justify a delayed filing carry real risk.

Whether Section 9 interim relief remains available once a foreign award has already been recognised as an enforceable decree under Section 49, during the execution stage proper, is equally unresolved: the Bombay High Court's 2026 ruling confirmed only that the two remedies can coexist before that point, and commentary following the decision has explicitly flagged the execution-stage question as needing the Supreme Court's own clarification. The precise boundaries of the transnational issue estoppel doctrine recognised in the PI Opportunities Fund ruling are also unsettled; the Supreme Court itself declined to define them in full, leaving open how the doctrine should apply where the seat court's decision was interlocutory rather than final, or where the seat court applied a standard of review for its own domestic challenge quite different from the Section 48 standard an Indian court applies.

The apparent tension between Vijay Karia's narrow reading of regulatory non-compliance as a public policy ground and NAFED's acceptance of an export-policy defence on broadly similar reasoning has also not been reconciled by any later Supreme Court bench, and both remain citable authority, leaving real uncertainty for any dispute that combines a foreign award with a genuine Indian regulatory overlay. And the gap between India's Convention membership generally and the specific list of countries gazetted as reciprocating territories under Section 44(b), the UAE example being the most discussed, means that a party contracting with a counterparty in a jurisdiction not clearly on the current notified list should not assume Part II enforcement will be straightforwardly available, and should confirm the current gazette position before relying on it in a cross-border contract.

Enforcing a foreign award in India has become a considerably more predictable exercise than it was a decade ago, with the single-proceeding structure from Fuerst Day Lawson, the settled three-year limitation period from Vedanta, and the consistently narrow reading of the Section 48 grounds across Shri Lal Mahal, Vijay Karia and Gemini Bay giving an award-holder a reasonably clear route to a decree, provided the procedural basics, the gazette notification, the documentary package, the limitation clock, are handled with care from the outset. The newer transnational issue estoppel doctrine tightens that route further against a debtor trying for a second bite at arguments a seat court has already rejected.

What has not settled, and should be planned around rather than assumed away, is the handling of a genuine Indian regulatory overlay on the underlying dispute, where NAFED and Vijay Karia point in different directions on broadly similar facts, and the precise reach of interim protection once an award moves from a pending enforcement petition to a recognised decree. A party on either side of a foreign award, holder or debtor, does better to build its strategy around the narrow, well-settled core of this law and treat these remaining open questions as genuine risk to be managed, rather than certainty to be relied on.

Frequently Asked Questions

References & Further Reading

The provisions, rulings and official documents below were relied on for this article, which states the law as on 22 October 2026. The position can change with amendments, rules and later decisions, so check the current text before acting on any of it.

1. Arbitration and Conciliation Act, 1996, Sections 2(2) proviso, 9, 27, 36, 37, 44, 46, 47, 48, 49
2. Limitation Act, 1963, Sections 5, 29(2), Articles 136 and 137
3. Code of Civil Procedure, 1908 (execution procedure applied once an award becomes a decree under Section 49)
4. New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, 1958
5. Renusagar Power Co. Ltd. v. General Electric Co., 1994 Supp (1) SCC 644
6. Bhatia International v. Bulk Trading S.A., (2002) 4 SCC 105
7. M/s. Fuerst Day Lawson Ltd. v. Jindal Exports Ltd., (2001) 6 SCC 356
8. Shri Lal Mahal Pvt. Ltd. v. Progetto Grano Spa, (2013) 7 SCC (approx.) (narrow public policy under Section 48)
9. Bharat Aluminium Co. v. Kaiser Aluminium Technical Services (BALCO), (2012) 9 SCC 552
10. NAFED v. Alimenta S.A., (2020) (fundamental policy and export control, decided 22 April 2020)
11. Vijay Karia v. Prysmian Cavi e Sistemi Srl, (2020) (narrow Section 48 grounds, decided February 2020)
12. Gemini Bay Transcription Pvt. Ltd. v. Integrated Sales Service Ltd., Civil Appeal Nos. 8343-8344 of 2018 (decided August 2021)
13. Government of India v. Vedanta Ltd., Civil Appeal No. 3185 of 2020 (decided 16 September 2020)
14. Raffles Design International India Pvt. Ltd. v. Educomp Professional Development Institute Pvt. Ltd., O.M.P.(I)(COMM.) 23/2015, Delhi High Court (decided 7 October 2016)
15. Nagaraj V. Mylandla v. PI Opportunities Fund-I, Supreme Court of India, SLP (C) Nos. 31866-68 of 2025 (transnational issue estoppel, 2026)
16. Aroha Labs Pte. Ltd. v. Prem Dharmani & Ors., Karnataka High Court, AP.IM No. 4 of 2026
17. Osterreichischer Lloyd v. Victore Ships, Bombay High Court, order dated 10 March 2026
18. Home Care Retail Marts v. Haresh N. Sanghavi, 2026 INSC 415 (post-award Section 9 relief, domestic arbitration)
19. Narayan Trading Co. v. Abcom Trading Pvt. Ltd. (no stamp duty requirement on a foreign award), Madhya Pradesh High Court
20. In Re: Interplay Between Arbitration Agreements and the Indian Stamp Act, 1899, Curative Petition No. 44 of 2023 (Constitution Bench, unstamped domestic arbitration agreements, decided December 2023)

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