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[Cites 36, Cited by 4]

Delhi High Court

Edelweiss Asset Reconstruction ... vs Gtl Infrastructure Limited And Anr. on 18 November, 2020

Author: C. Hari Shankar

Bench: C. Hari Shankar

                            $~
                            *     IN THE HIGH COURT OF DELHI AT NEW DELHI
                                                                 Reserved on: 20th July, 2020
                                                          Pronounced on: 18th November, 2020

                            +     ARB. A. (COMM) 13/2020 & I.A. 4322/2020

                                  EDELWEISS ASSET RECONSTRUCTION COMPANY
                                  LIMITED, ACTING IN ITS CAPACITY AS TRUSTEE OF
                                  THE EARC TRUSTS SC-338,343,366 AND 389
                                                                          ..... Petitioner
                                                Through: Mr. Sandeep Sethi, Sr. Adv.
                                                          with Ms. Misha, Ms. Mahima
                                                          Sareen and Ms. Moulshree
                                                          Shukla, Advs.

                                                     versus


                                  GTL INFRASTRUCTURE LIMITED AND ANR.
                                                                        ..... Respondents
                                               Through: Mr. Parag Tripathi, Sr. Adv.
                                                        with Mr. D.N. Ray, Mr. Rohan
                                                        Rajyadhaksha, Mr. Prasad
                                                        Lotlikar, Mr. Suresh Gadre, Mr.
                                                        Vinod Bhadang, Mr. Lokesh
                                                        Choudhary and Ms. Sumita
                                                        Ray, Advs. for the Respondent
                                                        No. 1
                                                        Mr. Rajiv Nayar, Sr. Adv. with
                                                        Mr. Saket Sikri, Mr. Amit
                                                        Mahajan, Mr. Essaji Vahanvati,
                                                        Mr. Vikalp Mudgal and Mr.
                                                        Ajay Pal Singh Kullar, Advs.
                                                        for R-2

                            CORAM:
                            HON'BLE MR. JUSTICE C. HARI SHANKAR

Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI                  ARB. A. (COMM) 13/2020                                  Page 1 of 95
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                             %                           JUDGMENT



                            1.    Edelweiss Asset Reconstruction Company Ltd. (abbreviated,
                            hereinafter, to "Edelweiss") invokes Section 37 of the Arbitration and
                            Conciliation Act, 1996 (hereinafter referred to as "the 1996 Act") to
                            challenge order, dated 17th December, 2019, passed by the learned
                            Arbitral Tribunal, which directed M/s. GTL Infrastructure Ltd.
                            (hereinafter referred to as "GIL") to pay ₹ 240 crores to M/s. GTL
                            Ltd. (hereinafter referred to as "GTL") and to deposit ₹ 200 crores in
                            an Escrow account, to be maintained by GIL.


                            2.    GTL and GIL were the claimant and respondent, before the
                            learned Arbitral Tribunal, respectively. The operative paragraphs of
                            the impugned Order, with which Edelweiss claims to be aggrieved,
                            reads thus:

                                  "37.    It is accordingly ordered that:

                                          (i)   The Respondent will pay a sum of Rs. 40 crores
                                          to the Claimant before or by 27th December, 2019
                                          towards Security Deposit as contemplated under
                                          Clause 4.5 of the Suspension Agreement dated 8th
                                          March, 2018. (hereinafter referred to as the
                                          "Suspension Agreement")

                                          (ii)  The Respondent shall pay Rs. 400 crores in
                                          accordance with the below mentioned schedule:

                                           80 Crores to be paid directly    Before or by 27th
                                           to the Claimant                  December, 2019
                                           80 Crores to be deposited in     Before or by 27th
                                           an Escrow Account to be          January, 2020
                                           maintained      by        the
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SINGH NEGI                  ARB. A. (COMM) 13/2020                                         Page 2 of 95
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                                           Respondent
                                          80 Crores to be paid directly   Before of by 27th
                                          to the Claimant                 February, 2020
                                          80 Crores to be deposited in    Before or by 27th
                                          an Escrow Account to be         March, 2020
                                          maintained        by      the
                                          Respondent
                                          40 Crores to be paid to the     Before or by 27th
                                          Claimant directly               April, 2020
                                          40 Crores to be deposited in    Before or by 27th
                                          an Escrow Account to be         April, 2020
                                          maintained        by      the
                                          Respondent

                                         (iii) The Claimant shall provide uninterrupted
                                         services to the Respondent subject to the terms of
                                         payment contained in the two foregoing sub-clauses.

                                  38.     The Respondent has agreed to furnish the details of the
                                  Escrow Account with the Tribunal as well as the Claimant on
                                  or before 27th December, 2019. It is made clear that in the
                                  eventuality of any default in adhering to the schedule
                                  mentioned above, the Respondent shall become immediately
                                  liable for payment of the entire sum of Rs. 400 crores less the
                                  unpaid/remaining sum to the Claimant.

                                  39.   It is clarified that the present order shall await the
                                  Final Award and shall be subject to adjustments in order to
                                  conform to the Final Award."


                            3.    Edelweiss was not a party before the learned Arbitral Tribunal,
                            but claims to be vitally affected by the impugned directions. In fact, it
                            is claimed, by Edelweiss, that GIL and GTL are in collusion, and that
                            they misled the learned Arbitral Tribunal into passing the impugned
                            Order, suppressing the fact that Edelweiss had a first charge over the
                            monies which GIL has been directed to pay to GTL, or to deposit in
                            the Escrow account.

Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI                  ARB. A. (COMM) 13/2020                                            Page 3 of 95
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                             4.    Before appreciating the grievance of Edelweiss, it would be
                            necessary to briefly capitulate the facts and the justification, cited in
                            the impugned Order, for issuing the above directions.


                            The Impugned Order


                            5.    M/s. Chennai Network Infrastructure Ltd . (hereinafter referred
                            to as "CNIL") and the Aircel group of Companies (hereinafter
                            referred to as "Aircel") entered into an Existing Site Agreement
                            (hereinafter referred to as "ESA") dated 14th January, 2010,
                            whereunder Aircel agreed to provide CNIL sites and land on
                            ownership/tenancy basis, to be developed by CNIL, so as to enable
                            Aircel to set up, on such sites/land, Active Equipment/infrastructure,
                            using which Aircel could provide telecommunication services.


                            6.    Under Clause 6 of the ESA, a tripartite Energy Management
                            Agreement (hereinafter referred to as "EMA") was executed, on 14 th
                            January, 2010 itself, between CNIL, Aircel and GTL. Clause 3.1 of
                            the EMA obligated CNIL to oversee the management of electricity
                            and diesel consumption at the above sites, and payment therefor,
                            whereas Clause 3.2 allowed CNIL to outsource these responsibilities
                            to GTL.


                            7.    On the same day, i.e. 14th January, 2010, a third, New Site
                            Agreement (hereinafter referred to as "NSA") was executed between
                            CNIL and Aircel. Clause 2.1 of the NSA required Aircel to grant
                            CNIL the Right of First refusal, in respect of all the requirements for
Signature Not Verified
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                             sites, of Aircel (other than certain excluded sites), by way of a written
                            proposal, for a period of three years. Each such site was required, by
                            Clause 2.5, to be developed by CNIL, for use by Aircel to install and
                            maintain its Active Equipment, for providing telecommunication
                            services. Clause 2.6 obligated Aircel to submit 20,000 proposals, to
                            CNIL, during this three-year proposal period, which was referred to as
                            the "Minimum Commitment". Of these, at least 4000 proposals (the
                            "Annual Commitment") were required to be submitted each year.


                            8.    CNIL, vide letter dated 18th January, 2010, requested GTL to be
                            its implementation partner. The request was accepted by GTL, vide
                            response dated 22nd January, 2010.        CNIL and GTL, thereupon,
                            entered into a TSPI Agreement dated 28th January, 2010, whereunder
                            GTL agreed to procure necessary materials for establishing Passive
                            Telecom Infrastructure on the sites provided by Aircel to CNIL, and
                            to convert them into completely built-up telecom sites, by carrying out
                            requisite civil and electrical work thereon, on behalf of CNIL.


                            9.    On 5th February, 2010, CNIL issued a Purchase Order, to GTL,
                            for ₹ 4350 crores, which was accepted by GTL vide letter dated 8th
                            February, 2010.     As GTL was incurring huge expenses, towards
                            establishing Passive Telecom Infrastructure on the sites, and
                            converting them to telecom sites, to be used by Aircel for providing
                            telecommunication services to its customers, it became necessary to
                            indemnify GTL, in the event of default, by Aircel, in adhering to the
                            "Minimum Commitment" visualised by Clause 2.6 of the NSA.
                            Accordingly, the TSPI Agreement dated 28th January, 2010 was
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                             modified by an Addendum dated 9th February, 2010, whereby CNIL
                            agreed to indemnify GTL against direct losses, liabilities, damages,
                            demands etc., suffered by it, or by parties indemnified by GTL, on
                            account of default, on the part of Aircel/CNIL to provide the
                            minimum commitment of 20,000 new sites, or on account of any other
                            breach of the terms and conditions of the Purchase Orders. CNIL also
                            undertook and agreed, vide the said Addendum, to make all efforts to
                            recover monies from Aircel and make payments to GTL, or to the
                            suppliers of GTL.


                            10.   Predicated on this Addendum, GTL proceeded to source
                            requisite material, as envisaged in the Purchase Order dated 5th
                            February, 2010 issued by CNIL. GTL alleged, before the learned
                            Arbitral Tribunal, that, despite such procurement of materials having
                            been effected by it, CNIL failed to provide details of the sites where
                            the material were to be delivered, resulting in considerable financial
                            prejudice to GTL. This fact was brought, by GTL, to the notice of
                            CNIL, vide letter dated 12th February, 2013, in response to which
                            CNIL replied, on 20th May, 2013, informing GTL that, as Aircel had
                            completely stopped site orders, CNIL was not able to provide such
                            orders, or details thereof, to GTL.      Expressing chagrin at this
                            development, GTL wrote back, to CNIL, on 10 th June, 2013,
                            informing CNIL that, based on the assurances held out by CNIL and
                            Aircel under the TSPI Agreement, GTL had placed bulk orders for
                            material, which was ready for being delivered and commissioned.
                            The failure, on the part of CNIL, in providing site details, it was
                            asserted, had seriously prejudiced GTL, as it had made huge advance
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                             payments to the vendors from whom it had procured the material, for
                            making which it had also availed considerable borrowings from
                            banks.


                            11.   Ultimately, on 24th May, 2014, a Settlement Agreement was
                            executed, between CNIL, Aircel and GTL, whereunder, against the
                            claim, of GTL, of ₹ 2450 crores, ₹ 1800 crores was "settled".


                            12.   The remaining ₹ 650 crores constitutes subject matter of the
                            arbitral proceedings, wherefrom the present appeal emanates.


                            13.   As the efforts of GTL, to recover the remaining ₹ 650 crores,
                            were proving abortive, a learned retired Judge of the High Court of
                            Bombay, Hon'ble Mr. Justice D. G. Deshpande, was requested to act
                            as Conciliator, to resolve the impasse. Before the learned Conciliator,
                            CNIL and GTL agreed - as reflected in Order dated 13th February,
                            2015 issued by the learned Conciliator - to enter into a long-term
                            Energy Management Agreement and Operations and Maintenance
                            Agreement, to remain alive till 2030, which would guarantee GTL
                            recovery of the amounts claimed by it, as well as generate reasonable
                            revenues to enable GTL to repay its lenders. It was further agreed that
                            breach, by CNIL, of its commitments under the said Agreements,
                            would result in reinstatement of the claim of GTL. Pursuant thereto,
                            on 31st March, 2015, CNIL and GTL executed, inter se, an Energy
                            Management Agreement (EMA) and an Operations and Maintenance
                            Agreement (OMA).


Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI                  ARB. A. (COMM) 13/2020                                          Page 7 of 95
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                             14.   At this stage, vide order dated 22nd December, 2017 issued
                            under Section 232 of the Companies Act, 2013, the learned National
                            Company Law Tribunal (hereinafter referred to as "the learned
                            NCLT"), transferred all liabilities of CNIL to GIL. GIL, thereby,
                            stepped into the shoes of CNIL, in the dispute with GTL.


                            15.   On 6th January, 2018, 10th January, 2018 and 15th January,
                            2018, three more communications were addressed by GIL to GTL
                            which resulted, effectively, in the exacerbation of the financial
                            distress of GTL. By these communications, GIL intimated GTL that
                            Aircel had surrendered their Unified Access Services Licences for 6
                            service areas and had requested CNIL (later GIL) to stop billing of all
                            types of charges to Aircel w.e.f. 1st February, 2018, for the Passive
                            Infrastructure provided at all sites in the said six circles. This, it was
                            stated, had resulted in a loss of 1,994 tenancies for Aircel. In these
                            circumstances, it was stated that it was not possible for GIL to adhere
                            to its obligations under the EMA dated 31st March, 2015.


                            16.   GIL and GTL attempted, as it were, to pour some oil on the
                            troubled waters by entering into yet another agreement, titled the
                            "Suspension Agreement" on 8th March, 2018. By this Agreement,
                            GTL agreed to suspend, without prejudice, various Clauses of the
                            EMA dated 31st March, 2015, and other Agreements, whereunder
                            GTL could otherwise have initiated legal proceedings against GIL,
                            albeit without prejudice, in order to enable GIL to attempt to
                            restructure its debts and stabilise its operations.     The suspension


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SINGH NEGI                  ARB. A. (COMM) 13/2020                                          Page 8 of 95
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                             period, which was originally till 31st June, 2018, was extended till 31st
                            March, 2019 and, thereafter, till 31st August, 2019.


                            17.   Alleging that, despite all these efforts, GIL had failed to
                            disgorge the amounts remaining to be paid to GTL, GTL issued a
                            Legal Notice, dated 29th August, 2019, to GIL, calling on GIL to pay,
                            forthwith, to GTL, the amounts outstanding, being ₹ 40 crores as per
                            Clause 4.5 of the Suspension Agreement as a refundable deposit and ₹
                            650 crores, being the outstanding amount payable under the TSPI
                            Agreement, along with interest.


                            18.   On receiving this missive, GIL requested for a meeting of the
                            Joint Steering Committee of GTL and GIL which, accordingly, was
                            held on 5th September, 2019. In the said meeting, GIL denied breach
                            of any obligation, towards GTL, on its part, and contended that all
                            obligations stood discharged.     The demand for payment of ₹ 40
                            crores, in terms of Clause 4.5 of the Suspension Agreement, was also
                            refuted, on the ground that the Suspension Agreement had expired.


                            19.   The impasse having thus proved incapable of an amicable
                            resolution, it was decided that the disputes be referred to arbitration.
                            Thus, came to be constituted the learned Arbitral Tribunal, which
                            passed the impugned Order on 17th December, 2019.


                            20.   We are not concerned with the main dispute between GIL and
                            GTL, with which the learned Arbitral Tribunal continues to remain in
                            seisin. The impugned Order came to be passed on an application,
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SINGH NEGI                  ARB. A. (COMM) 13/2020                                         Page 9 of 95
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                             dated 24th September, 2019, filed by GTL, containing the following
                            prayers (as reproduced in para 1 of the Impugned Order):
                                  "(a) Pass an order directing the Respondent to pay to the
                                  Applicant/Claimant an admitted sum of Rs 650,00,00,000
                                  (Rupees Six Hundred Fifty Crores Only) and the
                                  Rs.40,00,00,000/- (Rupees Forty Crores Only), totalling
                                  Rs.690,00,00,000/- (Rupees Six Hundred Ninety Crores
                                  Only), along with interest @ 21% p.a. or at such rate as the
                                  Hon'ble Tribunal may deem fit and proper from the due date
                                  till the date of realization.

                                  (b)     In an alternative to prayer clause (a) Pass an order
                                  directing the Respondent to furnish security in the sum of Rs
                                  Rs 650,00,00,000 (Rupees Six Hundred Fifty Crores Only)
                                  and Rs.40,00,00,000/- (Rupees Forty Crores Only) totalling to
                                  Rs.690,00,00,000/- (Rupees Six Hundred Ninety Crores
                                  Only) along with interest @ 21% p.a. or at such rate as the
                                  Hon'ble Tribunal may deem fit and proper from the due date
                                  till the date of realization, in the form of deposit of the same
                                  before this Hon'ble Tribunal to secure the claim in the
                                  Claimant in the arbitration proceedings;

                                  (c)     Pending the hearing and final disposal of the Claim by
                                  this Hon'ble Tribunal, the Respondent be directed to pay to
                                  the Claimant a sum of Rs.40,00,00,000/- (Rupees Forty
                                  Crores Only) in order to enable the Claimant to keep the
                                  network of the Respondent keep going or such other amount
                                  as this Hon'ble Tribunal may deem fit and proper;

                                  (d)    Pass an order directing that pending the
                                  furnishings/deposit of security in terms of prayer (a),
                                  Respondent is restrained from proceeding further with the
                                  sale of any of its assets including its real estate assets and
                                  tower assets as proposed;

                                  (e)    Pass an order directing the Respondent from
                                  transferring, encumbering, alienating or in any other manner
                                  dealing with the shares of Respondent;

                                  (f)    Pending furnishing of security in the form of (a)
                                  above, pass an order of injunction restraining the Respondent,
                                  whether directly or indirectly, from selling, disposing or
Signature Not Verified
                                  creating any third party interest in all of any of its movable or
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                                   immovable assets including cash reserves in bank accounts
                                  and the active infrastructure equipment installed at the sides
                                  of the Claimant;

                                  (g)    Issue an ad-interim and interim order and/or direction
                                  in terms of prayer (a) to (f) above;

                                  (h)    Grant costs of this petition; and

                                  (i)    Pass such other/further order(s) as this Hon'ble Court
                                  deem fit and proper in the facts and circumstances of the
                                  case."


                            21.   After arguments were heard and orders were reserved, by the
                            learned Arbitral Tribunal on the application, of GTL, under Section
                            17, "clarificatory submissions", opposing the application, were
                            tendered by GIL. It was contended, therein, that, as the application of
                            GTL was premised on the advisability of securing the claim amount,
                            so as to obviate the possibility of the eventual award, if any, being
                            rendered a mere paper decree, no direction for payment of any
                            amount, by GIL to GTL, was necessary, and that the apprehension of
                            GTL would be sufficiently allayed if deposit, in an Escrow account,
                            were directed. Any direction, for payment of the claimed amount, by
                            GIL to GTL would, it was submitted, result in the following
                            "irreversible consequences" for GIL (the respondent before the
                            learned Arbitral Tribunal):
                                  "(A) The Respondent's net worth will erode to a point
                                  where it will be definitely pushed into insolvency. Whereas,
                                  if the moneys are parked in an escrow, till the pendency of the
                                  present proceedings, the Respondent will still be able to (at
                                  least on paper) lay a potential claim to the funds. This might
                                  be all the edge the Respondent requires in its balance sheet to
                                  stay afloat which will also be crucial to the Claimant's
                                  interests. Therefore also, the balance of convenience lies with
                                  a direction for escrow.
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                                   (B) In a situation where outright payment is ordered to be
                                  made to the Claimant, they will be every possibility that other
                                  creditors of the Respondent will immediately file similar
                                  proceedings and pray for similar reliefs, thereby eroding the
                                  substratum of the Respondent, which, to say the least, will
                                  jeopardize even the Claimant's ability to recover any amount
                                  from the Respondent. Further, the Respondent's accounts are
                                  in CDR (corporate debt restructuring) with banks who may
                                  advise the Respondent or independently challenge the
                                  payment direction in appeal. Either way, the balance of
                                  convenience lies in a direction to deposit in escrow."

                            Apropos the claim of ₹ 40 crores, under the Suspension Agreement,
                            GIL assented to a direction to pay the said amount to GTL, but prayed
                            that the payment be made subject to the outcome of the arbitral
                            proceedings.


                            22.   While opposing, on principle, the aforesaid "Clarificatory
                            Submissions" tendered by GIL on the ground, inter alia, that the
                            liability of ₹ 400 crores, as payable to GTL, had been admitted by
                            GIL since long, GTL, in its response to the said submissions of GIL,
                            tentatively agreed to the deposit of the said amount of ₹ 400 crores in
                            an escrow account, to be maintained by GTL or any other mutually
                            agreed Escrow Agent.


                            23.   During arguments before the learned Arbitral Tribunal, GTL
                            contended that there was no dispute, by GIL, to its liability to pay ₹
                            650 crores to GTL, in its Statement of Defence. Accordingly, it was
                            submitted that GIL was liable to suffer an Interim Award/Partial
                            Decree, for the said amount, even at that stage. In opposition, GIL
                            argued that an amount of ₹ 200 to 250 crores, in terms of the EMA
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                             and OMA dated 31st March, 2015, already stood recovered by GTL
                            and that, therefore, GTL could no longer lay a claim to ₹ 650 crores.
                            Had the interim arrangements, as contemplated by the EMA and
                            OMA been allowed to continue, it was submitted that GIL would have
                            been able to liquidate the entire ₹ 650 crores.         There was no
                            justification, it was contended, for the Interim Arrangements,
                            contemplated by the said Agreements, not being allowed to continue.


                            24.   During arguments before the learned Tribunal, GIL, while
                            reasserting the fact that ₹ 250 crores already stood recovered, by GTL,
                            in terms of the EMA and OMA, was unable to dispute the remaining
                            claim of ₹ 400 crores, or to establish that the said amount stood
                            liquidated. All that was submitted, in this regard, was that, had the
                            EMA and OMA been allowed to continue, the entire debt of ₹ 650
                            crores would stand liquidated.


                            Reasoning and Findings of the learned Arbitral Tribunal


                            25.   The learned Tribunal, on these facts, held that there was no
                            denial, by GIL, of its liability to pay ₹ 400 crores to GTL which,
                            therefore, was "not a sum presently in dispute" within the meaning of
                            Order VIII Rules 3, 4 and 5 of the Code of Civil Procedure, 1908
                            (CPC).    Qua the remaining ₹ 250 crores, the learned Tribunal
                            recorded the fair statement, of GTL, that adjudication, of the liability
                            of GIL, was necessary.




Signature Not Verified
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                             26.        After referring to the judgement of the Supreme Court in Uttam
                            Singh Duggal v. United Bank of India Ltd1 and of the Division
                            Bench of this Court in Numero Uno International Ltd v. Prasar
                            Bharti2, the impugned Order concludes thus (before issuing the
                            impugned directions in para 37):

                                       "33. On 22nd October, 2019, Mr. Ray, Learned Counsel Ld.
                                       for the Respondent on instructions received from the
                                       Authorised representatives present before the Tribunal stated,
                                       by way of an Interim arrangement, the Respondent would
                                       make payment of Rs 400 crores in five tranches of Rs 80
                                       crores each, along with a Security Deposit of the Rs 40
                                       crores, in terms of Clause 4.5 of the Suspension Agreement.
                                       This arrangement was not opposed by Ld. Counsel for the
                                       Claimant.

                                       34.    However, as noted in paragraph 19 above, the
                                       Respondent thereafter pressed for depositing the aforesaid
                                       amount in escrow, which prayer was not resisted by the
                                       Claimant in its response thereto. However, Ld Counsel for
                                       the Claimant may have vehemently opposed this proposed
                                       arrangement during the oral arguments on 26th November,
                                       2019 and indeed pressed for the passing of an Interim Award.

                                       35.     In these circumstances, though the Claimant has
                                       moved its Application under Section 17, Mr. Wadhwa has
                                       urged the Tribunal to treated under Section 31(6) of the A &
                                       C Act and pass an Interim Award/Partial Decree against the
                                       Respondent and in favour of the Claimant qua the undisputed
                                       sum of Rs 400 crores. In the SOC there is a claim of over Rs
                                       890 crores. In reply to which the Respondent has pleaded in
                                       the SOD that approximately Rs 200-250 crores has been
                                       recovered from adjustments made by inter party transactions
                                       from 2015 to 2019. The Tribunal finds that the Claimant is
                                       justified in its contention that there being no categorical
                                       denial to the Respondent's liability for the sum of Rs 400


                            1   (2000) 7 SCC 120
                            2   150 (2008) DLT 688

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SINGH NEGI                      ARB. A. (COMM) 13/2020                                           Page 14 of 95
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                                   crores, the Tribunal must deduce that there is a tacit
                                  admission by the Respondent.

                                  36.     The Tribunal is further mindful of the financial
                                  situation of the parties herein, as submitted by Ld Counsel on
                                  both sides. Ld Senior Counsel for the Claimant has
                                  emphasized that it has continued till date to perform its
                                  contractual obligations for maintenance of the Passive
                                  Telecom Infrastructure even in the absence of payment of 10-
                                  15% towards 'Interim Service Fee' as postulated in the
                                  Suspension Agreement. On the other hand, Learned Counsel
                                  for the Respondent had stated that it is in the interest of both
                                  the parties that inter-se agreements should run their course
                                  and tenure till 2030 to enable the recoupment of the
                                  Respondent's dues to the Claimant."

                            The impugned directions, as reproduced in para 2 supra, follow.

                            Subsequent proceedings


                            27.   The impugned Order has formed subject matter of three judicial
                            proceedings, prior to the institution of the present appeal, viz. (i)
                            Arb.A. (COMM) 7/2020 (GTL Infrastructure Ltd v. GTL Ltd), filed
                            by GIL under Section 37(2)(b) of the 1996 Act before this Court, (ii)
                            OMP (ENF) (COMM) 23/2020 (GTL Ltd v. GTL Infrastructure
                            Ltd), preferred by GTL under Section 36 of the 1996 Act, before this
                            Court and (iii) Suit LD-VC No 55/2020 (Edelweiss Asset
                            Reconstruction Co. Ltd v. GTL Infrastructure Ltd & ors.), filed by
                            the appellant Edelweiss against GIL and GTL before the High Court
                            of Bombay. Edelweiss was not a party, either in Arb.A. (COMM)
                            7/2020 or in OMP (ENF) (COMM) 23/2020.


                            28.   Arb.A. (COMM) 7/2020

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                             28.1 By this appeal, under Section 37(2)(b) of the 1996 Act, GIL
                            challenged the presently impugned Order dated 17th December, 2019.


                            28.2 Holding the reliance, by the learned Arbitral Tribunal, on
                            Uttam Singh Duggal1 and Numero Uno International Ltd2 to be
                            justified, a learned Single Judge of this Court, vide judgement dated
                            4th March, 2020, dismissed Arb A (COMM) 7/2020, observing and
                            finding, in paras 31 and 34 of the judgement, thus:

                                  "31. This Court finds no error or infirmity in this finding of
                                  the Tribunal. Once any part of the liability is admitted, law
                                  does not envisage that the admitted payments should be
                                  postponed till the disputed amounts are adjudicated and
                                  finalized. Even today before this Court while learned counsel
                                  for the appellant has argued that there was no tacit admission
                                  of liability, but the fact of the matter is that on being
                                  confronted with the observations of the Tribunal, regarding
                                  the admission of liability, it could not be pointed out that
                                  these findings were incorrect. Learned counsel has also not
                                  been able to point out any material or document from which it
                                  could be gathered that the finding of the Tribunal of admitted
                                  liability is erroneous. In fact, the admission of liability by the
                                  appellant is further fortified by the fact that the appellant
                                  itself on 22.10.2019 had agreed to an interim arrangement
                                  whereby it undertook to make the payments in five tranches
                                  of Rs 80 crores each. Relevant para of the Order is extracted
                                  in the earlier part of the judgement. Since the appellant itself
                                  offered to clear the outstanding liability in five tranches, the
                                  Tribunal accepted the offer and directed accordingly. The
                                  Schedule that has been drawn out by the Tribunal regarding
                                  the modalities of payment in para 37 of its Order is only in
                                  terms of the offer, voluntarily made by the appellant.
                                  Learned senior counsel for the respondent is thus right in its
                                  contention that having offered to clear the liability in
                                  instalments, the appellant cannot even assail the impugned
                                  order.
                                                             *****


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                                   34.    Thus in my view, on account of the admission and
                                  offer of the appellant to clear its liability and the law that if an
                                  amount is admitted by a party, the same should be released to
                                  the opposite party in the earliest, without waiting for
                                  adjudication of the remaining disputes, no infirmity can be
                                  found with the impugned order, calling for any interference
                                  by this Court in the present proceedings. The appeal has no
                                  merits and is accordingly dismissed."


                            29.   OMP (ENF.) (COMM) 23/2020


                            29.1 These proceedings have been initiated by GTL, for enforcement
                            of the impugned Order. Notice stands issued thereon. Edelweiss has
                            applied for impleadment therein.


                            30.   Suit LD-VC No 55/2020


                            30.1 Alleging that the payments made by GIL to GTL, including the
                            amounts paid as a consequence of the impugned Order, amounted to
                            illegal diversion of monies secured in favour of Edelweiss, this suit,
                            filed before the High Court of Bombay, prayed, inter alia, for a
                            permanent injunction, restraining GIL "from transferring, alienating
                            and/or conveying the amount of ₹ 440 crores (the amount of the
                            Arbitral Order) or any other amount in favour of (GTL) including ₹
                            320 crores, prior to fully discharging the outstanding dues of
                            (Edelweiss)". In the event any such transfer had already taken place,
                            the suit prayed for a decree of mandatory injunction, directing GIL to
                            reconvey the amounts. Ad interim ex parte injunction, against GIL,
                            "restraining it from transferring, alienating and/or conveying the


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                             amount of ₹ 440 crores (the amount of the Arbitral Order) or any
                            other amount in favour of (GTL)" was also sought.


                            30.2 This suit came up for hearing before the High Court of Bombay
                            on 5th May, 2020. On the said date, GIL submitted, the High Court,
                            that the Demand Drafts for ₹ 320 crores, drawn in favour of GTL, had
                            been returned to GIL, and stood deposited in the TRA (Trust and
                            Retention Agreement) Account of GIL. The statement was accepted
                            as an undertaking given to the High Court. In view thereof, the High
                            Court opined that it was not necessary to grant the urgent ad interim
                            relief sought by Edelweiss. Apropos the interim prayer for restraining
                            the amounts covered by the impugned Order of the learned Arbitral
                            Tribunal being transferred by GIL to GTL, Edelweiss did not press the
                            said relief at that stage. Liberty was granted, by the High Court, to
                            Edelweiss to apply for this relief at a later stage, when the merits of
                            the matter would be examined.


                            The appellant's case


                            31.   The case set up by the appellant may be best understood by
                            paraphrasing it, thus:

                                  (i)    The appellant is an asset reconstruction company, in
                                  terms of Section 3 of the Securitisation and Reconstruction of
                                  Financial Assets and Enforcement of Financial Securities
                                  Interests (SARFAESI) Act, 2002.


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                                   (ii)    In 2007-2008, CNIL and GTL availed loans from various
                                  banks and financial institutions, for financing of installation of
                                  telecom towers. Default, in liquidating the loans, however,
                                  occurred, resulting in GTL and CNIL requesting the consortium
                                  of lenders for corporate debt restructuring (CDR). Accordingly,
                                  the case of GTL and CNIL were referred to the CDR Cell on 1 st
                                  July, 2011, and the existing loans were restructured.


                                  (iii)   On   31st   December,    2011,   two   separate     Master
                                  Restructuring Agreements (MRAs) was executed between the
                                  CDR lenders and GIL, and between the CDR lenders and
                                  CNIL, containing the terms for restructuring of the debt.


                                  (iv)    On 25th June, 2013, a Trust and Retention Account
                                  (TRA) Agreement was executed between the Union Bank of
                                  India (which acted as the Monitoring Institution as well as the
                                  Account Bank for the MRA) and the IDBI Trusteeship Services
                                  Ltd (acting as a Security Trustee) and GIL, whereunder,
                                  consequent to the agreement of the CDR Lenders to restructure
                                  the debts of GIL, all receivables of GIL from its operations and
                                  businesses, duly charged to its secured financial creditors, were
                                  to flow to various accounts set up in the 'Account Bank'. Any
                                  outflow, from the said account, could be made only in the
                                  manner envisaged by the TRA Agreement.


                                  (v)     As the account of GIL was performing unsatisfactorily, it
                                  was declared a Non-Performing Asset (NPA), w.e.f. 31st June,
                                  2000. Consequent thereupon, the CDR Lenders, in a meeting
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                                   held on 26th September, 2016, invoked the Strategic Debt
                                  Restructuring Scheme (SDR Scheme), in accordance with the
                                  guidelines of the Reserve Bank of India (RBI), agreeing, inter
                                  alia, to conversion of part of the debt into equity, and to the
                                  merger of CNIL with GIL. As a result of conversion of part of
                                  the debt of GIL into equity, the CDR Lenders came to hold
                                  about 63.16% of the share capital of GIL.


                                  (vi)   The SDR Scheme, however, also failed to take off. The
                                  account of GIL was again declared NPA w.e.f. 1st July 2011.


                                  (vii) As a result, the CDR Lenders decided to sell the financial
                                  assets of GIL to an asset reconstruction company. Edelweiss,
                                  along with Bank of America Merrill Lynch, bid for acquisition
                                  of the entire financial asset sale of GIL. The offer of Edelweiss,
                                  for ₹ 2400 crores, was accepted by the Monitoring Institution,
                                  i.e. the Union Bank of India, on 13th July, 2018. Thereafter, a
                                  majority of the CDR Lenders assigned their loans, advanced to
                                  GIL, in favour of Edelweiss, by way of various Assignment
                                  Agreements. As a result, Edelweiss stepped into the shoes of
                                  the Assignor Banks of GIL.        Under one such Assignment
                                  Agreement dated 28 August, 2018, Edelweiss was also assigned
                                  the role of 'Monitoring Institution', in place of Union Bank of
                                  India, under the TRA Agreement.             As such, Edelweiss
                                  controlled and supervised the TRA capital, which, naturally,
                                  would include all outgos therefrom. Resultantly, Edelweiss has
                                  acquired 79.36% of the secured rupee debt of GIL.             The
                                  Assignor Banks also assigned their rights, title and interest
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                                   under the MRA and TRA Agreement in favour of Edelweiss,
                                  and all covenants of the said agreements, therefore, constitute
                                  binding obligations between Edelweiss and GIL.


                                  (viii) Under the MRA,
                                         (a)    GIL was prohibited from creating, or allowing the
                                         subsistence of, any security interest, or any type of
                                         preferential arrangement, on any of its assets, as well as
                                         from creating an escrow on its future cash flows or any
                                         charge, lien or interest thereon,
                                         (b)    GIL was to provide full disclosure, to the CDR
                                         Lenders, including Edelweiss, at the first instance, as to
                                         initiation, or threatened initiation, of any litigation,
                                         investigation or proceedings, judicial, quasi-judicial or
                                         administrative, before any arbitrator or government entity
                                         or other legal proceedings, which would result in a
                                         material adverse effect on the ability, of GIL, to
                                         discharge its obligations under the financing documents,
                                         including its obligation to repay the debts,
                                         (c)    GIL was also required to apprise Edelweiss of the
                                         occurrence of any event which had a material adverse
                                         effect on its business or financial condition or upon
                                         discharge of its obligations under the financing
                                         agreements,
                                         (d)    GIL was also required to notify the CDR Lenders,
                                         including Edelweiss, of any event which had a material
                                         impact on the debt servicing capacity of GIL, and
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                                          (e)    GIL was required to establish a trust and retention
                                         account (TRA) with the Account Bank in terms of the
                                         TRA Agreement, close all its other accounts and transfer
                                         the amounts contained in such other accounts to the
                                         TRA.


                                  (ix)   Under the TRA Agreement,
                                         (a)    GIL was required to open a series of accounts with
                                         the Account Bank, debits from, and credits into, which,
                                         could only be carried out under the supervision of the
                                         Monitoring Institution, i.e. Edelweiss,
                                         (b)    all business proceeds of GIL were to flow into the
                                         said accounts, under Clause 2.9 of the TRA Agreement,
                                         (c)    GIL was obligated to provide monthly reports and
                                         details of proposed debits from the said accounts, and
                                         (d)    in the event of default, the Account Bank was
                                         required, in accordance with the instructions of
                                         Edelweiss and taking over of the operation of the TRA
                                         Account by Edelweiss.


                                  (x)    The MRA and TRA secured the loans and facilities
                                  granted by Edelweiss to GIL by hypothecation over all the
                                  movable assets of GIL and a charge on the TRA, which
                                  included reserves and bank accounts, present and future, of
                                  GIL, wherever maintained.




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                                   (xi)   The joint effect of the aforesaid agreements was,
                                  therefore, that GIL could not have paid any amount to anyone,
                                  including GTL, in priority to Edelweiss and its other secured
                                  financial creditors.


                                  (xii) As there was consistent default, of GIL, in servicing its
                                  debt obligations, under the MRA and TRA, Edelweiss issued a
                                  formal notice of default, to GIL on 24th January, 2020.


                                  (xiii) In this scenario, GIL and GTL instituted collusive
                                  arbitration proceedings, solely with a view to divert the funds of
                                  GIL, secured in favour of Edelweiss and other secured
                                  creditors, to GTL, which was a related entity, in violation of the
                                  superior priority rights of Edelweiss and other secured
                                  creditors.


                                  (xiv) Edelweiss was never made aware of the said proceedings.
                                  It was only vide letter dated 8th January, 2020, received by
                                  Edelweiss on 9th January, 2020, that GIL informed Edelweiss of
                                  the impugned Order.


                                  (xv) In the backdrop of the aforesaid facts, GIL could not
                                  have proposed a schedule of payments to be made to GTL,
                                  which led to the passing of the impugned Order. Any such
                                  payment could have been made only after all outstanding dues
                                  of Edelweiss and other secured financial creditors of GIL, had
                                  been liquidated.       Prior thereto, creation of such a liability,
                                  without prior consent and approval of Edelweiss and other
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                                   secured financial creditors was illegal and wrongful. GIL had,
                                  thereby, committed culpable breach of the terms of the MRA
                                  and the TRA, by defeating the superior priority rights of its
                                  secured financial lenders. The impugned Order, which results
                                  in according a seal of approval to the said breach is also,
                                  therefore, unsustainable in law.


                                  (xvi) Had the learned Arbitral Tribunal been apprised of the
                                  MRA and the TRA, and the covenants thereof, the impugned
                                  Order would not have been passed.          The learned Arbitral
                                  Tribunal would, thereupon, have become aware of the fact that
                                  the amounts, which GIL consented to pay to GTL, were not
                                  GIL's, to fritter away.   It is also pointed out, in this context,
                                  that, till the conversion of the debt of GIL into equity, under the
                                  SDR Scheme, GTL was the controlling and holding company of
                                  GIL.


                                  (xvii) Edelweiss was a stranger to Arb. A. (COMM) 7/2020.
                                  The judgement, dated 4th March, 2020, had come to be passed,
                                  by the coordinate Bench of this Court, in the said appeal, owing
                                  to any lack of a serious challenge, on the part of GTL, or
                                  substantive contest by GIL.


                                  (xviii) OMP (ENF.) (COMM) 23/2020, too, had not resulted in
                                  any direction to GIL to remit any amounts to GTL. Edelweiss
                                  had moved an application, seeking intervention in the said
                                  proceedings.
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                                   (xix) Edelweiss addressed a number of communications to
                                  GIL, directing it not to make any unilateral payments to GTL
                                  without    prior   consent   of   Edelweiss.     Despite     such
                                  communications, on 13th and 14th March, 2020, GIL and GTL
                                  issued disclosures under Regulation 30 of the SEBI (Listing
                                  Obligations and Disclosure Requirements) Regulations, 2015,
                                  affirming the fact of payments having to be made in terms of
                                  the impugned Order of the learned Arbitral Tribunal.


                                  (xx) On 26th March, 2020, Edelweiss addressed an email, to
                                  GIL, precluding GIL from making any payments, towards the
                                  impugned Order without its prior consent, enforcing, thereby,
                                  Clauses 2.12 and Clause 5 of the TRA Agreement, as GIL had
                                  failed to cure its default for more than 30 days after notice of
                                  event of default, issued to GIL, by Edelweiss, on 24th January,
                                  2020.


                                  (xxi) In a Joint Lenders' Meeting held on 23rd April, 2020, GIL
                                  intimated the fact that, pursuant to a settlement between GIL
                                  and GTL, consequent on the passing of the impugned Order, ₹
                                  320 crores had been paid by GIL to GTL. This was done
                                  without any prior intimation to Edelweiss. It was sought to be
                                  submitted, by GIL, that the said amount had been paid, to GTL,
                                  by way of Demand Drafts, which were yet to be encashed.
                                  Edelweiss, therefore, directed GIL, vide return email dated 24th
                                  April, 2020, to obtain a return of the said Demand Drafts and
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                                   deposit the said amount in the TRA Account, as per the
                                  covenants of the MRA and TRA Agreements, on or before 27th
                                  April, 2020.


                                  (xxii) It was in these circumstances that Edelweiss moved the
                                  High Court of Bombay, vide Suit LD-VC No 55 of 2020. In
                                  view of the order, dated 5th May, 2020, passed by the High
                                  Court of Bombay (to which I have already alluded,
                                  hereinabove), the amount of ₹ 320 crores, sought to be paid by
                                  GIL to GTL in compliance with the impugned Order of the
                                  learned Arbitral Tribunal, was required to be retained in the
                                  TRA. In fact, in its counter-affidavit, filed before the High
                                  Court of Bombay, GIL had admitted the preferential priority
                                  rights of Edelweiss, over the said amount.


                            32.   Premised on the above facts and contentions, Edelweiss has
                            sought, by the present appeal, quashing of the impugned Order dated
                            17th December, 2019, passed by the learned Arbitral Tribunal.


                            Rival submissions


                            33.   Detailed arguments were advanced at the bar, by Mr. Sandeep
                            Sethi, learned Senior Counsel appearing on behalf of Edelweiss, Mr.
                            Rajiv Nayar, learned Senior Counsel on behalf of GTL and Mr.
                            Mukul Rohatgi, learned Senior Counsel on behalf of GIL. Written
                            submissions were also filed, both during and after the conclusion of
                            proceedings, and learned Counsel consented, at the Bar, to disposal of
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                             the present petition, on the basis of the oral arguments advanced in
                            written submissions filed, without requiring exchange of pleadings.


                            34.       I proceed to deal with the issues arising for consideration,
                            seriatim.


                            35. Re. Preliminary objection to maintainability of the appeal,
                            under Section 37, on the ground that it is an "interim award":


                            35.1 GTL contends that the present appeal is not maintainable, as the
                            impugned Order is an "interim award" within the meaning of Section
                            31(6) of the 1996 Act, read with the judgement of the Supreme Court
                            in Indian Farmers Fertiliser Cooperative Ltd v. Bhadra Products3
                            and of this Court in ONGC Petro Additions Ltd v. Tecnimont S.P.A.4
                            Before proceeding to the contentions of GTL, in this regard, it would
                            be appropriate, first, to examine these decisions.


                            35.2 Before that, however, it is necessary to reproduce Section 37,
                            thus:
                                      "37.     Appealable orders. -

                                               (1)    Notwithstanding anything contained in any
                                               other law for the time being in force, an appeal shall
                                               lie from the following orders (and from no others) to
                                               the Court authorised by law to hear appeals from
                                               original decrees of the Court passing the order,
                                               namely: -

                                                       (a)    refusing to refer the parties to arbitration
                                                       under section 8;
                            3   (2018) 2 SCC 534
                            4   2019 SCC OnLine Del 8976

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                                                 (b)    granting or refusing to grant any measure
                                                under section 9;

                                                (c)     setting aside or refusing to set aside an
                                                arbitral award under section 34.

                                         (2)     An appeal shall also lie to a Court from an order
                                         of the arbitral tribunal -

                                                (a)    accepting the plea referred to in sub-
                                                section (2) or sub- section (3) of section 16; or

                                                (b)   granting or refusing to grant an interim
                                                measure under section 17.

                                         (3)    No second appeal shall lie from an order passed
                                         in appeal under this section, but nothing in this section
                                         shall affect or take away any right to appeal to the
                                         Supreme Court."

                            Quite obviously, appeals from orders passed by arbitral tribunals
                            would be confined to sub-section (2) of Section 37, as sub-section (1)
                            refers to appeals against orders passed by the Court. Mr. Nayar has,
                            while opposing the maintainability of the present appeal, emphasised
                            the words "and from no others", figuring in Section 37.                  This
                            emphasis is, however, misguided, as these words occur in Section 37
                            (1), and not in Section 37 (2). In any event, these words appear to be
                            a legislative superfluity - a rare aberration from the sanctified
                            principle that the legislature does not indulge in tautology - as, even if
                            the words were absent, once the categories of cases, in which appeals
                            would lie, stand specifically enumerated in the provision providing for
                            appeal, the obvious corollary is that appeals would not lie in any other
                            case.


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                             35.3 Appeals, therefore, lie, under Section 37 (2), from orders of the
                            arbitral tribunal, passed either under sub-sections (2) or (3) of Section
                            16, or under Section 17.


                            35.4 It is nobody's case that the impugned Order has been passed by
                            the learned Arbitral Tribunal under Section 16. Mr. Sethi, for the
                            appellant, would contend that the Order has been passed under
                            Section 17. Mr. Nayar, for the respondent would, per contra, asserted
                            that the order has been passed under Section 31(6).


                            35.5 Section 31(6) reads thus:
                                  "31.   Form and contents of arbitral award. -

                                         (1) - (5)     *****

                                         (6)   The arbitral Tribunal may, at any time during
                                         the arbitral proceedings, make an interim arbitral
                                         award on any matter with respect to which it may
                                         make a final arbitral award."

                            As against this, Section 17 reads as under:
                                  "17.   Interim measures ordered by arbitral tribunal. -

                                         (1)    A party may during the arbitral proceedings, or
                                         at any time after the making of the arbitral award but
                                         before it is enforced in accordance with section 36,
                                         apply to the arbitral tribunal -

                                                (i)   for the appointment of a Guardian for a
                                                minor or person of unsound mind for the
                                                purposes of arbitral proceedings; or

                                                (ii)   for an interim measure of protection in
                                                respect of any of the following matters, namely
                                                :-

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                                                        (a)    the preservation, interim custody
                                                       or sale of any goods which are the
                                                       subject matter of the arbitration
                                                       agreement;

                                                       (b)    securing the amount in dispute in
                                                       the arbitration;

                                                       (c)    the detention, preservation or
                                                       inspection of any property or a thing
                                                       which is the subject matter of the dispute
                                                       in arbitration, or as to which any
                                                       question may arise therein and
                                                       authorising for any of the aforesaid
                                                       purposes any person to enter upon any
                                                       land or building in the possession of any
                                                       party, or authorising any samples to be
                                                       taken, or any observation to be made, or
                                                       experiment to be tried, which may be
                                                       necessary or expedient for the purpose of
                                                       obtaining full information or evidence;

                                                       (d)   interim     injunction     or    the
                                                       appointment of a receiver;

                                                       (e)    such other interim measure of
                                                       protection as may appear to the arbitral
                                                       tribunal to be just and convenient,

                                                and the arbitral tribunal shall have the same
                                                power for making orders, as the court has for
                                                the purpose of, and in relation to, any
                                                proceedings before it.

                                         (2)    Subject to any orders passed in appeal under
                                         section 37, any the order issued by the arbitral tribunal
                                         under this section shall be deemed to be an order of the
                                         Court for all purposes and shall be enforceable under
                                         the Code of Civil Procedure, 1908 (5 of 1908), in the
                                         same manner as if it were an order of the Court."




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                             35.6 There is no gainsaying the position, apparent from the statute,
                            that appeals lie, only against the orders passed by the arbitral tribunal
                            under Section 17.                  By implication, therefore, "interim awards",
                            rendered by the arbitral Tribunal under Section 31(6), are not
                            amenable to appeal under Section 37.5


                            35.7 "Interim award" is not, however, defined in the 1996 Act.
                            Consequently, the exact scope of Section 37(2)(b), and whether the
                            order under challenge was actually relatable to Section 17, or was an
                            "interim award" under Section 31(6), was never really examined, till
                            IFFCO3. The actual dispute in that case need not concern us. Suffice
                            it to state that a plea of limitation, advanced by the respondent IFFCO
                            before the learned sole arbitrator in that case, was taken up initially,
                            and was decided in favour of the claimant Bhadra Products, This
                            decision was challenged, by IFFCO, by way of a petition under
                            Section 34, before the learned District Judge. The learned District
                            Judge dismissed the Section 34 petition, stating that the decision of
                            the learned Sole Arbitrator could not be regarded as an "interim
                            award" and could not, therefore, be assailed under Section 34. IFFCO
                            appealed, against the decision of the learned District Judge, to the
                            High Court, which dismissed the appeal. IFFCO appealed, further, to
                            the Supreme Court.


                            35.8 IFFCO contended, before the Supreme Court, that, as the
                            learned Sole arbitrator had, by his order dated 23rd July, 2015, finally

                            5 Refer the maxim expressio unius est exclusio alterius, of especial application while construing jurisdiction
                            clauses - Ref. Swastik Gases (P) Ltd v. Indian Oil Corporation Ltd, (2013) 9 SCC 32; EXL Careers v.
                            Frankfinn Aviation Services Pvt Ltd, AIR 2020 SC 3670

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                             adjudicated the issue of limitation against IFFCO, the order was an
                            "interim award" within the meaning of Section 31(6) and was,
                            therefore, amenable to challenge under Section 34, of the 1996 Act.
                            As against this, Bhadra contended that the order, dated 23 rd July,
                            2015, was passed under Section 16 of the 1996 Act (which
                            empowered the arbitral tribunal to rule on its own jurisdiction) and
                            could not, therefore, be related to Section 31(6). Pointing out that an
                            appeal against an order passed under Section 16 lay, under Section
                            37(2)(a), only where the order accepted the plea of limitation, and not
                            where it rejected the plea, it was submitted, by Bhadra, that, as the
                            order dated 23rd July, 2015 rejected the plea of limitation advanced by
                            IFFCO, the order was not appealable either.


                            35.9 The Supreme Court, therefore, delineated the issues arising
                            before it for consideration as "whether an award on the issue of
                            limitation can first be said to be an interim award and, second, as to
                            whether a decision on a point of limitation would go to jurisdiction
                            and, therefore, be covered by Section 16 of the Act". Relying on its
                            earlier decision in McDermott International Inc. v. Burn Standard
                            Co Ltd6, it was held that "an interim award or partial award is a final
                            award on matters covered therein made at any intermediate stage of
                            the arbitral proceedings". Tested on this principle, it was held that
                            the order dated 23rd July, 2015, of the learned Sole arbitrator in that
                            case, was an 'interim award', as the learned Sole arbitrator had, by the
                            said award, disposed of the issue of limitation finally.


                            6
                                (2006) 11 SCC 181

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                             35.10 The two indicia which distinguish interim awards, as postulated
                            in IFFCO3 are, therefore, that (i) the award, or order, is made at an
                            intermediate stage of the arbitral proceedings, and (ii) the award
                            finally disposes of the matter covered therein.


                            35.11 Mr. Nayar also chose to place reliance on the judgement, of a
                            coordinate Single Bench of this Court in ONGC Petro Additions Ltd4,
                            and drew particular attention to para 13 of the said decision. The
                            reliance is, in my view, misdirected. Para 13 observed, inter alia,
                            thus:
                                    "In order to ascertain whether an order is an interim award or
                                    partial award, the two most important factors that would
                                    weigh upon the Court are the concept of "finality" and
                                    "issue". If the nature of the order is "final" in a sense that it
                                    conclusively decides an issue in the arbitration proceedings,
                                    the order would qualify to be an interim award."
                                                                               (Emphasis supplied)


                            35.12 I am entirely in agreement with the above enunciation of the
                            law, as contained in ONGC Petro Additions Ltd4. I also agree with
                            Mr. Nayar that, in deciding whether an order, by the arbitral tribunal,
                            is an "interim award", or not, the essential test is whether the order
                            decides an issue conclusively and finally.            How, then, is one to
                            ascertain whether the order, under challenge, decides an issue
                            conclusively and finally? In my view, the decision, in this regard, has
                            either to flow from an overall reading of the order itself, giving due -
                            but not undue - importance to the words used therein. I say "due, but
                            not undue" because there may, conceivably, be cases in which the
                            order itself may claim to be an "interim award" order and to
                            determine, finally, the issue between the parties, but such a recital
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                             cannot be treated as the end of the matter. The Court would have to
                            take an informed decision as to whether, in fact, the order
                            conclusively and finally decides the issue between the parties. In
                            other words, to borrow the felicitous expression used in IFFCO3,
                            there must be a "final determination" of an issue "at the interim
                            stage". Whether there is, or is not, such a "final determination" has to
                            be essentially gleaned from the order itself, seen in the backdrop of
                            the circumstances and considerations that governed its passing.


                            35.13 The circumstances, which Mr. Nayar stresses, to impress, on
                            the Court, that the impugned order is, in fact, in the nature of an
                            "interim award", within the meaning of Section 31(6), may be
                            examined thus:


                                  (i)    Mr. Nayar points out that, in para 22 of the Impugned
                                  Order, the learned Arbitral Tribunal notes the contention, of
                                  GTL, that GIL was liable to suffer an interim award/partial
                                  decree at that stage itself. For ready reference, para 22 may be
                                  reproduced thus:
                                         "Mr. Wadhwa, Ld. Senior Counsel on behalf of the
                                         Claimant has urged before us, that the Respondent has
                                         all throughout admitted its liability of Rs.650 crores
                                         towards the Claimant. Ld. Senior Counsel has drawn
                                         the attention of the Tribunal to several clauses of the
                                         Suspension Agreement (reproduced above) to contend
                                         that it was only an Interim Arrangement arrived at by
                                         the parties to enable the Respondent, to restructure its
                                         debt to enable it to perform its obligations under the
                                         EMA dated 31st March, 2015 and other agreements
                                         entered into between the parties. Mr. Wadhwa has
                                         further submitted that the Respondent has not disputed
                                         the claim of Rs.650 crores in its Statement of Defence
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                                          and thus the Respondent is liable to suffer an Interim
                                         Award/Partial Decree at this stage itself.
                                         Furthermore, it has been urged that the Respondent
                                         had failed to deposit Rs.40 crores in terms of Clause
                                         4.5 of the Suspension Agreement towards Refundable
                                         Deposit."
                                                                           (Emphasis supplied)

                                  This passage, in my view, cannot help Mr. Nayar.                The
                                  reference to the liability, of GIL, to suffer an Interim
                                  Award/Partial Decree, at that stage itself, is merely in the nature
                                  of a recording of the submission advanced, before the learned
                                  Arbitral Tribunal, by learned Senior Counsel appearing on
                                  behalf of GTL.      Mr. Sethi, learned Senior Counsel for the
                                  petitioner, has pointed out, correctly, that there is, beyond this,
                                  no finding or observation, of the learned Arbitral Tribunal,
                                  evincing its acceptance of the aforesaid submission advanced
                                  by Mr. Wadhwa.         The recording, by the learned Arbitral
                                  Tribunal, of the submission of Mr. Wadhwa cannot, therefore,
                                  assist in determining whether the impugned order is, or is not,
                                  in the nature of an "interim award".


                                  (ii)   It is next contended, by Mr. Nayar, that the reliance, by
                                  the learned Arbitral Tribunal, on Order VIII Rules 3 to 5 of the
                                  Code of Civil Procedure, 1908 (CPC), in para 28 of the
                                  impugned Order, and the accompanying observations of the
                                  learned Arbitral Tribunal, "ex facie show that the Tribunal was
                                  undertaking a final adjudication to the extent of ₹ 400 crores on
                                  the basis that liability could not be denied by Respondent No.
                                  1". Here, again, para 28 of the impugned Order would, if
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                                   properly read, militates against the submission of Mr. Nayar.
                                  The para reads thus:
                                         "A holistic reading of Order VIII and Rules 3, 4 and 5
                                         thereof, of the CPC make it clear that if every
                                         allegation stated in the Plaint is not denied specifically
                                         or by necessary implication, the said allegation or
                                         assertion shall be taken to have been admitted. In this
                                         conspectus, it is held at this stage of the proceedings
                                         that the sum of Rs.400 crores is not a sum presently in
                                         dispute but is a liability not specifically denied at this
                                         stage by the Respondent. As regards the remaining
                                         sum of Rs. 250 crores, Ld. Counsel for the Claimant
                                         has fairly stated that the same would require
                                         adjudication by this Arbitral Tribunal."
                                                                              (Emphasis supplied)

                                  It would be a complete misadventure for a Court to interpret an
                                  Order, or an Award, passed by an Arbitral Tribunal, in a
                                  manner different from the clear intent emanating from the order
                                  or award, as is apparent from the words used therein. The
                                  learned Arbitral Tribunal has, in a single sentence in para 28 of
                                  the impugned Order, used the expressions "at this stage of the
                                  proceedings", "presently in dispute" and "at this stage". The
                                  intent is apparent. It is clear that the learned Arbitral Tribunal
                                  is not conclusively determining the liability of GIL, or the
                                  corresponding entitlement of GTL, even to the extent of ₹ 400
                                  crores. The findings that follow are, clearly, therefore, ad hoc
                                  in nature, entered at that stage of the proceedings, based on the
                                  non-denial, by GIL, of its liability, at that stage. The reliance,
                                  by the learned Arbitral Tribunal, on Order VIII Rules 3 to 5 of
                                  the CPC, is totally irrelevant, in my view, as these provisions
                                  deal with the requirement of denial, by the defendant in a suit,

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                                  of the pleadings of the plaintiff, to be specific, and the
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                                   consequences that follow in the alternative.       They cannot,
                                  therefore, seriously impact the issue of whether the impugned
                                  Order is in the nature of an "interim award", or is merely
                                  interlocutory in nature.


                                  (iii)   Mr. Nayar draws attention, next, to the reference, by the
                                  learned Arbitral Tribunal, in para 31 of the impugned Order, to
                                  the judgement of the Supreme Court in Uttam Singh Duggal1.
                                  It is emphasised that the said decision concerns Order XII Rule
                                  6 of the CPC, which provides for judgement on admissions. It
                                  is not necessary to extract para 31, as a bare reading thereof
                                  makes it clear that the learned Arbitral Tribunal has merely
                                  relied on a passage from Uttam Singh Duggal1, to observe that,
                                  where the claim is admitted, a Court has jurisdiction to enter a
                                  judgement for the plaintiff and pass a decree on the admitted
                                  claim. The rationale, reflected in the said para has been relied
                                  upon, by the learned Arbitral Tribunal as "fortifying" its
                                  decision.    This, by itself, in my view, cannot convert the
                                  impugned Order into an "interim award", contrary to all that is
                                  reflected from the express wordings contained in other paras
                                  thereof.


                                  (iv)    For the same reason, the reliance, by Mr. Nayar, on the
                                  reference, by the learned Arbitral Tribunal, on the judgement of
                                  this Court in Numero Uno International Ltd2, fails to impress.
                                  The passage, in Numero Uno International Ltd2, on which the
                                  learned Arbitral Tribunal placed reliance, reads thus:
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                                          "8. The issue can be viewed from yet another angle.
                                         The making of the interim award ensures to the party
                                         in whose favour the same is made the payment of an
                                         amount which is an admitted position payable to it.
                                         There is no reason why the payment of what is
                                         admittedly due should await the determination of other
                                         disputes which may take years before they are finally
                                         resolved. If at the conclusion of the arbitral
                                         proceedings, the defendant were to succeed in his
                                         claim, either wholly or partially, and if after
                                         adjustment of the amounts found payable to the
                                         plaintiff, any amount is eventually held payable to one
                                         or the other party, the arbitrator can undoubtedly make
                                         such an adjustment and direct payment of the amount
                                         to one or the other party, as the case may be. The final
                                         award would in any such case also take into
                                         consideration the payments, if any, made under the
                                         interim award. Suffice it to say that the making of the
                                         interim award in no way prevents the arbitrator from
                                         making adjustments of the amount in the final award
                                         and doing complete justice between the parties. By that
                                         logic even if we assume that the Prasar Bharti was to
                                         fail in substantiating its further claims which are
                                         disputed and the appellant were to succeed wholly in
                                         the counter claim that it has made, all that it would
                                         result in is an award in favour of the appellant. There
                                         is, therefore, no inherent illegality or perversity in the
                                         making of the interim award by the arbitrator so as to
                                         call for interference by this Court under Section 34 of
                                         the Act."

                                  There is no denying the fact that the afore-extracted passage,
                                  from Numero Uno2, does refer to the passing of an "interim
                                  award". This passage was, however, a full decade prior to the
                                  enunciation of the law in IFFCO3.               The legal position,
                                  regarding the ingredients and indicia of an "interim award",
                                  within the meaning of Section 31(6), can no longer be regarded
                                  as in a state of flux, after IFFCO3. Moreover, a proper reading
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                                   of the passage, from Numero Uno International Ltd2, on which
                                  the learned Arbitral Tribunal relies, discloses that it essentially
                                  underscores the authority, of the Arbitral Tribunal, to direct
                                  payment of admitted amounts at the interlocutory stage in
                                  arbitral proceedings, and does not, expressly or by necessary
                                  implication, delineate the scope and contours of the expression
                                  "interim award". In the present case, para 28 of the impugned
                                  Order is clear and categorical in observing that the direction for
                                  payment of ₹ 400 crores was being made only because, at that
                                  stage of the proceedings, there was no denial, by GIL, of its
                                  liability. The learned Arbitral Tribunal has, in the said para, left
                                  the field wide open for contest, even at any later, or the final,
                                  stage, of the liability of GTL in that regard. In view of the said
                                  para, the submission, specifically so made in the written
                                  submissions tendered by GTL, that the learned Arbitral
                                  Tribunal was, by the impugned Order, "undertaking a final
                                  adjudication to the extent of Rs. 400 crores", cannot be
                                  accepted, being directly contrary to para 28 thereof.


                                  (v)    Attention has also been invited, by Mr. Nayar, to the
                                  recording, in para 35 of the impugned Order, of the request,
                                  advanced by Mr. Wadhwa, learned Senior Counsel before the
                                  learned arbitral Tribunal, to treat the Section 17 application of
                                  GTL as having been preferred under Section 31(6), and to pass
                                  an interim award thereon. As Mr. Sethi has correctly pointed
                                  out, this submission is, no doubt, recorded; there is, however,
                                  no acceptance, by the learned Arbitral Tribunal, thereof.
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                                   Indeed, one is unable to find, in the entire impugned Order, any
                                  specific observation, by the learned Arbitral Tribunal, that the
                                  impugned Order was in the nature of an interim award, finally
                                  adjudicating the liability of GTL, to GIL, to the extent of ₹ 400
                                  crores, or, for that matter, any other amount. The recording of
                                  the submission of Mr. Wadhwa, by the learned Arbitral
                                  Tribunal     cannot,   therefore,   suffice   to   constitute     an
                                  acknowledgement, to the effect that the impugned Order was in
                                  the nature of an interim award.


                            35.14 As against this, Mr. Sethi has pointed out, correctly, that the
                            concluding para of the impugned Order clearly states that "the present
                            order shall await the Final Award and shall be subject to adjustments
                            in order to conform to the Final Award". This caveat, obviously
                            consciously entered, seen in juxtaposition with para 28 of the
                            impugned Order, completely defeats the submission, of Mr. Nayar,
                            that the impugned Order is in the nature of an "interim award" and is,
                            therefore, not amenable to challenge under Section 37.


                            35.15 Reference may once again be made, in this context, to para 14
                            of the judgment in IFFCO3, which reproduces paras 68 to 70 of the
                            earlier decision of the Supreme Court in McDermott International6.
                            Para 68 of McDermott International6 reads thus:

                                  "68. The 1996 Act does not use the expression "partial
                                  award". It uses interim award or final award. An award has
                                  been defined under Section 2(c) to include an interim award.
                                  Sub-section (6) of Section 31 contemplates an interim award.
                                  An interim award in terms of the said provision is not one in
                                  respect of which a final award can be made, but it may be a
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                                   final award on the matters covered thereby, but made at an
                                  interim stage."
                                                                         (Emphasis supplied)

                            An interim award, for the purpose of Section 31(6) has, therefore, to
                            be a final award on the matters covered thereby made at an interim
                            stage. Even while directing GIL to pay ₹ 400 crore to GTL, the
                            impugned order makes it clear that the direction was ad hoc in nature,
                            made at that of point of time in view of the situation emanating from
                            the pleadings till then. In my view, it cannot be said that the learned
                            Arbitral Tribunal has finally pronounced on the liability of GIL, to
                            pay ₹ 400 crores to GTL, so as to render the present appeal
                            incompetent.


                            35.16 Interestingly, Arb. A. (COMM) 7/2020 was preferred, by GIL,
                            before this Court, under Section 37(2)(b) of the 1996 Act, as is noted
                            in the very first sentence of the judgement, dated 4th March, 2020,
                            rendered thereon. Having itself chosen to invoke Section 37(2)(b), to
                            challenge the impugned Order, I am in agreement with Mr. Sethi that
                            it cannot lie in the mouth of GIL to oppose the maintainability of the
                            appeal of Edelweiss, on the ground that Section 37(2)(b) would not
                            apply. What is sauce for the goose, axiomatically, is sauce for the
                            gander. The only response of GIL, to this submission of Edelweiss, is
                            that this aspect escaped scrutiny, as no such objection was raised, to
                            challenge the maintainability of the appeal preferred by it. To say the
                            very least, such an argument is completely unconscionable, and does
                            not even merit a cursory consideration. Having itself chosen to avail
                            the remedy of appeal, under Section 37(2)(b) of the 1996 Act, to
                            challenge the impugned Order dated 17th December, 2019, of the
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                             learned Arbitral Tribunal, GIL cannot, in my view, legitimately seek
                            to contest the right of Edelweiss to do so.


                            35.17 There is yet another, and more empirical, reason why this
                            submission, of Mr. Nayar, cannot succeed. Admittedly, the impugned
                            Order was passed on an application, preferred by GTL under Section
                            17 of the 1996 Act.       The suggestion, of Mr. Wadhwa, that the
                            application could be treated as one under Section 31(6), though noted,
                            cannot be said to have been accepted by the learned Arbitral Tribunal,
                            either expressly or by necessary implication. The impugned Order
                            does not state that the application, preferred by GTL under Section 17,
                            was being converted into one under Section 31(6), or being treated as
                            an application under the said sub-section. The directions contained in
                            the impugned Order do not purport to have been issued under Section
                            31(6). They have, therefore, necessarily to be regarded as having
                            been issued under Section 17, while adjudicating an application
                            preferred under that provision. I have already opined, hereinabove,
                            that a holistic appreciation of the impugned Order, particularly para
                            28 thereof, indicates that the direction for the payment of ₹ 400 crores,
                            by GIL to GTL, was merely being issued "at that stage of the
                            proceedings", and by way of an interim arrangement. There was,
                            therefore, no final adjudication of the entitlement, of GTL, to the said
                            amount. The said direction was modifiable, by adjustment, at the
                            stage of passing of the Final Award. Any order, granting an interim
                            measure under Section 17 is, statutorily, appealable under Section
                            37(2)(b). Even on this ground, therefore, the appeal of Edelweiss is
                            maintainable.

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                             35.18 I am, therefore, of the view that the submission, of Mr. Nayar,
                            that the impugned Order is an "interim award" and is, therefore, not
                            amenable to appeal under Section 37 of the 1996 Act, is
                            misconceived. It is accordingly rejected.


                            36. Re. Preliminary objection to maintainability of the appeal,
                            under Section 37, on the ground that the impugned order has merged
                            with the judgement, dated 4th March, 2020, in Arb. A (COMM)
                            7/2020

                            36.1 Mr. Nayar predicates his submission, regarding the merger of
                            the impugned order, with the judgment, dated 4th March, 2020 in Arb.
                            A. (COMM) 7/2020 on the well known decision in Kunhayammed v.
                            State of Kerala7. Juxtaposed therewith, Mr. Nayar also relies on the
                            acknowledgement, in para 31 of the appeal, that GIL had filed Arb. A.
                            (COMM) 7/2020, at the instance of Edelweiss. It is sought to be
                            contended that, having thus taken a chance at challenging the
                            impugned order, dated 17th December, 2019, of the learned Arbitral
                            Tribunal, by way of Arb. A. (COMM) 7/2020, though by proxy, and
                            failed, the appellant could not now seek challenge the same order by
                            its own substantive appeal.


                            36.2 In response Mr. Sethi submits that the order, dated 4 th March,
                            2020, of this Court in Arb. A. (COMM) 7/2020, was obtained by
                            fraud, as this Court as well as the learned Arbitral Tribunal, were kept
                            in the dark, again regarding the prior charge of Edelweiss, over the


                            7
                                (2000) 6 SCC 359
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                             funds and assets of GIL. Relying on the judgments of the Supreme
                            Court in A.V. Papayya Sastry v. Government of A.P.8, and U.O.I.
                            India v. Ramesh Gandhi9, it is contended that judgment obtained by
                            fraud is a nullity and that, therefore, such a judgment cannot restrain
                            Edelweiss from prosecuting the present appeal.


                            36.3 Before examining the applicability of the decision in
                            Kunhayammed7 to the facts of the present case, it merits mention that
                            Kunhayammed7 was explained, subsequently, by R.C. Lahoti, J. (as
                            the then was) - who had authored Kunhayammed7 - in S.
                            Shanmugavel Nadar v. State of Tamil Nadu10, to which reference
                            would be made, in somewhat greater detail, hereinafter.


                            36.4 Kunhayammed7 related to a dispute, initiated by a family, in
                            respect of 1020 acres of land, before the Forest Tribunal, Kozhikode.
                            The Forest Tribunal held that the land did not vest in the Government.
                            The appeal preferred by the State of Kerala was dismissed by the High
                            Court on 17th December, 1982, by a detailed judgment. SLP (C)
                            8098/1983 was preferred, thereagainst, by the State of Kerala, before
                            the Supreme Court. By order, dated 18th July, 1983, the SLP was
                            "dismissed on merits", without stating anything more.


                            36.5 In January, 1984, the State of Kerala filed an application, for
                            review of the judgment, dated 17th December, 1982, before the High
                            Court.       Kunhayammed opposed the maintainability of the review

                            8
                              2007 (4) SSC 221
                            9
                              (2012) 1 SCC 476
                            10
                               2002 (8) SCC 361

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                             petition on the ground of dismissal of SLP (C) 8098/1983. The High
                            Court overruled the objection and directed that the review petition be
                            listed for hearing on merits. Aggrieved thereby, Kunhaymmed
                            approached the Supreme Court.


                            36.6 Before the Supreme Court, the State of Kerala contended that
                            the order, dated 17th December, 1982, of the High Court had merged
                            with the order, dated 18th July, 1983, whereby the SLP, against the
                            said order, was dismissed by the Supreme Court. No application for
                            review, it was contended, could lie before the High Court thereafter.
                            Another ground, which was interlinked with the first, was that the
                            order, dated 18th July, 1983, of the Supreme Court, affirmed the order,
                            dated 17th December, 1982, of the High Court, thereby disabling the
                            High Court from reviewing its order. In para 12 of its judgment, the
                            Supreme Court observed thus:-
                                  "12. The logic underlying the doctrine of merger is that there
                                  cannot be more than one decree or operative orders governing
                                  the same subject-matter at a given point of time. When a
                                  decree or order passed by an inferior court, tribunal or
                                  authority was subjected to a remedy available under the law
                                  before a superior forum then, though the decree or order under
                                  challenge continues to be effective and binding, nevertheless
                                  its finality is put in jeopardy. Once the superior court has
                                  disposed of the lis before it either way -- whether the decree
                                  or order under appeal is set aside or modified or simply
                                  confirmed, it is the decree or order of the superior court,
                                  tribunal or authority which is the final, binding and operative
                                  decree or order wherein merges the decree or order passed by
                                  the court, tribunal or the authority below. However, the
                                  doctrine is not of universal or unlimited application. The
                                  nature of jurisdiction exercised by the superior forum and the
                                  content or subject-matter of challenge laid or which could
                                  have been laid shall have to be kept in view."


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                             36.7 The Supreme Court went on to notice that its earlier decision in
                            Shankar Ramchandra Abhyankar v. Krishnaji Dattatreya Bapat11,
                            had emphasized three pre-conditions for the doctrine of merger to be
                            attracted, viz that (i) the jurisdiction exercised by the higher court
                            should have been appellate or revisional in nature, (ii) the jurisdiction
                            should have been exercised after issuance of notice and (iii) the
                            judgment should have been rendered after a full hearing had been
                            granted to the parties. Satisfaction of these three criteria, it was held,
                            resulted in merger of the judgment of the lower court with that of the
                            higher court. These principles, it was held, were useful in resolving
                            the issue before the Supreme Court.


                            36.8 Though the decision, in Kunhayammed7, centrally dealt with
                            the question of merger in the case of dismissal of an SLP, with which
                            we are not concerned, the Supreme Court summed up its conclusion in
                            para 44 of the report, thus:

                                      "(i) Where an appeal or revision is provided against an
                                      order passed by a court, tribunal or any other authority before
                                      superior forum and such superior forum modifies, reverses or
                                      affirms the decision put in issue before it, the decision by the
                                      subordinate forum merges in the decision by the superior
                                      forum and it is the latter which subsists, remains operative
                                      and is capable of enforcement in the eye of law.

                                      (ii)   The jurisdiction conferred by Article 136 of the
                                      Constitution is divisible into two stages. The first stage is upto
                                      the disposal of prayer for special leave to file an appeal. The
                                      second stage commences if and when the leave to appeal is
                                      granted and the special leave petition is converted into an
                                      appeal.

                            11
                                 (1969) 2 SCC 74
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                                   (iii) The doctrine of merger is not a doctrine of universal or
                                  unlimited application. It will depend on the nature of
                                  jurisdiction exercised by the superior forum and the content or
                                  subject-matter of challenge laid or capable of being laid shall
                                  be determinative of the applicability of merger. The superior
                                  jurisdiction should be capable of reversing, modifying or
                                  affirming the order put in issue before it. Under Article 136 of
                                  the Constitution the Supreme Court may reverse, modify or
                                  affirm the judgment-decree or order appealed against while
                                  exercising its appellate jurisdiction and not while exercising
                                  the discretionary jurisdiction disposing of petition for special
                                  leave to appeal. The doctrine of merger can therefore be
                                  applied to the former and not to the latter.

                                  (iv) An order refusing special leave to appeal may be a
                                  non-speaking order or a speaking one. In either case it does
                                  not attract the doctrine of merger. An order refusing special
                                  leave to appeal does not stand substituted in place of the order
                                  under challenge. All that it means is that the Court was not
                                  inclined to exercise its discretion so as to allow the appeal
                                  being filed.

                                  (v)    If the order refusing leave to appeal is a speaking
                                  order, i.e., gives reasons for refusing the grant of leave, then
                                  the order has two implications. Firstly, the statement of law
                                  contained in the order is a declaration of law by the Supreme
                                  Court within the meaning of Article 141 of the Constitution.
                                  Secondly, other than the declaration of law, whatever is stated
                                  in the order are the findings recorded by the Supreme Court
                                  which would bind the parties thereto and also the court,
                                  tribunal or authority in any proceedings subsequent thereto by
                                  way of judicial discipline, the Supreme Court being the Apex
                                  Court of the country. But, this does not amount to saying that
                                  the order of the court, tribunal or authority below has stood
                                  merged in the order of the Supreme Court rejecting the
                                  special leave petition or that the order of the Supreme Court is
                                  the only order binding as res judicata in subsequent
                                  proceedings between the parties.

                                  (vi) Once leave to appeal has been granted and appellate
                                  jurisdiction of Supreme Court has been invoked the order
                                  passed in appeal would attract the doctrine of merger; the
                                  order may be of reversal, modification or merely affirmation.
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                                   (vii) On an appeal having been preferred or a petition
                                  seeking leave to appeal having been converted into an appeal
                                  before the Supreme Court the jurisdiction of High Court to
                                  entertain a review petition is lost thereafter as provided by
                                  sub-rule (1) of Rule 1 of Order 47 CPC."


                            36.9 A holistic reading of Kunhayammed7 reveals that the doctrine
                            of merger cannot be blindly applied, wherever a higher court decides a
                            challenge to the decision of a lower court. It depends on the nature of
                            jurisdiction exercised by the superior court and the content of the
                            subject matter of challenge laid or capable of being laid before the
                            superior court. Additionally, the decision of the superior court would
                            have to be a decision rendered after issuance of notice to, and after
                            fully hearing, the parties. Fundamentally, therefore, the decision of
                            the superior court can never operate as merger, so as to non-suit a
                            party who was not heard by the superior court, before the judgment
                            was passed. Much less can it operate to non-suit a non-party before
                            the superior court.


                            36.10 Applying this principle to the present case, it would be seen that
                            Edelweiss was not a party before this Court in Arb. A. (COMM)
                            7/2020, that judgment, therefore, proceeded without any intimation to
                            Edelweiss, without issuance of notice to it and without granting any
                            hearing to it. It is not possible, therefore, to apply Kunhayammed7, to
                            hold that Edelweiss is proscribed from prosecuting the appeal because
                            of the judgment, dated 4th March, 2020, passed by the coordinate
                            Single Bench in Arb. A. (COMM) 7/2020.


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                             36.11 The same position would emanate, from the well settled
                            principle that a litigant cannot, ordinarily, be bound by a judgment to
                            which it is not a party.12


                            36.12 A third reason, for rejecting the submission, of Mr. Nayar,
                            regarding merger of the impugned order of the learned Arbitral
                            Tribunal, with the judgment, dated 4th March, 2020 of this Court in
                            Arb. A. (COMM) 7/2020, also exists. That appeal was preferred by
                            GIL, challenging the impugned order. A reading of the judgment
                            reveals that there is not a whisper of an averment, far less any
                            discussion, regarding the prior charge, over the assets of GIL, by
                            Edelweiss and other secured creditors. There is, therefore, substance
                            in the contention, of Mr. Sethi, that this Court was not made aware, at
                            the time of deciding the said appeal, regarding the claims of prior
                            secured creditors, such as Edelweiss. A reading of the judgment
                            reveals that this Court proceeded on the premise that, once GIL had
                            admitted its liability to pay ₹ 400 crores to GTL, no fault could be
                            found with the learned Arbitral Tribunal, in directing such payment.
                            In these circumstances, this Court found the reliance by the learned
                            Arbitral Tribunal, on the judgments of the Supreme Court, in Uttam
                            Singh Duggal1 and of this Court in and Numero Uno International
                            Ltd2 to be apt and well taken. Even applying the well known principle
                            of issue estoppel, as well as the ratio of Kunhayammed7 that the
                            applicability of the doctrine of merger has to be examined with
                            respect to the challenge before the superior court, the claims of
                            Edelweiss - or, indeed, of any other secured creditors - not having

                            12
                                 Sneh Gupta v. Devi Sarup, (2009) 6 SCC 194

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                             constituted any part of the challenge before this Court in Arb. A.
                            (COMM) 7/2020, the judgment rendered in that case cannot operate
                            as a bar to any secured creditor, including Edelweiss, maintaining its
                            own substantive appeal. In fact, the concluding para of the judgment,
                            dated 4th March, 2020, in Arb. A. (COMM) 7/2020 reveals that this
                            Court has clearly held that it was passing its judgment "on account of
                            the admission and offer of the appellant to clear its liability and the
                            law that if that amount is admitted by a party, the same should be
                            released to the opposite party at the earliest, without waiting for
                            adjudication of the remaining disputes". In my view, it would be
                            contrary to the basic principles of common sense, let alone justice and
                            fair play, to refuse to adjudicate a challenge, by the appellant as a
                            secure creditor of GIL, to the transfer of moneys from the account of
                            GIL - over which it claimed prior security rights - to GTL, thereby
                            substantially reducing the corpus of the amounts, over which it held
                            security. The judgment of this Court, in Arb. A. (COMM) 7/2020,
                            clearly, cannot justify the lending, by this Court, of its imprimatur to
                            any such inference or conclusion.


                            36.13 There is, yet another, fourth reason, why the argument of
                            merger, based by Mr. Nayar, cannot succeed.          As I have noted
                            hereinabove, Kunhayammed7 was, subsequently, explained in S.
                            Shanmugavel Nadar10. In that case, the State Legislature of Tamil
                            Nadu amended certain provisions of the Madras City Tenants
                            Protection Act, 1991, by the Madras City Tenants Protection
                            (Amendment) Act, 1960 (hereinafter referred to as "the 1960
                            Amendment Act").         The constitutional validity of the 1960
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                             Amendment Act was challenged before the High Court of Madras in a
                            batch of writ petitions, which was dismissed by a judgment, which
                            came to be reported, subsequently, as Varadaraja Pillai v. Salem
                            Municipal Council13. SLPs were preferred, thereagainst, which were
                            also dismissed by the Supreme Court, vide order, dated 10th
                            September, 1986, which reads thus:

                                      "The constitutional validity of Act 13 of 1960 amending the
                                      Madras City Tenants Protection Act, 1921 is under challenge
                                      in these appeals. The State of Tamil Nadu was not made a
                                      party before the trial court. However, the State was impleaded
                                      as a supplemental respondent in appeal as per orders of the
                                      High Court. When the appellants lost the appeal, they sought
                                      leave to appeal to this Court. The State of Tamil Nadu was not
                                      made a party in the said leave petition. In the SLP before this
                                      Court also the State of Tamil Nadu was not made a party. A
                                      challenge to the constitutional validity of the Act cannot be
                                      considered or determined, in the absence of the State
                                      concerned. The learned counsel now prays for time to implead
                                      the State of Tamil Nadu. This appeal is of the year 1973. In
                                      our view it is neither necessary nor proper to allow this prayer
                                      at this distance of time. No other point survives in these
                                      appeals. Therefore, we dismiss these appeals, but without any
                                      order as to costs."

                            36.14 Subsequently, the Madras City Tenants Protection Act, 1921
                            was again amended by the Madras City Tenants Protection
                            (Amendment) Act, 1994 (hereinafter referred to as "1994 Amendment
                            Act"). The constitutional validity of this Act was also challenged in a
                            batch of writ petitions filed in the High Court. Before the High Court,
                            reliance was placed by the State of Tamil Nadu, on the earlier
                            decision in Varadaraja Pillai13. The Division Bench expressed some
                            doubt regarding the correctness of its earlier decision in Varadaraja

                            13
                                 1972 (85) L.W.760

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                             Pillai13, but as the SLP preferred against the said decision, had been
                            dismissed by the Supreme Court, followed the decision and dismissed
                            the appeals, before it, challenging the validity of 1994 Amendment
                            Act.


                            36.15 Aggrieved, the petitioners, before the High Court, appealed to
                            the Supreme Court.


                            36.16 The Supreme Court commenced its discussion with the
                            following prescient observations, regarding the doctrine of merger :

                                   "10. Firstly, the doctrine of merger. Though loosely an
                                   expression merger of judgment, order or decision of a court or
                                   forum into the judgment, order or decision of a superior
                                   forum is often employed, as a general rule the judgment or
                                   order having been dealt with by a superior forum and having
                                   resulted in confirmation, reversal or modification, what
                                   merges is the operative part i.e. the mandate or decree issued
                                   by the court which may have been expressed in a positive or
                                   negative form. For example, take a case where the
                                   subordinate forum passes an order and the same, having been
                                   dealt with by a superior forum, is confirmed for reasons
                                   different from the one assigned by the subordinate forum,
                                   what would merge in the order of the superior forum is the
                                   operative part of the order and not the reasoning of the
                                   subordinate forum; otherwise there would be an apparent
                                   contradiction. However, in certain cases, the reasons for
                                   decision can also be said to have merged in the order of the
                                   superior court if the superior court has, while formulating its
                                   own judgment or order, either adopted or reiterated the
                                   reasoning, or recorded an express approval of the reasoning,
                                   incorporated in the judgment or order of the subordinate
                                   forum."




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                             36.17 It was also observed, in para 11 of the report, that the doctrine
                            of merger was a doctrine of limited application. The Supreme Court
                            went on to hold, in paras 12 to 16 and 20 of the report thus:

                                  "12. Thirdly, as we have already indicated, in the present
                                  round of litigation, the decision in M. Varadaraja Pillai
                                  case [85 LW 760] was cited only as a precedent and not as res
                                  judicata. The issue ought to have been examined by the Full
                                  Bench in the light of Article 141 of the Constitution and not
                                  by applying the doctrine of merger. Article 141 speaks of
                                  declaration of law by the Supreme Court. For a declaration of
                                  law there should be a speech i.e. a speaking order.
                                  In Krishena Kumar v. Union of India, (1990) 4 SCC 207 :
                                  1991 SCC (L&S) 112, this Court has held that the doctrine of
                                  precedents, that is being bound by a previous decision, is
                                  limited to the decision itself and as to what is necessarily
                                  involved in it. In State of U.P. v. Synthetics and Chemicals
                                  Ltd., (1991) 4 SCC 139, R.M. Sahai, J. (vide para 41) dealt
                                  with the issue in the light of the rule of sub silentio. The
                                  question posed was: can the decision of an appellate court be
                                  treated as a binding decision of the appellate court on a
                                  conclusion of law which was neither raised nor preceded by
                                  any consideration or in other words can such conclusions be
                                  considered as declaration of law? His Lordship held that the
                                  rule of sub silentio is an exception to the rule of precedents.
                                  "A decision passes sub silentio, in the technical sense that has
                                  come to be attached to that phrase, when the particular point
                                  of law involved in the decision is not perceived by the court
                                  or present to its mind." A court is not bound by an earlier
                                  decision if it was rendered "without any argument, without
                                  reference to the crucial words of the rule and without any
                                  citation of the authority". A decision which is not express and
                                  is not founded on reasons, nor which proceeds on
                                  consideration of the issues, cannot be deemed to be a law
                                  declared, to have a binding effect as is contemplated by
                                  Article 141. His Lordship quoted the observation from B.
                                  Shama Rao v. Union Territory of Pondicherry,AIR 1967 SC
                                  1480 : (1967) 2 SCR 650, "it is trite to say that a decision is
                                  binding not because of its conclusions but in regard to its ratio
                                  and the principles, laid down therein". His Lordship tendered
                                  an advice of wisdom -- "Restraint in dissenting or overruling
                                  is for sake of stability and uniformity but rigidity beyond
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                                   reasonable limits is inimical to the growth of law." (SCC p.
                                  163, para 41)

                                  13.     Rup Diamonds v. Union of India [(1989) 2 SCC 356 :
                                  AIR 1989 SC 674] is an authority for the proposition that
                                  apart altogether from the merits of the grounds for rejection,
                                  the mere rejection by a superior forum, resulting in refusal of
                                  exercise of its jurisdiction which was invoked, could not by
                                  itself be construed as the imprimatur of the superior forum on
                                  the correctness of the decisions sought to be appealed against.
                                  In Supreme Court Employees' Welfare Assn. v. Union of
                                  India [(1989) 4 SCC 187 : 1989 SCC (L&S) 569 : AIR 1990
                                  SC 334] this Court observed that a summary dismissal,
                                  without laying down any law, is not a declaration of law
                                  envisaged by Article 141 of the Constitution. When reasons
                                  are given, the decision of the Supreme Court becomes one
                                  which attracts Article 141 of the Constitution which provides
                                  that the law declared by the Supreme Court shall be binding
                                  on all the courts within the territory of India. When no
                                  reasons are given, a dismissal simpliciter is not a declaration
                                  of law by the Supreme Court under Article 141 of the
                                  Constitution. In Indian Oil Corpn. Ltd. v. State of
                                  Bihar [(1986) 4 SCC 146 : 1986 SCC (L&S) 740 : AIR 1986
                                  SC 1780] this Court observed that the questions which can be
                                  said to have been decided by this Court expressly, implicitly
                                  or even constructively, cannot be reopened in subsequent
                                  proceedings; but neither on the principle of res judicata nor on
                                  any principle of public policy analogous thereto, would the
                                  order of this Court bar the trial of identical issue in separate
                                  proceedings merely on the basis of an uncertain assumption
                                  that the issues must have been decided by this Court at least
                                  by implication.

                                  14.   It follows from a review of several decisions of this
                                  Court that it is the speech, express or necessarily implied,
                                  which only is the declaration of law by this Court within the
                                  meaning of Article 141 of the Constitution.

                                  15.    A situation, near similar to the one posed before us,
                                  has been dealt in Salmond's Jurisprudence (12th Edn., at pp.
                                  149-50) under the caption -- "Circumstances destroying or
                                  weakening the binding force of precedent: (perhaps)
                                  affirmation or reversal on a different ground." It sometimes
                                  happens that a decision is affirmed or reversed on appeal on a
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                                   different point. As an example, suppose that a case is decided
                                  in the Court of Appeal on ground A, and then goes on appeal
                                  to the House of Lords, which decides it on ground B, nothing
                                  being said upon A. What, in such circumstances, is the
                                  authority of the decision on ground A in the Court of Appeal?
                                  Is the decision binding on the High Court, and on the Court of
                                  Appeal itself in subsequent cases? The learned author notes
                                  the difficulty in the question being positively answered and
                                  then states: (i) The High Court may, for example, shift the
                                  ground of its decision because it thinks that this is the easiest
                                  way to decide the case, the point decided in the court below
                                  being of some complexity. It is certainly possible to find cases
                                  in the reports where judgments affirmed on a different point
                                  have been regarded as authoritative for what they decided. (ii)
                                  The true view is that a decision either affirmed or reversed on
                                  another point is deprived of any absolute binding force it
                                  might otherwise have had; but it remains an authority which
                                  may be followed by a court that thinks that particular point to
                                  have been rightly decided.

                                  16.    In the present case, the order dated 10-9-1986 passed
                                  by this Court can be said to be a declaration of law limited
                                  only to two points -- (i) that in a petition putting in issue the
                                  constitutional validity of any State legislation the State is a
                                  necessary party and in its absence the issue cannot be gone
                                  into, and (ii) that a belated prayer for impleading a necessary
                                  party may be declined by this Court exercising its jurisdiction
                                  under Article 136 of the Constitution if the granting of the
                                  prayer is considered by the Court neither necessary nor proper
                                  to allow at the given distance of time. By no stretch of
                                  imagination can it be said that the reasoning or view of the
                                  law contained in the decision of the Division Bench of the
                                  High Court in M. Varadaraja Pillai case [85 LW 760] had
                                  stood merged in the order of this Court dated 10-9-1986 in
                                  such sense as to amount to declaration of law under Article
                                  141 by this Court or that the order of this Court had affirmed
                                  the statement of law contained in the decision of the High
                                  Court.

                                                               *****

                                  20.    Inasmuch as in the impugned judgment, the Full Bench
                                  has not adjudicated upon the issues arising for decision before
                                  it, we do not deem it proper to enter into the merits of the
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                                   controversy for the first time in exercise of the jurisdiction of
                                  this Court under Article 136 of the Constitution. We must
                                  have the benefit of the opinion of the Full Bench of the High
                                  Court as to the vires of the State legislation involved."

                            36.18 The law enunciated, in the afore-extracted passages from S.
                            Shanmugavel Nadar10 also goes to indicate that issues, to which the
                            superior court deciding the appeal, deciding the appeal was not even
                            alive, passed sub silentio and can never be prevented, from being
                            agitated subsequently, by applying the doctrine of merger. As has
                            been held in S. Shanmugavel Nadar10 what merges is the operative
                            part of the judgment.


                            36.19 The consequence of application of the doctrine of merger is that
                            the parties before the court would be proscribed from re-agitating the
                            issues, which were raised before the "inferior court" earlier and
                            decided by the decision which was upheld in appeal. The doctrine
                            cannot operate, in any event, to non-suit a third party, who was never
                            before the appellate court, from raising a challenge, to which the
                            appellate court was not even made aware. Any such view would be
                            clearly contrary to the enunciation of law in Kunhayammed7 and,
                            more particularly, in S. Shanmugavel Nadar10.


                            36.20 For all these reasons, I am of the view that the contention, of
                            Mr. Nayar, that the impugned order dated 17th December, 2019, of the
                            learned Arbitral Tribunal, has merged with the judgment dated 4 th
                            March, 2020, of the co-ordinate Single Bench of this Court in Arb.A
                            (COMM) 7/2020 and that, therefore, the Edelweiss is proscribed from
                            maintaining the present appeal, has, necessarily, to fail.
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                             36.21 Mr. Nayar also sought to contend that, were this Court to allow
                            the present appeal, it would result in setting, at naught, the judgment,
                            dated 4th March, 2020 (supra), passed in Arb. A. (COMM) 7/2020. I
                            am unable to agree. The judgment, dated 4th March, 2020, did not
                            adjudicate, at all, on the challenge raised in the present appeal. The
                            impugned order, dated 17th December, 2019, directed GIL to pay
                            certain amount to GTL. GIL challenged that order by way of Arb. A.
                            (COMM) 7/2020. The judgment, dated 4th March, 2020, finds the
                            challenge to be without merit, "on account of the admission and offer
                            of the appellant to clear its liability and the law that if that amount is
                            admitted by a party, the same should be released to the opposite party
                            at the earliest, without waiting for adjudication of the remaining
                            disputes" (as is expressly stated in concluding para of the judgment).
                            Ergo, in view of the admission of liability, by GIL to GTL, this Court
                            found that the challenge, by GIL, to the consequent direction for
                            payment, as made by the learned Arbitral Tribunal, was bereft of
                            merit.   In my view, the said finding cannot, by any stretch of
                            imagination, foreclose secured creditors from opposing the impugned
                            direction of the learned Arbitral Tribunal, and compromising their
                            rightful interests.


                            36.22 Whether such compromise has, or has not, taken place, would,
                            of course, be a matter of contest. Even so, accepting the submission,
                            as advanced by Mr. Nayar, could lead to deleterious consequences.
                            Let us pare down the issue to its rudiments. A and B are locked in
                            arbitration. A claims a certain amount from B. The arbitrator is not

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                             made aware of the fact that all assets of B stand secured in favour of a
                            secured creditor X. A moves an application, under Section 17, for a
                            direction to B, to pay forthwith to A, the claimed amount. B admits
                            its liability. Unaware of the fact that the assets of B stand secured
                            with X, the Arbitral Tribunal allows the prayer in the Section 17
                            application of A, and directs B to pay the amounts to A, subject to
                            final orders to be passed in the arbitral proceedings. B, thereafter,
                            challenges the direction, of the Arbitral Tribunal, before the High
                            Court. The High Court is also not made alive to the fact that assets of
                            B stand secured with X. Observing that the direction of learned
                            Arbitral Tribunal proceeded on admission, by B, of its liability
                            towards A, the High Court dismisses the petition of B. Can it be said,
                            in such circumstances, that X stands foreclosed from challenging the
                            arbitral order, on the ground that the directions contained therein
                            stands merged with the judgment of this Court? The answer, in my
                            opinion, has most definitively, to be in the negative. Else, it would
                            provide a carte blanche for crafty litigants to collude, circumvent the
                            legal process by subterfuge and obtained orders, to the prejudice of
                            legitimate secured creditors.     (I make this observation only ex
                            hypothesi, to test the merits of the reliance, by Mr. Nayar, on the
                            principle of merger, and not by way of affirmation of the allegation of
                            collusion, as levelled by Edelweiss in the present case.) The plea of
                            merger, as advanced by Mr. Nayar, has, therefore, to fail even on this
                            ground.


                            36.23 I may observe, here, that I have not chosen to enter into the
                            allegation, of Edelweiss, that the judgment of the Coordinate Single

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                             Bench in Arb.A (COMM) 7/2020 was obtained by perpetuating fraud
                            on this Court. "Fraud" is an extremely strong expression, and has
                            serious repercussions. It is not to be lightly alleged. Inasmuch as it is
                            not necessary, to decide the contention, of Mr. Nayar, regarding
                            merger of the impugned order of the learned Arbitral Tribunal with
                            the judgment dated 4th March, 2020 of the learned Single Judge in
                            Arb.A(Comm) 7/2020, to traverse the fraud ground, I refrain from
                            doing so.

                            37. Re: the challenge to maintainability of present appeal on the
                            ground of pendency, before the High Court of Bombay, of suit LD-
                            VC 55/20.

                            37.1 The third ground, on which the maintainability of the present
                            appeal is sought to be assailed, is the filing, by Edelweiss, of Suit LD-
                            VC 55/20 before the High Court of Bombay.

                            37.2 Considerable efforts were expended in pointing out, to me, the
                            identity of cause of action, and the averments of the prayers, in the
                            said suit, vis-à-vis the present appeal.


                            37.3 Following thereupon, it was asserted that Edelweiss, having
                            elected to seek restraint from enforcement of the impugned order,
                            dated 17th December, 2019, of the learned Arbitral Tribunal, by way
                            of original proceedings before the High Court of Bombay, was
                            estopped from maintaining the present appeal.


                            37.4 I am unable to agree with this submission, either. A remedy of
                            appeal, available under the statute, can never be denied to an eligible
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                             appellant, merely because the appellant has, earlier in point of time,
                            chosen similar reliefs by way of other proceedings. Alternative
                            remedy can operate as a proscription only against invocation of extra-
                            ordinary jurisdiction, not against ordinary jurisdiction, or jurisdiction
                            conferred by statute. The right to maintain an appeal, in accordance
                            with a statutory provision, can be curtailed or, indeed, restricted, only
                            by constraints to be found in the provision conferring the right of
                            appeal itself, and on no other count. An appellate court, equally,
                            cannot refuse to exercise appellate jurisdiction, on the ground that the
                            appellant has also availed another remedy, in law. The availability of
                            statutory appeal may take the character of an efficacious alternative
                            remedy; there cannot, however, be an alternate remedy to a remedy of
                            statutory appeal.


                            37.5 On the other hand, if the appeal, under Section 37 of the 1996
                            Act, could validly be maintained by Edelweiss, despite being a third
                            party and the stranger to the arbitration agreement, one may well
                            visualise an argument, before the High Court of Bombay, to the effect
                            that an effective alternate remedy was available to Edelweiss. Of
                            course, it is not in my place to hazard any validity of such objection, if
                            at all raised; I merely visualize it, for the purpose of dealing with the
                            objection raised by Mr. Nayar.


                            37.6 There can, however, be no legitimate objection to Edelweiss
                            maintaining and prosecuting its own appeal against the impugned
                            order, dated 17th December, 2019, of the learned Arbitral Tribunal,


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                             provided such appeal is available to it under Section 37 of the 1996
                            Act.


                            37.7 To reiterate, the maintainability of the Edelweiss, of other
                            proceedings, may be affected by the existence of an alternative
                            efficacious appellate remedy; the law can never, however, work vice-
                            versa.


                            37.8 Which brings us to the issue of whether, Edelweiss as a third
                            party can maintain an appeal under Section 37 of the 1996 Act.


                            37.9 The only judgment, which pronounces on the maintainability of
                            an appeal, by a third party, under Section 37 of the 1996 Act, has been
                            rendered by a learned Single Judge of the High Court of Bombay in
                            Prabhat Steel Traders Private Ltd. v. Excel Metal Processes Pvt.
                            Ltd.14.


                            37.10 In the said decision, the High Court of Bombay noted that the
                            interim measures, which could be awarded by an Arbitral Tribunal in
                            exercise of its power under Section 17, could, very conceivably,
                            affect third parties, who were not privy to the arbitration agreements.
                            In conjunction therewith, it was noticed that, though the expression
                            "party" was defined in Section 2(1)(h), Section 37 did not stipulate
                            that an appeal, thereunder, could be filed only by a party in the
                            agreement. The High Court of Bombay also placed reliance on the
                            judgment of Supreme Court in Chloro Controls India Pvt. Ltd. v.

                            14
                                 2018 SCC OnLine Bom 2347
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                             Severn Trent Water Purification Inc.15, which recognises the
                            permissibility of adding parties, who were strangers to the arbitration
                            agreement, in arbitral proceedings, albeit in exceptional cases. The
                            High Court observed and held, in paras 38 to 42, 47, 49, 50, 54, 59 to
                            61, 66 to 68, 73 and 102 of the report, thus:

                                      "38. Section 2(1)(h) defines "party" means a party to an
                                      arbitration agreement. Sections 2(1)(h) to 36 refers the
                                      "party" for different purposes. However, section 37 does not
                                      provide that an appeal under the said provision can be filed
                                      only by the parties to the arbitration agreement. By virtue of
                                      the amendment inserted by the Act 2 of 2016 with effect from
                                      23rd October, 2015 thereby amending section 17 of the
                                      Arbitration & Conciliation Act, 1996, powers which are
                                      available with the Court under section 9 for grant of interim
                                      measures, identical powers are now also granted to the
                                      arbitral tribunal.

                                      39. A perusal of section 17(1)(ii) clearly indicates that though
                                      such interim measures under section 17 can be applied only
                                      by a party to the arbitral tribunal and more particularly
                                      specified in section 17(1)(ii)(a) to (e), such reliefs may in
                                      some of the cases affect even third parties.

                                      40. The said provision clearly indicates that a party to the
                                      arbitration agreement who is permitted to apply for interim
                                      measures to the arbitral tribunal under the said provision and
                                      seek interim measures of protection in respect of any goods
                                      which are subject matter of the arbitration agreement or even
                                      to enter upon any land or building in possession of any party.
                                      Under section 17(1)(d) such party to the arbitration agreement
                                      can even apply for interim measures for appointment of a
                                      Court Receiver or for such interim measures or protection as
                                      may be appeared to the arbitral tribunal to be just and
                                      convenient. There may be a situation that a property or goods
                                      may belong to a third party who is not a party to the
                                      arbitration agreement but still a relief may be applied in
                                      respect of such goods or properties belonging to a third party

                            15
                                 2013(1) SCC 641
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                                   and more particularly if a party to the arbitration agreement is
                                  either in possession or custody thereof claiming any right
                                  therein in any manner whatsoever.

                                  41. In such a situation, where third party who is the owner of
                                  such goods or properties or claiming any right, title or interest
                                  in respect of such goods or properties but may not be in
                                  physical possession thereof and such goods or properties
                                  being in possession of one of the party to the arbitration
                                  agreement, such a third party is obviously going to be affected
                                  if any order is passed by the arbitral tribunal for interim
                                  measures under section 17 of the Act. There is no dispute
                                  about the proposition of law that a third party cannot appear
                                  before the arbitral tribunal and seek any interim measures
                                  under section 17 of the Arbitration & Conciliation Act, 1996
                                  or seek any modification or variation of the interim measures
                                  if granted by the arbitral tribunal against such third party
                                  though he may be aggrieved by such interim measures
                                  granted by the arbitral tribunal.

                                  42. The question therefore arises for consideration of this
                                  Court is whether a third party who is aggrieved by any such
                                  order of interim measures granted by the arbitral tribunal can
                                  file an appeal under section 37 of the Arbitration &
                                  Conciliation Act, 1996 after obtaining the leave of the Court
                                  or otherwise and whether can impugn such order of the
                                  arbitral tribunal in respect of any goods or properties in
                                  respect of any such right, title or interest claimed by such
                                  third party or in any other manner affected by such interim
                                  measures or not.
                                                                *****
                                  47. The question thus arises for consideration of this Court is
                                  that whether the remedy of an appeal under section 37 of the
                                  Arbitration & Conciliation Act, 1996 can be availed off by
                                  such a third party who is affected by an order of interim
                                  measures granted by the arbitral tribunal under section 17 of
                                  the Arbitration & Conciliation Act, 1996. Learned counsel for
                                  the respondents did not dispute the proposition that if a third
                                  party is impleaded in the proceedings under section 9 of the
                                  Arbitration & Conciliation Act, 1996 filed by a party to the
                                  arbitration agreement or the rights of any third party is
                                  affected by an order passed by a Court in an application under
                                  section 9 of the Arbitration & Conciliation Act, 1996 filed by
                                  a party to the arbitration agreement, such third party can apply
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                                   for impleadment or intervention in such proceedings and to
                                  apply for modification and/or for variation of such order. If
                                  such third party does not succeed in such application for
                                  modification or variation of the order passed by a Court in
                                  favour of a party to the arbitration agreement affecting the
                                  right, title and interest of such third party, such third party can
                                  file an appeal under section 37 of the Arbitration &
                                  Conciliation Act, 1996 before the Court under section 2(1)(e)
                                  of the Act.
                                                                 *****
                                  49. The Division bench construed Rule 803E of the Bombay
                                  High Court (Original Side) Rules and has held that section 9
                                  is distinct from Section 17 in as much as Petition under
                                  section 17 is moved before the Arbitrator for an order against
                                  a party to the proceedings, whereas section 9 vests remedy in
                                  a party to arbitration proceedings to seek interim measure of
                                  protection against a person who need not be either party to the
                                  arbitration agreement or to the arbitration proceedings. In the
                                  said proceedings under section 9, third party was also
                                  impleaded since the grant of the proposed relief was to
                                  incidentally affect those third parties. This Court entertained
                                  an appeal under section 37 of the Arbitration Act filed by
                                  such third party who was affected by the order passed by the
                                  learned Single Judge under section 9 though dismissed the
                                  said appeal on merit.

                                  50. In view of the fact that powers of Court under section 9 to
                                  grant interim measures and powers of the arbitral tribunal
                                  under section 17 of the Arbitration Act are identical in view
                                  of the amendment to section 17 with effect from 23rd October
                                  2015, in my view, even a third party who is directly or
                                  indirectly affected by interim measures granted by the arbitral
                                  tribunal will have a remedy of an appeal under section 37 of
                                  the Arbitration Act. The principles of law laid down by the
                                  Division bench of this Court in the case of Girish Mulchand
                                  Mehta and Durga Jaishankar Mehta v. Mahesh S. Mehta and
                                  Harini Cooperative Housing Society Ltd. (supra) can be
                                  extended to this situation.
                                                                *****
                                  54. Though a stranger to an agreement cannot be allowed to
                                  be impleaded as party to the arbitral proceedings before the
                                  arbitral tribunal and more particularly under section 17 of the
                                  Arbitration Act nor can such third party seek impleadment to
                                  the proceedings before the arbitral tribunal, he is however not
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                                   precluded from challenging the said order before the arbitral
                                  tribunal under section 17 if he so aggrieved by such order by
                                  invoking the remedy of an appeal under section 37 of the
                                  Arbitration Act.
                                                                *****
                                  59.    In order to invoke jurisdiction of the Court
                                  under Section 45, the applicant should satisfy the pre-
                                  requisites stated in Section 44 of the 1996 Act.

                                  60.     Chapter I, Part II deals with enforcement of certain
                                  foreign awards in accordance with the New York Convention,
                                  annexed as Schedule I to the 1996 Act. As per Section 44,
                                  there has to be an arbitration agreement in writing. To such
                                  arbitration agreement the conditions stated in Schedule I
                                  would apply. In other words, it must satisfy the requirements
                                  of Article II of Schedule I. Each contracting State shall
                                  recognize an agreement in writing under which the parties
                                  undertake to submit to arbitration their disputes in respect of a
                                  defined legal relationship, whether contractual or not,
                                  concerning a subject matter capable of settlement by
                                  arbitration. The arbitration agreement shall include an
                                  arbitration clause in a contract or an arbitration agreement
                                  signed by the parties or entered in any of the specified modes.
                                  Subject to the exceptions stated therein, the reference shall be
                                  made.

                                  61.     The language of Section 45 read with Schedule I of the
                                  1996 Act is worded in favour of making a reference to
                                  arbitration when a party or any person claiming through or
                                  under him approaches the Court and the Court is satisfied that
                                  the agreement is valid, enforceable and operative. Because of
                                  the legislative intent, the mandate and purpose of the
                                  provisions of Section 45 being in favour of arbitration, the
                                  relevant provisions would have to be construed liberally to
                                  achieve that object. The question that immediately follows is
                                  as to what are the aspects which the Court should consider
                                  while dealing with an application for reference to arbitration
                                  under this provision.

                                                               *****

                                  66.    Mr. Nariman, learned senior counsel appearing on
                                  behalf of the appellant, contended that in terms of Section
                                  45 of the 1996 Act, parties to the agreement shall essentially
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                                   be the parties to the suit. A stranger or a third party cannot ask
                                  for arbitration. They have to be essentially the same. Further,
                                  the parties should have a clear intention, at the time of the
                                  contract, to submit any disputes or differences as may arise, to
                                  arbitration and then alone the reference contemplated
                                  under Section 45 can be enforced.
                                                                 *****
                                  67.     To the contra, Mr. Salve, the learned senior counsel
                                  appearing for respondent No. 1, submitted that the phrase "at
                                  the request of one of the parties or any person claiming
                                  through or under him" is capable of liberal construction
                                  primarily for the reason that under the 1996 Act, there is a
                                  greater obligation to refer the matters to arbitration. In fact,
                                  the 1996 Act is the recognition of an indefeasible Right to
                                  Arbitration. Even a party which is not a signatory to the
                                  arbitration agreement can claim through the main party.
                                  Particularly, in cases of composite transactions, the approach
                                  of the Courts should be to hold the parties to the bargain of
                                  arbitration rather than permitting them to escape the reference
                                  on such pleas.

                                  68.    At this stage itself, we would make it clear that we are
                                  primarily discussing these submissions purely on a legal basis
                                  and not with regard to the merits of the case, which we shall
                                  shortly revert to.

                                                               *****

                                  73.     A non-signatory or third party could be subjected to
                                  arbitration without their prior consent, but this would only be
                                  in exceptional cases. The Court will examine these exceptions
                                  from the touchstone of direct relationship to the party
                                  signatory to the arbitration agreement, direct commonality of
                                  the subject matter and the agreement between the parties
                                  being a composite transaction. The transaction should be of a
                                  composite nature where performance of mother agreement
                                  may not be feasible without aid, execution and performance
                                  of the supplementary or ancillary agreements, for achieving
                                  the common object and collectively having bearing on the
                                  dispute. Besides all this, the Court would have to examine
                                  whether a composite reference of such parties would serve the
                                  ends of justice. Once this exercise is completed and the Court
                                  answers the same in the affirmative, the reference of even
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                                       non-signatory parties would fall within the exception afore-
                                      discussed.

                                                                  *****

                                      102. Joinder of non signatory parties to arbitration is not
                                      unknown to the arbitration jurisprudence. Even the ICCA's
                                      Guide to the Interpretation of the 1958 New York Convention
                                      also provides for such situation, stating that when the question
                                      arises as to whether binding a non-signatory to an arbitration
                                      agreement could be read as being in conflict with the
                                      requirement of written agreement under Article I of the
                                      Convention, the most compelling answer is "no" and the same
                                      is supported by a number of reasons."


                            37.11 I concur, respectfully, with the exposition of the law, in the
                            passages from Prabhat Steel Traders Private Ltd.14, extracted
                            hereinabove.


                            37.12 The principles enunciated in these paragraphs would also draw
                            sustenance from the judgment of the Supreme Court in State Bank of
                            India v. Ericsson India Ltd.16, in which it is clearly held thus:

                                      "5.    There can be no dispute that the Arbitral Tribunal has
                                      no jurisdiction to affect the rights and remedies of the third
                                      party-secured creditors in the course of determining disputes
                                      pending before it..."
                                                                                (Emphasis supplied)


                            37.13 If, therefore, the order of Arbitral Tribunal operates to the
                            prejudice of interests of secured creditors, such an order would be
                            amenable to interference in view of the law laid down in SBI v.
                            Ericsson16.

                            16
                                 (2018) 16 SCC 617
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                             37.14 It stands to reason, therefore, that, as a person aggrieved, and
                            affected, by such an order, the secured creditor has necessarily to be
                            allowed to maintain an appeal, thereagainst, under Section 37 of the
                            1996 Act, rather than driven to filing a civil suit. Indeed, as was
                            observed in para 73 of Prabhat Steel Traders Private Ltd.14, the very
                            maintainability of a civil suit may be questionable.


                            37.15 Inasmuch as, therefore, (i) an appeal, against an order passed
                            passed by the Arbitral Tribunal under Section 17, would lie only
                            under Section 37 of the 1996 Act and (ii) the remedy is also available
                            under Section 37 to third parties, who are not signatories to the
                            agreement, this Court cannot refuse to entertain the present appeal, at
                            the instance of Edelweiss. The mere filing of a prior suit, by
                            Edelweiss, before the High Court of Bombay, cannot, in my view,
                            extinguish the right of appellate remedy statutorily conferred by
                            Section 2(1)(b) of the 1996 Act.


                            37.16 The submission, of Mr. Nayar that Edelweiss, having elected to
                            file Suit LD-VC No. 55/20 before the High Court of Bombay, which
                            is pending as on date, cannot maintain the present appeal before this
                            Court, is also bereft of merit and is, accordingly, rejected.


                            38. Re. The objection to maintainability of the present appeal, on
                            the ground that Edelweiss has applied for impleadment/intervention in
                            OMP (ENF.) (COMM) 23/2020.



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                             38.1 It is obvious that this argument has no substance. By applying
                            for impleadment in OMP (ENF.) (COMM) 23/2020, filed by GTL for
                            enforcement of the impugned order, dated 17th December, 2019, of the
                            learned Arbitral Tribunal, it cannot be said that GIL has forfeited its
                            right to challenge the impugned order. Indeed, it was only necessary
                            for Edelweiss to oppose the impugned order, both way of the present
                            appeal, as well as by way of impleadment in OMP (ENF.) (COMM)
                            23/2020.


                            38.2 This submission of Mr. Nayar is, therefore, also rejected.


                            39.   Resultantly, this Court finds no ground to hold that the present
                            appeal is not maintainable at the instance of Edelweiss. The challenge
                            to the maintainability of the present appeal, as raised by the
                            respondents, is, therefore, dismissed.


                            On merits:


                            40.   The position, in law, that an Arbitral Tribunal cannot pass an
                            order, which affects the rights and remedies of third party secured
                            creditors, while determining the disputes pending before it, stands
                            authoritatively exposited, in para 5 of the report in SBI vs. Ericsson16,
                            in so many words, thus:
                                  "5.    There can be no dispute that the Arbitral Tribunal has
                                  no jurisdiction to affect the rights and remedies of the third
                                  party-secured creditors in the course of determining disputes
                                  pending before it..."
                                                                            (Emphasis supplied)


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                             41.   If, therefore, Edelweiss, in fact, is a secured creditor of GIL,
                            and the direction contained in the impugned order, affect the assets of
                            GIL, secured with Edelweiss and other secured creditors, the
                            direction, ex facie, cannot sustain.


                            42.   The clauses of the MRA and the TRA, on which Edelweiss
                            relies, may be reproduced, for ready reference, thus:

                                  Clauses of MRA

                                  "3.1 SECURITY FOR THE FACILITIES

                                  3.1.1 The Facilities together with all Interest, liquidated
                                  damages, fees, premia on prepayment or on redemption, costs,
                                  expenses and other all other fees, costs, charges, expenses
                                  and/or other monies whatsoever stipulated or payable to the
                                  CDR Lenders and their trustees and agents under this
                                  Agreement and the other CDR Documents shall be secured
                                  by:

                                         (i)    A charge and mortgage on all of Borrower's
                                         immovable properties, present and future, except for
                                         land related to the tower sites, being small pieces of
                                         existing land having aggregate book value of less than
                                         or equal to Rs. 5.78 crores (Rupees Five Crores and
                                         Seventy Eight Lakhs only) situated at various places
                                         where mortgage are not perfected;

                                         (ii)   A charge by way of hypothecation over all the
                                         Borrower's movable assets, present and future,
                                         including movable plant and machinery, machinery
                                         spares, tools, towers, accessories, operating cashflows,
                                         book debts, receivables, commissions, revenues of
                                         whatsoever nature, furniture, fixtures, vehicles and all
                                         other movable assets, present and future, intangible and
                                         tangible, goodwill, uncalled capital;

                                         (iii) A charge on the Trust and Retention Account
                                         and other reserves and any other bank accounts,
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                                          present and future, of the Borrower wherever
                                         maintained;
                                                           *****

                                  4.1    Representations and Warranties

                                                              *****

                                  (vi) No Litigation. Except as disclosed in Schedule XVI
                                  hereof, no litigation, investigation or proceeding, whether
                                  judicial, quasi-judicial, administrative or otherwise, of or
                                  before any arbitrator or Governmental Entity or any other
                                  Legal Proceedings, whether in India or any other jurisdiction,
                                  which may result in a Material Adverse Effect, is:

                                  (a) pending or threatened against the Borrower and/or the
                                  other Obligors, their business and/or any of the assets of the
                                  Borrower and the other Obligors; or

                                                              *****

                                  5.1 INFORMATION COVENANTS

                                  The Borrower shall furnish promptly after request of the
                                  Monitoring Institution such information and data as is
                                  reasonably requested about the Borrower, the Borrower's
                                  business, the Borrower's assets and the compliance by the
                                  Borrower with the terms of the CDR Documents or any
                                  Clearance and other related matters, including without
                                  limitation, information and data (i) to monitor the conduct of
                                  the business, (ii) to evaluate transactions with Affiliates, and
                                  (iii) in relation to goods and services financed with the
                                  proceeds of the Facilities.

                                  Without prejudice to the above, the Borrower shall promptly:

                                  (i) Representations and Warranties

                                  Notify the Finance Parties promptly, in any case not later than
                                  3 (three) Business Days upon becoming aware of the
                                  occurrence of any event or the existence of any circumstances
                                  which constitutes or results in any representation, warranty,
                                  covenant or condition under the CDR Documents being or
                                  becoming untrue or incorrect in any respect.
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                                                               *****


                                  (vi) Winding-Up/ Revocation/ Dissolution and Legal
                                  Process

                                  Notify the Finance Parties promptly, in any case not later than
                                  3 (three) Business Days upon becoming aware of any such
                                  event occurring, of any action or steps taken or legal
                                  proceedings started by or against it and/or any other Obligors
                                  in any court of law for their respective winding-up,
                                  insolvency, dissolution, revocation, administration or re-
                                  organisation or for the appointment of a receiver,
                                  administrator, administrative receiver, trustee or similar
                                  officer of the Borrower, or of the other Obligors, or of any or
                                  all of their respective assets or the outcome of which
                                  proceedings would have a material impact on the debt
                                  servicing capability of the Borrower; the Borrower shall also
                                  keep the Finance Parties informed of any legal proceedings,
                                  including but not limited to (A) the legal proceedings
                                  commenced by ICICI Bank Limited for invocation of pledge
                                  of shares of GTL, in relation to its objection against the
                                  merger of CNIL and the Borrower in the High Court of
                                  Judicature at Madras and for filing a case against admittance
                                  of CNIL into the CDR scheme and (B) any actions (whether
                                  amounting to a legal proceeding or otherwise) taken by IFCI
                                  Limited in respect of shares of the Borrower held by GTL
                                  offered as security to IFCI Limited and any subsequent
                                  actions taken by any of the Obligors in this regard, the
                                  outcome of which would have a material impact on the debt
                                  servicing capacity of the Borrower and/or the CDR Package
                                  and/or the ability of the Borrower to avail and comply with
                                  the terms of the CDR Package offered by the CDR Lenders.
                                  The Borrower shall, in consultation with the Monitoring
                                  Institution, take such remedial actions as may be required in
                                  relation to such legal proceedings in the best interest of the
                                  Borrower and the Lenders.

                                  (vii) Events affecting the Borrower/its business

                                  Notify the Finance Parties of any litigation, arbitration,
                                  administrative or other proceedings initiated or threatened
                                  against the Borrower, or to the best of the knowledge of the
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                                   Borrower, of the other Obligors, and/or their respective assets,
                                  or any material events/occurrences in the business sectors to
                                  which the Borrower and/or any of the Obligors cater,
                                  including the telecom sector, impacting the business of the
                                  Borrower and/or the other Obligors, and which may have a
                                  Material Adverse Effect.

                                  The Borrower shall promptly, but in any case not later than 3
                                  (three Business Days) upon becoming aware of any such
                                  events/circumstances, inform the CDR Lenders of the
                                  circumstances and conditions which are likely to disable the
                                  Borrower from reviving the business/its operations or which
                                  are likely to delay its completion or compel the Borrower to
                                  abandon the same.

                                                              *****

                                  5.2    AFFIRMATIVE COVENANTS

                                                              *****

                                  (iv) Trust and Retention Accounts

                                  The Borrower shall establish a Trust and Retention Accounts,
                                  with the Account Bank and all sub-accounts thereunder as
                                  required under the Trust and Retention Account Agreement,
                                  to the satisfaction of the CDR Lenders/Monitoring Committee
                                  and close all other accounts (save and except such accounts
                                  that are required by the Borrower for operational convenience
                                  and the same has been agreed by the Monitoring Institution)
                                  of the Borrower and transfer all amounts deposited therein to
                                  the Trust and Retention Account. The Borrower shall deposit
                                  all its cash inflows/receivables related to its operations and
                                  business, including the proceeds of any disbursements, its
                                  repayment/recoveries, income and receipts and all other cash
                                  inflows in the appropriate account as specified in the Trust
                                  and Retention Account Agreement and utilise such proceeds
                                  in a manner and priority as specified in the Trust and
                                  Retention Account Agreement. The Borrower shall comply
                                  with all provisions of the Trust and Retention Account
                                  Agreement, including maintaining all reserves required to be
                                  maintained. The Borrower shall furnish to the CDR Lenders a
                                  report from the Concurrent Auditor auditing all withdrawals
                                  from the Trust and Retention Account every fifteen (15) days
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                                   or such other period as may be specified by the CDR Lenders
                                  / Monitoring Committee in this regard. The Borrower shall
                                  provide information, on a monthly basis, and in such detail as
                                  may be required by the CDR Lenders / Monitoring Committee
                                  in respect of all its other bank accounts and shall comply with
                                  all directions of the CDR Lenders/Monitoring Committee in
                                  this regard. The Borrower further agrees and undertakes that
                                  all payments in relation to One Time Settlement, if any, shall
                                  be made out of the Trust and Retention Account;


                                                              *****

                                  5.3    NEGATIVE COVENANTS

                                                              *****

                                  (ix) One Time Settlements

                                  Without prior written approval of the Monitoring
                                  Committee/CDR EG, the Borrower shall not enter into any
                                  one time settlement or any other settlement with any of the
                                  lenders other than Existing Lenders (i.e., non CDR members).

                                                              *****


                                  (xvi) Security Interest

                                  (a) Create or permit to subsist any Security Interest (save and
                                  except for Permitted Security Interest) or any type of
                                  preferential arrangement (including retention arrangements or
                                  escrow arrangements having the effect of granting security),
                                  in any form whatsoever on any of its assets (including over its
                                  undertaking, either in whole or part, Intellectual Property and
                                  Intellectual Property Rights), in favour of any bank, financial
                                  institution, bank, company, firm or Persons.

                                  (b) Escrow its future cash flows or create any charge or lien or
                                  interest of whatsoever nature on such cash flows except as
                                  provided in the CDR Package without prior approval of the
                                  CDR EG.

                                                              *****
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                                   Clauses of TRA

                                  1. DEFINITIONS AND CONSTRUCTION

                                  1.1 Definitions

                                  In this Agreement, unless there is anything repugnant to the
                                  subject or context thereof, capitalized terms used but not
                                  defined shall have the meaning as specified to such term in
                                  the Master Restructuring Agreement and the expressions
                                  listed below shall have the following meanings viz.:

                                  "Business Proceeds" means all monies due and payable
                                  to/received by the Borrower from any source including
                                  without limitation any monies received in relation to its
                                  business, all rents/service receipts in relation thereto, proceeds
                                  from any disbursements, all amounts brought in as Promoter
                                  Contribution, all funding from the Sponsors or other
                                  shareholders/investors, including realisation of any current
                                  assets and monetisation of assets, realizations from CN1L,
                                  any funds brought into the Borrower as per the terms of the
                                  Sponsor Support Agreement, monies received/receivable
                                  pursuant to the terms of (or in respect of any termination or
                                  breach of) any of the Project Documents (including any
                                  guarantee/s, bond/s, letters of credit or other security in
                                  respect of any of it) and any amounts envisaged to be received
                                  by the Borrower as per the terms of the Base Case Business
                                  Plan, the CDR Package, the CDR LOA and/or the CDR
                                  Documents.

                                                               *****

                                  2.9 Deposit of Business Proceeds

                                  Subject to the terms and conditions of the Master
                                  Restructuring Agreement, on and from the opening of the
                                  Trust and Retention Account, all Business Proceeds (other
                                  than as provided in Section 3.2 hereof) shall be deposited by
                                  the Borrower into the Account(s) and withdrawn by the
                                  Account Bank to and from the relevant Accounts at the time
                                  and in the manner required by this Agreement. Other than (a)
                                  the Accounts, and (b) the Site Accounts, the Borrower further
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                                   agrees and undertakes that prior to such date that may be
                                  stipulated by the Monitoring Institution ("Closure Date"), it
                                  shall close all other accounts maintained by it whether with a
                                  bank or other institution, and transfer all funds lying to the
                                  credit of such other accounts to the Accounts, unless
                                  otherwise permitted by the Monitoring institution.

                                                               *****
                                  2.11 Monthly Plan
                                  The Borrower shall at least 5 (five) Business Days prior to
                                  every Monthly Distribution Date, provide to the Account
                                  Bank, with a copy to the Monitoring Institution, a monthly
                                  plan (the "Monthly Plan") setting out the amounts which are
                                  required to be maintained as balances in each of the Accounts
                                  (other than the Debt Service Accounts, which is to be guided
                                  by the Notice of Debt Service or as otherwise provided for
                                  herein) on such Monthly Distribution Date which amounts
                                  shall be equal to the monies required to be expended from
                                  each of the Accounts till the next Monthly Distribution Date.
                                  The Borrower agrees that the Monthly Plan will not specify
                                  any amounts in excess of the amounts agreed in the Annual
                                  Plan, except with the prior written consent of the Monitoring
                                  Institution. Provided that the amounts specified in any
                                  Monthly Plan may exceed the amounts agreed in the Annual
                                  Plan by a maximum margin of 20% (twenty percent) so long
                                  as the cumulatively for the entire Fiscal Year the amounts do
                                  not exceed the levels agreed to in the Annual Plan. However,
                                  the said 20% (twenty percent) restriction will not be
                                  applicable for any tax or statutory payments from the Tax and
                                  Statutory Dues Account.

                                  The Account Bank shall make the withdrawals (or enable the
                                  Borrower to make withdrawals) into/from the relevant
                                  Account, other than as expressly provided for in this
                                  Agreement or for the purposes of making Permitted
                                  Investments, in accordance with the Monthly Plan.

                                  The Account Bank shall not be under any duty to verify the
                                  Monthly Plan and shall act on the Monthly Plan as provided
                                  by the Borrower. The Borrower further agrees that if the
                                  Monitoring Institution disagrees with any Monthly Plan
                                  and/or if the Monthly Plan has not been prepared for any
                                  particular period, then any transaction in the Accounts shall
                                  only be with the prior permission of the Monitoring
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                                   Institution. Without prejudice to the aforesaid, the Monitoring
                                  institution may refer any such disagreement in relation to any
                                  Monthly Plan to the Monitoring Committee and the Borrower
                                  hereby agrees that any decision of the Monitoring Committee
                                  in this regard will be final and binding on the Borrower.

                                  The Monitoring Institution may, in consultation with the
                                  Borrower, change any Monthly Plan issued (or amended) by
                                  the Borrower. Any such changes to the Monthly Plan, shall be
                                  binding on the Borrower and the Account Bank and the
                                  Monthly Plan shall be amended to the extent of such changes
                                  intimated by the Monitoring Institution.

                                                              *****
                                  2.12 Default

                                  If an Event of Default or Potential Event of Default has
                                  occurred and is continuing the Finance Parties, or the
                                  Monitoring Institution (on their behalf) may, without
                                  prejudice to any other rights that they have and by written
                                  notice of 30 (thirty) days to the Borrower and the Account
                                  Bank, direct the Account Bank that the Account Bank shall
                                  thereafter (till further notice) act only in accordance with
                                  Section 5 hereof. The Monitoring Institution shall be entitled
                                  to instruct the Account Bank to realise the Permitted
                                  Investments, whether such investments have matured or not,
                                  and deposit the proceeds in the Enforcement Proceeds
                                  Account.

                                                              *****

                                  5.     WITHDRAWALS FOLLOWING DEFAULT

                                                              *****

                                  5.3     Upon the occurrence and during the subsistence of an
                                  Event of Default or Potential Event of Default, the Borrower
                                  undertakes not to issue any payment instructions to the
                                  Account Bank without the prior written consent of the
                                  Monitoring Institution and the Account Bank shall not be
                                  entitled to honour such instructions."



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                             43.   By referring to the aforesaid Clauses, it has been contended in
                            paras 11 and 12 of the written submissions, filed by Edelweiss, thus:


                                  "11. The MRA executed inter alia between R-1 and its
                                  lenders, record the terms of the restructuring of the debt of R-
                                  1 . (Ref: Document 2 at Pg 11 - 194 of Folder-IV). The
                                  following terms of MRA records the rights the Appellant:

                                         a.       The debts owed to the Appellant are secured by:
                                         (i) a first charge over all the movable assets of the R-1
                                         (including operating cash flows, book debts,
                                         receivables, revenue, etc.), (ii) a charge on the trust and
                                         retention account; and other reserves and bank
                                         accounts, present and future of the Respondent No.1,
                                         wherever maintained. (Clause 3.1 @ Pg. 66 of Folder-
                                         IV).

                                         b.     R-1 has been specifically prohibited from
                                         creating or permitting to subsist any security interest or
                                         any type of preferential arrangement on any of its
                                         assets. The said clause further prohibits R-1 from
                                         creating an escrow on its future cash flows or creating
                                         any charge or lien or interest on such cash flows.
                                         (Clause 5.3 (xvi) @ Pg. 94 of Folder-IV/).

                                         c.     R-1 has been specifically prohibited from
                                         entering into any one-time settlement without the
                                         approval of its lenders, including the appellant.
                                         (Clause 5.3 (ix) @ Pg. 94 of Folder-IV).

                                         d.      R-1 was to give a full disclosure to the lenders,
                                         including the Appellant, at the first instance, as to
                                         initiation or threatened initiation of any litigation,
                                         investigation, or proceedings or any other legal
                                         proceedings whether in India or any other jurisdiction
                                         which may result in a material adverse effect upon the
                                         R-1's ability to discharge its obligations under the
                                         financing documents, which includes its obligation to
                                         repay the debts. (Clause 4.1(vi)(a) @Pg. 71 of Folder-
                                         IV, Clause 5.1 (i) @ Pg. 79 of Folder-IV and Clause
                                         5.1(vii) @Pg. 81 of Folder-IV) .

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                                          e.     R-1 was to apprise the Appellant in case of
                                         occurrence of any event including any legal
                                         proceedings which has a material adverse effect upon
                                         discharge of its obligations including debt servicing
                                         capacity under the financing agreements (Clause 5.1
                                         (i) and (vi) of the MRA @ Pg. 79 of Folder-IV and @
                                         Pg. 80 of Folder-IV) Further, in terms of Clause 5.1(vi)
                                         of the MRA (@Pg. 80-81 of Folder-IV), R-1was
                                         obliged to take remedial steps with respect to any
                                         adverse legal proceedings in consultation with the
                                         Appellant in its capacity as the Monitoring Institution.

                                         f.     R-1 and its lenders subsequently, entered into a
                                         Trust and Retention Account Agreement on 25 June
                                         2013 ("TRA Agreement") (Ref: Document 4 at Pg
                                         345 - of Folder - IV), as per which all of the
                                         receivables of R-1 from all its operations and business
                                         were to flow into a trust and retention account and its
                                         sub-accounts, opened with a designated bank (the
                                         "Account Bank") and outflows could only have been
                                         made in the manner as determined under the terms of
                                         the TRA Agreement (Clause 5.2 (iv) @ Pg.83 of
                                         Folder                       IV)                      .

                                  12.    Under the terms of the TRA Agreement, all the cash
                                  and proceeds of R-1 is to route through the TRA Account,
                                  with full supervision and control of the Appellant in its
                                  capacity as a Monitoring Institution:

                                         a.      As per Clause 2.9 of the TRA, R-1 was to open
                                         a Trust and Retention Account, whose permissible
                                         debits and credits could only be carried out under the
                                         supervision and permission of the Monitoring
                                         Institution (i.e. the Appellant). All the "business
                                         proceeds" of R-1 were to flow into the said accounts,
                                         as per Clause 2.9 of the TRA Agreement (@Pg. 359 of
                                         folder IV), read with the definition of "business
                                         proceeds" provided within Clause 1.1 of the TRA
                                         agreement (@Pg. 350 of Folder IV).

                                         b.    Pertinently, all of the debits and credits,
                                         envisaged within Clauses 3.2 ad 3.3 of the TRA
                                         Agreement, into the TRA Accounts were under the
                                         supervision and permission of the Monitoring
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                                          Institution/Appellant. R-1 was obligated to provide
                                         monthly reports and details of proposed debits and had
                                         various other reporting obligations to the Appellant, as
                                         per Clause 2.11 of the TRA Agreement (@Pg. 361 of
                                         Folder IV).

                                         c.     In case of any default or potential default
                                         (defined within the MRA, whose definition is
                                         incorporated by reference within the TRA and includes
                                         any payment default), Clause 2.12 (@Pg. 262 of
                                         Folder IV), read with Clause 5 of the TRA Agreement
                                         (@Pg. 377 of Folder IV), requires the Account Bank,
                                         to act solely in accordance with the instructions of the
                                         Monitoring Institution/Appellant. More specifically,
                                         Clause 5.3 of the TRA (@Pg. 377 of Folder-IV)
                                         specifically barred R-1 from issuing any payment
                                         instructions to the Account Bank without prior written
                                         consent of the Monitoring Institution, i.e. the
                                         Appellant. "


                            44.   A juxtaposed reading of these submissions, with a reading of
                            the Clauses of the MRA and the TRA, cited therein, reveals that the
                            submissions of Edelweiss, ex facie, merit acceptance.


                            45.   Significantly, GIL has not chosen to traverse the aforesaid
                            submissions of Edelweiss. GTL, in its written submissions, however,
                            contended thus:
                                  "13. As set out above, the essence of the Appellant's case as
                                  argued before this Court is that Respondent No. 1 suppressed
                                  from the Tribunal that under the MRA and the TRA, the
                                  Appellant (and other lenders) have a charge over all of
                                  Respondent No. 1's assets, bank account and receivables.
                                  The Appellant has argued that this suppression from the
                                  Tribunal was collusive between Respondent No. 1 and
                                  Respondent No. 2 and intended to defeat and violate the
                                  provisions of the MRA and the TRA. The Appellant contends
                                  that if the terms of the MRA and TRA had been pointed out to
                                  the Tribunal, then the Tribunal would not have passed the S.
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                                   31(6) The award. This is a totally misconceived contention
                                  for the following reasons:

                                         a.     The Tribunal was called upon to decide whether
                                         the Respondent No. 1 had denied liability to the extent
                                         of Rs. 400 crore to Respondent No. 2.

                                         b.     In answering this question, the Tribunal
                                         analysed Respondent No. 1's pleadings and on the test
                                         of Order VIII Rules 3-5 of the CPC, came to the
                                         conclusion that Respondent No. 1 had failed to
                                         establish that it had denied liability to the extent of ₹
                                         400 crore.

                                         c.     In view of the Tribunal's finding that
                                         Respondent No. 1 had failed to dispute liability to the
                                         extent of ₹ 400 crore, relying on Order XII Rule 6 of
                                         the CPC, Uttam Singh Duggal (supra) and Numero
                                         Uno (supra), the Tribunal observes that Respondent
                                         No. 2 was entitled to payment of the undisputed sum of
                                         Rs. 400 crore at this stage itself.

                                         d.     To the aforesaid question of whether
                                         Respondent No. 1 had disputed its liability to
                                         Respondent No. 2 the extent of Rs. 400 crore, the terms
                                         of the MRA and the TRA between Respondent No. 1
                                         and its lenders (including the Appellant) were totally
                                         and utterly irrelevant.

                                         e.      To put it another way, even if the terms of the
                                         MRA and TRA had been pointed out by Respondent
                                         No. 1 to the Tribunal, it would have had no bearing
                                         whatsoever (and correctly so) on the Tribunal's
                                         analysis. Even on the terms of the MRA in the TRA,
                                         the Tribunal would not have come to any different
                                         conclusion on the analysis of Respondent No. 1's
                                         pleadings as to whether Respondent No. 1 had disputed
                                         its liability to Respondent No. 2 to the extent of Rs.
                                         400 crore. On a bare reading of Order VIII Rule 3-4
                                         and Order XII Rule 6 of the CPC and the law laid
                                         down in Uttam Singh Duggal (supra) and Numero
                                         Uno (supra), when a Court is called upon to consider
                                         whether a plaintiff is entitled to a decree based on
                                         admission, it is utterly and totally irrelevant that the
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                                          assets of the defendant are charged in favour of
                                         another party. Therefore, the argument that the award
                                         is fraudulent on account of charge on assets in favour
                                         of the Appellant is totally misconceived.

                                         f.      The Appellants argument amounts to saying
                                         that if a defendant's assets have been charged in
                                         favour of a lender, then a decree based on admission
                                         can never be passed against such a defendant,
                                         effectively meaning that such a defendant is exempt
                                         from Order VIII Rule 3-5 of the CPC and Order XII
                                         Rule 6 of the CPC. Such an argument is clearly
                                         misconceived.

                                         g.      At the very highest, the effect of the Appellant's
                                         so-called charge over Respondent No. 1's assets, bank
                                         accounts and receivables would be that during the
                                         process of execution of the S. 31(6) Award by
                                         Respondent No. 2, Respondent No. 2 may have some
                                         difficulty in executing the S. 31(6) Award against
                                         assets over which the Appellants hold a so-called
                                         charge. However, this is entirely a question which
                                         must be left to the Court seized with proceedings for
                                         execution of the S. 31(6) Award. In the present case,
                                         on 06.02.2020, Respondent No. 2 has already initiated
                                         proceedings under Section 36 of the Act being before
                                         the Delhi High Court (being OMP (Enf.) (Comm.) No.
                                         23/2020) for execution of the S. 31(6) Award. By way
                                         of an Order dated February 6, 2020, the Delhi High
                                         Court issued notice to Respondent No. 1 and directed
                                         Respondent No. 1 to file an affidavit in reply within 3
                                         weeks reflecting the position of its assets as they stood
                                         on the date on which the cause of action arose, on the
                                         date of the S. 31(6) Award as well as the date of the
                                         said Order. The Execution Petition is pending as on
                                         date. However, for reasons best known to Respondent
                                         No. 1, it has failed to comply with the Order dated
                                         February 6, 2020 and disclose its assets. Furthermore,
                                         para-32 of the appeal states that the Appellant has
                                         allegedly filed an intervention application in such
                                         execution petition, therefore indicating knowledge of
                                         such proceedings on the part of the Appellant."

                                                                             (Emphasis supplied)
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                             46.   In my view, the submissions of GTL are no answer to the
                            enunciation of the law by the Supreme Court in SBI v. Ericsson16. In
                            fact, in SBI v. Ericsson16, there was no transfer of the secured assets.
                            Rather, the Supreme Court was dealing with the challenge to an order
                            passed, under Section 17 of the 1996 Act, at the instance of certain
                            unsecured creditors.     The learned Arbitral Tribunal restrained the
                            transfer of the assets of the debtors, of such unsecured creditors,
                            without obtaining its prior permission. This decision of the Arbitral
                            Tribunal was confirmed by the High Court of Bombay, in an appeal,
                            under Section 37 of the 1996 Act. The creditors moved the Supreme
                            Court pointing out that they were not parties before the arbitrator, and
                            complaining that the directions issued by the Arbitral Tribunal
                            deprived them of their statutory rights, against the assets of the
                            debtors.


                            47.   The Supreme Court, as noted more than once hereinabove, went
                            out to state that the Arbitral Tribunal could not have affected the
                            rights and liabilities of third party secured creditors in the course of
                            determining the disputes pending before it.


                            48.   Mr. Sandeep Sethi, learned Senior Counsel points out,
                            correctly, that the present case stands on the better footing than the
                            case of SBI v. Ericsson 16 before the Supreme Court. In the present
                            case, the learned Arbitral Tribunal has actually directed transfer of the
                            amounts, secured in favour of the Edelweiss, from the accounts of
                            GIL to GTL.       Any such transfer, contends Edelweiss, would be
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                             completely impermissible in law, being directly in the teeth of the
                            afore-extracted covenants of the MRA and the TRA.


                            49.   The response "on merits", as contained in the submissions filed
                            by GTL, does not answer this issue. There is no contest to the fact
                            that the monies, which the impugned order, dated 17th December,
                            2019, of the learned Arbitral Tribunal directs transfer, from the
                            account of GIL to that of GTL, actually stood secured in favour of
                            Edelweiss. What GTL seeks to submit is that, once GIL had admitted
                            its liability towards GTL, applying the principle is analogous to those
                            contained in Order XII Rule 6, read with the decision in Uttam Singh
                            Duggal1, the learned Arbitral Tribunal was perfectly justified in
                            issuing the impugned directions to GIL, to make payment to GTL. It
                            is sought to be contended that, in considering whether a case for
                            granting a decree based on admissions existed, the Court was not
                            required to consider whether the assets, in respect of which the decree
                            was being passed, were charged in favour of any other party. On the
                            other hand, GTL contends that accepting the arguments of the
                            Edelweiss would amount to holding that, merely because, the assets of
                            GIL stood charged in favour of other secured creditors, a decree on
                            admission could never be passed against GIL. GIL contends,
                            therefore, that in determining "the aforesaid question" of whether
                            "(GIL) had disputed its liability to (GTL) to the extent of ₹ 400 crore,
                            the terms of the MRA and TRA between (GIL) and its lenders
                            (including the appellant), were totally and utterly irrelevant".




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                             49.1 The enunciation of the law in SBI16 clearly forecloses the
                            availability of such an argument, to GTL.


                            49.2 Specifically dealing with the jurisdiction of arbitral tribunals,
                            the Supreme Court has held, in clear and unmistakable terms, that an
                            Arbitral Tribunal cannot, in determining the issues before it, pass
                            directions which prejudice the legitimate rights of secured creditors.
                            This proposition, as enunciated by the Supreme Court, is not hedged
                            in by any caveat.


                            49.3 GTL cannot, therefore, seek to advance any submission which
                            would do violation with this proposition, which constitutes "law
                            declared", within the meaning of Article 141 of the Constitution of
                            India.


                            49.4 The contention that, in assessing whether monies were ought to
                            be directed to be transferred from the account of GIL to GTL, the
                            issue of whether the said monies stood secured with any other secured
                            creditor was "totally and utterly irrelevant" flies directly in the face of
                            the said enunciation of the law and is, therefore, summarily rejected.


                            49.5 As a matter of fact, this somewhat empirically worded
                            proposition, as put forth by the appellant, essentially misses the wood
                            for the trees. The present case is not one of a simple instance in which
                            there is an admission of liability by the defendant, qua the plaintiff,
                            and the amounts, in respect of which liabilities admitted, stands
                            charged in favour of a third party. While, even in such a case, the
                            question of whether the Court, after having been made aware of the
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                             existence of such a charge by the third-party, could, nevertheless,
                            ignore the submission and proceed to decree the suit on the basis of
                            the admission made by the defendant, may itself be highly debatable.
                            In the present case, the situation is exacerbated by the fact that the
                            MRA and the TRA contain, inter alia, covenants conveying an
                            absolute first charge, on the secured creditors of GIL - principally
                            Edelweiss - over the very monies which the Impugned Order conveys
                            to the account of GTL. Further, the MRA and the TRA prohibit GIL
                            from transferring the said monies, or even in depositing the monies in
                            an escrow account, without the prior permission of Edelweiss. I am
                            not prepared to countenance the submission that, even if all these facts
                            were made known to the learned Arbitral Tribunal, it would have
                            proceeded, nevertheless, to direct payment of ₹ 400 crore to GTL, in
                            stark violation of the covenants of the MRA and the TRA.


                            49.6 Interestingly,      in   its   written   submissions,   GTL     has
                            acknowledged, albeit by a side wind, that the consequence of the
                            implementation of the impugned directions of the learned Arbitral
                            Tribunal "would be that ... Respondent No. 2 may have difficulty in
                            executing the Section 31(6) award against assets over which the
                            appellant holds a so-called charge." It is, at the same time, sought to
                            be contended that this is an issue which has to be left to the court
                            seized with the proceedings for execution of the impugned directions.


                            49.7 Again, this submission has merely to be stated to be rejected. It
                            is trite that an executing court cannot go behind the decree being
                            executed by it. Any challenge, to the impugned directions of the
                            learned Arbitral Tribunal has, therefore, to be examined in substantive
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                             proceedings, wherein such challenge is raised, whether by way of an
                            appeal under Section 37 or objections under Section 34.             The
                            shoulders of the executing court cannot be made to bear this
                            responsibility.


                            49.8 GTL has sought to query that "if a defendant's assets have been
                            charged in favour of a lender, can a decree of admission never be
                            passed against defendant, effectively meaning that such a defendant is
                            exempt from Order VIII Rules 3 to 5 of the CPC and Order XII Rule 6
                            of the CPC".         Such a position, contends GTL, is "clearly
                            misconceived" in law. This submission fails to notice the qualitative
                            difference between proceedings before a Civil Court and before an
                            Arbitral Tribunal. It would not be permissible, even for a civil court
                            seized with an application under Order XII Rule 6 CPC, to directly
                            order payment of any amount, by the defendant, to the plaintiff, on the
                            ground that the defendant has admitted its liability to pay the said
                            amount, once the court has been made aware of the fact that the
                            amount has been charged in favour of a third party. In such a
                            situation, the court would, at very least, have to implead the third
                            party, in whose favour the amount is charged, before directing
                            payment of the amount under Order XII Rule 6.


                            49.9 The issue, therefore, is not of the defendant becoming exempt
                            from Order XII Rule 6, but of the necessity to ensure that the rights of
                            an unheard party are not prejudiced by a decree under Order XII Rule
                            6.



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                             49.10 In arbitral proceedings, normally, the parties before the Arbitral
                            Tribunal are the parties to the arbitration agreement. A third party
                            secured creditor would, therefore, normally, not be heard by the
                            Arbitral Tribunal though, with the development of law in Chloro
                            Controls15 and Cheran Properties Ltd. v. Kasturi & Sons17, which
                            had been followed by this Court in Nirmala Jain v. Jasbir Singh18,
                            third parties, whose rights are affected by the Arbitral proceedings,
                            may in exceptional cases, be impleaded therein.


                            49.11 For the time being, I am refraining from expressing any
                            opinion, regarding the necessity of the appellant-Edelweiss being
                            heard by the learned Arbitral Tribunal, leaving that issue open for
                            decision by learned Arbitral Tribunal, in the event of any such request
                            being made before it. Suffice it to state that, the impugned order dated
                            17th December, 2019 does not indicate that the attention of the learned
                            Arbitral Tribunal was invited to the existence of the MRA and TRA,
                            or of the securing of the assets, of GIL, in favour of the appellant-
                            Edelweiss, thereunder.


                            49.12 In this context, GIL has referred, in its written submissions, to
                            averments in its Statement of Defence filed before the learned Arbitral
                            Tribunal, to the fact that the debts, owed by GIL, stood referred to
                            Corporate Debt Restructuring and Strategic Debt Restructuring, as
                            well as the fact of sale of its debts to Edelweiss. The impugned order
                            does not, however, disclose that the attention of the learned Arbitral
                            Tribunal was invited to these passages. Merely including, in the
                            17
                                 (2018) 16 SCC 413
                            18
                                 256(2019) DLT 186
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                             pleadings before the learned Arbitral Tribunal, reference to certain
                            facts, without drawing the attention of the learned Arbitral Tribunal to
                            the said facts, especially during the course of argument in a Section 17
                            Application, cannot amount to full disclosure of the factual position to
                            the learned Arbitral Tribunal, even if it may stop short of fraud as
                            Edelweiss would allege. The learned Arbitral Tribunal cannot be
                            expected, while deciding a Section 17 application, to peruse, cover-to-
                            cover, every document placed before it, without its attention being
                            invited to such documents, or the contents thereof.


                            49.13 In the e-mail, dated 24th October, 2019, addressed by the lawyer
                            for GIL to the learned Arbitral Tribunal, an oblique reference to the
                            fact that the accounts of GIL were in CDR with lenders, who might
                            choose to challenge any decision, of the learned Arbitral Tribunal, in
                            appeal, is certainly to be found. The particulars of the "lenders" are
                            conspicuously absent, and there is no reference either to the MRA or
                            the TRA, or to the obligations cast on GIL by the covenants thereof. It
                            cannot, therefore, be said that GIL, or GTL, disclosed, to the learned
                            Arbitral Tribunal the fact of securing of the assets of GIL with various
                            secured creditors, a majority being secured in favour of Edelweiss.


                            49.14 Edelweiss has also sought to allege fraud, and collusion,
                            between GIL and GTL, which are interrelated corporate undertakings.
                            Mr. Mukul Rohatgi, appearing on behalf of GIL, restricted his
                            submissions to disputing the said stand of Edelweiss. Mr. Rohatgi
                            submitted that, in any case, his client was required, by the impugned
                            Order, to disgorge ₹ 440 crores, and it hardly mattered, to his client,
                            whether the payment was required to be made to GTL, or to
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                             Edelweiss. Mr. Rohatgi, however, seriously contests the allegation of
                            fraud and collusion, and submits that there is no justifiable basis for
                            such allegations. On the material on record, I, too, am unwilling to
                            hold that there is any evidence of collusion, between GIL and GTL.
                            GIL and GTL were independent corporate undertakings. The debts,
                            which constituted subject matter of the dispute between them, and,
                            consequently, subject matter of the proceedings before the learned
                            Arbitral Tribunal, date back to a time when GIL was nowhere in the
                            picture. It was only subsequently that GIL stepped into the shoes of
                            CNIL. No case of collusion, between GIL and GTL can, therefore, in
                            my view, be said to have been made out. The submission of Mr.
                            Rohatgi, in this regard, therefore, merits acceptance.


                            Relief - Can the directions of the learned Arbitral Tribunal be
                            modified, under Section 37 of the 1996 Act?

                            50.   While, in view of the aforesaid discussion, the direction, by the
                            learned Arbitral Tribunal, to GIL, to pay the allegedly acknowledged
                            debt, to GTL, may not be sustainable, the power of the learned
                            Arbitral Tribunal to secure the amount in dispute in the arbitral
                            proceedings, under Section 17(1)(b)(ii) of the 1996 Act, cannot be
                            gainsaid. In view of the fact that the assets of GIL stands secured
                            with its secured creditors, including, principally, Edelweiss, it may not
                            be possible to direct the amounts to be paid to GTL, or be deposited in
                            an Escrow account to be operated by GTL. The question that arises
                            is, therefore, whether, in view of this position, this Court would
                            necessarily have to set aside the directions contained in the impugned
                            Order and, perhaps, remand the matter to the learned Arbitral Tribunal
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                             for a reconsideration, or whether this Court could modify the
                            directions, to the extent of securing the amounts in question otherwise
                            than by way of payment to GIL or deposited in an account to be
                            operated by GIL.


                            51.        That, however, would require this Court to, in exercise of its
                            powers under Section 37(2)(b) of the 1996 Act, modify the directions
                            issued by the learned Arbitral Tribunal. Can it do so?


                            52.        I have not been able to come across any direct authority, on the
                            issue of whether, in exercise of its powers under Section 37, the Court
                            can modify the order, of the learned Arbitral Tribunal, under
                            challenge. The generally accepted position, in law, under Section 34,
                            appears to be that, unlike the situation as it existed under the earlier
                            Arbitration Act, 1940, Section 34 of the 1996 Act does not empower
                            the Court, adjudicating on objections to an arbitral award, to modify
                            the award, though there are some decisions - including Prabhat Steel
                            Traders Private Ltd.14 - which doubt this proposition. I am not,
                            however, exercising Section 34 jurisdiction.           Section 37, unlike
                            Section 34, confers appellate power on the Court. The power of an
                            Appellate Court, classically, includes the power to modify the order
                            appealed against. In the context of the scope of appellate jurisdiction,
                            albeit under sections 99 and 100 of the CPC, the Supreme Court, in
                            Tirupati Balaji Developers (P) Ltd. v. State of Bihar19, held as under:




                            19   (2004) 5 SCC 1

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                                   "9.     In a unified hierarchical judicial system which India
                                  has accepted under its Constitution, vertically the Supreme
                                  Court is placed over the High Courts. The very fact that the
                                  Constitution confers an appellate power on the Supreme
                                  Court over the High Courts, certain consequences naturally
                                  flow and follow.
                                  Appeal implies in its natural and ordinary meaning the
                                  removal of a cause from any inferior court or tribunal to a
                                  superior one for the purpose of testing the soundness of
                                  decision and proceedings of the inferior court or tribunal. The
                                  superior forum shall have jurisdiction to reverse, confirm,
                                  annul or modify the decree or order of the forum appealed
                                  against and in the event of a remand the lower forum shall
                                  have to rehear the matter and comply with such directions as
                                  may accompany the order of remand.
                                  The appellate jurisdiction inherently carries with it a power
                                  to issue corrective directions binding on the forum below and
                                  failure on the part of the latter to carry out such directions or
                                  show disrespect to or to question the propriety of such
                                  directions would -- it is obvious --be destructive of the
                                  hierarchical system in administration of justice. The seekers
                                  of justice and the society would lose faith in both.
                                                                *****
                                  11. The very conferral of appellate jurisdiction carries with it
                                  certain consequences. Conferral of a principal substantive
                                  jurisdiction carries with it, as a necessary concomitant of that
                                  power, the power to exercise such other incidental and
                                  ancillary powers without which the conferral of the principal
                                  power shall be rendered redundant. As held by their
                                  Lordships of the Privy Council in Nagendra Nath
                                  Dey v. Suresh Chandra Dey [AIR 1932 PC 165 : 59 IA 283]
                                  (Sir Dinshaw Mulla speaking for the Bench of five), an appeal
                                  is an application by a party to an appellate court asking it to
                                  set aside or revise a decision of a subordinate Court. The
                                  appeal does not cease to be an appeal though irregular or
                                  incompetent. Placing on record his opinion, Subramania
                                  Ayyar, J. as a member of the Full Bench (of five Judges)
                                  in Chappan v. Moidin Kutti [ILR (1899) 22 Mad 68 : 8
                                  MLJ 231] (at ILR p. 80) stated inter alia that appeal is "the
                                  removal of a cause or a suit from an inferior to a superior
                                  judge or court for re-examination or review". According
                                  to Wharton's Law Lexicon such removal of a cause or suit is
                                  for the purpose of testing the soundness of the decision of the
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                                   inferior court. In consonance with this particular meaning of
                                  appeal, "appellate jurisdiction" means "the power of a
                                  superior court to review the decision of an inferior court".
                                  "Here the two things which are required to constitute
                                  appellate jurisdiction, are the existence of the relation of
                                  superior and inferior court and the power on the part of the
                                  former to review decisions of the latter. This has been well
                                  put by Story: 'The essential criterion of appellate jurisdiction
                                  is, that it revises and corrects the proceedings in a cause
                                  already instituted and does not create that cause. In reference
                                  to judicial tribunals an appellate jurisdiction, therefore,
                                  necessarily implies that the subject-matter has been already
                                  instituted and acted upon, by some other court, whose
                                  judgment or proceedings are to be revised,' (Section
                                  1761, Commentaries on the Constitution of the United
                                  States)." (ILR p. 80)"
                                                                             (Emphasis supplied)



                            53.   Once the legislature has consciously conferred appellate
                            powers, to the High Court, against orders of Arbitral Tribunals,
                            rendered under Section 17 of the 1996 Act, I see no reason, absent any
                            statutory or precedential proscription to the contrary, for not allowing
                            such appellate jurisdiction its full play and effect. No doubt, while
                            exercising jurisdiction, even as an appellate court under Section 37,
                            the High Court would be required to maintain the discipline of the
                            1996 Act, which requires minimal interference with the decision of
                            the learned Arbitral Tribunal.        Where, however, the directions
                            contained in the impugned Order of the learned Arbitral Tribunal are
                            found to be unsustainable on account of the prior rights of the
                            appellant before this Court, to which the attention of the learned
                            Arbitral Tribunal was never invited, interference, in order to protect
                            the legitimate interests of the appellant, is justified. Once a case for
                            interference is found to exist, the appellate jurisdiction of the Court,
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                             under Section 37 would, in my view, also extend to modifying the
                            order of the learned Arbitral Tribunal, in view of the inalienable
                            indicia of appellate jurisdiction, as identified and delineated in
                            Tirupati Balaji Developers (P) Ltd.19.


                            Conclusion


                            54.    As a result of the aforesaid discussion, I hold that the present
                            appeal, at the instance of Edelweiss, is maintainable. The objection to
                            maintainability, as advanced by the respondents, is rejected.


                            55.   I do not find any ground to hold that GIL and GTL acted in
                            collusion or that they perpetrated fraud either on the learned Arbitral
                            Tribunal or on this Court. At the same time, I agree with Mr. Sandeep
                            Sethi, learned Senior Counsel, that the learned Arbitral Tribunal was
                            never made specifically aware of the covenants of MRA and the TRA,
                            or the obligations cast on GIL vis a vis Edelweiss and other secured
                            creditors, thereunder. In view of the position of law enunciated in
                            SBI v. Ericsson16, it would not be permissible for the learned Arbitral
                            Tribunal to issue any such direction as would prejudice the rights of
                            such secured creditors, over the assets of GIL.


                            56.   The order, dated 5th May, 2020, passed by the High Court of
                            Bombay in the Suit LD-VC No. 55/20, discloses that, consequent to
                            the issuance of the impugned directions, by the learned Arbitral
                            Tribunal, a settlement had been arrived at, between GIL and GTL,
                            consequent to which ₹ 320 crores had been transferred by GIL to
                            GTL. The order also discloses that this amount was, subsequently,
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                             transferred back by GTL and stands deposited in the TRA, maintained
                            in accordance with the TRA agreement. The impugned directions of
                            the learned Arbitral Tribunal would, therefore, stand modified to
                            the extent that all payments directed thereunder, would be
                            deposited, not with GIL or in an Escrow account to be maintained
                            by GIL, but in the TRA, created and maintained in accordance
                            with the TRA agreement. The said deposit shall remain subject to
                            further orders to be passed by the learned Arbitral Tribunal.


                            57.   In passing the above directions, I am exercising my jurisdiction
                            as an appellate court under Section 37(2) of the 1996 Act, as, in my
                            view, appellate jurisdiction would also include, within its fold, the
                            power to modify the directions of the learned Arbitral Tribunal.


                            58.   The present appeal, therefore, stands allowed to the aforesaid
                            extent, with no orders as to costs.


                            59.   In light of the above, I.A. 4322/2020 does not survive for
                            consideration.




                                                                         C. HARI SHANKAR, J.

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