In Brief
The Supreme Court held that an appeal against a judgment enforcing a foreign arbitral award cannot be filed under Section 13(1) of the Commercial Courts Act 2015, even where the award exceeds Rs. 1 crore. Section 50 of the Arbitration and Conciliation Act 1996—which governs appeals in foreign award enforcement—provides appeals only against orders *refusing* to enforce awards, not against orders *allowing* enforcement. This special provision is exhaustive and self-contained, excluding the general Commercial Courts appeal remedy. Allowing such appeals would contradict both statutes' objects: speedy dispute resolution and expeditious enforcement of international commercial awards. The doctrine of harmonious construction requires the special statute (Arbitration Act) to prevail over the general statute (Commercial Courts Act) in its field.
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