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Supreme Court of India 2021-08-10 dismissed

Gemini Bay Transcription Pvt. Ltd vs Integrated Sales Service Ltd. & Anr

Bench: 2 — Rohinton Fali Nariman, B.R. Gavai

In Brief

Integrated Sales Services Ltd, a Hong Kong-based company, obtained a foreign arbitral award against Indian companies DMC, Gemini Bay Consulting, and others for breaching a representation agreement by diverting business and avoiding commission payments. The arbitrator applied the alter ego doctrine under Delaware law to bind non-signatories like Gemini Bay Transcription Pvt. Ltd. On enforcement, the Supreme Court upheld the award, holding that non-signatories can be bound under applicable substantive law; Section 48 grounds for refusing enforcement do not cover non-signatory status; tort claims sufficiently connected to contracts are arbitrable; and poor reasoning or damages based on reasonable estimation do not vitiate awards under the pro-enforcement New York Convention framework.

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Arbitration and Conciliation Foreign Awards Recognition and Enforcement Non-Signatories Alter Ego Doctrine Corporate Veil Piercing New York Convention Arbitrability of Tort Claims Arbitral Award International Commercial Arbitration Public Policy Damages Assessment

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