Arbitration and Conciliation Act 1996 – ss.8 and 11 – Arbitration agreements embedded in underlying instruments or substantive contracts – Whether such arbitration agreements would be non-existent, unenforceable, or invalid if the underlying contract is not stamped – Interplay between Arbitration Agreements under the Arbitration and Conciliation Act, 1996 and the Indian Stamp Act, 1899 – Unstamped or insufficiently stamped instruments – If admissible in evidence – Nonstamping or inadequate stamping – If curable. Ed. Note. Hon’ble Dr Dhananjaya Y Chandrachud, CJI pronounced the judgment on behalf of himself, Hon’ble Mr Justice Sanjay Kishan Kaul, Hon’ble Mr Justice B R Gavai, Hon’ble Mr Justice Surya Kant, Hon’ble Mr Justice J B Pardiwala and Hon’ble Mr Justice Manoj Misra. Hon’ble Mr Justice Sanjiv Khanna pronounced a separate but concurring judgment. Held (per Dr. D.Y. Chandrachud, CJI) (for himself, Sanjay Kishan Kaul, B.R Gavai, Surya Kant, J B Pardiwala and Manoj Misra, JJ.): Agreements which are not stamped or are inadequately stamped are inadmissible in evidence u/s.35 of the Stamp Act – Such agreements are not rendered void or void ab initio or unenforceable – Non-stamping or inadequate stamping is a curable defect – The Stamp Act itself provides for the manner in which the defect may be cured and sets out a detailed procedure for it – An objection as to stamping does not fall for determination u/ss.8 or
11 of the Arbitration Act – The concerned court must examine whether the arbitration agreement prima facie exists – Any objections in relation to the stamping of the agreement fall within the ambit of the arbitral tribunal. [Paras
48 and 224] – Held (per Sanjiv Khanna, J.) (Concurring): Unstamped or insufficiently stamped instruments inadmissible in evidence in terms of s.35 of the Indian Stamp Act, 1899, are not rendered void and void ab initio – An objection as to the under-stamping or non-stamping of the underlying contract will not have any bearing when the prima facie test, “the existence of arbitration agreement”, is applied by the courts while deciding applications under Sections 8 or 11 of the Arbitration and Conciliation Act, 1996 – An objection as to insufficient stamping of the underlying agreement can be examined and decided by the arbitral tribunal. [Para 1] Evidence – Admissibility of documents – Difference between inadmissibility and voidness – Contract Act, 1872 – s.2(g). Held (per Dr. D.Y. Chandrachud, CJI) (for himself, Sanjay Kishan Kaul, B.R Gavai, Surya Kant, J B Pardiwala and Manoj Misra, JJ.): The admissibility of an instrument in evidence is distinct from its validity or enforceability in law – An agreement can be void without its nature as a void agreement having an impact on whether it may be introduced in evidence – Similarly, an agreement can be valid but inadmissible in evidence – When an agreement is void, one is speaking of its enforceability in a court of law – When it is inadmissible, one is referring to whether the court may consider or rely upon it while adjudicating the case – This is the essence of the difference between voidness and admissibility. [Paras 44, 45 and 46] Indian Stamp Act, 1899 – Purpose of.
Held (per Dr. D.Y. Chandrachud, CJI) (for himself, Sanjay Kishan Kaul, B.R Gavai, Surya Kant, J B Pardiwala and Manoj Misra, JJ.): The Stamp Act is a fiscal legislation which is intended to raise revenue for the government – It is a mandatory statute. [Para 58] Arbitration – Principle of arbitral autonomy – Doctrines /Principles.
Held (per Dr. D.Y. Chandrachud, CJI) (for himself, Sanjay Kishan Kaul, B.R Gavai, Surya Kant, J B Pardiwala and Manoj Misra, JJ.): The principle of arbitral autonomy is an integral element of the ever-evolving domain of arbitration law – Arbitral autonomy means that the parties to an arbitration agreement can exercise their contractual freedom to bestow the arbitral tribunal with the authority to decide disputes that may arise between them – The basis of arbitral autonomy is to give effect to the true intention of parties to distance themselves from the “risk of domestic judicial parochialism. [Para 66]
Doctrines / Principles – Principle of judicial interference in arbitration proceedings – Scope of non-obstante clause contained in s.5 of the Arbitration and Conciliation Act 1996 – Legislative intention. Held (per Dr. D.Y. Chandrachud, CJI) (for himself, Sanjay Kishan Kaul, B.R Gavai, Surya Kant, J B Pardiwala and Manoj Misra, JJ.): The principle of judicial non-interference in arbitral proceedings serves to proscribe judicial interference in arbitral proceedings, which would undermine the objective of the parties in agreeing to arbitrate their disputes, their desire for less formal and more flexible procedures, and their desire for neutral and expert arbitral procedures – The principle of judicial non-interference in arbitral proceedings respects the autonomy of the parties to determine the arbitral procedures – This principle has also been incorporated in international instruments – s.5 of the Arbitration Act is of aid in interpreting the extent of judicial interference under ss.8 and 11 of the Arbitration Act – s.5 contains a general rule of judicial non-interference – Therefore, every provision of the Arbitration Act ought to be construed in view of s.5 to give true effect to the legislative intention of minimal judicial intervention. [Paras 69 and 82]
Arbitration and Conciliation Act, 1996 – Is a self-contained code – Provisions of other statutes cannot interfere with the working of the Arbitration Act, unless specified otherwise. [Para 85 in judgment of Dr. D.Y. Chandrachud, CJI]
Arbitration – Arbitration agreement – Is the foundation of arbitration as it records the consent of the parties to submit their disputes to arbitration. [Para 88 in judgment of Dr. D.Y. Chandrachud, CJI]
Arbitration – Arbitration agreement – Separability of the arbitration agreement from the underlying contract in which it is contained.
Held (per Dr. D.Y. Chandrachud, CJI) (for himself, Sanjay Kishan Kaul, B.R Gavai, Surya Kant, J B Pardiwala and Manoj Misra, JJ.): An arbitration agreement is juridically independent from the underlying contract in which it is contained – The concept of separability reflects the presumptive intention of the parties to distinguish the underlying contract, which captures the substantive rights and obligations of the parties, from an arbitration agreement which provides a procedural framework to resolve the disputes arising out of the underlying contract – This presumption has various consequences in theory and practice, the most important being that an arbitration agreement survives the invalidity or termination of the underlying contract – The separability presumption gives effect to the doctrine of competence-competence. [Paras 90 and 112] Doctrines / Principles – Doctrine of competence-competence – Comparative analysis – Arbitration and Conciliation Act 1996 – s.16. Held (per Dr. D.Y. Chandrachud, CJI) (for himself, Sanjay Kishan Kaul, B.R Gavai, Surya Kant, J B Pardiwala and Manoj Misra, JJ.): The doctrine of kompetenz-kompetenz (also known as competence competence), as originally developed in Germany, was traditionally understood to imply that arbitrators are empowered to make a final ruling on their own jurisdiction, with no subsequent judicial review of the decision by any court – However, many jurisdictions allow an arbitral tribunal to render a decision on its jurisdiction, subject to substantive judicial review – The UK position is that although the arbitral tribunal is empowered to consider whether it has jurisdiction, its determination is subject to the examination of the courts – The courts in the United States have considered the principle of competence-competence to be intertwined with the separability presumption – The Singapore High Court has given full effect to the doctrine of competence-competence since the arbitral tribunal gets the first priority to determine issues even with respect to the very existence of the arbitration agreement, while the jurisdiction of the courts is limited to a prima facie determination – s.16 of the Arbitration Act recognizes the doctrine of competence-competence in Indian arbitration law. [Paras 115, 117, 118, 119, 120]
Doctrines / Principles – Doctrine of competence-competence –Positive and negative aspects of the doctrine – Negative competencecompetence – Discussed. Held (per Dr. D.Y. Chandrachud, CJI) (for himself, Sanjay Kishan Kaul, B.R Gavai, Surya Kant, J B Pardiwala and Manoj Misra, JJ.): The international arbitration law as well as domestic law prioritize the arbitral tribunal by permitting them to initially decide challenges to their authority instead of the courts – The policy consideration behind this approach is twofold: first, to recognize the mutual intention of the parties of choosing the arbitrator to resolve all their disputes about the substantive rights and obligations arising out of contract; and second, to prevent parties from initiating parallel proceedings before courts and delaying the arbitral process – This is the positive aspect of the doctrine of competence-competence – The negative aspect, in contrast, speaks to the national courts – It instructs the courts to limit their interference at the referral stage by deferring to the jurisdiction of the arbitral tribunal in issues pertaining to the existence and validity of an arbitration agreement – Allowing arbitral tribunals to first rule on their own jurisdiction and later allowing the courts to determine if the tribunal exercised its powers properly safeguards both the power and authority of the arbitral tribunal as well as the courts – The negative aspect of the doctrine has been expressly recognized by Indian courts – Considering both the positive and negative facets, the principle can be defined as a rule whereby arbitrators must have the first opportunity to hear challenges relating to their jurisdiction, which is subject to subsequent review by courts. [Paras 129, 130]
legislation enacted to inter alia consolidate the law relating to arbitration in India – It will have primacy over the Stamp Act and the Contract Act in relation to arbitration agreements. [Para 166 in judgment of Dr. D.Y. Chandrachud, CJI]
Interpretation of Statutes – Harmonious construction – Provisions contained in two statutes must be, if possible, interpreted in a harmonious manner to give full effect to both the statutes – In providing a harmonious interpretation, the Court has to be cognizant of the fact that it does not defeat the purpose of the statutes or render them ineffective. [Para 165 in judgment of Dr. D.Y. Chandrachud, CJI] Interpretation of Statutes – Non-obstante clause – Held: Although a non-obstante clause must be allowed to operate with full vigour, its effect is limited to the extent intended by the legislature. [Para 77 in judgment of Dr. D.Y. Chandrachud, CJI]
Words and Phrases – “admissible”. [Para 44 in judgment of Dr. D.Y. Chandrachud, CJI]
Words and Phrases – Word “shall” – In ss.33 and 35 of the Stamp Act – Meaning and effect of. [Para 189 in judgment of Dr. D.Y. Chandrachud, CJI]
LIST OF CITATIONS AND OTHER REFERENCES
In the judgment of Dr D.Y. Chandrachud, CJI
N N Global Mercantile (P) Ltd. v. Indo Unique Flame Ltd. (2023) 7 SCC 1 and SMS Tea Estates (P) Ltd. v. Chandmari Tea Co. (P) Ltd (2011)
14 SCC 66 : [2011] 9 SCR 382 – overruled.
Garware Wall Ropes Ltd. v. Coastal Marine Constructions & Engg. Ltd. (2019) 9 SCC 209 : [2019] 5 SCR 579 – overruled to an extent. Uttarakhand Purv Sainik Kalyan Nigam Ltd v. Northern Coal Field (2020) 2 SCC 455 – relied on.
Vidya Drolia v. Durga Trading Corporation (2021) 2 SCC 1 : [2020]
11 SCR 1001 – clarified.
N N Global Mercantile (P) Ltd. v. Indo Unique Flame Ltd. (2021) 4 SCC 379; Dharmaratnakara Rai Bahadur Arcot Narainswamy Mudaliar Chattram v. Bhaskar Raju and Brothers (2020) 4 SCC 612 : [2020] 3 SCR 798; Rupa Ashok Hurra v. Ashok Hurra (2002) 4 SCC 388 : [2002]
2 SCR 1006; Bharat Petroleum Corporation v. Mumbai Shramik Sangha (2001) 4 SCC 448: [2001] 3 SCR 208; Pradip Chandra Parija v. Pramod Chandra Patnaik (2002) 1 SCC 1: [2001] 5 Suppl. SCR 460; Union of India v. Hansoli Devi, (2002) 7 SCC 273: [2002] 2 Suppl. SCR 324; Central Board of Dawoodi Bohra Community v. State of Maharashtra (2005) 2 SCC 673: [2004] 6 Suppl. SCR 1054; Shilpa Sailesh v. Varun Sreenivasan 2023 SCC OnLine SC 544; Kantaru Rajeevaru v. Indian Young Lawyers Association (2020) 9 SCC 121; Ganga Sugar Corporation Ltd. v. State of Uttar Pradesh, (1980) 1 SCC 223: [1980] 1 SC 769; Thiruvengadam Pillai v. Navaneethammal, (2008) 4 SCC 530: [2008] 3 SCR 23; Hindustan Steel Ltd. v. Dilip Construction Co. (1969) 1 SCC 597: [1969] 3 SCR 736 ; Union of India v. Popular Construction Co., (2001) 8 SCC 470: [2001] 3 Suppl. SCR 619; P Anand Gajapathi Raju v. P.V.G. Raju, (2000) 4 SCC 539: [2000]
2 SCR 684; Food Corporation of India v. Indian Council of Arbitration, (2003) 6 SCC 564: [2003] 1 Suppl. SCR 568; Union of India v. Popular Construction Co., (2001) 8 SCC 470; Swiss Timing Ltd. v. Commonwealth Games 2010 Organising Committee, (2014) 6 SCC 677:[ 2014] 6 SCR 514; State of Bihar v. Bihar Rajya M.S.E.S.K.K. Mahasangh (2005) 9 SCC 129:[2004] 5 Suppl. SCR 376; Owners and Parties Interested in the Vessel M.V. Polaris Galaxy v. Banque Cantonale De Geneva, 2022 SCC OnLine SC 1293; Chandavarkar Sita Ratna Rao v. Ashalata S. Guram (1986) 4 SCC 447: [1986] 3 SCR 866; ICICI Bank Ltd v. SIDCO Leathers Ltd, (2006)
10 SCC 452: [2006] 1 Suppl. SCR 528; JIK Industries Ltd. v. Amarlal V. Jumani, (2012) 3 SCC 255: [2012] 3 SCR 114; Morgan Securities & Credit (P) Ltd. v. Modi Rubber Ltd. (2006) 12 SCC 642:[2006] 10 Suppl. SCR 1022; Secur Industries Ltd v. Godrej & Boyce Mfg. Co. Ltd, (2004) 3 SCC 447: [2004] 2 SCR 705; Bhaven Construction v. Sardar Sarovar Narmada Nigam Ltd,(2022) 1 SCC 75: [2021] 1 SCR 1; Girnar Traders v. State of Maharashtra (2011) 3 SCC 1: [2011] 3 SCR 1; Fuerst Day Lawson Ltd. v. Jindal Exports Ltd, (2011) 8 SCC 333: [2011] 11 SCR 1; Pasl Wind Solutions (P) Ltd v. GE Power Conversion (India) (P) Ltd., (2021) 7 SCC 1; Kandla Export Corporation v. OCI Corporation, (2018) 14 SCC 715: [2018] 1 SCR 915; Subal Paul v. Malina Paul, (2003) 10 SCC 361: [2003] 1 SCR 1092; Bihar State Mineral Development Corporation v. Encon Builders (2003) 7 SCC 418: [2003] 2 Suppl. SCR 812; Union of India v. Kishorilal Gupta,1959 SCC OnLine SC 6; Damodar Valley Corporation v. K K Kar (1974) 1 SCC 141: [1974] 2 SCR 240 ; Firm Ashok Traders v. Gurumukh Das Saluja(2004) 3 SCC 155: [2004] 1 SCR 404; National Agricultural Coop. Marketing Federation India Ltd. v. Gains Trading Co. (2007) 5 SCC 692; P Manohar Reddy & Bros. v. Maharashtra Krishna Valley Development Corp. (2009) 2 SCC 494: [2008] 17 SCR 1217; Magma Leasing & Finance Ltd. v. Potluri Madhavilata, (2009) 10 SCC 103: [2009] 14 SCR 815; Arcelor Mittal Nippon Steel (India) Ltd. v. Essar Bulk Terminal Ltd. (2022) 1 SCC 712; A Ayyasamy v. A Paramsivam, (2016) 10 SCC 386: [2016] 11 SCR 521; SPB & Co. v. Patel Engineering Ltd.(2005) 8 SCC 618: [2005] 4 Suppl. SCR 688; National Insurance Co. Ltd. v. Boghara Polyfab Pvt. Ltd.(2009)
1 SCC 267: [2008] 13 SCR 638; Duro Felguera, S A v. Gangavaram Port Ltd. (2017) 9 SCC 729: [2017] 10 SCR 285; Mayavati Trading (P) Ltd. v. Pradyuat Deb Burman (2019) 8 SCC 714: [2019] 12 SCR 123; Shin-Etsu Chemical Co. Ltd. v. Aksh Optifibre Ltd. (2005) 7 SCC 234: [2005] 2 Suppl. SCR 699; CIT v. Hindustan Bulk Carriers, (2003) 3 SCC 57: [2002] 5 Suppl. SCR 387; Sultana Begum v. Prem Chand Jain (1997) 1 SCC 373: [1996] 9 Suppl. SCR 707; Kandla Export Corporation v. OCI Corporation (2018) 14 SCC 715: [2018] 1 SCR 915; Silpi Industries v. Kerala State Road Transport Corporation 2021 SCC OnLine SC 439; LIC v. D.J. Bahadur (1981) 1 SCC 315: [1981] 1 SCR 1083; Sundaram Finance Ltd. v. T. Thankam (2015) 14 SCC 444: [2015] 2 SCR 228; CDC Financial Services (Mauritius) Ltd. v. BPL Communications Ltd., (2003) 12 SCC 140; Empire Jute Co. Ltd. v. Jute Corpn. of India Ltd., (2007) 14 SCC 680: [2007] 11 SCR 388; Associate Builders v. DDA, (2015) 3 SCC 49: [2014] 13 SCR 895; Bhaven Construction v. Sardar Sarovar Narmada Nigam Ltd., (2022) 1 SCC 75: [2021] 1 SCR
1 ; Hameed Joharan v. Abdul Salam (2001) 7 SCC 573: [2001] 1 Suppl. SCR 469; A. Ayyasamy v. A. Paramasivam (2016) 10 SCC 386: [2016]
11 SCR 52; State of U.P. v. Babu Ram Upadhya 1960 SCC OnLine SC 5; Emmar MGF Land Ltd. v. Aftab Singh (2019) 12 SCC 751; Intercontinental Hotels Group (India) (P) Ltd v. Waterline Hotels (P) Ltd.(2022) 7 SCC 662; Jupudi Kesava Rao v. Pulavarthi Venkata Subbarao (1971) 1 SCC 545; Hariom Agrawal v. Prakash Chand Malviya (2007) 8 SCC 514; United India Insurance Co. Ltd. v. Hyundai Engg. & Construction Co. Ltd. (2018)
17 SCC 607; Career Institute Educational Society v. Om Shree Thakurji Educational Society 2023 SCC OnLine SC 586; Indian Farmers Fertilizer Cooperative Limited v. Bhadra Products (2018) 2 SCC 534: [2018] 1 SCR 848; Official Trustee, West Bengal v. Sachindra Nath Chatterjee [1969] 3 SCR 92; NTPC v. Siemens Atkeingesllchaft (2007) 4 SCC 451: [2007] 3 SCR 399; Chloro Controls India (P) Ltd. v. Severn Trent Water Purification Inc.(2013) 1 SCC 641: [2012] 3 SCR 402 and Seka Dobric v. SA Eonsoftech Private Limited (Decision of Supreme Court of India in Arbitration Petition No. 25 of 2023) – referred to.
Sukh Lal Sheikh v. Tara Chand Ta, 1905 SCC OnLine Cal 164; Gulzari Lal Marwari v. Ram Gopal 1936 SCC OnLine Cal 275; Boottam Pitchiah v. Boyapati Koteswara Rao 1964 SCC OnLine AP 5; Mulheim Pipecoatings GmbH v. Welspun Fintrade Ltd., 2013 SCC OnLine Bom 1048 – referred to. Rio Algam v. Sammi Steel Co., Ontario Court of Justice, Canada,
1 March 1991 [1991] O.J. No. 268; Heyman v. Darwins [1942] AC 356; Harbour Assurance Co. (U.K.) Ltd. v. Kansa General International Insurance Co. Ltd. [1993] Q.B. 701; Premium Nafta Products Limited v. Fili Shipping Co. Ltd.[2007] UKHL 40; Prima Paint Corporation v. Flood & Conklin Mfg. Co.,388 US 395 (1967); Buckeye Check Cashing Inc v. Cardegna 546 U.S. 440, 440 (2006); Rent-A-Center, West, Inc. v. Jackson
2 561 U.S. 63 (2010); Dallah Real Estate and Tourism Holding Company v. The Ministry of Religious Affairs, Government of Pakistan [2010] UKSC 46; Malini Ventura v. Knight Capital Pte Ltd [2015] SGHC 225; Tobler v. Justizkommission des Kantons Schwyz, DFT 59 | 177 (1933) – referred to. Gary Born, The Principle of Judicial Non-Interference in International Arbitration Proceedings’ (2009) 30 University of Pennsylvania Journal of International Law 999, 1002; Gary Born, International Arbitration Law and Practice (3rd ed, 2021) 2361; Digest of Case Law on the Model Law on International Commercial Arbitration (2012) 21, 60; Richard Garnett, ‘Article 5 of the Model Law: Protector of the Arbitral Process?’ (2021) 38(2) Journal of International Arbitration 127-146; Redfern and Hunter on International Arbitration (7th edn, Oxford University Press, 2023) 3; Stephen Schwebel, Luke Sobota, and Ryan Manton, International Arbitration: Three Salient Problems (Cambridge University Press, 2nd edn, 2020) 4; Henry Horwitz and James Oldham, ‘John Locke, John Mansfield, and Arbitration during the Eighteenth Century’ (1993) 36(1) The Historical Journal 137, 139; Earl Wolaver, ‘The Historical Background of Commercial Arbitration’ (1934) 83 University of Pennsylvania Law Review 132, 142; Julian D M Lew, ‘Achieving the Dream: Autonomous Arbitration’ (2006) 22(2) Arbitration International 179, 183 and P Ramanatha Aiyar’s The Law Lexicon – referred to.
In the judgment of Sanjiv Khanna, J.
N N Global Mercantile (P) Ltd. v. Indo Unique Flame Ltd. (2023) 7 SCC 1 – overruled.
Vidya Drolia and Others v. Durga Trading Corporation (2021) 2 SCC 1: [2020] 11 SCR 1001 – clarified.
Javer Chand and Others. v. Pukhraj Surana AIR 1961 SC 1655: [1962]
2 SCR 333; State of Bihar v. M/s Karam Chand Thapar and Brothers Ltd. AIR 1962 SC 110: [1962] 1 SCR 827; Jupudi Kesava Rao v. Pulavarthi Venkata Subbarao and Others (1971) 1 SCC 545: [1971] 3 SCR 590; Hameed Joharan (Dead) and Others v. Abdul Salam (Dead) by LRs. and Others (2001) 7 SCC 573: [2001] 1 Suppl. SCR 469; Dr. Chiranji Lal (D) by LRs. v. Hari Das (D) by LRs. (2005) 10 SCC 746: [2005] 1 Suppl. SCR 359; Hariom Agrawal v. Prakash Chand Malviya (2007) 8 SCC 514: [2007] 10 SCR 772; Shyamal Kumar Roy v. Sushil Kumar Agarwal (2006)
11 SCC 331: [2006] 8 Suppl. SCR 47; Avinash Kumar Chauhan v. Vijay Krishna Mishra (2009) 2 SCC 532: [2008] 17 SCR 944; Keshav Mills Co. Ltd. v. Commissioner of Income Tax, Bombay North, Ahmedabad, AIR 1965 SC 1636: [1965] 2 SCR 908; Government of Andhra Pradesh and Others v. A.P. Jaiswal and Others, (2001) 1 SCC 748; Total Environment Building Systems Pvt. Ltd. v. Deputy Commissioner of Commercial Taxes and Others, 2022 SCC OnLine SC 953; Union of India and Another v. Raghubir Singh (Dead) by LRs. etc., (1989) 2 SCC 754: [1989] 3 SCR 316; Caravel Shipping Services (P) Ltd. v. Premier Sea Foods Exim (P) Ltd. (2019) 11 SCC 461: [2018] 14 SCR 289; Govind Rubber Ltd. v. Louis Dreyfus Commodities Asia Pvt. Ltd. (2015) 13 SCC 477: [2014] 12 SCR 488; B.O.I. FinanceLtd. v. Custodian and Others (1997) 10 SCC 488: [1997]
3 SCR 51; Canara Bank and Others v. Standard Chartered Bank (2002)
10 SCC 697; Swiss Timing Ltd. v. Commonwealth Games 2010 Organising Committee (2014) 6 SCC 677: [2014] 6 SCR 514; Avitel Post Studioz Ltd. v. HSBC PI Holdings (Mauritius) Ltd. (2021) 4 SCC 713: [2020] 10 SCR 791; Career Institute Educational Society v. Om Shree Thakurji Educational Society 2023 SCC OnLine SC 586 and Garware Wall Ropes Ltd. v. Coastal Marine Constructions & Engg. Ltd. (2019) 9 SCC 209: [2019] 5 SCR 579 – referred to.
Ram Rattan v. Parma Nand AIR 1946 PC 51– referred to. BNA v. BNB and Another [2019] SGHC 142 and Insigma Technology Co Ltd v. Alstom Technology Ltd [2009] SGCA 24 – referred to. OTHER CASE DETAILS INCLUDING IMPUGNED
ORDER AND APPEARANCES
As published in the Supreme Court Reports, Supreme Court of India. Text from the Indian Supreme Court Judgments open data set (Dattam Labs), CC BY 4.0.
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