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Supreme Court of India 2018-02-07 dismissed

Kandla Export Corporation & Anr vs OCI Corporation & Anr

Bench: 2 — R.F. Nariman

In Brief

A dispute arose over whether appeals against High Court orders enforcing foreign arbitral awards could be filed under the Commercial Courts Act, 2015 even though the Arbitration and Conciliation Act, 1996 (Section 50) excludes such appeals. The Court held that Section 50 of the Arbitration Act is part of a self-contained statutory code that impliedly bars all appeals not expressly provided. Therefore, Section 13(1) of the Commercial Courts Act—a general appeals provision—does not apply to foreign award enforcement cases. Allowing an appeal would contradict both Acts' purpose of speedily resolving commercial disputes. The Court dismissed the appeals, holding that harmonious construction requires the special Arbitration Act to prevail over the general Commercial Courts Act on arbitration matters.

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Arbitration and Conciliation International Commercial Arbitration Foreign Awards Commercial Courts Act Appellate Jurisdiction Statutory Interpretation

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