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Supreme Court of India 2025-11-03 dismissed

MMTC LIMITED vs ANGLO AMERICAN METALLURGICAL COAL PVT. LIMITED

Bench: 2 — Sanjay Kumar, K. V. Viswanathan

In Brief

MMTC and Anglo American entered a coal supply agreement in 2007. A dispute arose over unlifted coal quantities in the 5th delivery period, priced at US$300/MT. Anglo claimed damages for the unlifted amount when market prices fell to US$126/MT. An arbitral tribunal awarded Anglo US$78.72 million. After the Supreme Court upheld this award in 2020, MMTC filed objections claiming its officials committed fraud and breach of fiduciary duty in fixing the inflated price. MMTC later filed a criminal complaint, leading to an FIR. The Court dismissed MMTC's execution objections, holding that fraud allegations raised years later require clear contemporaneous proof, not hindsight. Courts cannot reopen final arbitral awards at execution stage except for jurisdictional voidness. The business judgment rule protects reasonable corporate decisions from judicial second-guessing.

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Arbitration Enforcement of Awards Fraud and Fiduciary Duty Commercial Contracts Coal Supply Agreement Breach of Contract

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