Interim relief in arbitration is available from two sources: a court under Section 9 of the Arbitration and Conciliation Act, 1996, and the arbitral tribunal under Section 17 of the same Act. Section 9 runs across the whole life of a dispute, before the arbitration begins, while it is on foot, and after the award is made but before it is enforced. Section 17 runs only while the tribunal holds office, and an order made under it is enforced as though it were an order of the court. In April 2026 the Supreme Court settled a long-running High Court conflict by holding that even a party that lost the arbitration may apply under Section 9 after the award.
This article sets out how interim relief in arbitration works across the life of a dispute, and where the limits of each provision now sit.
For most applicants the choice between the two provisions is a question of timing rather than strategy. Before a tribunal exists there is only Section 9. Once a tribunal is in place, Section 9(3) pushes the applicant towards Section 17 unless the court finds a circumstance that makes the tribunal’s remedy inefficacious.
The settled comparison between the two provisions is well covered ground. The harder questions now sit at the edges: what happens after the award, how far a tribunal can go before its interim order starts deciding the case, what an appeal against such an order actually tests, and how the scheme behaves when the seat is abroad or the target is not a party.
How interim relief in arbitration works under Section 9 and Section 17
Interim relief in arbitration works through two provisions that grant the same substantive powers to different forums. Section 9 of the Arbitration and Conciliation Act, 1996 empowers a court to order interim measures. Section 17 empowers the arbitral tribunal to do the same. The powers overlap almost entirely; what separates them is when each is available and whom each can reach.
Section 9(1) fixes an unusually wide window. A party may apply before the commencement of arbitral proceedings, during those proceedings, or at any time after the arbitral award is made but before it is enforced under Section 36. That third limb is the one most often overlooked, and it is the subject of the most significant recent development in this area.
The measures themselves fall into two groups. Section 9(1)(i) covers the appointment of a guardian for a party under disability. Section 9(1)(ii) covers the commercially significant reliefs: preservation, interim custody or sale of goods, securing the amount in dispute, detention or inspection of property, interim injunctions, and the appointment of a receiver.
Does Section 17 give the tribunal the same power as a court?
Section 17(1) gives the arbitral tribunal the same power as the court, exercisable during the arbitral proceedings. The drafting is deliberate: the tribunal has “the same power for making orders, as the court has for the purpose of, and in relation to, any proceedings before it”.
What changed the practical value of Section 17 was the 2015 amendment. Section 17(2) now provides that an order issued by the tribunal is deemed to be an order of the court and is enforceable under the Code of Civil Procedure, 1908, in the same manner as if it were an order of that court. Before 2015 a tribunal could grant relief but had no direct means of enforcing it, which made Section 17 a considerably weaker instrument than it now is.
Section 9(3) governs the relationship between the two. Once the arbitral tribunal has been constituted, the court shall not entertain a Section 9 application unless it finds that circumstances exist which may not render the remedy under Section 17 efficacious. The provision is a filter rather than a bar, but it places the burden on the applicant to explain why the tribunal cannot do the job.
What must an applicant prove to get interim relief?
An applicant must prove a good prima facie case, a balance of convenience favouring relief, and a likelihood of irreparable harm, on a standard that tracks ordinary injunction principles. In Essar House Private Limited v. ArcelorMittal Nippon Steel India Limited, (2022) 20 SCC 178, the Supreme Court set out what the court examines at paragraph 47, a passage the Court returned to in 2026:
“Section 9 of the Arbitration Act confers wide power on the Court to pass orders securing the amount in dispute in arbitration, whether before the commencement of the arbitral proceedings, during the arbitral proceedings or at any time after making of the arbitral award, but before its enforcement in accordance with Section 36 of the Arbitration Act. All that the Court is required to see is, whether the applicant for interim measure has a good prima facie case, whether the balance of convenience is in favour of interim relief as prayed for being granted and whether the applicant has approached the court with reasonable expedition.”
Three elements, then, plus a fourth that applicants frequently neglect: reasonable expedition. Delay in approaching the court undercuts the claim of urgency that justifies interim intervention in the first place.
One point of statutory history matters for the section that follows. Under Section 18 of the Arbitration Act, 1940, the grant of interim measures was expressly confined to the successful party and directed solely at ensuring enforcement of the award. The 1996 Act carries no equivalent restriction, and the Supreme Court has treated that omission as deliberate.
Interim relief in arbitration: the two routes compared
Same powers, different forums, different windows
Section 9, the court
COURT
- WindowBefore the arbitration, during it, and after the award until enforcement under Section 36
- ForumThe court identified by Section 2(1)(e)
- ReachParties, and arguably certain non-parties (unsettled)
- EnforcementDirectly, as an order of the court
- AppealSection 37(1)(b)
- FilterSection 9(3): once the tribunal exists, the applicant must show the Section 17 remedy would not be efficacious
Section 17, the tribunal
TRIBUNAL
- WindowOnly while the tribunal holds office; closes on the award
- ForumThe arbitral tribunal itself
- ReachOnly the parties before the tribunal
- EnforcementDeemed an order of the court under Section 17(2), enforceable under the CPC, 1908
- AppealSection 37(2)(b)
- LimitMust preserve a position, not decide the dispute (Khurana Educational Society, 2026)
The test in either forum: a good prima facie case, balance of convenience, likelihood of irreparable harm, and approach with reasonable expedition. (Essar House Private Limited v. ArcelorMittal Nippon Steel India Limited, (2022) 20 SCC 178, para 47)
Sources: Arbitration and Conciliation Act, 1996, ss. 2(1)(e), 9, 17, 36, 37; Essar House, (2022) 20 SCC 178; Khurana Educational Society v. Shashi Bala (Delhi HC, 26 February 2026)iPleaders
Should you seek interim relief from the court or the arbitral tribunal?
Choosing between Section 9 and Section 17 turns on four questions that can be answered before any application is drafted. Has the tribunal been constituted, and can it actually deliver the relief sought? Does the relief need to operate against someone who is not a party, and is the matter urgent enough that waiting for the tribunal to sit would defeat the purpose?
The first question is usually dispositive. Before constitution, Section 9 is the only route, and the applicant should be alive to the fact that a Section 9 application filed before the arbitration begins carries an obligation to commence arbitral proceedings within ninety days of the order, or within such further time as the court determines.
Where the tribunal exists, Section 17 is generally the better route on cost and speed, provided the tribunal is sitting. It avoids the court queue, the tribunal already knows the dispute, and since 2015 the resulting order is enforceable in the same way as a court order. The application to the tribunal is also less exposed to the procedural objections that attach to court filings.
Where do Section 9 and Section 17 each fall short?
Section 17 has three real limitations. The tribunal is not continuously in session, so genuinely urgent relief may be difficult to obtain quickly. The tribunal’s authority runs only to the parties before it, so relief that must bind a bank, a depository or a purchaser sits awkwardly within it. And the tribunal becomes functus officio once it delivers the award, at which point Section 17 closes entirely.
Section 9 has its own weaknesses. It is a court process with the delay that implies, and Section 9(3) is a genuine filter once the tribunal is constituted rather than a formality. Courts have declined Section 9 applications where the applicant could not explain what made the Section 17 remedy inefficacious.
A short comparison of the two provisions:
| Section 9 | Section 17 | |
|---|---|---|
| Forum | Court under Section 2(1)(e) | Arbitral tribunal |
| Window | Before, during, and after the award until enforcement | Only during arbitral proceedings |
| Binds | Parties, and arguably certain non-parties | Parties before the tribunal only |
| Enforcement | Directly, as a court order | Deemed a court order under Section 17(2) |
| Appeal | Section 37(1)(b) | Section 37(2)(b) |
What the application must establish is the same in either forum, and the drafting burden is heavier than the short statutory language suggests. A practical treatment of what goes into the pleading is set out in this guide to drafting a Section 9 petition.
The timing of constitution therefore matters more than it appears, and the mechanics of when a tribunal comes into existence are covered in our guide to the appointment of arbitrators under Section 11. Who may apply at all depends on being a party to the agreement, a question addressed in our treatment of the arbitration agreement under Section 7.
Can interim relief in arbitration be granted after the award?
Interim relief in arbitration can be granted after the award under Section 9, and since April 2026 it is available to both sides rather than only to the winner. The statutory window stays open from the making of the award until enforcement under Section 36, which in practice covers the entire period during which a Section 34 challenge is pending.
For more than a decade the High Courts were split on who could use that window. The restrictive view held that post-award relief under Section 9 existed only to protect the “fruits of the arbitration”, so a party that had lost had nothing to protect and no standing to apply. That position was taken by the Bombay High Court in Dirk India Pvt. Ltd. v. Maharashtra State Electricity Generation Co. Ltd., 2013 SCC OnLine Bom 481, by the Delhi High Court in Nussli Switzerland Ltd. v. Organizing Committee Commonwealth Games 2010, 2014 SCC OnLine Del 4834 and in National Highways Authority of India v. Punjab National Bank, 2023 SCC OnLine Del 4810, by the Karnataka High Court in Padma Mahadev v. Sierra Constructions Private Limited, COMAP No. 2 of 2021, and by the Madras High Court in A. Chidambaram v. S. Rajagopal, OA No. 843 of 2024.
The contrary view came from the Telangana High Court in Saptarishi Hotels Pvt. Ltd. v. National Institute of Tourism and Hospitality Management, 2019 SCC OnLine TS 1765, the Gujarat High Court in GAIL (India) Ltd. v. Latin Rasayani Pvt. Ltd., 2014 SCC OnLine Guj 14836, and the Punjab and Haryana High Court in DLF Home Developers Ltd. v. Orris Infrastructure Pvt. Ltd., FAO-CARB-51-2024 (O&M), decided on 21 February 2025. These courts read the statutory word “party” as carrying no qualification based on the outcome of the arbitration.
What did the Supreme Court hold on post-award Section 9 in April 2026?
The Supreme Court resolved the conflict in Home Care Retail Marts Pvt. Ltd. v. Haresh N. Sanghavi, 2026 INSC 415, decided on 24 April 2026. The question, framed at paragraph 2, was whether a Section 9 petition at the post-award stage, brought by a party that lost in the arbitration and holds no enforceable award, is maintainable in law.
The Court held at paragraph 62 that “any party to an arbitration agreement, including an unsuccessful party in arbitration, may invoke Section 9 of the Act at the post-award stage”. The restrictive High Court decisions, it held at paragraph 61, do not lay down good law, and the Telangana, Gujarat and Punjab and Haryana view correctly reflects the statutory position.
Three strands of reasoning support the conclusion. The first is textual: the expressions “subject matter of arbitration” and “amount in dispute” in Section 9(1)(ii) are, at paragraph 47, “broader in scope, width and amplitude than the phrase ‘fruits of arbitration’”, so a restriction to securing the successful party’s claim cannot be read into plain language. The second is historical: Section 18 of the 1940 Act expressly confined interim measures to the successful party and the 1996 Act does not, which the Court treated at paragraph 48 as manifest legislative intent.
The third strand is practical, and it is the part a practitioner will actually use. At paragraph 49 the Court set out situations where a losing party genuinely needs protection: where an award has been rendered without proper notice to a party, and where a party can prima facie show that the award was induced or tainted by fraud or corruption. It also identified the bank guarantee problem. A party that obtained interim protection restraining invocation of a guarantee ordinarily loses that protection when the award is made, yet it may be challenging the award under Section 34 with a stay on enforcement under Section 36(3), and immediate removal of the protection may cause irreversible prejudice while the challenge remains undecided.
At paragraph 51 the Court added the partially successful party. A claimant whose claims partly succeed but who is branded unsuccessful because a larger counter-claim was allowed would, on the restrictive view, be unable to stop the other side dissipating assets, even though a Section 34 court might later sever the counter-claim from the award.
How high the threshold is for a party that lost the arbitration
The threshold for a party that lost the arbitration is deliberately high, because the ruling does not make post-award relief easy. At paragraph 60 the Court held that “the threshold for grant of interim relief will be higher in the case of an unsuccessful party in arbitration seeking such relief”, and confined the remedy to “rare and compelling cases”. At paragraph 62 it directed courts to exercise “care, caution and circumspection” when dealing with such applications.
Two connected points are worth carrying away. The Court leaned at paragraph 52 on Gayatri Balasamy v. ISG Novasoft Technologies Ltd., 2025 INSC 605, decided on 30 April 2025, in which a Constitution Bench held by a four to one majority that a court has a limited power under Sections 34 and 37 to modify an award, including by severing the invalid portion from the valid. Because a Section 34 court can now alter an award rather than only set it aside or uphold it, the losing party’s stake in the post-award period is more substantial than it once was.
The second is limitation. Section 43(4) excludes the period between the commencement of arbitration and the date of the court’s order when computing limitation for fresh proceedings, so a party whose award is set aside is not left without time to arbitrate again. The grounds on which an award may be set aside are covered in our guide to setting aside an arbitral award under Section 34.
When each remedy is open
Interim relief across the life of a dispute
Before arbitration beginsPhase 1
Tribunal constitutedPhase 2
Award madePhase 3
Section 34 challenge pendingPhase 4
Award enforcedPhase 5
The 2026 change sits in phases 3 and 4. A party that lost the arbitration may now invoke Section 9 at the post-award stage, on a higher threshold and in rare and compelling cases only. (Home Care Retail Marts Pvt. Ltd. v. Haresh N. Sanghavi, 2026 INSC 415, paras 60 and 62)
Sources: Arbitration and Conciliation Act, 1996, ss. 9, 9(2), 9(3), 17, 34, 36, 36(3); Home Care Retail Marts, 2026 INSC 415 (24 April 2026)iPleaders
What an arbitral tribunal cannot order as interim relief under Section 17
An arbitral tribunal cannot order, as interim relief under Section 17, anything that decides the dispute rather than preserving a position pending adjudication. An order that resolves a contested issue in substance is not saved by being labelled interim.
The Delhi High Court applied that principle in Khurana Educational Society (Regd.) v. Shashi Bala, decided on 26 February 2026. An arbitrator had directed a party to deposit Rs 3,00,000 per month towards disputed mesne profits or usage charges while the arbitration continued. The court set that direction aside, holding that it exceeded the permissible contours of interim jurisdiction under Section 17 and amounted to partial final adjudication of issues that remained undecided.
Two features of the decision repay attention. The court criticised the evidentiary basis for the figure, noting that the arbitrator had relied on lease deeds from 2021 to 2025 to fix charges for 2018 without scrutinising whether those comparators were genuinely comparable. And it did not set aside the whole order: the protective directions in the same order, permitting inspection of the property and restraining the creation of third-party interests, were upheld.
That division marks the practical line. Measures that hold a position steady, inspection, preservation, restraint on transfer or on creating third-party rights, sit comfortably within Section 17. Directions that require a party to pay a quantified sum calculated on a contested measure of damages are a different matter, because fixing the figure means deciding the dispute.
Courts approach Section 9 applications for security in a similar spirit, treating Order 38 Rule 5 and Order 39 of the Code of Civil Procedure, 1908 as a guide to the principles rather than as provisions to be applied mechanically. In Essar House the Supreme Court was explicit that the technical rigour of those provisions does not straitjacket the arbitral court, while the underlying requirement of a genuine risk to the amount in dispute remains.
Can an interim relief order be appealed under Section 37?
An interim relief order is appealed under Section 37, and the route differs depending on which forum made the order. Section 37(1)(b) provides an appeal from an order of a court granting or refusing a measure under Section 9. Section 37(2)(b) provides an appeal from an order of the arbitral tribunal granting or refusing a measure under Section 17.
What the appeal tests is narrower than a rehearing. An interim order is a discretionary order, and an appellate court applies the standard developed for injunctions in Wander Ltd. v. Antox India Pvt. Ltd., 1990 (Supp) SCC 727: the appellate court does not substitute its own view merely because it would have reached a different conclusion, and interferes only where the discretion has been exercised arbitrarily, capriciously or perversely, or where the order ignores settled principles.
The practical consequence is that an appeal is a poor substitute for getting the original application right. An appellant who can only argue that the balance of convenience should have been struck differently is unlikely to succeed. An appellant who can show that the tribunal or court applied the wrong test, ignored a relevant consideration, or granted what was in substance final relief is on considerably stronger ground, which is why the reasoning in Khurana Educational Society matters beyond its own facts.
Section 37(3) bars a second appeal, though the right to appeal to the Supreme Court under Article 136 of the Constitution is preserved. On limitation, appeals falling within the scheme of the Commercial Courts Act, 2015 must be filed within sixty days from the date of the order under Section 13(1A) of that Act. Courts have taken a strict view of delay in Section 37 appeals, and applications for condonation supported by generic explanations have been refused.
Is Section 9 interim relief available in a foreign seated arbitration?
Section 9 interim relief is available in a foreign seated arbitration, but only because Parliament restored it by amendment after the Supreme Court had removed it. The current position rests on a proviso rather than on the main provision, and it can be excluded by agreement, which makes the drafting of the arbitration clause decisive.
The starting point is Bharat Aluminium Co. v. Kaiser Aluminium Technical Services Inc., (2012) 9 SCC 552, in which a Constitution Bench held that Part I of the Act, and so Section 9, does not apply to arbitrations seated outside India. The consequence was that a party to a foreign-seated arbitration with assets or a counterparty in India had no Indian route to interim protection.
The Arbitration and Conciliation (Amendment) Act, 2015 inserted a proviso to Section 2(2) which reverses that result in part. Sections 9, 27 and 37(1)(a) apply to an international commercial arbitration even where the place of arbitration is outside India, unless the parties have agreed to the contrary. The relief is therefore available by default and can be contracted away.
When an arbitration agreement impliedly excludes Section 9
An arbitration agreement impliedly excludes Section 9 when it amounts to an agreement to the contrary, and what qualifies is the live issue. Parties rarely write “Section 9 shall not apply”, so courts have had to decide whether the choice of a foreign seat, a foreign curial law, or a set of institutional rules containing their own emergency provisions impliedly excludes the Indian remedy. The answers have not been uniform, and an applicant should expect the point to be argued.
Two practical propositions are reasonably settled. A Section 9 order does not presuppose that the respondent holds assets in India: the Delhi High Court so held in Goodwill Non-Woven (P) Limited v. Xcoal Energy & Resources LLC, decided on 13 June 2020, reasoning that security furnished under such an order can be realised by the Indian party regardless of where the foreign entity’s assets sit. And a Section 9 application in support of a foreign-seated arbitration is decided on its own merits under Indian law, not as a mechanism for enforcing what a foreign tribunal has already ordered.
That second proposition explains the treatment of emergency awards from a foreign seat. In Raffles Design International India Pvt. Ltd. v. Educomp Professional Education Ltd., decided on 7 October 2016, the Delhi High Court held that an emergency award from a Singapore-seated arbitration was not directly enforceable in India, while leaving the party free to apply under Section 9 on the merits. In Ashwani Minda v. U-Shin Ltd., decided on 7 July 2020 in the context of a Japan-seated arbitration, the same court declined to grant relief where an emergency arbitrator had already considered and refused it, treating the Section 9 application as an attempt at a second bite.
The position for arbitrations seated in India is different, because an emergency arbitrator’s order there has been treated as an order under Section 17 and enforced accordingly. The distinction is one of seat, not of the merits of emergency relief as an institution.
A word on the legislative horizon, stated precisely because it is often overstated. The Arbitration and Conciliation (Amendment) Bill, 2024 is a consultation draft published by the Department of Legal Affairs. It has not been introduced in Parliament, has not been referred to a standing committee, and has not received assent.
Its proposals, which include express provision for emergency arbitrators and a narrowing of the court’s interim powers while the tribunal is seized, are not law. The governing statute remains the 1996 Act as amended in 2015, 2019 and 2021.
Because the remedy can be excluded by agreement, the clause deserves attention at the drafting stage rather than at the point of crisis, a discipline that applies to cross-border contracting generally and is discussed in this guide to drafting contracts for foreign clients.
Can interim relief be granted against a third party or non-signatory?
Whether interim relief can be granted against a third party or non-signatory is unsettled under Section 9, and any account that presents it as resolved is overstating the position. There is no binding Supreme Court ruling squarely on the question, and the High Courts have divided.
Section 17 raises no comparable difficulty, because the answer is clear and negative. A tribunal derives its authority from the arbitration agreement and can bind only those before it, so an order under Section 17 cannot operate against a stranger to the reference. The question is whether Section 9, being an exercise of judicial power, reaches further.
The permissive line is the older one. In CREF Finance Ltd. v. Puri Construction Ltd., decided by the Delhi High Court in 2000, relief was granted in circumstances that operated against an entity that had not signed the arbitration agreement. In Arun Kapoor v. Vikram Kapoor, decided in 2001, the court observed that an application under Section 9 is not limited to parties to the proceedings and that the remedy may lie against a person who is not a party to the arbitration agreement, expressly distinguishing Section 9 from Section 17 on that footing.
The restrictive line runs the other way. In Shoney Sanil v. Coastal Foundations (P) Ltd., decided by the Kerala High Court in 2006, the court held that the scheme of the Act does not permit the court’s power under Section 9 to interfere with the rights of third parties, and that interim measures may be granted only against parties to the agreement or those claiming under them.
A distinction drawn in practice helps reconcile some of the case law without pretending the conflict is resolved. An order that operates on a party’s own asset which happens to be in a third party’s hands, a bank account, shares held with a depository, sums due from a debtor, affects the third party incidentally and is more readily granted. An order that determines a third party’s own substantive rights is a different thing, and is where the restrictive reasoning has most force. An applicant seeking relief that touches a non-party should expect to justify it on that basis and should not assume the point is settled.
Frequently asked questions
Can a party that lost the arbitration still apply under Section 9?
Yes. In Home Care Retail Marts Pvt. Ltd. v. Haresh N. Sanghavi, 2026 INSC 415, decided on 24 April 2026, the Supreme Court held that any party to an arbitration agreement, including an unsuccessful party, may invoke Section 9 at the post-award stage. The threshold is higher than for a successful party and the remedy is confined to rare and compelling cases, with courts directed to act with care, caution and circumspection.
Until when does Section 9 remain available after the award?
Section 9(1) allows an application at any time after the arbitral award is made but before it is enforced in accordance with Section 36. In practice this covers the period during which a challenge under Section 34 is pending, since enforcement does not follow automatically from the making of the award.
Does Section 9(3) bar a court application once the tribunal is constituted?
Not absolutely. Section 9(3) provides that the court shall not entertain a Section 9 application after the tribunal is constituted unless it finds that circumstances exist which may not render the Section 17 remedy efficacious. It is a filter that shifts the burden to the applicant, not a jurisdictional bar, and the applicant must explain what makes the tribunal’s remedy inadequate on the facts.
How is an order under Section 17 enforced?
Section 17(2), inserted by the 2015 amendment, deems an order of the arbitral tribunal to be an order of the court and makes it enforceable under the Code of Civil Procedure, 1908, in the same manner as an order of that court. No separate proceeding to convert the tribunal’s order into a court order is required.
Can an arbitral tribunal order a party to deposit money at the interim stage?
Only where the direction preserves a position rather than decides the dispute. In Khurana Educational Society (Regd.) v. Shashi Bala, decided on 26 February 2026, the Delhi High Court set aside a direction to deposit monthly mesne profits, holding that it exceeded the permissible contours of Section 17 and amounted to partial final adjudication while foundational issues remained unresolved. Protective directions in the same order, including inspection and a restraint on creating third-party interests, were upheld.
On what grounds can an interim order be appealed?
An appeal lies under Section 37(1)(b) against a court’s Section 9 order and under Section 37(2)(b) against a tribunal’s Section 17 order. The appellate court does not rehear the application; following Wander Ltd. v. Antox India Pvt. Ltd., 1990 (Supp) SCC 727, it interferes only where the discretion was exercised arbitrarily, capriciously or perversely, or where settled principles were ignored. A second appeal is barred by Section 37(3), leaving only Article 136.
Is Section 9 available when the arbitration is seated outside India?
Yes, by virtue of the proviso to Section 2(2) inserted by the 2015 amendment, which applies Sections 9, 27 and 37(1)(a) to international commercial arbitrations seated outside India unless the parties agree otherwise. Before that amendment, Bharat Aluminium Co. v. Kaiser Aluminium Technical Services Inc., (2012) 9 SCC 552 had held Part I inapplicable to foreign-seated arbitrations. Whether a given agreement impliedly excludes the remedy is frequently litigated.
Can interim relief be obtained against someone who did not sign the arbitration agreement?
Under Section 17, no, because the tribunal’s authority extends only to the parties before it. Under Section 9 the position is unsettled: the Delhi High Court has granted relief affecting non-signatories in CREF Finance Ltd. v. Puri Construction Ltd. (2000) and Arun Kapoor v. Vikram Kapoor (2001), while the Kerala High Court in Shoney Sanil v. Coastal Foundations (P) Ltd. (2006) held that Section 9 cannot interfere with third-party rights. There is no binding Supreme Court ruling on the point.
References
Case law
- A. Chidambaram v. S. Rajagopal, OA No. 843 of 2024 (Madras High Court)
- Arun Kapoor v. Vikram Kapoor (2001) (Delhi High Court)
- Bharat Aluminium Co. v. Kaiser Aluminium Technical Services Inc., (2012) 9 SCC 552
- Ashwani Minda v. U-Shin Ltd., decided 7 July 2020 (Delhi High Court)
- CREF Finance Ltd. v. Puri Construction Ltd. (2000) (Delhi High Court)
- Dirk India Pvt. Ltd. v. Maharashtra State Electricity Generation Co. Ltd., 2013 SCC OnLine Bom 481
- DLF Home Developers Ltd. v. Orris Infrastructure Pvt. Ltd., FAO-CARB-51-2024 (O&M), decided 21 February 2025 (Punjab and Haryana High Court)
- Essar House Private Limited v. ArcelorMittal Nippon Steel India Limited, (2022) 20 SCC 178
- GAIL (India) Ltd. v. Latin Rasayani Pvt. Ltd., 2014 SCC OnLine Guj 14836
- Gayatri Balasamy v. ISG Novasoft Technologies Ltd., 2025 INSC 605 (Supreme Court judgment PDF)
- Goodwill Non-Woven (P) Limited v. Xcoal Energy & Resources LLC, decided 13 June 2020 (Delhi High Court)
- Home Care Retail Marts Pvt. Ltd. v. Haresh N. Sanghavi, 2026 INSC 415 (Supreme Court judgment PDF)
- Khurana Educational Society (Regd.) v. Shashi Bala, decided 26 February 2026 (Delhi High Court)
- National Highways Authority of India v. Punjab National Bank, 2023 SCC OnLine Del 4810
- Nussli Switzerland Ltd. v. Organizing Committee Commonwealth Games 2010, 2014 SCC OnLine Del 4834
- Padma Mahadev v. Sierra Constructions Private Limited, COMAP No. 2 of 2021, decided 22 March 2021 (Karnataka High Court)
- Raffles Design International India Pvt. Ltd. v. Educomp Professional Education Ltd., decided 7 October 2016 (Delhi High Court)
- Saptarishi Hotels Pvt. Ltd. v. National Institute of Tourism and Hospitality Management, 2019 SCC OnLine TS 1765
- Shoney Sanil v. Coastal Foundations (P) Ltd. (2006) (Kerala High Court)
- Wander Ltd. v. Antox India Pvt. Ltd., 1990 (Supp) SCC 727
Statutes
- Arbitration and Conciliation Act, 1996 sections cited: 2(1)(e), 2(2) proviso, 9, 9(3), 17, 17(2), 27, 34, 36, 36(3), 37, 43(4)
- Arbitration Act, 1940 section cited: 18
- Code of Civil Procedure, 1908 provisions cited: Order 38 Rule 5, Order 39
- Commercial Courts Act, 2015 section cited: 13(1A)
Related reading
This article is for informational and educational purposes only and does not constitute legal advice. Readers should consult a qualified legal practitioner for advice on their specific circumstances.
