Scope of Judicial Interference in International Commercial Arbitration


International commercial arbitration is an alternative method of resolving disputes between private parties arising out of commercial transactions conducted across national boundaries that allows the parties to avoid litigation in national courts. However, there is a distinction in the process for enforcement of an award based on the seat of arbitration. While the enforcement and execution of an India - seated arbitral award (“domestic award”) would be governed by the provisions of Part I of the Act[1], enforcement of foreign - seated awards (“foreign award”) would be governed by the provisions of Part II of the Act[2] which subsequently is in consonance with the New York Convention[3] and Geneva Convention respectively[4]. India is a signatory to both .

Section 44 of the Arbitration and Conciliation Act 1996 defines “foreign award” as an arbitral award, arising out of legal relationships which are considered as commercial under the law in force in India, in one of such territories which the Central Government notifies to the territories to which the said Conventions applies. Therefore any foreign award received by a party/country under the ICC arbitration regime who is a signatory to either New York Convention or the Geneva Convention can get the same enforced within the territory of India.

APPROPRIATE COURT/ FORUM FOR APPLICATION
Where the subject matter of a Foreign Award is money, the jurisdiction for the execution of arbitral award will be with the Commercial Division of those High Courts, in whose jurisdiction, the assets of the opposite party shall lie and otherwise the jurisdiction will lie with the Commercial Division of those High Court which would have jurisdiction if the subject matter of the award was a subject matter of a suit.

EFFECTIVE ENFORCEMENT
Section 47(1)[5] of the Act of 1996 specifies that a party, in whose favour the award is issued, shall make an application under section 47 and shall produce documents and evidence along with the application.
Secondly, the other party is to raise a defence as per section 48 with evidence and thirdly, the court, if it is satisfied with the evidence produced by the parties, decide on the enforceability of the award and enforce it under section 49 of the Act.

The Supreme court in P.E.C Limited Versus Austbulk Shipping [6]has interpreted the word ‘shall’ has to be read as  ‘may’ and further observed that such an interpretation would mean that a party applying for enforcement of the award need not necessarily produce before the court a document mentioned therein “at the time of the application”. Nonetheless, it further clarified that such interpretation of the word “shall” as “may” is restricted “only to the initial stage of the filing of the application and not thereafter.”

Section 48 specifies certain conditions for enforcement of foreign awards. The other party also can raise a defence as per section 48 with evidence. The Courts can though intervene only to limited extents as stated above and shall not be entitled to go into the merits of the case as the same has not been provided in the scheme of the Act. The concerned court, if it is satisfied with the evidence produced by the parties, decide on the enforceability of the award and enforce it under section 49[7] of the Act like a decree of the Court and shall issue warrants of attachment/ execution.
In case of a refusal for enforcement an appeal would lie only to the Supreme Court under Article 136 on very limited grounds. Such principles hold the value of mutual recognition of arbitral awards in International Arbitrating Community. In cases of execution of such Awards which are not passed in Countries with whom India has a reciprocal treaty, the Award has to be filed as a regular civil suit and the proceedings would be the same as are applicable to a civil suit filed in India.

WHAT DO THE CONVENTIONS SAY?
As discussed above, foreign awards are majorly of two kinds, New York Convention Awards (Section 48) and Geneva Convention Awards (Section 57) of Arbitration and Conciliation Act, 1996. It is relevant to mention here that both the awards are two be enforced by the Indian Courts, on certain conditions which are mentioned in Section 48 and Section 57 respectively. The different type of Awards which are enforceable include Money Award, Award Containing Injunction and Declaratory Awards. The said conditions are mentioned as under:

Conditions for Enforcement of New York Convention Awards:

Ø  That the subject agreement is not in accordance with the law to which the parties have subjected it or under the law of the country where the foreign award was made.
Ø   The award is ultra vires to the agreement.
Ø   The award contains decision on matters beyond the scope of arbitration.
Ø  The arbitral procedure was not in accordance with the law of the country where the arbitration took place.
Ø   The foreign award has not yet become binding on the parties or was set aside by the higher authority of the country in which that award was made.
Ø   Enforcement of foreign award will be contrary to public policy of India.
Ø  Subject matter of the dispute is not capable of settlement under the Indian Arbitration & Conciliation Act, 1996.
Ø   The parties to the agreement were under some incapacity
Ø   There is a failure to give proper notice of appointment of arbitrator or arbitral proceedings or the party against whom the award was rendered was otherwise unable to present his case.
Ø   Composition of the arbitral authority or the arbitral procedure is ultra vires agreement

Moving on, Section 57 lays down several conditions for enforcement of Geneva Convention Awards in India. The procedure for enforcement of foreign awards under the Geneva Convention of 1937 and the New York Convention of 1958 are much the same. Any person interested in enforcing a foreign award may apply in writing to any court having jurisdiction over the subject matter of the award. In addition to filing of the award and the agreement on which it is based as required by the Convention, the Act requires that evidence as to the award being a foreign award has to be filed.

The said conditions, as laid in Section 57 are as under:

Ø  The award has been made in pursuance of a submission to arbitration which is valid under the law applicable thereto;
Ø  The subject-matter of the award is capable of settlement by arbitration under the law of India;
Ø  The award has been made by the arbitral tribunal provided for in the submission to arbitration or constituted in the manner agreed upon by the parties and in conformity with the law governing the arbitration procedure;
Ø  The award has become final in the country in which it has been made, in the sense that it will not be considered as such if it is open to opposition or appeal or if it is proved that any proceedings for the purpose of contesting the validity of the award are pending;
Ø  The enforcement of the award is not contrary to the public policy or the law of India

THE TWO RESERVATIONS OF INDIA
India has made two reservations while ratifying the Conventions namely,

(i)  That it would apply the Conventions to the recognition and enforcement of an award only if it was made in the territory of another contracting State.
·         In pursuance of the said reservation, the two implementing Acts of 1937 and 1961 provide that the Government of India will notify the names of countries to which the Convention would apply and which countries had made reciprocal provisions for the enforcement of Indian awards in those countries.
(ii)  That India would apply the Convention only to differences arising out of legal relationship which are considered 'commercial' under Indian Law.
·         Courts have interpreted the term 'commercial dispute' under the two Acts, in certain decisions where the question was at issue

JURISPRUDENCE, AS DEVELOPED BY THE COURTS
Before delving into the question of the process adopted by Indian Courts in enforcing the Foreign Arbitral Awards, and the factors affecting the view of the Court, we must ask ourselves one question, as to what would happen to awards, not passed in countries, and which are not signatories to New York and Geneva Convention. The answer to the same would be, that such awards would be enforced by instituting a regular civil suit in Indian Courts on the basis of the said award, in such a case, award would be considered as evidence under the Evidence Act.

In M/s Fuerst Day Lawson Ltd. V. Jindal Exports Ltd.[8] , the Hon'ble Apex Court held as under:

In one proceeding there may be different stages. In the first stage the Court may have to decide about the enforceability of the award having regard to the requirement of the said provisions. Once the court decides that foreign award is enforceable, it can proceed to take further effective steps for execution of the same. There arises no question of making foreign award as a rule of court/decree again.”

Furthermore in Venture Global Engineering Vs Satyam Computer Services Ltd. [9] held that a foreign award can be set aside by an Indian Court u/s 34 of the Arbitration and Conciliation Act, 1996. In that particular case, the Court clearly held that the award was actuated by fraud, and hence contrary to the public policy, and thus incapable of being enforced.

However, the pro-enforcement view of the Apex Court was recently acknowledged in the case of Vijay Karia Vs Prysmian Cavi E Sistemi Srl[10], wherein the Apex Court clearly held as under:

"107. Having answered each of the submissions of Dr. Singhvi on behalf of the Appellants, we cannot help but be left with a feeling that the Appellants are indulging in a speculative litigation with the fond hope that by flinging mud on a foreign arbitral award, some of the mud so flung would stick. We have no doubt whatsoever that all the pleas taken by the Appellants are, in reality, pleas going to the unfairness of the conclusions reached by the award, which is plainly a foray into the merits of the matter, and which is plainly proscribed by Section 48 of the Arbitration Act read with the New York Convention."
There are other judgement as well like Campos Brothers Farms Vs Matrubhumi Supply Chain Pvt. ltd[11].  of the Delhi High Court wherein the Delhi High Court, set aside the award on the aspect that it was against the public policy of India.

CONCLUDING REMARKS
From the above discussions it is ample clear that the above said the view of Indian Courts in matters pertaining to International Commercial Arbitration has been divergent. Moreover, initially there was a lot of court interference in International Arbitration Awards, which led to overall decline of India's reputation as it failed in its commitment to honour its obligation for enforcement of Arbitral Awards. However the situation has improved for better after the 2015 amendment to the Act came into force,

The amendments to section 9 of the Act restore the authority of Indian courts to grant interim measures in aid of international arbitration seated outside India, while also striving to curtail the potential for resulting delays or judicial interference. If a court grants interim relief before an arbitration has commenced, the arbitral proceedings must be commenced within 90 days of the court’s order or within a time period specified by the court. Once the tribunal has been constituted, Indian courts are precluded from accepting applications for interim relief unless the tribunal is unable to provide an efficacious remedy. The Amendment also extends the scope of section 27, providing for court assistance in taking evidence in support of arbitration, to arbitration seated outside India.

The Amendment attempts to rectify this situation by limiting the 'public policy' to three particular circumstances:

Ø  the making if the award as actuated by fraud, collusion or any of the provisions;
Ø  the award contravenes the fundamental policy of Indian Law
Ø  the award conflicts with the basic notion of morality and justice’.[12]

The Amendment clarifies that a court’s determination of whether an award is in contravention with the fundamental policy of Indian law shall not entail a review on the merits of the dispute.

Aditya Jain is an Advocate on Record at Supreme Court of India and Partner at J&G Advocates
Neha Gyamlani is an Advocate at Supreme Court of India/Rajasthan High Court at Partner at J&G Advocates


[1] Arbitration and Conciliation Act of 1996.
[2] Part II specifically deals with foreign awards which are in consonance with the provisions of the Convention on the Recognition and Enforcement of Foreign Arbitral Awards, 1958 or Convention on the Execution of Foreign Arbitral Awards, 1927.
[3] Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958.
[4] Convention on the Execution of Foreign Arbitral Awards 1927.
[5] 47. Evidence.—(1) The party applying for the enforcement of a foreign award shall, at the time of the application, produce before the court— (a) the original award or a copy thereof, duly authenticated in the manner required by the law of the country in which it was made; (b) the original agreement for arbitration or a duly certified copy thereof; and (c) such evidence as may be necessary to prove that the award is a foreign award.
[6] PEC Limited v. Austbulk Shipping SDN BHD (Civil Appeal No. 4834 of 2007) decided on 14 November 2018
[7] 49. Enforcement of foreign awards.—Where the Court is satisfied that the foreign award is enforceable under this Chapter, the award shall be deemed to be a decree of that Court.
[8] 2001(6)SCC 356
[9] 2008 (4) SCC 190
[10] MANU/SC/0171/2020, Decided on 13.02.2020
[11] (2009) 261 DLT 201
[12] The Amendment presents this clarification as ‘Explanation 2’ to both s 34(2)(b) and s 48(2) of the Act

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