An arbitration award is the award granted by the arbitrator in their decision. This award can be money one party has to pay to the other party. It can also be a non-financial award, such as stopping a certain business practice or adding an employment incentive. In simpler words, arbitral awards refer to the decision of an arbitral tribunal, whether in a domestic or international arbitration.

Arbitral awards include interim awards

Domestic awards are governed by Part I whereas foreign awards are governed by part II of the Arbitration and Conciliation Act of India. A domestic award is an award passed under the provisions of Section 2 to 43 of the Act.

A domestic award is a result of domestic arbitration , hence it confines itself to the territory of India, the parties should have a nexus or birth to Indian origin, basically territory comes into play in order to asses a domestic arbitration. Award given by an arbitral institution in India or an award even if given by a foreign state for a dispute where both the parties are of an Indian origin and the nationality is also governed by the Indian laws shall also come within the purview of domestic arbitration.

A Foreign award as per section 44 means an arbitral award which relates to differences relating to the matters considered as commercial under the law in force in India.

Essentials of an arbitral award

For an arbitral award to be valid it must contain the following essential elements:

• The award shall be in writing.
• The award shall be signed by all the members of the arbitral tribunal.
• The award shall state the reasoning on which it is based.
• Date and place of arbitration should be mentioned on the award.

A signed copy of the award should be sent to both the parties. It should be signed by the arbitrator or the majority of the arbitrators of the tribunal.

The arbitral award shall be defined as any arbitral tribunal's judgment on the nature of the dispute referred to it and shall include a temporary, interlocutory or partial arbitral award. The arbitral tribunal may grant an interim arbitral award on any matter for which it will make a final arbitral award at any time during the arbitral proceedings. The interim award may be applied in the same way as a final award of arbitration. Unless otherwise decided by the parties, a party may ask the arbitral tribunal to make an additional arbitral award in respect of the claims raised in the arbitral proceedings but omitted from the arbitral award within 30 days of receipt of the arbitral award.

Evolution Of Arbitration Awards In India

The recognition and enforcement of arbitral awards in India is primarily governed by the'Arbitration'and Conciliation Act 1996 (ACA 1996) (as amended) as well as the Code of Civil Procedure 1908 (CPC).

Domestic and foreign awards are enforced in the same manner as a decree of the Indian court. This is true even for consent awards obtained pursuant to a settlement between parties. 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 Indian-seated arbitral award (a domestic award) would be governed by the provisions of ACA 1996, Pt I, enforcement of foreign seated awards (or foreign awards) would be governed by the provisions of ACA 1996, Pt II.

ACA 1996, Pt II incorporates and gives effect to the provisions of the Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (the New York Convention) and the Convention on the Execution of Foreign Arbitral Awards (the Geneva Convention), both of which have been ratified by India. India is not a signatory to any other convention relating to enforcement of foreign awards.

The regulation and execution of decrees in India is regulated by the Civil Procedure Code, 1908 (CPC), while the arbitral award procedure in India is governed mainly by the Arbitration & Conciliation Act, 1996 (Act) and the CPC.

For the same way as an Indian court decree, domestic and international awards are enforced. However, there is a difference depending on the seat of arbitration. Seated arbitral award (domestic award) would be governed by Part I of the Act, enforcement of foreign — seated awards (international award) would be governed by Part II of the Act.

Applicable Requirements For Enforcing Arbitral Awards In India

1. Must an award take any particular form

   Section 31 of the Arbitration and Conciliation Act 1996 (the Arbitration Act) provides,'inter alia, that an arbitral award shall be made in writing and be signed by the members of the arbitral tribunal. In this respect, Section 31(2) clarifies that in arbitral proceedings with more than one arbitrator, the signatures of the majority of the members of the arbitral tribunal shall be sufficient provided the reason for any omitted signature is stated. After the award is made, a signed copy is required to be delivered to each party.
   
   Section 31 also provides that the arbitral award shall state the reasons on which it is based unless the parties have agreed that no reasons are to be given, or the award is an arbitral award on agreed terms under Section 30 (Settlement).
   
   Additionally, the award is required to state the date and place of arbitration as determined in accordance with Section 20 (Place of Arbitration) and the award shall be deemed to have been made at that place.
    

2. Provisions governing modification, clarification or correction of an award

   Under circumstances may an award be retracted or revised (for fraud or other reasons)
   
   Section 33 of the Arbitration Act provides that a party, with notice to the other party, may within 30 days of receipt of the arbitral award (unless another time limit has been agreed by the parties) request the arbitral tribunal to correct any computation errors, any clerical or typographical errors, or any other errors of a similar nature occurring in the award.
   
   Additionally, if so agreed by the parties, a party, with notice to the other party, may request the arbitral tribunal to give an interpretation of a specific point or part of the award.
   
   If the arbitral tribunal considers the request made by a party to be justified, then it is required to make the correction or give the interpretation within 30 days of receipt of the request and any such interpretation shall form part of the arbitral award. The arbitral tribunal may also correct any errors of the types referred to above on its own initiative within 30 days of the date of the award.
   
   Section 33 also provides that a party may request the arbitral tribunal, with notice to the other party and within 30 days of receipt of the award, to make an additional award as to claims presented in the arbitral proceedings but omitted from the arbitral award, unless otherwise agreed by the parties. The arbitral tribunal is then required to make the additional arbitral award within 60 days of receipt of the request, if it considers the request to be justified.
   
   If necessary, the arbitral tribunal may also extend the time limit within which it shall make a correction, give an interpretation or make an additional award. The provisions of Section 31 (Form and contents of arbitral award) shall apply to a correction or interpretation of the arbitral award or to an additional award made under Section 33.
   
   Although an award may be corrected on the grounds mentioned above (Section 33), the retractation of an award on any matter of substance is not permissible by the arbitral tribunal since the arbitral tribunal becomes'functus officio'after rendering the award. A party may move the courts to have the award set aside under Section 34 (domestic award) or Section 48 (foreign award) of the Arbitration Act if the making of the award was induced by fraud, corruption or under other grounds set out in these Sections.
    

3. An award be appealed to or set aside by the courts. The differences between appeals and applications to set aside awards.

   India
   A domestic award may be set aside by the court under Section 34(2) of the Arbitration Act if the the arbitral records can establish that:
   
   • the party was under some incapacity;
   • the arbitration agreement is not valid under the law chosen by the parties or, in its absence not valid under the law in force at the relevant time;
   • the applicant was not given proper notice of the appointment of an arbitrator or of the arbitral proceedings, or was otherwise unable to present his or her case;
   • the arbitral award deals with a dispute not contemplated by or not falling within the terms of the submission to arbitration, or it contains decisions on matter beyond the scope of the submission to arbitration; or
   • the composition of the arbitral tribunal or the arbitral procedure was not in accordance with the agreement of the parties, or failing any such agreement, was not in accordance with Part I of the Arbitration Act.
   An arbitral award may also be set aside if the court finds that:
   
   1. The subject matter of the dispute is not capable of settlement by arbitration under the law for the time being in force or
   2. The arbitral award is in conflict with the public policy of India.
   An appeal may lie under Section 37 of the Arbitration Act from an order setting aside or refusing to set aside an arbitral award under Section 34. Significantly, no second appeal lies from an order passed in appeal under Section 37; however, nothing prevents a party from approaching the Supreme Court by way of a Special Leave Petition under Article 136 of the Constitution of India.
   
   As for the difference between appeals and applications for set-aside, the first recourse available to a party against a domestic arbitral award would be to file an application for setting aside the award under Section 34 of the Arbitration Act. Thereafter, and as a second recourse, an appeal may lie under Section 37 of the Act from an order setting aside or refusing to set aside an arbitral award under Section 34.
   
   Applicable procedural law for setting aside of arbitral awards
    

4. Time limit for applying for the setting aside of an arbitral award

   Insofar as a domestic award is concerned, Section 34(3) of the Arbitration Act provides that an application for setting aside an arbitral award has to be made within three months of the date of receipt of the arbitral award by the applicant or of the date on which a request for correction or interpretation of the award under Section 33 of the Act has been disposed by the tribunal, if such requests have been made. However, if the court is satisfied that the applicant was prevented by sufficient cause from making the application within the given period of three months, it may entertain the application within a further period of 30 days but not thereafter.
   
   Insofar as a foreign award is concerned, an award debtor can only file its objections under Section 48 of the Arbitration Act once the award holder files for enforcement of the award (Arbitration Act, Section 47 read with Section 49). Although the Act does not provide a timeline within which such objections are to be filed by the award debtor, the courts typically grant between two and four weeks to file such objections (subject to further extensions granted by the court).
    

5. Kind of arbitral decision can be set aside in your jurisdiction

   Under Section 34(2) of the Arbitration Act, an arbitral award rendered in India may be set aside if the applicant furnishes proof that:
   
   • the party was under some incapacity
   • the arbitration agreement is not valid under the law chosen by the parties or, absent any such choice, the law in force at the relevant time;
   • the applicant was not given proper notice of the appointment of an arbitrator or of the arbitral proceedings or was otherwise unable to present his or her case;
   • the arbitral award deals with a dispute not contemplated by or not falling within the terms of the submission to arbitration, or it contains decisions on matters beyond the scope of the submission to arbitration; or
   • the composition of the arbitral tribunal or the arbitral procedure was not in accordance with the agreement of the parties or, absent any such agreement, was not in accordance with Part I of the Arbitration Act.

Additionally, a court can set aside an award if it finds that the subject matter of the dispute is not capable of settlement by arbitration under the law for the time being in force or the arbitral award is in conflict with the public policy of India. The Arbitration Act clarifies that an award is in conflict with the public policy of India, only if,'inter alia,

1. the making of the award was induced or affected by fraud or corruption, or
2. it is in contravention of the fundamental policy of Indian law, or
3. it is in conflict with the most basic notions of morality or justice. Section 34(2) clarifies that the test as to whether there is a contravention with the fundamental policy of Indian law shall not entail a review on the merits of the dispute.

In terms of Section 34(2A) of the Arbitration Act, if an award made in India does not emanate from an international commercial arbitration in which one of the parties is not an Indian, then it can also be set aside on the ground that it is vitiated by patent illegality appearing on the face of the award, although an award is not to be set aside merely on the ground of an erroneous application of the law or by reassessment of the evidence.

Insofar as foreign-seated awards are concerned, a court may refuse their enforcement under the terms of Section 48 of the Arbitration Act, at the request of the party against whom it is invoked, only if that party furnishes to the court proof that:

• the parties to the agreement were, under the law applicable to them, under some incapacity, or the said agreement is not valid under the law to which the parties have subjected it or, failing any indication thereon, under the law of the country where the award was made;
• the party against whom the award is invoked was not given proper notice of the appointment of the arbitrator or of the arbitral proceedings or was otherwise unable to present his or her case;
• the award deals with a difference not contemplated by or not falling within the terms of the submission to arbitration, or it contains decisions on matters beyond the scope of the submission to arbitration (although Section 48 clarifies that if the decisions on matters submitted to arbitration can be separated from those not so submitted, that part of the award which contains decisions on matters submitted to arbitration may be enforced);
• the composition of the arbitral authority or the arbitral procedure was not in accordance with the agreement of the parties or, absent any such agreement, was not in accordance with the law of the country where the arbitration took place; or
• the award has not yet become binding on the parties, or has been set aside or suspended by a competent authority of the country in which, or under the law of which, the award was made.

Furthermore, the enforcement of a foreign-seated arbitral award may also be refused if the court finds that:

1. the subject matter of the dispute is not capable of settlement by arbitration under the law of India, or
2. enforcement of the award would be contrary to the public policy of India.

Similarly to Section 34, Section 48 of the Arbitration Act clarifies that an award is in conflict with the public policy of India only if,'inter alia,

1. the making of the award was induced or affected by fraud or corruption, or
2. it is in contravention with the fundamental policy of Indian law, or
3.  it is in conflict with the most basic notions of morality or justice.

Section 48 further clarifies that the test as to whether there is a contravention with the fundamental policy of Indian law shall not entail a review on the merits of the dispute.

Finally, the courts have discretion to adjourn their decision on enforcement if an application for the setting aside or suspension of an award has been made to a competent authority and may also, on the application of the party claiming enforcement of the award, order the other party to give suitable security.

An interim award under the Arbitration Act is a final award as to certain claims between the parties, which is made at an interim stage in the arbitration proceeding. This type of interim award falls within the meaning of 'award' under Section 2(1)(c) of the Act and can be set aside under Section 34 (domestic award) or Section 48 of the Act (foreign awards).

Documentations required when applying for the setting aside of an arbitral award

Although the Arbitration Act does not prescribe the relevant documentation to be furnished by an applicant, an application for setting aside an award is typically accompanied by the original copy of the impugned award (with some courts holding that filing at least a copy of the impugned award is'sine qua non'to filing the setting-aside application) and the arbitral record (i.e., pleadings, evidence, etc. presented to the tribunal). The high courts have different requirements as regards the number of copies required by the court.

Although, ordinarily, courts in India will not go beyond the award and the record before the arbitrator in deciding the setting-aside application, in Emkay Global Financial Services Limited v. Girdhar Sondhi (2018) 9 SCC 49, the Supreme Court has clarified that documents that do not form part of the arbitral record, but are relevant to the determination of issues, may be brought to the notice of the court by way of affidavits filed by parties.

Steps of the proceedings
Insofar as a domestic award is concerned, Section 34(3) of the Arbitration Act provides that an application for setting aside an arbitral award will have to be filed by the aggrieved party within three months of the date of receipt of the award or the date of disposal of a request for correction of the award under Section 33, if any. The application shall be filed only after serving a prior notice to the other party, accompanied by an affidavit endorsing compliance with the requirement under Section 34(5) of the Act.

On receipt of the application, the applicant will prima facie have to satisfy the court that there exist grounds to set aside the arbitral award. Once satisfied, the court will typically issue a notice in the matter and direct the other party to file its response to the application, and may permit the applicant to file a rejoinder to the response filed by the applicant thereafter, if required.

Once pleadings are complete, the court will typically hear oral arguments by the parties to ascertain whether grounds set out in Section 34, Paragraphs (2) and (2A) of the Act are made out, and accordingly either set aside the arbitral award or refuse to do so. Ordinarily, the courts will not reassess the evidence examined by the arbitral tribunal and therefore it is quite rare for courts to cross-examine witnesses in setting-aside proceedings.

An application for setting aside a domestic arbitral award will have to be disposed expeditiously, and in any event, within one year of the date on which the notice referred to in Section 34(5) is served on the other party, as prescribed by Section 34(6) of the Act. However, the Supreme Court in State of Bihar v. Bihar Rajya Bhumi, AIR 2018 SC 3862 has clarified that the requirement under Section 34(6) is a direction and not mandatory.

Insofar as a foreign award is concerned, the award debtor must wait for the award holder to file for enforcement proceedings for execution of the award under Section 47 read with Section 49 of the Act, and then file its objections to the award in terms of the grounds stipulated under Section 48. The steps of the proceedings are similar to those in a domestic award in that the court will first direct that pleadings are completed in the matter, and then hear oral arguments on enforceability of the award.

Grounds on which an arbitral award may be set aside

Under Section 34(2) of the Act, an arbitral award rendered in India may be set aside if the applicant furnishes proof that:

• the party was under some incapacity;
• the arbitration agreement is not valid under the law chosen by the parties or, absent such an agreement, not valid under the law in force at the relevant time;
• the applicant was not given proper notice of the appointment of an arbitrator or of the arbitral proceedings or was otherwise unable to present his or her case;
• the arbitral award deals with a dispute not contemplated by or not falling within the terms of the submission to arbitration, or it contains decisions on matters beyond the scope of the submission to arbitration; or
• the composition of the arbitral tribunal or the arbitral procedure was not in accordance with the agreement of the parties, or absent any such agreement, was not in accordance with Part I of the Arbitration Act.

Additionally, a court can set aside an award if it finds that the subject-matter of the dispute is not capable of settlement by arbitration under the law for the time being in force or the arbitral award is in conflict with the public policy of India.

The Arbitration Act clarifies that an award is in conflict with the public policy of India only if, inter alia,

1. the making of the award was induced or affected by fraud or corruption, or
2. it is in contravention with the fundamental policy of Indian law, or
3. it is in conflict with the most basic notions of morality or justice.

Section 34(2) of the Act clarifies that the test as to whether there is a contravention with the fundamental policy of Indian law shall not entail a review on the merits of the dispute.

Under the terms of Section 34(2A), if an award made in India does not emanate from an international commercial arbitration in which one of the parties is not an Indian, then it can also be set aside on the ground that it is vitiated by patent illegality appearing on the face of the award, although an award is not to be set aside merely on the ground of an erroneous application of the law or by reassessment of evidence.

Insofar as foreign awards are concerned, courts may refuse their enforcement, under the terms of Section 48 of the Arbitration Act, at the request of the party against whom it is invoked, only if that party furnishes to the court proof that:

• the parties to the agreement were, under the law applicable to them, under some incapacity, or the agreement is not valid under the law to which the parties have subjected it or, failing any indication thereon, under the law of the country where the award was made;
• the party against whom the award is invoked was not given proper notice of the appointment of the arbitrator or of the arbitral proceedings or was otherwise unable to present his or her case;
• the award deals with a difference not contemplated by or not falling within the terms of the submission to arbitration, or it contains decisions on matters beyond the scope of the submission to arbitration (although Section 48 clarifies that if the decisions on matters submitted to arbitration can be separated from those not so submitted, that part of the award which contains decisions on matters submitted to arbitration may be enforced);
• the composition of the arbitration authority or the arbitration procedure was not in accordance with the agreement of the parties, or, absent any such agreement, was not in accordance with the law of the country where the arbitration took place; or
• the award has not yet become binding on the parties, or has been set aside or suspended by a competent authority of the country in which, or under the law of which, the award was made.

Landmark Judgements

Uttarakhand Purv Sainik Kalyan Nigam Ltd. Vs. Northern Coal Field Ltd.1

Relying on the doctrine of'kompetenz – kompetenz'enshrined in Section 16 of the Arbitration & Conciliation Act, 1996 ( Arbitration Act ) and the legislative intent to restrict judicial intervention at pre-reference stage, the Supreme Court held that the issue of limitation would be decided by an arbitrator.

It also reaffirmed that the legislative intent of the Arbitration Act is party autonomy and minimal judicial interference in the arbitration process. It observed that the regime of the Arbitration Act outlines that once an arbitrator has been appointed, all objections and issues are to be decided by the arbitrator.

The Supreme Court observed that the issue of limitation is a jurisdictional issue which should be decided by the arbitrator in terms of Section 16 of the Arbitration Act and not before the High Court at the pre-reference stage under Section 11 of the Arbitration Act. The Supreme Court observed that once the arbitration agreement is not in dispute, all issue including jurisdictional issues are to be decided by the arbitrator.

Hindustan Construction Company Limited & Anr. Vs. Union of India & Ors.2

A three (3) member bench of the Hon'ble Supreme Court comprising of Hon'ble Mr. Justice R.F. Nariman, Hon'ble Mr. Justice Surya Kant and Hon'ble Mr. Justice V. Ramasubramanium (Bench) has struck down Section 873'of the Arbitration & Conciliation Act, 1996 (Arbitration Act) as being "manifestly arbitrary" in terms of Article 14 of the Constitution of India.

The Bench observed that Section 87 of the Arbitration Act is against the intent of the Arbitration and Conciliation (Amendment) Act, 2015 (2015 Amendment) and further nullifies the ratio laid down in the recent judgment of' Board of Control for Cricket in India Vs. Kochi Cricket Pvt. Ltd.4, wherein it was observed that the intent and purport of Section 87 is contrary to the overall scheme of the Arbitration Act and the 2015 Amendment.

Accordingly, Section 26 of the 2015 Amendment was revived by the Supreme Court and the decision rendered in Board of Control for Cricket in India Vs. Kochi Cricket Pvt. Ltd. continues to apply as the guiding principle for determining the applicability of the 2015 Amendment.

The Oriental Insurance Co. Ltd. and Ors. Vs. Dicitex Furnishing Ltd.5

The Supreme Court held that an arbitration clause can be invoked by an aggrieved party pursuant to execution of no objection certificates or discharge vouchers. The Supreme Court while upholding the concept of economic duress dealt in the case of' Associated Construction Vs. Pawanhans Helicopters Ltd 6 and National Insurance Co. Ltd. Vs. Boghara Polyfab Pvt. Ltd.7observed that a court which is required to ensure that an arbitrable dispute exists, has to be prima facie convinced about the genuineness or credibility of the plea of coercion; it cannot be too particular about the nature of the plea, which necessarily has to be made and established in the substantive proceeding.

If the court were to take a contrary approach and minutely examine the plea and judge its credibility or reasonableness, there would be a danger of its denying a forum to the applicant altogether, because rejection of the application would render the finding (about the finality of the discharge and its effect as satisfaction) final, thus, precluding the applicant of its right event to approach a civil court.

Brahmani River Pellets Limited Vs. Kamachi Industries Limited 13

The Supreme Court, while relying on Swastik Gases (P) Ltd. Vs. Indian Oil Corporation Ltd.14 observed that non-use of words like 'exclusive jurisdiction', 'only', 'exclusive', 'alone' is not decisive and does not make any material difference.

It observed that when the contract specifies the jurisdiction of the court at a particular place, only such court will have the jurisdiction to deal with the matter and the parties intended to exclude all other courts.

The Supreme Court held that in the instant case, the parties had agreed for Bhubaneshwar as the 'venue' for arbitration proceedings. Thus, the intention of the parties was to exclude jurisdiction of all other courts. Accordingly, the Supreme Court held that the High Court of Madras had no jurisdiction to entertain jurisdiction under Section 11(6) of the Arbitration & Conciliation Act, 1996.

Vijay Karia v. Prysmian Cavi E Sustemi Srl & Ors.

Brief Facts:'Respondents in the instant matter had initiated arbitration under the London Court of International Arbitration Rules (2014) against the Appellants, alleging material breach of contractual obligations. The Appellants, in turn, had raised several counterclaims against the Respondents. The arbitrator had pronounced three partial awards on the issues of jurisdiction, material breaches, and counterclaims as raised by the Appellant. Subsequently, the final award was passed in April 2017.

The four awards in question were not challenged before England's courts, although the provision for such challenge was available to the Appellants. These awards were challenged for the first time when they were sought to be enforced before the High Court of Bombay. However, the challenge was declined by the High Court of Bombay, stating that none of the grounds raised to resist enforcement of the awards fell within the scope of the narrow exceptions provided in Section 48 of the Arbitration and Conciliation Act, 1996 (Arbitration Act). Thereafter, the Appellants preferred a special leave petition before the Supreme Court, under Article 136 of the Constitution of India.

Held:
The Supreme Court took this opportunity to clarify that the Apex Court's scope of intervention under Article 136 of the Constitution is minimal and could not be used to circumvent legislative policy set out in the Arbitration Act. Having established this, the Supreme Court proceeded to discuss the matter at hand in the context of international jurisprudence on enforcement of foreign arbitral awards and recognising the pro-enforcement bias being adopted in countries where execution is sought.

The Apex Court also observed that courts in a country of primary jurisdiction, i.e., a country where the award has been rendered has far more power when it comes to review of an arbitral award, as compared to the courts in countries of secondary jurisdiction, i.e., the countries where the execution of the foreign award is sought. In this case, India is a country of secondary jurisdiction; the courts in India have very limited scope to interfere with a foreign arbitral award.

The Supreme Court further stated that ground of violation of 'principles of natural justice' may be invoked for resisting enforcement of a foreign arbitral award only if it is such that the party resisting enforcement was not given a fair opportunity of hearing. The onus is on the party seeking the benefit of this ground to prove that it was not given a fair opportunity to present its case.

As far as the 'public policy' ground goes, the Apex Court opined that the arbitral tribunal's failure to consider an issue that goes to the root of the matter or contravention of 'fundamental policy' of Indian law may be valid grounds for resisting enforcement. However, contravention of 'fundamental policy' is not to be equated with contravention of just about any statute/statutory provision, which may be easily rectifiable in nature.

The Appellant here tried to plead breach of a Foreign Exchange Management Act, 1999 provision as a violation of "fundamental policy", but the Supreme Court outright rejected this argument.

Serajuddin v. Michael Golodetz
The Calcutta High Court established the necessary conditions for an arbitration to be referred to as ' foreign arbitration ' or the essential elements of a foreign arbitration where the award could also be referred to as a foreign arbitration award.

The important points laid were as follow:

• Arbitration should have been held in a foreign country.
• By a foreign arbitrator.
• Arbitration by applying foreign laws.
• One of the parties consists of foreign nationals.

Conclusion
India is not a country that has anti-arbitration prejudice. It is therefore easy to argue that India's legal system seeks to create a facilitative atmosphere for applying international awards. A major issue with the 1996 Arbitration and Conciliation Act is compliance, it handles foreign arbitral awards and foreign court rulings in a similarly.

Due to the lack of distinction between foreign arbitral awards and court decisions, the Indian Law does not explicitly address issues directly related to foreign awards. Some changes, such as trying to clarify convention countries with reciprocal provisions that are yet to be specified in the official gazette, and legislation dealing directly with international arbitral awards would allow the arbitral system to be more organized and India to be compatible with advanced legal regimes around the world. Written By Yashi