In Brief
An ICC arbitral award delivered in London favoured Rioglass Solar SA against Shriram EPC Limited. Shriram challenged the award's enforceability in India, arguing that an unstamped foreign award cannot be enforced under the Arbitration and Conciliation Act, 1996. The Supreme Court held that the term 'award' in Schedule I of the Indian Stamp Act, 1899 has never included foreign awards since its enactment. Although foreign awards existed in 1899, the legislature deliberately created separate legislative frameworks to govern them without expanding the original definition. Consequently, foreign awards are not liable to stamp duty under Indian law and cannot be rendered unenforceable by lack of stamping. The appeal was dismissed and the Single Judge's order enforcing the foreign award was upheld.
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