Principles with regard to scope of interference under Section 34 of the Arbitration and Conciliation Act, 1996 – A.P. State Trading Corporation Ltd. Vs. Hima Bindu Chemicals Pvt. Ltd. and Anr. – Telangana High Court

(i) Even though Arbitral Tribunal may have committed mere error of fact or law in reaching its conclusion on the disputed questions of law submitted to it for adjudication, the Court has no jurisdiction to interfere with the award.
(ii) The Court while dealing with application under section 34 of the Act, cannot act as an appellate Court and substitute its own findings and cannot correct error of law or fact.
(iii) If two views are possible then, the view taken by the Arbitrator shall prevail and the court would not interfere with the Award passed.
(iv) The Arbitrator cannot re-write the contract in the guise of interpretation.
(v) If an Award on the face of it, is passed in violation of statutory provisions, it cannot be said to be in public interest, as the same is likely to affect administration of justice. Thus an award can be set aside if it is contrary to fundamental policy of Indian law, the interest of India, Justice or Morality or if it is patently illegal and such illegality goes to the root of the matter.
(vi) The Award can be interfered with even if it is contrary to terms of the contract, as the same would be patently illegal and opposed to public policy of India.
(vii) The expression ‘Fundamental Policy of Indian Law’ would inter alia include that every determination by Court or Authority which affects the right of citizen must adopt judicial approach, and should record reasons in support of its decision and perversity and irrationality of decision would be tested on the touch stone of Wednesbury Principle.
(viii) In the absence of agreement to the contrary between the parties section 31(7)(a) of the Act confers jurisdiction on the arbitral tribunal to award interest unless otherwise agreed by the parties, at such rate as the arbitral tribunal considers necessary.

Principles with regard to scope of interference under Section 34 of the Arbitration and Conciliation Act, 1996 – A.P. State Trading Corporation Ltd. Vs. Hima Bindu Chemicals Pvt. Ltd. and Anr. – Telangana High Court Read Post »

The unilateral enhancement/revision of fee by Arbitrator is not permissible in the eyes of law | No objection was raised on unilateral enhancement of fee, it does not amount to consent | The issue of bias has to be raised first before the Arbitral Tribunal at the earliest opportunity – SPML Infra Ltd. Vs. Power Grid Corporation of India Ltd. – Delhi High Court

Hon’ble Delhi High Court held that:
(i) The unilateral enhancement of fee is not permissible in the eyes of law.
(ii) Giving “consent” and having “no objection” may be two different things in particular circumstances.
(iii) The issue of bias has to be raised first before the same tribunal at the earliest opportunity.

The unilateral enhancement/revision of fee by Arbitrator is not permissible in the eyes of law | No objection was raised on unilateral enhancement of fee, it does not amount to consent | The issue of bias has to be raised first before the Arbitral Tribunal at the earliest opportunity – SPML Infra Ltd. Vs. Power Grid Corporation of India Ltd. – Delhi High Court Read Post »

Is an amount which was seized by the Income Tax Department and adjusted against demand prior to initiation of CIRP, an asset of the Corporate Debtor? – Harish Chander Arora Liquidator of Rathi Super Steel Ltd. Vs. The Principal Commissioner of Income Tax (PCIT), Ghaziabad, and Anr. – NCLAT New Delhi

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Is an amount which was seized by the Income Tax Department and adjusted against demand prior to initiation of CIRP, an asset of the Corporate Debtor? – Harish Chander Arora Liquidator of Rathi Super Steel Ltd. Vs. The Principal Commissioner of Income Tax (PCIT), Ghaziabad, and Anr. – NCLAT New Delhi Read Post »

Is imposition of an exorbitant interest in the background of contemporary commercial practices against the fundamental policy? – BPL Ltd. Vs. Morgan Securities & Credits Pvt. Ltd. – Delhi High Court

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Is imposition of an exorbitant interest in the background of contemporary commercial practices against the fundamental policy? – BPL Ltd. Vs. Morgan Securities & Credits Pvt. Ltd. – Delhi High Court Read Post »

Regulation 3(2)(b)(i) of the SEBI (Delisting of Equity Shares) Regulations, 2021, providing that the Delisting Regulations shall not apply in the case of delisting of equity shares pursuant to a Resolution Plan approved under Section 31 of the IBC cannot be regarded as ultra-vires the SEBI Act – Harsh Mehta Vs. Securities and Exchange Board of India (SEBI) and Ors. – Bombay High Court

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Regulation 3(2)(b)(i) of the SEBI (Delisting of Equity Shares) Regulations, 2021, providing that the Delisting Regulations shall not apply in the case of delisting of equity shares pursuant to a Resolution Plan approved under Section 31 of the IBC cannot be regarded as ultra-vires the SEBI Act – Harsh Mehta Vs. Securities and Exchange Board of India (SEBI) and Ors. – Bombay High Court Read Post »

Revival/restore of CIRP petition even no liberty was granted to the Applicant to get the Petition revived nor there was any stipulation in the consent terms – OCS Group (India) Pvt. Ltd. Vs. Mystical Constructions Pvt. Ltd. – NCLT Mumbai Bench

Hon’ble NCLT Mumbai Bench held that the Corporate Debtor cannot be allowed to take advantage of its own wrongs. The said liberty in the given situation can be construed to be a liberty to get the Petition revived and it would be just and equitable if the Petition under Section 9 of the Insolvency and Bankruptcy Code, 2016 filed by the Applicant, which was dismissed on the basis of consent terms, is revived to be decided on merits. In case neither the Petition is revived nor a contempt is issued against the Corporate Debtor, it will cause grave injustice to the Applicant who would be rendered remediless.

Revival/restore of CIRP petition even no liberty was granted to the Applicant to get the Petition revived nor there was any stipulation in the consent terms – OCS Group (India) Pvt. Ltd. Vs. Mystical Constructions Pvt. Ltd. – NCLT Mumbai Bench Read Post »

Application u/s 95 of IBC can be filed against Personal Guarantor even when no CIRP or Liquidation is pending against Corporate Debtor and such application can be filed only before the NCLT that has territorial jurisdiction over the Corporate Debtor – Stressed Assets Stabilisation Fund (SASF) Vs. Sh. Anil Rai – NCLT Allahabad Bench

Hon’ble NCLT Allahabad Bench held that from the Scheme of Section 60 as analysed and adjudicated upon in the above judicial pronouncements, it is clear that application u/s 95 can be filed against the Personal Guarantor even when no CIRP or Liquidation is pending against the corresponding Corporate Debtor and such application can be filed only before the NCLT that has territorial jurisdiction over the corresponding Corporate Debtor.

Application u/s 95 of IBC can be filed against Personal Guarantor even when no CIRP or Liquidation is pending against Corporate Debtor and such application can be filed only before the NCLT that has territorial jurisdiction over the Corporate Debtor – Stressed Assets Stabilisation Fund (SASF) Vs. Sh. Anil Rai – NCLT Allahabad Bench Read Post »

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