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This article has been written by Vivek Sanghi, pursuing a Certificate Course in International Commercial Arbitration and Mediation from LawSikho. It has been edited by Prashant Baviskar (Associate, LawSikho) and Ruchika Mohapatra (Associate, Lawsikho).

Introduction

In the last two years, we have come to realise the increasing importance of emergency dispute resolution mechanisms. Emergency arbitration is one such mechanism that provides for a disputing party to apply for urgent interim relief even before an arbitration tribunal has been formally constituted. An emergency arbitrator is an arbitrator that gets appointed urgently by an arbitral institution in response to an application for interim relief that cannot wait for the constitution of the arbitration tribunal that shall adjudicate the substantive dispute between the parties and subsequently pass an award. One such award passed in an emergency arbitration conducted as per SIAC Rules assumed significance before the Indian Courts. This article is going to analyse the approach of Indian Courts to Emergency Arbitrations in the light of that particular judgment i.e. Amazon v Future Retail. 

Reliefs possible in the case emergency arbitration

  • Restraining the respondent, in the interim, from committing a violative action.
  • Relief of status-quo pending dispute resolution. 
  • Securing monetary claims by praying for freezing orders, deposits of money in an escrow account, and interim payment orders.
  • Preserve evidence that may be material and relevant to the resolution of the dispute.
  • Take action or refrain from taking an action that could likely cause prejudice to the arbitral process.

Emergency Arbitration: Position under Indian Law

The term ‘Emergency Arbitration’, surprisingly, has no definition under the Indian Arbitration and Conciliation Act, considering the growing prevalence and popularity of international commercial arbitration, coupled with the fact that foreign investment in India is becoming a primary driver of growth in the corporate economy. To alleviate this situation and bring recognition to the orders passed by a foreign seated emergency arbitrator, the 246th Law Commission report and the B.N. Srikrishna Report had recommended inclusion of the definition of the term “Emergency Arbitrator ” under the definition of the arbitral tribunal in Section 2(d) of the Indian Arbitration and Conciliation Act. Besides this,  they had further suggested incorporating the term “emergency award” under the definition of “arbitral award” which currently only includes the  term “interim award” under Section 2(1)(c) of the Indian Arbitration and Conciliation Act. However, the said recommendations were ignored both in the 2015 Amendment Act and the 2019 Amendment Act. This has created lacuna and compelled the pro-arbitration judiciary of India, through its High courts and its apex Supreme Court, to pass judgments that acknowledge and provide legal force to emergency arbitration awards, thereby setting precedents that shall fill up the lacunae that await the attention of the legislature.

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Enforceability of Emergency Arbitration Awards in India

Situation pre 2015 Amendment of the Arbitration and Conciliation Act

A mere mention, explicit or implied, of a foreign seat was enough for the Hon’ble Courts to decide that arbitration laws of India would not be applicable. Emergency Arbitrators in foreign seated arbitration have no recognition or acknowledgment in the Arbitration and Conciliation Act of India and they were considered aliens by courts of Law in India. This made it impossible to enforce  any foreign-seated Emergency Arbitration orders or awards in India.

In several cases the Indian courts refused to recognize the orders and awards of emergency arbitrators (particularly foreign seated ones), for example in: –

  • Hardy Oil and Gas Limited vs. Hindustan Oil Exploration Company Limited and Ors., (2006) 1 GLR 658 – An agreement where the parties had agreed that the law of the arbitration would be the English law, fell within the purview of the rule of ‘implied exclusion’ laid in Bhatia International. Accordingly, the Gujarat High Court held that an Indian Court did not have the jurisdiction to try the petition filed under Section 9 of the Indian Arbitration and Conciliation Act.
  • Raffles Design v. Educomp Professional Education – The High Court of Delhi in this case held that an emergency award passed by a foreign-seated arbitration tribunal was unenforceable under the Indian Arbitration and Conciliation Act. The Court held that the party that has obtained a foreign-seated emergency award would have to file a fresh civil suit in an Indian court seeking provisional or interim orders therefrom, in terms of the emergency award. The approach in this order defeats the very purpose of an arbitration clause and the concepts of party autonomy and competence – competence.

Situation post 2015 Amendment of the Arbitration and Conciliation Act

  • After the 2015 amendment to the Arbitration and Conciliation Act, Section 27 of the said act became applicable to foreign seated arbitrations (vide the amendment to the Section 2(2) of the said Act). Section 27(5) of the Arbitration and Conciliation Act is now available to be used for enforcement of emergency awards of arbitration tribunals seated abroad, in the same manner that Section 27 (5) is applied for enforcing interim orders of domestic arbitration tribunals. 
  • To elucidate the above point with judgments related to interim awards passed by domestic arbitration tribunals in India, it may be noted that in Sri Krishan v. Anand the High Court of Delhi, held that it had the authority to punish a party for contempt, under Section 27(5) of the Arbitration and Conciliation Act, at behest of the arbitration tribunal if a party breached interim orders of the arbitration tribunal. This interpretation was upheld by the Hon’ble Supreme Court in the judgment passed in Alka Chandewar v. Shamshul Ishrar Khan where the Hon’ble Supreme Court observed that “the orders of the arbitral tribunal cannot be rendered a dead letter”.
  • Now the 2015 amendment (supra) makes it possible to start contempt of court proceedings even for foreign seated emergency arbitration awards.
  • Section 43(2) empowers the Court to subject persons guilty of contempt of the arbitration tribunal to the same penalties and punishments as offences in suits tried before the Court. This provision has now been incorporated in section 27(5) of the Arbitration and Conciliation Act by way of legislative amendment.
  • Section 44 of the Arbitration and Conciliation Act within its scope of the definition of a foreign award, also encompasses a foreign-seated emergency arbitration award, subject to the nature of the relief granted by the emergency arbitrator. This is again possible by the 2015 Amendment to Section 2(2) of the act.
  • In dealing with a Singapore International Arbitration Centre (SIAC) emergency arbitration order, the High Court of Maharashtra seated in Mumbai, in HSBC vs. Avitel came to characterise the Emergency Arbitrator’s decision as an award and the same was upheld by the Hon’ble Supreme Court.
  • It may be noted that merely having a foreign seat and foreign venue in the arbitration agreement, is no longer going to be construed as an intention to exclude Part One of the Indian Arbitration and Conciliation Act.
  • An award made by an emergency arbitrator is still  not directly enforceable in India, but the same may be enforced indirectly by: – 
  • Filing an application with an Indian court under Section 9 of the Arbitration and Conciliation Act; (or)
  • Approaching an Indian Court to initiate contempt proceedings against the defaulting party under Section 27(5) of the Arbitration and Conciliation Act. This works only with respect to interim measures or orders by the arbitration tribunal not in the form of an interim award, considering that ‘interim award’ is expressly included in the definition of the ‘award’ under the Arbitration and Conciliation Act.

Therefore, despite the 2015 amendment to the Arbitration and Conciliation Act, an emergency arbitrator is not yet recognised under Indian law and the aforementioned ‘round-about’ ways need to be followed to enforce the emergency award of a foreign seated arbitration tribunal. This situation is likely to remain until the recommendation (supra) of the 246th Law Commission of India Report, 2014, is given effect by the legislature.

What changes with the case of Amazon vs Future Retail Limited & Others?

Factual Matrix of the Case with Timeline

S.No.DateParticulars
1August 2019Amazon entered into three shareholder agreements with Future Retail Limited, Future Coupons Pvt. Ltd., and its promoters and  directors led by Mr. Kishore Biyani, and all collectively referred to as “Biyani Group” or “Future Group”The Shareholders’ Agreement executed on 12th August 2019 is in relation to  Future Retail Limited wherein Future Coupons Pvt Ltd was accorded negative, protective, special, and material rights regarding Future Retail Limited more particularly, Future Retail Limited’s retail stores. The rights granted to Future Coupons Pvt Ltd under the said Shareholders’ Agreement were for the purpose of being exercised for Amazon’s benefit and thus were reflected in a Shareholders’ Agreement executed on 22nd August 2019 between Amazon, Future Coupons Pvt Ltd and the Future Group. Amazon agreed to invest a sum of Rs.1431 crores only (international: Rupees Fourteen Billion Three Hundred and Ten Million Only), in Future Coupons Pvt Ltd to buy 49% stake in it, based on the rights obtained by Future Coupons Pvt Ltd under previous Shareholders’ Agreements. Future Coupons Pvt Ltd holds a 7.3% stake in Future Retail Limited, effectively giving Amazon an indirect stake of 3.58% in Future Retail Limited because of the said transaction.Future Retail Limited could not transfer its retail assets without Future Coupons Private Limited’s explicit consent which could not be granted until and unless Amazon had consented to it.Future Retail Limited and Biyani family were also prohibited from dealing with ‘restricted persons’ regarding the sale or encumbrance of assets of Future Retail Limited. Mukesh Dhirubhai Ambani Group (“Reliance Group”) was one such restricted person.This Shareholder’s Agreement dated 22nd August 2019, had a dispute resolution clause where any disputes were agreed to be resolved by arbitration under SIAC Rules and seated in Singapore.
2December 2019Future Coupons Pvt Ltd received s a payment of INR 1,431 Crores only, from Amazon and began  injecting it in Future Retail Limited.
329th August 2020Future Retail Limited, Future Coupons Pvt. Ltd., and its promoters / directors entered a transaction with Reliance Retail (part of the Mukesh Dhirubhai Ambani Group or “Reliance Group”) which envisions the amalgamation of Future Retail Limited with Reliance Group, the resultant cessation of Future Retail Limited as an entity, and the complete disposal/transfer of its assets in favour of the said group.
45th October 2020Amazon, aggrieved by the events of 29th August 2020, initiated arbitration proceedings and sought emergency interim relief of injunction from an emergency arbitrator appointed by SIAC under the SIAC Rules.
525th October 2020The emergency arbitrator of SIAC passed an emergency award against the Future Group and in favour of Amazon. However the Future Group proceeded with the disputed transaction, terming the emergency award a ‘nullity’ and the emergency arbitrator as coram non judice.
67th November 2020Future Retail Limited moved High Court of Delhi against Amazon by filing a civil suit before the High Court of Delhi in C.S. No. 493 of 2020, in which Future Retail Limited sought to prohibit the arbitration proceedings and asked for interim relief seeking to restrain Amazon from making representations to the statutory authorities based on the SIAC emergency arbitrator’s award, calling it a tortious interference with its civil rights.
720th November 2020The deal  dated 29th August 2020, between Future Group and Mukesh Dhirubhai Ambani Group got the nod from Competition Commission of India.
8November 2020Amazon pressed a petition under Section 17(2) of the Indian Arbitration and Conciliation Act which was heard and disposed of by a learned single Judge bench of the High Court of Delhi.
921st December 2020In C.S. No. 493 of 2020, a single Judge bench of the High Court of Delhi refused to stay the disputed deal (as prayed by Amazon), upheld  the August 29th board resolution for Future Retail Limited, but allowed Amazon to make representations to statutory regulators. The said bench upheld Future Retail’s claim of alleged tortious interference by Amazon.
10January 2021SIAC constituted a 3-member arbitration panel to pass the final verdict.
1113th January 2021A notice was issued to Future Group by the High Court of Delhi’s division bench, on Amazon’s plea against 21st December 2020 order.
1220th January 2021SEBI gave a  nod to Future Group – Reliance Group deal.
132nd February 2021A single Judge bench of the High Court of Delhi passed an order of status quo restraining the Future Group from proceeding with the impugned transaction. 
143rd February 2021Future Group disputed the status-quo order before a two-judge bench before the High Court of Delhi.
158th February 2021The operation of both the above orders of learned single Judge was stayed by a Division Bench of the High Court of Delhi vide two separate orders passed on Future Group’s appeal. 
1611th February 2021Amazon moved the Supreme Court to challenge revoking of “status-quo” orders by a division bench of the High Court of Delhi.
1712th February 2021NCLT heard and reserved the  order on the plea by Future Group for calling a meeting of shareholders to approve the deal with Reliance Group.
1822nd February 2021The Supreme Court permitted  the Future Group to go ahead with its plea before NCLT but restrained NCLT from passing final orders approving the Future Group’s amalgamation scheme. The apex court issued notice to Future Group on Amazon plea seeking status quo.
1918th March 2021The order passed on 2nd February 2021 by the learned single Judge bench of the High Court of Delhi was followed by a detailed judgment where the Judge held that the interim award made by the SIAC Emergency Arbitrator was enforceable under the arbitration laws of India. The Court stated that Future Retail Limited, Kishore Biyani and other promoters, directors of Future Group deliberately and wilfully disobeyed the order of the Court, liable to face action. The Court directed that the assets of Kishore Biyani, other Future Group Promoters, Directors be attached. The Court asked Future Retail Limited and Future Coupons Pvt Ltd to approach statutory regulators and seek a recall of the grant of deal approval.
2020th March 2021Future Group appealed against the orders directing stay on the disputed deal regarding the  attachment of assets of Mr. Kishore Biyani and other Future Group Promoters/ Directors.
2122nd March 2021The High Court of Delhi stayed the order granting status quo passed by the single-Judge bench, and further stayed the order that directed attachment of assets of Future Group promoters.
2217th April 2021Future Retail Limited’s board approved a resolution plan to restructure a secured financial debt under the circular of RBI dated 6th August 2020.
2319th May 2021Reliance Group approached the NCLT, seeking a nod to call for a shareholder meeting.
2422nd June 2021NCLT reserved the  order on Reliance Group’s plea to call a shareholder meeting.
2520th July 2021The Supreme Court resumed hearing of Amazon plea seeking a stay on Future Retail Limited – Reliance Retail deal.
2629th July 2021The Supreme Court reserved judgment in the appeals filed by Amazon seeking to stay the sale of Future Retail Limited.
2706th August 2021The Supreme Court held that Singapore’s Emergency Arbitrator award was enforceable.

Detailed Order of the Hon’ble High Court of Delhi in Amazon’s appeal

In the month of November of 2020, Amazon filed a petition under Section 17(2) of the Arbitration and Conciliation Act that was heard and later disposed of by a learned single Judge of the High Court of Delhi. On 2nd February 2021, the learned single Judge passed an order of status-quo restraining the Future Group from proceeding with the disputed transaction with Reliance Group, stating that reasons and a detailed order will follow.

On 18th March 2021, the said learned single Judge passed a detailed judgment giving elaborate reasoning for the order passed under Section 17(2) of Arbitration and Conciliation Act read with Order XXXIX Rule 2-A of the Code of Civil Procedure, in which the Judge held that an Emergency Arbitrator’s award is an order under Section 17(1) of the Arbitration and Conciliation Act.

A review of the language in the conclusion portion of the said order is valuable in understanding how the learned Single Judge interpreted the Arbitration and Conciliation Act, thus laying the foundation for the judgment to be passed later by the Hon’ble Supreme Court, which came to be regarded as a landmark decision.

Applicability of Group of Companies doctrine and other facts considered by the High Court of Delhi

The Court considered the Emergency Arbitrator’s order alongside the following factual grounds:

  • Future Coupons Pvt Ltd and Future Retail Limited belong to the same business group hence ‘Group of Companies’ doctrine applies.
  • The conduct of the parties i.e., Amazon and Future Coupons Pvt ltd reflects the clear intention to bind Future Retail Limited.
  • Concurrent negotiations of the agreements occurred; a common negotiation and legal team represented both Future Coupons Pvt Ltd and Future Retail Limited.
  • The direct relationship of  Future Retail Limited with Future Coupons Pvt Ltd, makes evident the harmony of the subject matter.
  • The composite nature and structure of transaction between the parties makes it apparent that neither the Future Coupons Pvt Limited Shareholders’ Agreement nor the Future Retail Limited Shareholders’ Agreement would take place without the others.
  • Funds received by Future Coupons Pvt Ltd have been used to financially support Future Retail Limited.
  • The multitude of agreements are intermingled and only their composite performance shall discharge the parties of their respective obligations under the said agreements.
  • Presence of similar ‘dispute resolution clauses’ in both, Future Coupons Pvt Ltd’s Shareholders’ Agreement, and the Future Retail Limited’s Shareholders’ Agreement, reflects the common intention of all the parties (whether signatory or non-signatory) to resolve their disputes by arbitration.

Issues in the Appeal before the Hon’ble Supreme Court

Whether an “award” delivered by an Emergency Arbitrator appointed under Schedule 1 of the SIAC Rules can be said to be an order under Section 17(1) of the Act?

  • The Hon’ble Supreme Court held that emergency arbitration was within the purview of the Arbitration and Conciliation Act and the definition of an arbitration tribunal, included within its scope an Emergency Arbitration.
  • The Hon’ble Supreme Court held that vide the 2015 Amendment to the Arbitration and Conciliation Act, the Section 17(2) was inserted to provide for creation of a legal fiction that any order issued by an arbitration tribunal (seated in India) shall be considered as an order of the Court and shall become enforceable. Therefore, since the arbitration tribunal in Amazon v. Future Group was India seated, the emergency award passed therein, was enforceable under this provision.
  • The Hon’ble Supreme Court observed that Section 2(1)(d) of the Arbitration & Conciliation Act defines ‘arbitration tribunal’ to encompass an arbitrator or a panel of arbitrators. The Supreme Court observed that the definition of ‘arbitration tribunal’ under the said Section 2(1)(d) does not include an “emergency arbitrator”. However, it stated that Section 1 of the Arbitration & Conciliation Act, opens with the words “unless the context otherwise requires”. When the said Section 1 is read together with Section 2(1)(a) of the Arbitration & Conciliation Act (that provides for “any” arbitration, whether or not administered by an arbitral institution) and Section 2(6) and Section 2(8) of the Arbitration & Conciliation Act (which permit incorporation of rules of arbitral institutions), it becomes apparent that interim orders passed by an emergency arbitrator under the rules of an arbitration institution are included within the purview of orders passed by an arbitration tribunal under Section 17(1) of the Arbitration & Conciliation Act.
  • The Hon’ble Supreme Court referred to the report of the Srikrishna Committee and stated that it is valid to interpret Section 17(2) of the Arbitration & Conciliation Act to enforce emergency awards for India-seated arbitrations and the said report had recommended that the Arbitration & Conciliation Act be amended such that it is abreast with international practice of recognising and enforcing an emergency award.
  • The Hon’ble Supreme Court held that a party after having agreed to institutional rules (in this case the SIAC Rules) providing for emergency arbitration and participating in an Emergency Arbitration proceeding, would be estopped by its acts and deeds, from subsequently contending that it could not be bound by the order of the Emergency Arbitrator.
  • With reference to the dispute raised stating that an emergency arbitration occurring prior to arbitral proceedings or prior to the constitution of the arbitration tribunal, is not covered by Section 17 of the Arbitration & Conciliation Act, the Hon’ble Supreme Court dismissed the said contention and held that Section 21 of the Arbitration & Conciliation Act, provides that arbitration proceedings with respect to a dispute commence from the date on which a request for that matter to be referred to arbitration is received by the other side. Also, Rule 3.3 of the SIAC Rules provides that the date of commencement of the arbitration is the date of receipt of the Notice of arbitration by the registrar as per SIAC Rules. Therefore, the Supreme Court inferred that the arbitral proceedings commence when a notice of arbitration is issued, which is preceding the constitution of an arbitration tribunal and the contentions of Future Group fail.

Whether an order passed under Section 17(2) of the Act in enforcement of the award of an Emergency Arbitrator by a learned Single Judge of the High Court is appealable?

  • The Supreme Court observed that the legal fiction deemed under Section 17(2) is solely for the purpose of enforcing orders passed by the arbitration tribunal as orders of the court. The Supreme Court relied on the judgment in Union of India v. Vedanta Ltd, where the Court had observed that an application to enforce a foreign award is to be considered as an application under the Indian Arbitration and Conciliation Act. Appeals from court orders enforcing an order under Section 17(2) cannot be made in the same manner as appeals from court orders under Section 9 of the Arbitration and Conciliation Act.
  • The Supreme Court noted that appeals from orders made under Arbitration and Conciliation Act are to be made within the bounds of Section 37 of the Arbitration and Conciliation Act. It was stated that Section 37 as a code is in itself whole so far as appeals from orders and awards made under the Arbitration and Conciliation Act are concerned. This has been validated further by the addition of the non-obstante clause by the Arbitration and Conciliation (Amendment) Act, 2019.
  • The Hon’ble Supreme Court referred to Section 37 of the Arbitration and Conciliation Act which deals with appeals and to Section 17(2) of the same act. The Supreme Court concluded that proceedings for enforcement of awards are not covered by the appeal provision and hence no appeal would be possible against the order of emergency awards under Section 37 of the Arbitration and Conciliation Act.

Key Highlights

The Court observed that “a conjoint reading of these provisions (Section 17(1), Section 17(2) of the Arbitration and Conciliation Act, and Rule 3.3 of SIAC Rules) coupled with there being no prohibition, either express or by necessary implication, against an Emergency Arbitrator would show that an Emergency Arbitrator’s orders, if provided for under institutional rules, would be covered by the Arbitration and Conciliation Act.”

Future Group argued that the emergency arbitrator was appointed before the arbitration tribunal was constituted therefore the emergency arbitrator would not fall under the realm of Section 17 (1) of the Indian Arbitration and Conciliation Act. The Supreme Court rejected this argument and held that Section 17(1) is “elastic enough” to capture emergency arbitration proceedings.

The Court observed that “there is nothing in the Arbitration and Conciliation Act that prohibits contracting parties from agreeing to a provision providing for an award being made by an Emergency Arbitrator. On the contrary, when properly read, various Sections of the Act which speak of party autonomy in choosing to be governed by institutional rules would make it clear that the said rules would apply to govern the rights between the parties, a position which, far from being prohibited by the Act, is specifically endorsed by it.”

The Court stated that “the introduction of Sections 9(2) and 9(3) would show that the objective was to avoid courts being flooded with Section 9 petitions when an arbitration tribunal is constituted for two good reasons – (i) that the clogged court system ought to be decongested, and (ii) that an arbitration tribunal, once constituted, would be able to grant interim relief in a timely and efficacious manner.”

The Court observed that “the parties having agreed to paragraph 12 of Schedule 1 contained in the SIAC Rules, it cannot lie in the mouth of a party to ignore an Emergency Arbitrator’s award by stating that it is a nullity when such party expressly agrees to the binding nature of such award from the date it is made and further undertakes to carry out the said interim order immediately and without delay.” (estoppel)

Following the law laid down in BGS SGS SOMA JV v. NHPC, the Court observed that “this judgment is determinative of the issue before us as it specifically ruled out appeals under Order XLIII Rule 1 of the Code of Civil Procedure when it comes to orders being made under the Arbitration Act.”

The issue in question pertains to an India-seated arbitration with venue as Singapore and rules of conduct of arbitration being SIAC Rules. Clarity is still needed on matters where the arbitration is seated abroad (out of India).

Future Implications

The judgment of the Hon’ble Supreme Court in the case of Amazon vs Future Retail Limited and Others provides support to emergency arbitration provisions contained in the institutional rules of various arbitration institutions in India and around the world. Parties can be expected to resort to institutional arbitration to avail the benefits of emergency arbitration without worrying much about the enforcement.

The said judgment encourages contracting parties to choose the seat of arbitration as India.

The said judgment leaves much to be desired for those who want to choose a seat of arbitration other than India, and the legal fraternity shall await clarity regarding enforcement (in India) of foreign seated emergency awards.

References

  1. Mundi, J. (2021, August 2). “Jus Mundi: Wiki Notes for Investment Law & Arbitration”. Jus Mundi. Retrieved November 3, 2021, from https://jusmundi.com/en/document/wiki/en-emergency-arbitration
  2. Sahai, R. (2009, August 18). “Sri Krishan vs Anand”. Indian Kanoon. https://indiankanoon.org/doc/155719426/
  3. Kaul, K., & Nariman, F. (2017, July 6). “Alka Chandewar vs Shamshul Ishrar Khan”. Indian Kanoon. https://indiankanoon.org/doc/53620809/
  4. Virmani, A., Nick Papadimos (Assistant Editor for Australia, New Zealand, and the Pacific Islands), & Scherer, M. (2021, October 2). “Rekindling the Debate on Enforcement of Foreign Seated Emergency Awards in India”. Kluwer Arbitration Blog. http://arbitrationblog.kluwerarbitration.com/2021/10/03/rekindling-the-debate-on-enforcement-of-foreign-seated-emergency-awards-in-india/
  5. Deshmukh, I. (2020, August 28). “Avitel v. HSBC – Finality on the Question of Arbitrability when Allegations of Fraud are Raised SMM”. India Corporate Law. https://corporate.cyrilamarchandblogs.com/2020/08/avitel-v-hsbc-finality-on-the-question-of-arbitrability-when-allegations-of-fraud-are-raised-smm/

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