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Delhi High Court

Gmr Hyderabad Vijayawada Expressways ... vs National Highways Authority Of India on 4 August, 2020

Author: C. Hari Shankar

Bench: C. Hari Shankar

                            $~1 to 3
                            *     IN THE HIGH COURT OF DELHI AT NEW DELHI
                                                                     Reserved on: 13th May, 2020
                                                                 Pronounced on: 4th August, 2020

                            +     I.A. 3714/2020 in O.M.P.(COMM) 425/2020

                            GMR HYDERABAD VIJAYAWADA
                            EXPRESSWAYS PVT LTD                  .... Petitioner
                                             Through: Dr. Abhishek Manu Singhvi
                                                      and        Mr.             Ciccu
                                                      Mukhopadhyaya, Sr. Advocates
                                                      with Mr. Mahesh Agarwal, Ms.
                                                      Megha Mehta, Mr. Nishant Rao
                                                      and Mr. Ankit Banati, Advs.
                                                      versus

                            NATIONAL HIGHWAYS AUTHORITY OF INDIA
                                                                 ..... Respondents
                                            Through: Mr. Tushar Mehta, Solicitor
                                                     General with Dr. Maurya Vijay
                                                     Chandra, Mr. Manish K.
                                                     Bishnoi and Mr. Karan Grover,
                                                     Advs.

                            +     O.M.P.(I) (COMM) 92/2020

                            GMR HYDERABAD VIJAYAWADA
                            EXPRESSWAYS PVT LTD                        .... Petitioner
                                             Through: Dr. Abhishek Manu Singhvi
                                                      and        Mr.            Ciccu
                                                      Mukhopadhyaya, Sr. Advocates
                                                      with Mr. Mahesh Agarwal, Ms.
                                                      Megha Mehta, Mr. Nishant Rao
                                                      and Mr. Ankit Banati, Advs.
                                             versus

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                             NATIONAL HIGHWAYS AUTHORITY OF INDIA
                                                                 ..... Respondents
                                            Through: Mr. Tushar Mehta, Solicitor
                                                     General with Dr. Maurya Vijay
                                                     Chandra, Mr. Manish K.
                                                     Bishnoi and Mr. Karan Grover,
                                                     Advs.


                            +     O.M.P. (COMM) 426/2020 & I.As.3759-63/2020

                            NATIONAL HIGHWAYS AUTHORITY OF INDIA
                                                                                     ... Petitioner
                                                      Through:     Mr. Tushar Mehta, Solicitor
                                                                   General with Dr. Maurya Vijay
                                                                   Chandra, Mr. Manish K.
                                                                   Bishnoi and Mr. Karan Grover,
                                                                   Advs.

                                                      versus

                            GMR HYDERABAD VIJAYAWADA
                            EXPRESSWAYS PVT LTD                    ..... Respondents
                                             Through: Dr. Abhishek Manu Singhvi
                                                      and        Mr.            Ciccu
                                                      Mukhopadhyaya, Sr. Advocates
                                                      with Mr. Mahesh Agarwal, Ms.
                                                      Megha Mehta, Mr. Nishant Rao
                                                      and Mr. Ankit Banati, Advs.

                                  CORAM
                                  HON'BLE MR. JUSTICE C. HARI SHANKAR


                            %                         JUDGMENT


                            1.    All these petitions relate, one way or the other, to the Award,
                            dated 31st March, 2020, passed by a 3-member Arbitral Tribunal

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                             (hereinafter referred to as "the learned Arbitral Tribunal") comprising
                            Hon‟ble Dr. Justice Arijit Pasayat (Retd.), Hon‟ble Mr. Justice C.M.
                            Nayar (Retd.) and Lt. Gen. Y. P. Khurana. The majority Award was
                            delivered by Hon‟ble Dr. Justice Arijit Pasayat (Retd.) and Lt. Gen. Y.
                            P. Khurana, with Hon‟ble Mr. Justice C.M. Nayar (Retd.) penning a
                            partly dissenting award.


                            2.    Before the learned Arbitral Tribunal, GMR Hyderabad
                            Vijayawada Expressways Pvt. Ltd. (hereinafter referred to as "GMR")
                            was the claimant and the National Highways Authority of India
                            (NHAI) was the respondent.


                            The issue, in a nutshell


                            3.    O.M.P. (COMM.) 426/2020, by the NHAI, and O.M.P.
                            (COMM.) 425/2020, by GMR, have been preferred under Section 34
                            of the Arbitration and Conciliation Act, 1996 (hereinafter referred to
                            as "the 1996 Act"), and assail the aforesaid Award, dated 31st March,
                            2020 (hereinafter referred to as "the Award"), albeit on different
                            aspects, and to different extents. O.M.P. (COMM) 426/2020, by the
                            NHAI, seeks setting aside of the Award, in toto. O.M.P. (COMM)
                            425/2020, by GMR, is directed against paras 288 (in part), 292 (in
                            part), 293 to 297 and 299 (in part) of the Award, and seeks setting
                            aside of the Award, to the extent of the said paras.


                            4.    The issue decided by the learned Arbitral Tribunal - and,
                            consequently, the scope of controversy in the petitions, preferred by
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                             NHAI and GMR, under Section 34 of the 1996 Act - is extremely
                            limited. On the ground that there had been a "change in law", during
                            the currency of the agreement between GMR and NHAI, GMR
                            claimed that it was entitled to compensation, under Clauses 41.1 and
                            41.3 of the Concession Agreement, dated 9th October, 2009, between
                            GMR and NHAI.         NHAI contested the claim. All the learned
                            Members of the Arbitral Tribunal have held, ad idem, that the
                            rejection, of the claim for compensation, by NHAI, was unsustainable.
                            The majority Award (by Hon‟ble Dr. Justice Pasayat and Lt Gen. Y.
                            P. Khurana) proceeds, however, to permit NHAI to take a fresh
                            decision, on the claims of GMR, and assess the compensation to
                            which it would be entitled. Nayar, J., however, held, per dissent, that
                            the task of examining the claim of GMR, on merits, ought not to have
                            been delegated to NHAI, but ought to have been assigned to experts,
                            such as an eminent body of auditors.


                            5.    NHAI claims to be aggrieved by the decision, of the learned
                            Arbitral Tribunal, holding GMR to be entitled to compensation, and
                            contends, in its petition [O.M.P. (COMM.) 426/2020] that GMR was
                            not entitled to any compensation on the ground of "change in law".
                            GMR, for its part, challenges [in O.M.P. (COMM.) 425/2020] the
                            majority Award, to the extent it delegates the decision-making power,
                            qua the claim, of GMR, to compensation, to NHAI. In other words,
                            GMR seeks to contend that the minority Award of Nayar, J., ought to
                            be accepted.




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                             6.    O.M.P. (I) (COMM.) 92/2020 has been preferred, by GMR,
                            under Section 9 of the 1996 Act, essentially for the interim stay of
                            operation of a letter, dated 16th April, 2020, issued by the NHAI to
                            GMR, demanding premium and, further, restraining GMR from taking
                            any coercive steps, under the Concession Agreement, dated 9 th
                            October,    2009    (hereinafter   referred   to   as   "the   Concession
                            Agreement"), against GMR, pending quantification of compensation
                            payable to GMR. It is also prayed, in the said application, that an
                            independent firm of Chartered Accountants of repute be appointed for
                            confirming the quantification of the compensation payable.


                            The impugned Award


                            7.    The facts of the case, as they emerge from the impugned
                            Award, dated 31st March, 2020, deserve to be paraphrased, at the very
                            outset, thus:


                                  (i)       Vide the National Highways (Amendment) Act, 1995,
                                  Section 8A was incorporated in the National Highways Act,
                                  1956. This newly introduced provision empowered NHAI to
                                  enter into agreements, for development and maintenance of the
                                  whole, or part of national highways. It further provided that any
                                  person, with whom such agreement had been entered into, could
                                  collect and retain fees, for the services or benefits rendered by
                                  him, as provided by the notification issued by the Central
                                  Government, having regard to the expenditure involved in
                                  building, maintenance, management and operation of the
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                                   National Highway, interest on capital invested, reasonable
                                  return, the volume of traffic and the period of the agreement.
                                  These collaborations were, therefore, characteristically on a
                                  Public Private Partnership (PPP) basis, under the "Build,
                                  Operate and Transfer" (BOT) framework. The BOT framework
                                  envisaged the developer obtaining support from a consortium of
                                  financiers, contractors and consultants, and offering to construct
                                  the project at its own cost, thereby saving public money. The
                                  developer was allowed to recover the cost, along with
                                  reasonable profit, over the concession period, during which the
                                  developer operated the project, by collecting and retailing toll
                                  revenues from the public, who made use of the facility (i.e. the
                                  highway) developed by the developer. On conclusion of the
                                  concession period, the highway was transferred to the NHAI.
                                  In such contracts, therefore, the entrepreneur-developer, as the
                                  concessionaire, arranged the finances. The concessionaire
                                  entered into one, or more, contracts for design, procurement of
                                  material and equipment, completion, maintenance and operation
                                  of the highway, in accordance with the agreement with the
                                  NHAI.


                                  (ii)   The high traffic section of the National Highways were
                                  generally bid out either on Premium basis, or on Grant basis,
                                  under the BOT framework. Under the Premium system, the
                                  concessionaire offered premium to NHAI, in lieu of the right to
                                  build and operate the highway, during the concession period. In
                                  such a framework, the concessionaire was entitled to collect and
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                                   retain the toll collected from the public, who were using the
                                  highway, from which amount the concessionaire would (i)
                                  recover the cost of construction, maintenance and operation of
                                  the highway during the concession period, (ii) repay loans to
                                  lenders, (iii) pay premium to NHAI and (iv) recover the
                                  investment made by the concessionaire in the project, along
                                  with reasonable returns thereon.


                                  (iii)   Sand mining, in the state of Andhra Pradesh was, on the
                                  date of the Concession Agreement, between GMR and NHAI,
                                  governed by the Sand Mining Policy, contained in GOMs No.
                                  24 Inds & Com (MIA) Dept. dated 12th February, 2007, issued
                                  by the Government of Andhra Pradesh, whereunder sand
                                  mining areas/leases of less than 5 Hectares (Ha) did not require
                                  environmental clearance.


                                  (iv)    A Request for Qualification (RFQ), inviting applications
                                  from bidders for 4/6 laning of NH-9 (now known as NH-65)
                                  was issued, by NHAI, in December, 2007. A consortium of
                                  GMR and Punj Lloyd Ltd. submitted its bid in January, 2008.
                                  Vide letter dated 26th August, 2008, NHAI disqualified the
                                  consortium, and qualified certain other bidders, for award of the
                                  tender. In September, 2008, the Request For Proposal (RFP) /
                                  tender documents were issued by NHAI.


                                  (v)     The consortium challenged its disqualification, by NHAI,
                                  before this Court, by way of CWP 6792/2008. Vide judgment
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                                   dated 16th December, 2008, the disqualification of the
                                  consortium, by NHAI, was quashed by this Court. The matter
                                  was carried, by the successful bidder, to the Supreme Court, but
                                  the Supreme Court allowed the consortium, inter alia, to bid for
                                  the project.


                                  (vi)   Pursuant thereto, on 16th December, 2008, the consortium
                                  furnished its bid and obtained a copy of the RFP/Tender
                                  Documents.       Along with the Tender Documents, NHAI
                                  provided a Detailed Project Report (DPR). Clause 2.1.3 of the
                                  RFP stipulated that the DPR was provided only as a preliminary
                                  reference, for assistance to bidders, who were expected to carry
                                  out their own survey before submitting their bid.


                                  (vii) Accordingly, the consortium had a detailed traffic study,
                                  of the Highway, conducted by M/s Halcrow Consulting India
                                  Private Limited (hereinafter referred to as "Halcrow"), to
                                  estimate the tollable traffic, and toll revenue, for NH 65, till the
                                  end of the 25-year concession period. Clause 1.2 (g) of the
                                  agreement noted that the purpose of the study was "Estimation
                                  of projected toll revenue as per categories of traffic streams".


                                  (viii) On 9th October, 2009, as already noted hereinabove,
                                  GMR and NHAI entered into the Concession Agreement.
                                  Clause 25.4 of the Concession Agreement contemplated
                                  payment of premium, by the concessionaire (GMR) to NHAI,
                                  and read thus:
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                                          "25.4 Premium

                                                The Concessionaire acknowledges and agrees
                                                that as set forth in the Bid, it shall pay to the
                                                Authority for each year of the Concession
                                                Period, but commencing from the day falling
                                                after 0 (zero) days from the COD, a premium
                                                (the "Premium") in the form of an additional
                                                Concession Fee, as set forth in Clause 26.2.1,
                                                and in the manner set forth in Clause 26.4."


                                  As per the Concession Agreement, the premium, payable by
                                  GMR to NHAI, was 32.6% of the total Realisable Fee during
                                  the year, and was to be increased by 1%, every year.


                                  (ix)   Fee, from users of the highway, could be collected, by the
                                  concessionaire, i.e. GMR, from the date of completion, till the
                                  date of transfer of the highway to NHAI, in accordance with
                                  Clause 27.1 of the Concession Agreement, which read thus:

                                         "27.1 Collection and appropriation of Fee

                                         27.1.1 On and from the COD till the Transfer Date, the
                                         Concessionaire shall have the sole and exclusive right
                                         to demand, collect and appropriate Fee from the Users
                                         subject to and in accordance with this Agreement and
                                         the National Highways Fee (Determination of Rates
                                         and Collection) Rules, 2008 (the "Fee Rules");
                                         provided that for ease of payment and collection, such
                                         Fee shall be rounded off to the nearest 5 (five) rupees
                                         in accordance with the Fee Rules; provided further that
                                         the Concessionaire may determine and collect Fee at
                                         such lower rates as it may, by public notice to the
                                         Users, specify in respect of all or any category of Users
                                         of vehicles."



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                                   (x)    Clause 4.1.3, which set out the conditions precedent, to
                                  be satisfied by the concessionaire, i.e. GMR, prior to the
                                  appointed date, read thus:

                                         "4.1.3 The Conditions Precedent required to be
                                         satisfied by the Concessionaire prior to the Appointed
                                         Date shall be deemed to have been fulfilled when the
                                         Concessionaire shall have:

                                               (a)   provided Performance Security to the
                                               Authority;

                                               (b)   executed and procured execution of the
                                               Escrow Agreement;

                                               (c)    executed and procured execution of the
                                               Substitution Agreement;

                                               (d)    procured all the Applicable Permits
                                               specified in Schedule-E unconditionally or is
                                               subject to conditions than all such conditions
                                               shall have been satisfied in full and such
                                               Applicable Permits are in full force and effect;

                                               (e)    executed the Financing Agreements and
                                               delivered by the Authority 3 (three) true copies
                                               thereof, duly attested by a Director of the
                                               Concessionaire;

                                               (f)    delivered to the Authority 3 (three) true
                                               copies of the Financial Package and the
                                               Financial Model, duly attested by a Director of
                                               the Concessionaire, along with 3 (three) soft
                                               copies of the Financial Model in MS Excel
                                               version or any substitute thereof, which is
                                               acceptable to the Senior Lenders;

                                               (g)    delivered to the Authority from the
                                               Consortium      Members,      their   respective
                                               confirmation, in original, of the correctness of
                                               the representations and warranties set forth in

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                                                       Subclauses (k), (l) and (m) of clause 7.1 of this
                                                      Agreement; and

                                                      (h)    delivered to the Authority a legal opinion
                                                      from the legal counsel of the Concessionaire
                                                      with respect to the authority of the
                                                      Concessionaire to enter into this Agreement and
                                                      the enforceability of the provisions thereof:

                                               Provided that upon request in writing by the
                                               Concessionaire, the Authority may, in its discretion,
                                               waive any of the Conditions Precedent set forth in this
                                               Clause 4.1.3."

                                       (xi)    As required by the afore-extracted Clause 4.1.3 of the
                                       Concession Agreement, GMR submitted its Financial Model to
                                       NHAI, along with the Financing Documents, on 6th April, 2010.
                                       Clause 48.1 defined the "Financial Model", thus:

                                               "Financial Model‟ means the financial model adopted
                                               by Senior Lenders, setting forth the capital and
                                               operating costs of the Project and revenues therefrom
                                               on the basis of which financial viability of the Project
                                               has been determined by the Senior Lenders, and
                                               includes a description of the assumptions and
                                               parameters used for making calculations and
                                               projections therein."

                                       (xii)   Prior to the Date of Completion fixed by the Concession
                                       Agreement between GMR and NHAI, the Supreme Court, vide
                                       an order dated 27th February, 2012, passed in Deepak Kumar v.
                                       State of Haryana1, ruled that sand mines, over areas
                                       admeasuring less than 5 Ha, were also required to obtain
                                       environment clearance. Additionally, the Central Government
                                       was directed to take steps to bring, into force, the Minor
                            1
                                (2012) 4 SCC 629
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                                   Minerals     Conservation   and    Development     Rules,    2010.
                                  Governments of States and Union Territories were also directed
                                  to take immediate steps to frame necessary rules under Section
                                  15 of the Mines and Minerals (Development and Regulation)
                                  Act, 1957.


                                  (xiii) This was followed by order, dated 21st March, 2012, of
                                  the High Court of Andhra Pradesh in WP (C) 18822 of 2011,
                                  whereby the Government was restrained from granting any sand
                                  mining/sand quarrying lease to any person, w.e.f. 1st April,
                                  2012, without the permission of the High Court. The order was
                                  made applicable throughout the state of Andhra Pradesh. This
                                  interim order was, subsequently, made absolute, while
                                  disposing of the aforesaid writ petition, on 26th April, 2012.


                                  (xiv) Further, vide order dated 7th May, 2012 in SLP (C)
                                  15301-15305/2012 (Government of Andhra Pradesh v. Annam
                                  Sivaiah), the Supreme Court directed the government of the
                                  State of Andhra Pradesh to mandatorily require obtaining of an
                                  environment clearance, even for mines in areas admeasuring
                                  less than 5 Ha.


                                  (xv) The consequence of these developments, according to
                                  GMR, was that mining activities, in the state of Andhra
                                  Pradesh, came to a standstill.




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                                   (xvi) Consequent on the aforesaid judicial orders, the
                                  Government of Andhra Pradesh issued a new sand mining
                                  policy, vide GOM No. 142 dated 13th October, 2012 and GOM
                                  No. 154 dated 15th November, 2012, which resulted in
                                  temporary stoppage of almost all sand mining contracts in force
                                  in the Krishna District.

                                  (xvii) On 6th July, 2013, GMR wrote to NHAI, submitting that
                                  the new sand mining policy, as issued by the Government of
                                  Andhra Pradesh vide GOM No. 142 dated 13th October, 2012
                                  and GOM No. 154 dated 15th November, 2012, constituted
                                  "change in law" for the purposes of Clauses 41.1 and 41.3 of
                                  the Concession Agreement, which read thus:

                                         "41.1 Increase in costs

                                               If as a result of Change in Law, the
                                               Concessionaire suffers an increase in costs or
                                               reduction in net after-tax return or other
                                               financial burden, the aggregate financial effect
                                               of which exceeds the higher of rupees one crore
                                               (rupees one crore) and 0.5% (zero point five
                                               percent) of the Realisable Fee in any
                                               Accounting Year, the Concessionaire may soon
                                               notify the Authority and propose amendments
                                               to this Agreement so as to place the
                                               Concessionaire in the same financial position as
                                               it would have enjoyed had there been no such
                                               Change in Law resulting in the cost increase,
                                               reduction in return or other financial burden as
                                               aforesaid. Upon notice by the Concessionaire,
                                               the Parties shall meet, as soon as reasonably
                                               practicable but no later than 30 (thirty) days
                                               from the date of notice, and either agree on
                                               amendments to this Agreement or on any other
                                               mutually agreed arrangement.
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                                                Provided that if no agreement is reached within
                                               90 (ninety) days of the aforesaid notice, the
                                               Concessionaire may by notice require the
                                               Authority to pay an amount that would place the
                                               Concessionaire in the same financial position
                                               that it would have enjoyed had there been no
                                               such Change in Law, and within 15 (fifteen)
                                               days of receipt of such notice, along with
                                               particulars thereof, the Authority shall pay the
                                               amount specified therein; provided that if the
                                               Authority shall dispute such claim of the
                                               Concessionaire, the same shall be settled in
                                               accordance with the Dispute Resolution
                                               Procedure. For the avoidance of doubt, it is
                                               agreed that this Clause 41.1 shall be restricted
                                               to changes in law directly affecting the
                                               Concessionaire‟s costs of performing its
                                               obligations under this Agreement."

                                         "41.3 Protection of NPV

                                               Pursuant to the provisions of Clauses 41.1 and
                                               41.2 and for the purposes of placing the
                                               Concessionaire in the same financial position as
                                               it would have enjoyed had there been no
                                               Change in Law affecting the costs, returns or
                                               other financial burden or gains, the Party shall
                                               rely on the Financial Model to establish and a
                                               net present value (the "NPV") of the net cash
                                               flow and make necessary adjustments in costs,
                                               revenues, compensation or other relevant
                                               parameters, as the case may be, to procure that
                                               the NPV of the net cash flow is the same as it
                                               would have been if no Change in Law had
                                               offered."

                                  "Change in law" was defined, in Clause 48.1 of the Concession
                                  Agreement, thus:
                                         "Change in Law" means the occurrence of any of the
                                         following after the date of Bid:

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                                          (a)     the enactment of any new Indian Law;

                                         (b)    the repeal, modification or re-enactment of any
                                         existing Indian Law;

                                         (c)    the commencement of any Indian law which has
                                         not entered into effect until the date of Bid;

                                         (d)    A change in the interpretation or application of
                                         any Indian law by a judgment of a court of record
                                         which has become final, conclusive and binding, as
                                         compared to such interpretation or application by a
                                         court of record prior to the date of Bid; or

                                         (e)    any change in the rates of any of the Taxes that
                                         have a direct effect on the Project".

                                  (xviii) As required by the Concession Agreement, GMR
                                  submitted the draft financing documents to NHAI, for review
                                  and approval, on 7th February, 2010. Consequent to review,
                                  thereof, by NHAI, the draft financing documents were executed
                                  on 5th April 2010 and submitted to NHAI, by GMR, on 6th
                                  April, 2010.


                                  (xix) The Concession Agreement was, as noted hereinabove,
                                  executed, between the parties, on 9th October, 2009.
                                  Admittedly, the construction (4-laning) of the highway was
                                  completed, by GMR, within time, and operation of the highway
                                  was commenced on 20th December, 2012.


                                  (xx) On commencing operations, it was found that the traffic,
                                  on the highway, was drastically low, compared to the traffic
                                  that had been estimated, at the time of entering into the
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                                   Concession Agreement. GMR asserted that this reduction in
                                  traffic was owing to (a) certain notifications/orders issued by
                                  the Government, as well as by various judicial authorities and
                                  Courts, resulting in changes in the sand mining policy
                                  applicable till then and (b) bifurcation of the State of Andhra
                                  Pradesh into the twin states of Andhra Pradesh and Telangana,
                                  in 2014. More specifically, GMR contended that the reduction
                                  in traffic was owing to
                                         (a)    court   orders    and     Government     notifications,
                                         resulting in an annulment/banning of, inter alia, sand
                                         mining     activities,   which     completely     eliminated
                                         commercial traffic carrying sand and related construction
                                         traffic,
                                         (b)    frequent disruption of movement of the regular
                                         traffic, on account of statewide agitation/block its, due to
                                         proposed bifurcation of the State of Andhra Pradesh into
                                         Andhra Pradesh and Telangana,
                                         (c)    bifurcation of the state of Andhra Pradesh, and
                                         introduction of new sand mining policies, resulting in
                                         complete ban on interstate transportation of minor
                                         minerals, which caused a major adverse impact on traffic
                                         and
                                         (d)    imposition of permit tax on inter-State movement
                                         of commercial vehicles to and from the newly created
                                         states of Andhra Pradesh and Telangana.




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                                   (xxi) The    above    events/developments,    contended GMR,
                                  constituted "change in law", which entitled GMR to
                                  compensation, in accordance with Clauses 41.1 and 41.3 of the
                                  Concession Agreement. GMR asserted, in its letter, that, during
                                  the bidding phase, sand contributed 30% of commercial truck
                                  traffic   movement,      especially   between      Krishna    and
                                  Nalgonda/Hyderabad Districts, with a majority of the trucks of
                                  loading the sand and returning the same day. The GOMs dated
                                  13th October, 2012 and 15th November, 2012, issued by the
                                  Government of Andhra Pradesh, however, annulled almost all
                                  mining contracts in force in the Krishna District, which were
                                  based on the earlier sand mining policy.        This reduction in
                                  commercial traffic, it was pointed out, had occurred after the
                                  Commercial Operation Date of 20th December, 2012. GMR
                                  submitted that the Financial Model, furnished by GMR to
                                  NHAI, too, was based on beating assumptions, which did not in
                                  research the change in Sand Mining Policy. GMR submitted,
                                  further, that, on observing the fall in commercial traffic, it had
                                  undertaken a detailed origin-destination study, in order to
                                  ascertain the reasons for the variation, which revealed that the
                                  reduction in movement of sand-carrying vehicles was the cause,
                                  and that this reduction was attributable to the new sand mining
                                  policies of the Government of Andhra Pradesh, promulgated in
                                  2012. These, therefore, it was submitted, constituted "Change
                                  in Law", within the meaning of Clause 41.2 of the Concession
                                  Agreement, which had resulted in reduction of the revenue of
                                  GMR, and consequent financial burden on it. As this financial
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                                   loss was more than ₹ 1 crore, GMR asserted its right to
                                  compensation, under Clause 41.1 of the Concession Agreement,
                                  so that it was restored to the position prior to the change in law.
                                  It was, therefore, proposed, in the said communication, to
                                  amend the provisions relating to Additional Concession Fee, so
                                  that the     financial loss, suffered by GMR, could be
                                  adjusted/recovered from the premium payable to NHAI, within
                                  12 months. GMR, therefore, solicited the cooperation of NHAI,
                                  to discuss the issue.


                                  (xxii) NHAI sought the opinion of the independent engineer
                                  appointed by it, M/s. Intercontinental Consultants and
                                  Technocrats Pvt. Ltd. (hereinafter referred to as "ICT"), on the
                                  aforesaid request of GMR. ICT responded to NHAI, vide letter
                                  dated 7th October, 2013. The letter, at the very outset, identifies
                                  the issues, which were referred to a legal expert for its opinion,
                                  thus:
                                          "-     Whether the Concessionaire is eligible to the
                                          benefits due to Change in Law

                                           -    The quantum of benefits due to the above
                                          change."


                                  Apropos the first issue, it was opined that "since there has been
                                  modification of existing notification and replacement of the
                                  same by a different one, the change in Sand mining policy
                                  would get covered under the definition of Change in Law."
                                  Apropos the second, even while observing that GMR was
                                  entitled to compensation, as it had established the existence of
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                                   substantial movement of sand mining vehicles on NH-9 (later
                                  renumbered NH-65) during the period 2007-2008 to 2012-2013,
                                  the communication, from ICT further went on to opine thus,
                                  towards the conclusion thereof:

                                         "The Concessionaire has claimed that the resultant loss
                                         due to reduction in traffic is a direct consequence of
                                         Change in Law. Therefore, the claim of the
                                         Concessionaire regarding the Change in Law is only
                                         based on the reduction in traffic of the sand mining
                                         vehicles. Be that as it may, whatever data has been
                                         submitted by the Concessionaire in respect of the
                                         number/percentage of the sand mining vehicles in
                                         support of its plaint, the same cannot be said to be final
                                         as the correctness thereof cannot be verified.

                                                 However, the quantum of compensation, if any,
                                         required to be paid to the Concessionaire in terms of
                                         the proviso to Clause 41.1, if it is able to establish the
                                         loss is a direct consequence of Change in Law, cannot
                                         be ascertained in view of the reasons explained
                                         hereinabove."


                                  In substance, therefore, ICT opined that, though the new sand
                                  mining policy, introduced by the Government of Andhra
                                  Pradesh vide GOM No. 142 dated 13th October, 2012 and GOM
                                  No. 154 dated 15th November, 2012, constituted "change in
                                  law" within the meaning of Clauses 41.1 and 41.3 of the
                                  Concession Agreement, the quantum of compensation payable
                                  to GMR, as a consequence thereof, in terms of the proviso to
                                  Clause 41.1, could not be ascertained on the basis of the data
                                  provided by GMR.



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                                   (xxiii) On 30th July, 2013, the demand for bifurcation of the
                                  state of Andhra Pradesh into two states, of Andhra Pradesh and
                                  Telangana, was approved, in principle, by the Congress
                                  Working Committee. This resulted in widespread agitation in
                                  the state, to the extent that several government establishments
                                  were shutdown, power supply was disrupted, highway traffic
                                  was affected, and riots took place.         This resulted in GMR
                                  addressing a further communication, dated 8th October, 2013, to
                                  NHAI, pointing out that, as a result of the widespread agitation
                                  following the proposal to bifurcate the State of Andhra Pradesh,
                                  commercial and economic activity in the state had been
                                  severely impacted, resulting in civil commotion, political
                                  agitation and industrial actions which continued for more than 7
                                  days, as stipulated in Clause 34.3 of the Concession Agreement.
                                  Article 34 of the Concession Agreement, it may be noted, dealt
                                  with force majeure. GMR suggested, in its communication, that
                                  the agitation, following the announcement of the proposal to
                                  bifurcate the state of Andhra Pradesh, and the resultant impact
                                  on the commercial and economic activity in the state,
                                  constituted an "indirect political event", which had resulted in
                                  "material adverse effect on the performance of obligations" by
                                  GMR.      It was informed, therefore, the GMR would seek
                                  appropriate   relief   from   NHAI,     in    that   regard,   after
                                  quantification of relevant data.


                                  (xxiv) Vide GOM No. 186, dated 17th December, 2013 and
                                  GOM No. 63 dated 22nd February, 2014, the Government of
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                                   Andhra Pradesh further amended the sand mining policy. This,
                                  GMR alleged, resulted in minimal or almost no allotments of
                                  sand mining, in the Krishna District catchment area during the
                                  year 2013-2014 which, in turn, further adversely impacted
                                  commercial traffic on the Project Highway.


                                  (xxv) The Andhra Pradesh Reorganisation Act, 2014, which
                                  crystallised the bifurcation of the state of Andhra Pradesh into
                                  the two states of Andhra Pradesh and Telangana, came into
                                  effect on 2nd June, 2014. Consequent thereupon, of the total
                                  length of the Project Highway, relating to the Concession
                                  Agreement, a length of 150.6 km fell within Telangana and
                                  30.9 km fell within Andhra Pradesh.


                                  (xxvi) Consequent to the bifurcation, the Government of
                                  Andhra Pradesh announced the Mines and Minerals New Sand
                                  Mining Policy, 2014, vide GOM No. 94, dated 28th August,
                                  2014. Clause (17) of the said Policy (hereinafter referred to as
                                  the "2014 AP Sand Mining Policy") specifically stipulated that
                                  no transportation of sand, from the State of Andhra Pradesh,
                                  would be made across the border to other States. The restricted
                                  movement of sand, across the border between Andhra Pradesh
                                  and Telangana, thereby, metamorphosed into a total cessation
                                  of such movement.


                                  (xxvii)      In the circumstances, GMR wrote to NHAI, on 5th
                                  September, 2014, stating that the total prohibition, on
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                                   transportation of sand, across the border from Andhra Pradesh
                                  to other states, majorly impacted the traffic and toll revenue on
                                  the Project Highway, regarding which an appropriate claim
                                  would be made, by GMR, under the provisions of the
                                  Concession Agreement.


                                  (xxviii)     On 8th January, 2015, the Government of
                                  Telangana also promulgated a new Mines and Minerals Sand
                                  Mining Policy, 2014, vide GOM No. 3. Clause 12 of the said
                                  policy (hereinafter referred to as "the 2014 Telangana Sand
                                  Mining Policy") was identical, to all intents and purposes, with
                                  Clause (17) of the 2014 AP Sand Mining Policy, and prohibited
                                  transportation of sand, from the State of Telangana, across the
                                  border, to other States.


                                  (xxix) On 13th January, 2015, GMR wrote to NHAI, drawing
                                  the attention of the latter, to the 2014 Telangana Sand Mining
                                  Policy, and pointing out that the ban on transportation of sand,
                                  from Telangana to all other states, had resulted in cessation,
                                  still further, of movement of sand on the Project Highway.
                                  This, it was reiterated, had a major impact on the traffic and toll
                                  revenue which could be generated from movement of traffic on
                                  the Project Highway, regarding which a claim would be made
                                  at the appropriate time, as per the Concession Agreement.


                                  (xxx)        On 24th February, 2015, GMR wrote to NHAI,
                                  requesting that, till it was compensated, by NHAI, for the
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                                   financial loss suffered on account of the change in the Sand
                                  Mining Policy from time to time, and the bifurcation of the
                                  state of Andhra Pradesh into the states of Andhra Pradesh and
                                  Telangana, both of which, according to GMR, constituted
                                  "change in law" within the meaning of Clauses 41.1 and 41.3 of
                                  the Concession Agreement, deferment of the requirement of
                                  payment of premium, by GMR to NHAI, be granted, as was
                                  permissible vide a Premium Deferment Scheme floated by the
                                  Government of India on 4th March, 2014, in the case of
                                  "stressed" projects.

                                  (xxxi)       As in the case of the new Sand Mining Policies,
                                  twin OMs, being GOM No. 15 dated 30th March, 2015 and
                                  GOM No. 22 dated 24th April, 2015, were issued by the
                                  Governments of Telangana and Andhra Pradesh, under the
                                  Telangana Motor Vehicle Taxation Act, 1963 and the Andhra
                                  Pradesh motor Vehicle Taxation Act, 1963, providing for levy
                                  of Tax on all commercial vehicles entering the concerned State
                                  from any other State. Correspondingly, GMR also wrote, on 6 th
                                  April, 2015 and 1st August, 2015, to NHAI, intimating NHAI of
                                  the issuance of the said GOMs, and informing that, as a result
                                  thereof, traffic and revenue numbers, on the Project Highway
                                  had dropped still further, vis-à-vis the traffic in the previous
                                  Financial Year 2014-2015. The claim, based on the quantum of
                                  revenue loss would, it was intimated, be submitted at the
                                  appropriate time, as per the provisions of the Concession
                                  Agreement.

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                                   (xxxii)      Premium was paid, by GMR to NHAI, as per
                                  Clause 25.4 of the Concession Agreement, till March, 2015.
                                  Initially, however, premium was paid only for January, 2015,
                                  whereupon NHAI wrote, to GMR on 7th May, 2015, calling on
                                  GMR to immediately deposit the concession fee/premium,
                                  constituting the revenue share of NHAI, for the months of
                                  February, March and April, 2015, within 7 days. This was
                                  followed by a request, dated 21st May, 2015, to the Escrow
                                  Bank (the IDBI Bank) to remit, to NHAI, the outstanding
                                  Concession Fee for the months February to April 2015, from
                                  the Escrow Account. Vide letter dated 22nd May, 2015, GMR
                                  requested NHAI to withdraw the said communication, to the
                                  Bank, as it had applied for premium deferment, which was
                                  pending consideration with NHAI.


                                  (xxxiii)      NHAI appointed M/s. Sheladia Associates Inc.
                                  (hereinafter referred to as "Sheladia") as the new Independent
                                  Engineer, substituting ICT. Sheladia tendered an opinion, dated
                                  20th June, 2015, to the effect that the claim for compensation,
                                  by GMR, under Clause 41 of the Concession Agreement, on the
                                  ground of change in law, was "an educated guess and
                                  conjecture". Following this, on 8th July, 2015, NHAI wrote to
                                  GMR, rejecting its claim for compensation, and advising it to
                                  seek a resolution of the dispute in accordance with Clause 44 of
                                  the Concession Agreement.




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                                   (xxxiv)       On 3rd August, 2015, NHAI issued a legal notice to
                                  GMR, demanding payment, by GMR, of the allegedly
                                  outstanding premium of ₹ 36,52,06,983/-. GMR responded,
                                  vide communication dated 13th August, 2015, drawing attention
                                  to the opinion of ICT, dated 20th June, 2015, to the effect that
                                  change in law, resulting in adverse financial consequences on
                                  GMR, had taken place, as well as the fact that it is request, for
                                  premium deferment, was pending with NHAI.


                                  (xxxv)        Ultimately,   vide   communication    dated    12th
                                  November, 2015, NHAI sanctioned premium deferment to
                                  GMR but subject to payment, by GMR, of penalty of ₹ 8.7
                                  crores along with arrears of premium of ₹ 10.4 crores with
                                  which condition, according to GMR, it was in no position to
                                  comply.       GMR,     accordingly,    requested   NHAI,     vide
                                  communication dated 19th November, 2015, to waive the said
                                  conditions.


                                  (xxxvi)       Vide communication dated 16th December, 2015,
                                  GMR served a notice of dispute on NHAI, in terms of Clause
                                  41.1 of the Concession Agreement, invoking the conciliation
                                  process, contemplated in Clause 44.2 thereof.


                                  (xxxvii)      Vide communications dated 2nd February, 2016 and
                                  22nd February, 2016, NHAI informed GMR that its request for
                                  premium deferment could not be accepted.           GMR, in the
                                  circumstances, paid NHAI the premium amounts, for the
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                                   months of February and March, 2015, with interest, under cover
                                  of letter dated 29th February, 2016.


                                  (xxxviii)    On the same day, i.e. 29th February, 2016, NHAI
                                  informed GMR that the conciliation process, initiated by GMR
                                  vide letter dated 16th December, 2015 supra, had failed.


                                  (xxxix)      On 8th June, 2016, NHAI wrote to GMR,
                                  withdrawing the premium deferment, granted by NHAI vide its
                                  earlier communication dated 12th November, 2015 supra.


                                  (xl)   Vide communication dated 9th June, 2016, addressed to
                                  NHAI, GMR claimed compensation of ₹ 87.64 crores, under
                                  Clauses 41.1 and 41.3 of the Concession Agreement, in respect
                                  of the Financial Year ending 31st March, 2016. This claim was
                                  amended, during the arbitral process, to ₹ 231.85 crores.


                                  (xli) This was followed by communication dated 17th June,
                                  2016, whereby GMR responded to the letter, dated 8th June,
                                  2016 supra, from NHAI, and protested against the withdrawal
                                  of premium deferment.


                                  (xlii) Vide communication dated 30th June, 2016, GMR
                                  invoked the arbitration clause in the Concession Agreement.


                                  (xliii) On 29th September, 2016, Sheladia wrote to NHAI,
                                  opining that the bifurcation of the state of Andhra Pradesh into
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                                   Andhra Pradesh and Telangana, on 2nd June, 2014, constituted
                                  "change in law", within the meaning of Clause 41 of the
                                  Concession Agreement, but that GMR had overestimated the
                                  prospective traffic on the Project Highway.


                                  (xliv) Sheladia had, in the meanwhile, solicited a legal opinion,
                                  from M/s S.V.S. Chowdary & Co., Advocates, on the following
                                  specific queries:

                                         "i.   Whether the changes made to the Sand Policy
                                         through „Government Orders‟ by State Government of
                                         AP would constitute a „Change in Law‟?

                                         ii.   Whether the bifurcation of the State of Andhra
                                         Pradesh into the reorganised states of State of Andhra
                                         Pradesh and the State of Telangana would constitute a
                                         „Change in Law‟?"

                                  (xlv) It was opined, by M/s S.V.S. Chowdary & Co., on 4 th
                                  October, 2016, that
                                         (a)   as a minor mineral, any policy, for mining of sand,
                                         fell exclusively within the domain of the State
                                         Government,
                                         (b)   such policy was normally issued in the form of
                                         Government Orders,
                                         (c)   GOMs No. 24, dated 12th February, 2007, 142
                                         dated 13th October, 2012 and 154 dated 15th November,
                                         2012, modified the existing law in the state of Andhra
                                         Pradesh from time to time, and each such GOM,
                                         consequently, constituted a Change in Law,

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                                          (d)     the interim order, dated 21st March, 2012 and final
                                         order dated 26th April, 2012, of the High Court of Andhra
                                         Pradesh in WP 18822/2011, and the consequent order,
                                         dated 7th May, 2012, of the Supreme Court, in SLP (C)
                                         15301-15305/2012, directing the State Government to
                                         obtain environmental clearance even for quarry leases of
                                         less than 5 Ha, resulted in sand quarrying activity coming
                                         to a standstill with effect from April and May 2012,
                                         which       adversely      affected     the      construction
                                         activity/industry and other developmental works, during
                                         the working season,
                                         (e)     this adverse effect, of the aforesaid judicial orders,
                                         was also noted in the OM No. 142 dated 13th October,
                                         2012 supra, whereby the Sand Mining Policy in the state
                                         of Andhra Pradesh was reviewed,
                                         (f)     the said judicial orders, therefore, constituted
                                         "Change in Law",
                                         (g)     the contention, of GMR, that the change in sand
                                         mining policy, by the Government, and the judicial
                                         orders passed by the Supreme Court and the High Court
                                         of Andhra Pradesh, constituted "change in law" was,
                                         therefore, correct,
                                         (h)     regarding the reorganisation of the State of Andhra
                                         Pradesh into the states of Andhra Pradesh and Telangana,
                                         there could be no two opinions that the said
                                         reorganisation amounted to a "Change in Law", and


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                                          (i)     the effect of such "change in law" would, however,
                                         have to be decided on the factual matrix of each case.


                                   (xlvi)        On 14th October, 2016, Sheladia wrote to NHAI, in
                                   continuation of its earlier letter dated 8th October, 2016 supra,
                                   computing the compensation, to which GMR would be
                                   entitled, were its claim for compensation, on the basis of
                                   change in law, on account of the new Sand Mining Policy and
                                   the bifurcation of the state of Andhra Pradesh, accepted by
                                   NHAI.       The computation, it was stated, was based on the
                                   approved DPR, of NHAI itself, comparing the figures therein
                                   with the actual traffic figures.      On the basis thereof, the
                                   communication estimated the compensation payable to GMR,
                                   for the financial years 2012-2013 to 2015-2016, as ₹ 185.54
                                   crores, against ₹ 229.55 crores, claimed by GMR. The balance
                                   premium, required to be paid by GMR to NHAI, for the said
                                   financial years, was also computed, in the said communication,
                                   as ₹ 136.52 crores.


                                  (xlvii) NHAI, in the meanwhile, requisitioned yet another legal
                                  opinion, regarding the claims of GMR, from M/s M. V. Kini, a
                                  well-known law firm. M/s M.V. Kini, too, provided a legal
                                  opinion, vide letter dated 7th November, 2016, opining thus:

                                         "The Concessionaire‟s claim against NHAI for
                                         payment to the storage to the same "Financial
                                         position" as it would have enjoyed had there been no
                                         such "Change in law", resulting in reduction of loss in
                                         revenue.     We therefore opined that AP State
                                         Bifurcation and substantial Amendments to AP Minor
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                                          Mineral Concession Rules, 1966 both satisfied the
                                         definition of "Change in law" in terms of Article 48,
                                         however whether the Concessionaire is entitled to
                                         release provided under Article 41.1 or not, can only be
                                         asserted by examining traffic data both prior to and
                                         post "Change in law" situations. Since it is beyond the
                                         scope of our expertise, we suggest that NHAI take a
                                         considered view and proceed with the matter. While
                                         analysing data NHAI must bear in mind Article 8 of
                                         the Concession Agreement as it needs to be strictly
                                         adhered to and no documents of material obtained by
                                         either party‟s prior to Concession Agreement (i.e. 09-
                                         10-2009) be given any credence."


                            8.    As the disputes, between GMR and NHAI, seemed incapable of
                            resolution by conciliation, or by any other means, they proceeded to
                            arbitration. C.M. Nayar, J. (retd.) and Lt. Gen. Y. P. Khurana, were
                            nominated, by GMR and NHAI, as their respective learned arbitrators.
                            As the said arbitrators were unable to arrive at a consensus regarding
                            the Presiding Arbitrator, the Indian Council of Alternative Dispute
                            Resolution (ICADR) was requested to appoint the Presiding
                            Arbitrator, in accordance with Clause 44.3.3 of the Concession
                            Agreement. The ICADR appointed Dr. Justice Arijit Pasayat (retd.)
                            as the learned Presiding Arbitrator. Thus was constituted the learned
                            Arbitral Tribunal, which came to pass the impugned Award.


                            9.    Statement of claim, Statement of Defence, Rejoinder of the
                            Claimant, i.e. GMR, and affidavits of admission/denial were filed,
                            before the learned Arbitral Tribunal, and evidence of witnesses
                            recorded. No exception has been taken, by either party before me, to
                            the procedure followed by the learned Arbitral Tribunal.

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                             10.   It is not necessary to dwell, in any detail, to the proceedings
                            before the learned Arbitral Tribunal, or even to the contentions of the
                            parties before the learned Tribunal, as they have been advanced, in
                            exhaustive detail, before me, over several days, and copious written
                            submissions have also been tendered by both parties. Suffice it to
                            state that, as NHAI was intent on proceeding, against the Escrow
                            Account of GMR, for recovering premium, allegedly due to it,
                            applications, under Section 17 of the 1996 Act were preferred, by
                            GMR, on 6th July, 2018 and, later, on 30th October, 2018, and that
                            NHAI agreed not to take any precipitate action against GMR.
                            Hearing, by the learned Arbitral Tribunal, was concluded on 2 nd
                            August, 2019, and award was reserved.             Subsequently, written
                            submissions were also filed, by GMR and NHAI, before the learned
                            Arbitral Tribunal, on 6th September, 2019.           Thereafter, on 9th
                            September, 2019, NHAI directed the IDBI Bank, as the Escrow agent
                            to remit, forthwith, to NHAI, ₹ 513.35 crores, representing the
                            allegedly outstanding premium, due from GMR till 31 st July, 2019.
                            This provoked GMR to file yet another application, under Section 17
                            of the 1996 Act, whereon the learned Arbitral Tribunal, vide order
                            dated 22nd September, 2019, restrained NHAI from taking any
                            coercive steps against GMR. IDBI, vide letter dated 27th September,
                            2019, clarified that the Escrow Account was for payment of debts, to
                            be made prior to payment of premium. In view thereof, the learned
                            Arbitral Tribunal disposed of the application, under Section 17 of the
                            1996 Act, preferred by GMR, vide order dated 7th November, 2019,
                            stating that no further orders were required to be passed on the
                            application, but reserving liberty, to GMR, to reapproach the learned
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                             Tribunal for interim directions, should occasion so arise. On 18th
                            November, 2019, NHAI invoked Article 36 of the Concession
                            Agreement, vide a Notice to GMR, seeking to immediately take over
                            operation and maintenance of the Project Highway. GMR, thereupon,
                            moved yet another application, under Section 17 of the 1996 Act,
                            before the learned Tribunal, which stayed the proposed action of
                            NHAI, vide order dated 18th November, 2019. This order was carried,
                            in appeal, by NHAI, to this Court, vide Arb A (COMM.) No. 33 of 2019,
                            which was dismissed, vide order dated 25th November, 2019. The
                            application of GMR, under Section 17 of the 1996 Act was, thereafter,
                            disposed of, by the learned Tribunal, vide order dated 9th December,
                            2019, directing GMR to pay ₹ 25 crore per month, for the next three
                            months. This order was challenged, by GMR as well as NHAI, before
                            this Court which, vide judgment dated 30th January, 2020, declined to
                            interfere with the order of the learned Arbitral Tribunal. The Supreme
                            Court was approached, thereagainst, by NHAI, vide SLP(C)
                            4107/2020, which was disposed of, by the Supreme Court, on 19 th
                            March, 2020, holding that, as the award of the learned Arbitral
                            Tribunal was scheduled to be delivered on 31st March, 2020, no
                            intervention was required.


                            11.   The impugned Award came, thus, to be rendered, by the learned
                            Arbitral Tribunal, on 31st March, 2020.


                            12.   I do not deem it necessary to advert, in detail, to the rival
                            contentions, of the parties, before the learned Arbitral Tribunal, as the
                            said contentions have been advanced, in detail, before me, and would
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                             be dealt with, at the appropriate stage(s). I proceed, therefore, to deal
                            with the findings, of the learned Arbitral Tribunal, on the issues in
                            controversy before it.


                            Issues, as framed by the learned Arbitral Tribunal


                            13.   The    "fundamental      questions",   arising    before   it   for
                            consideration, were enumerated, by the learned Tribunal, in para 220
                            of the impugned Award, thus:
                                  "(a) Whether Court orders and sand mining policies of
                                  2011-12 and 2012-13 including the ban on non-issuance of
                                  sand mining permits in the State of Andhra Pradesh (prior to
                                  bifurcation) constituted a "Change in Law" as defined in the
                                  CA?

                                  (b)    Whether the Bifurcation of the State of Andhra
                                  Pradesh into the State of Andhra Pradesh and State of
                                  Telangana constitutes a "Change in Law" (in fact NHAI
                                  accepts that Bifurcation amounts to "Change in Law" and
                                  hence it is the admitted position by the Parties insofar as
                                  Bifurcation is concerned)?

                                  (c)     Whether the Change in Law negatively impacted the
                                  commercial traffic on the Project Highway vis-à-vis the
                                  traffic numbers which have been incorporated in the Financial
                                  Model and for the earlier periods basis the Halcrow Report
                                  (as explained above)?

                                  (d)    Whether the Financial Model is to be the basis on
                                  which the impact of the "Change in Law" is to be determined
                                  for the purposes of compensation in order to put the
                                  Concessionaire back in the same position it would have been
                                  but for the "Change in Law"?

                                  (e)   Whether in view of the plain language of Clauses 41.1
                                  and 41.3 read with the definition of "Financial Model", the
                                  Respondent is estopped from disputing traffic numbers which

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                                   form the basis of the revenue streams in the Financial
                                  Model?"


                            14.   On these issues, the majority Award, passed by the learned
                            Arbitral Tribunal (per Dr Pasayat, J. and Lt. Gen. Y.P. Narula),
                            proceeds to observe, reason, and hold, as under:


                                  (i)    All other issues being purely legal in nature, the only
                                  limited question of fact, which arose for consideration, was
                                  whether the change in law, in the form of bifurcation of the
                                  State of Andhra Pradesh, resulted in lower actual commercial
                                  traffic, on the Project Highway, vis-à-vis the numbers
                                  incorporated in the Financial Model.


                                  (ii)   The toll plaza data relied on, by NHAI, in its Statement
                                  of Defence, to contend that, in fact, after bifurcation, traffic had
                                  increased in most of the toll plazas, demonstrated the following:
                                         (a)   The Project Highway fed sand reaches of the
                                         Krishna river proximate to the Project Highway to
                                         Hyderabad, the main consumption Centre for sand, prior
                                         to the bifurcation.


                                         (b)   There was substantial reduction in commercial
                                         traffic on the Project Highway, due to bifurcation and
                                         ban on interstate traffic of sand, as well as the imposition
                                         of entry tax on commercial vehicles.



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                                          (c)   After bifurcation, even while transportation to
                                         Hyderabad was banned, increased development activities
                                         were taking place within Andhra Pradesh, at places such
                                         as Vijayawada, Visakhapatnam, Guntur and other areas
                                         which developed as a result of the bifurcation.        This
                                         resulted in increased traffic, to those areas, from sand
                                         reaches proximate thereto, which did not involve the use
                                         of the Project Highway, being situated in a different
                                         direction.


                                         (d)   While refuting the claim of GMR, NHAI had
                                         disputed the applicability of Clause 41 of the Concession
                                         Agreement, to the present case, altogether. NHAI sought
                                         to contend that Clause 41 related to change in costs, etc.,
                                         on account of change in law, and did not cover losses of
                                         toll revenue, on account of reduction of traffic on the
                                         Project Highway.       Such an eventuality, according to
                                         NHAI, was covered by Article 29 of the Concession
                                         Agreement, and the various Clauses thereunder.          For
                                         ready reference, Article 29 of the Concession Agreement
                                         is reproduced, thus:
                                                                     "Article 29

                                               EFFECT OF VARIATIONS IN TRAFFIC
                                               GROWTH

                                               29.1 Effect of variations in traffic growth

                                                      29.1.l The    Authority   and   the
                                                      Concessionaire acknowledge that the
                                                      traffic as on December 1, 2019 (the
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                                                       "Target Date") is estimated to be 36666
                                                      PCUs per day (the "Target Traffic"),
                                                      and hereby agree that for determining the
                                                      modifications to the Concession Period
                                                      under this Article 29, the actual traffic on
                                                      the Target Date shall be derived by
                                                      computing the average of the traffic as
                                                      determined by traffic sampling to be
                                                      undertaken, in accordance with Clause
                                                      22.3, on the date that falls one year prior
                                                      to the Target Date, on the Target Date
                                                      and on the first anniversary of the Target
                                                      Date (the "Actual Traffic"). For the
                                                      avoidance of doubt, it is agreed that
                                                      traffic sampling shall be undertaken for a
                                                      continuous period of 7 (seven) days
                                                      during anytime within 15 (fifteen) days
                                                      prior to the date specified herein and the
                                                      average thereof shall be deemed to be the
                                                      actual traffic.

                                                      29.1.2 In the event that the Actual Traffic
                                                      shall have fallen short of the Target
                                                      Traffic by more than 2.5% (two point
                                                      five per cent) thereof or exceeded the
                                                      Target Traffic by more than 2.5% (two
                                                      point five per cent) thereof, the
                                                      Concession Period shall be deemed to be
                                                      modified in accordance with Clause 29.2.
                                                      For the avoidance of doubt, in the event
                                                      of any Dispute relating to Actual Traffic,
                                                      the Dispute Resolution Procedure shall
                                                      apply.

                                               29.2   Modification in the Concession Period

                                                      29.2.1 Subject to the provisions of
                                                      Clause 29.l.2, in the event Actual Traffic
                                                      shall have fallen short of the Target
                                                      Traffic, then for every 1% (one per cent)
                                                      shortfall as compared to the Target
                                                      Traffic, the Concession Period shall,
                                                      subject to payment of Concession Fee in
                                                      accordance with this Agreement, be
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                                                       increased by 1.5% (one point five per
                                                      cent) thereof; provided that such increase
                                                      in Concession Period shall not in any
                                                      case exceed 20% (twenty per cent) of the
                                                      Concession Period. For the avoidance of
                                                      doubt, and by way of illustration, it is
                                                      agreed that in the event of a shortfall of
                                                      10.6% (ten point six per cent) in Target
                                                      Traffic, the Concession Period shall be
                                                      increased by 15% (fifteen per cent)
                                                      thereof. 29.2.2 Subject to the provisions
                                                      of Clause 29.1.2, in the event Actual
                                                      Traffic shall have exceeded the Target
                                                      Traffic, then for every l % (one per cent)
                                                      excess as compared to the Target Traffic.
                                                      the Concession Period shall be reduced
                                                      by 0.75% (zero point seven five per cent)
                                                      thereof; provided that such reduction in
                                                      Concession Period shall not in any case
                                                      exceed l 0% (ten per cent) thereof. For
                                                      the avoidance of doubt and by way of
                                                      illustration, it is agreed that in the event
                                                      of an excess of 8.7% (eight point seven
                                                      per cent) in Target Traffic, the
                                                      Concession Period shall be reduced by
                                                      6% (six per cent) thereof:

                                                      Provided further that in lieu of a
                                                      reduction in Concession Period under
                                                      this Clause 29.2.2, the Concessionaire
                                                      may elect to pay, in addition to the
                                                      Concession Fee that would be due and
                                                      payable if the Concession Period were
                                                      not reduced hereunder, a further
                                                      premium equal to 25% (twenty five per
                                                      cent) of the Realisable Fee, and upon
                                                      notice given to this effect by the
                                                      Concessionaire no later than two years
                                                      prior to the Transfer Date contemplated
                                                      by this Clause 29.2.2, the Authority shall
                                                      waive the reduction in Concession Period
                                                      hereunder forthwith.


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                                                       29.2.3.Notwithstanding anything to the
                                                      contrary contained in this Agreement, if
                                                      the average daily traffic of PCUs in any
                                                      Accounting Year shall exceed the
                                                      designed capacity of the Project
                                                      Highway and shall continue to exceed
                                                      the designed capacity for 3 (three)
                                                      Accounting Years following thereafter,
                                                      an Indirect Political Event shall be
                                                      deemed to have occurred and the
                                                      Authority may in its discretion terminate
                                                      this Agreement by issuing a Termination
                                                      Notice and making a Termination
                                                      Payment under and in accordance with
                                                      the provisions of Clause 34.9.2; provided
                                                      that before issuing such Termination
                                                      Notice, the Authority shall inform the
                                                      Concessionaire of its intention and grant
                                                      180 (one hundred and eighty) days time
                                                      to make a representation, and may after
                                                      the expiry of such 180 (one hundred and
                                                      eighty) days period, whether or not it is
                                                      in receipt of such representation, in its
                                                      so]e discretion issue the Termination
                                                      Notice. For the avoidance of doubt, the
                                                      Parties agree that an average daily traffic
                                                      of 60000 PCUs and 90000 PCUs shall be
                                                      deemed to be the designed capacity of
                                                      the Four-Lane Project Highway and Six-
                                                      Lane Project Highway respectively.

                                                      29.2.4 If the Concessionaire shall have,
                                                      prior to issue of a Termination Notice
                                                      under Clause 29.2.3, completed the
                                                      Construction Works necessary for
                                                      augmenting the capacity of the Project
                                                      Highway such that its capacity shall have
                                                      increased sufficiently for carrying the
                                                      then current traffic in accordance with
                                                      the corresponding provisions of the
                                                      Indian Roads Congress Publication No.
                                                      IRC-64, 1990 or any substitute thereof,
                                                      the Indirect Political Event specified in
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                                                               Clause shall be deemed to have been
                                                              cured."


                                             (e)      This issue was required to be decided in the light
                                             of the definition of "change in law", as contained in
                                             Clause 48.1 of the Concession Agreement, read
                                             conjointly with Clause 1.2.1 (b) which may be
                                             reproduced thus:
                                                      "1.2.1 In this Agreement, unless the context
                                                      otherwise requires,
                                                              (b)     references to laws of India or
                                                              Indian law or regulation having the force
                                                              of law should include the laws, act,
                                                              ordinances, rules, regulations, bylaws or
                                                              notifications which have the force of law
                                                              in the territory of India and as from time
                                                              to time may be amended, modified,
                                                              supplemented, extended or re-enacted;"


                                             In view of Article 1.2.1 (b), the contention, of NHAI, that
                                             the expression "law" included only primary legislation,
                                             and did not include Rules or Regulations, was not
                                             sustainable. Reliance was also placed, in this regard, on
                                             the judgements of the Supreme Court in Energy
                                             Watchdog v. C.E.R.C.2, and of this Court in N.H.A.I. v.
                                             Hindustan Construction Co Ltd 3, N.H.A.I. v. Oriental
                                             Structure Engineers Ltd4 and N.H.A.I. v. Hindustan
                                             Construction Co Ltd5. Reckoned thus, "the amendment
                                             notification/Government Orders issued by the undivided

                            2
                              (2017) 14 SCC 80
                            3
                              Judgement dated 20th November 2011 in OMP 455/2010 and OMP 456/2011
                            4
                              Judgement dated 7th December 2013 in OMP 357/2011
                            5
                              2018 (4) Arb LR 392 (Del)
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                                          State of Andhra Pradesh and the States of Andhra
                                         Pradesh and Telangana (were) covered by clauses (b) and
                                         (d) of the definition of Change in Law".


                                         (f)   NHAI sought, further, to contend that the
                                         expression "modification", as employed in clause (b) of
                                         Article 48 of the Concession Agreement, was required to
                                         be interpreted ejusdem generis, and noscitur a sociis,
                                         with the expressions in the company of which it was
                                         found and, thus interpreted, had to be construed as "an
                                         amendment of the existing Indian Law". The changes in
                                         the Sand Mining Policy and other measures taken by the
                                         erstwhile State of Andhra Pradesh, relatable to judicial
                                         orders passed between March and November, 2012 were
                                         not, therefore, "changes in law". This plea was clearly
                                         untenable. "If that was the intention, it is not explained,
                                         as to why the expression „amendment‟ was not used and
                                         the expression „modification‟ was used."


                                         (g)   NHAI further sought to contend that statutory
                                         notifications were not covered by clause (b) of Article 48,
                                         as they already stood covered by clause (d) thereof,
                                         relating to changes in rates of taxes. The learned Arbitral
                                         Tribunal rejected this contention, in the following words:


                                               "This stand is untenable because clauses (b) and
                                               (d) envisaged different situations and it cannot
                                               be amalgamated of crystallized into one
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                                                 category. Additionally the position regarding
                                                subordinate legislation is an statutory rules as
                                                been highlighted in detail supra."


                                          (h) NHAI sought, further, to contend that the
                                          judgement of the Supreme Court, in Deepak Kumar1 did
                                          not impose any new obligation, but merely clarified the
                                          legal position. This submission, too, was not correct as,
                                          prior to the judgement, there was no obligation for
                                          obtaining environment clearance for the Sand reaches of
                                          less than 5 Ha. The said direction was issued, by the
                                          Supreme Court, in exercise of the powers conferred by
                                          Article 141 of the Constitution of India. The judgement,
                                          therefore, did bring about a "change in law".


                                          (i)   The Independent Engineer, on the basis of legal
                                          opinions, notified NHAI that there was a change in law,
                                          but that the quantum of compensation was disputable.
                                          On the position that there was, in fact, a "change in
                                          law", therefore, there was no real dispute.


                                          (j)   The attempt, of NHAI, to brush aside the opinions,
                                          of the Independent Engineer and legal experts, as not
                                          binding on it, could not sustain, as there was no
                                          document on record, to show that NHAI had ever
                                          disagreed with the said views. In fact, the opinion, of
                                          the Independent Engineer and legal experts, that a


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                                                "commodity-wise       survey"     was   necessary,    itself
                                               predicated the existence of "change in law".


                                               (k) NHAI had itself constituted a „Conciliation
                                               committee‟ of three Chief General Managers, to
                                               examine the claims of GMR, of reduction in commercial
                                               traffic carrying sand.          The constitution of this
                                               Committee, too, indicated that NHAI was of the view
                                               that there was a "change in law" situation.


                                               (l)    "Force majeure" stood defined in Dhanrajmal
                                               Gobindram v. Shamji Kalidas & Co.6, Md. Serajuddin
                                               v.    State of Orissa7 and Continental Grain Export
                                               Corpn. v. S.T.M. Grain 8, as well as in Article 34 of the
                                               Concession Agreement.


                                               (m) Apropos the question of whether Article 29 of the
                                               Concession Agreement would apply, or Article 41
                                               thereof, GMR had correctly pointed out that Article 29
                                               (2) referred to "modification in the concession period".
                                               The only sub-clause, under Article 29, which referred to
                                               financial implications, was Clause 29.2.3 (already
                                               reproduced hereinabove).




                            6
                              AIR 1961 SC 1285 : (1961) 3 SCR 1020
                            7
                              (1975) 2 SCC 47
                            8
                              [1979] 2 Lloyd's Rep 460
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                                           (n) In these facts, the principle of contra proferentem
                                          would also apply.


                                          (o) In order to buttress its stand that there had been
                                          reduction in traffic, post the Commercial Operation Date
                                          (COD), GMR stressed the following:


                                               (a)    Though the actual number of passenger
                                               vehicles, during the period 2012-2013 to 2018-
                                               2019, had increased, over the projected numbers as
                                               reckoned in the DPR as well as in the Financial
                                               Model, the number of commercial vehicles, for
                                               2018-2019, vis-à-vis the projected numbers in the
                                               DPR for the said period, had decreased. The DPR
                                               projected the traffic volume, for commercial
                                               vehicles for 2018-2019, was 11635, whereas the
                                               actual flow was 4647. In contradistinction, for the
                                               year 2012-2013, the actual commercial traffic,
                                               4499, was comparable to the projected commercial
                                               traffic, as per the DPR, of 5813.


                                               (b)    The actual commercial traffic of 4219, up to
                                               2017-2018, was significantly less than the actual
                                               commercial traffic in 2005.




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                                                (c)    NHAI had not sought to assign any reason,
                                               to justify the sharp decrease in commercial traffic,
                                               though, in non-commercial traffic, there was a rise.


                                               (d)    The     only   attributable    reason    could,
                                               therefore, be the change in law that occurs in the
                                               interregnum.


                                               (e)    The significant drop in commercial traffic
                                               was also borne out by the data of NHAI itself, for
                                               35 toll plazas in the state of Andhra Pradesh and
                                               the State of Telangana after bifurcation, of which
                                               32 toll plazas were away from the Project
                                               Highway.


                                               (f)    The reduction in commercial traffic, and
                                               consequent reduction in revenue, suffered by GMR
                                               as a result thereof, were borne out by the
                                               certificates, dated 8th January, 2018, of the statutory
                                               auditor/Chartered Accountant, which compared the
                                               category-wise projected vehicles in the Financial
                                               Model, vis-à-vis the actual number, and assessed
                                               the revenue and shortfall in revenue collection as a
                                               result thereof. The witness of GMR was not cross-
                                               examined, resulting in the correctness of the said
                                               computations     remaining      undisputed.        No
                                               alternative calculation was provided by NHAI. As
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                                                such, one of the conditions were relatable to Article
                                               41.1 had been established.

                                          (p) NHAI contended, per contra, that the traffic and
                                          revenue projections, made by GMR, in the Financial
                                          Model, were exaggerated and unrealistic and that,
                                          therefore, the submission that there had been reduction
                                          in traffic and revenue was false. It was submitted that
                                          GMR had subverted the competitive bidding process by
                                          putting a high premium and, after having secured the
                                          bid, was attempting to wriggle out of its obligation
                                          regarding payment, thereof, to NHAI. The veracity and
                                          validity of the Halcrow Report was disputed, pointing
                                          out that the said Report had been prepared prior to
                                          submission of bid, in which process NHAI had no role
                                          to play. As such, it was contended that the Halcrow
                                          Report had no contractual relevance, qua NHAI.
                                          Moreover, the Halcrow Report was not submitted to
                                          NHAI, with the Financial Model, and was tendered,
                                          belatedly,   in   2013,   to   support   the   claim    for
                                          compensation on the ground of change in law.           The
                                          Financial Model, it was further submitted, contained
                                          only the category-wise traffic numbers, without any
                                          information regarding the commodity-wise traffic. In
                                          the absence of any information regarding commodity-
                                          wise traffic, no claim for compensation could be
                                          founded solely on the Financial Model. No evidence
                                          had, it was submitted, been produced, by GMR, to
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                                           substantiate its claim that sand carrying commercial
                                          traffic had reduced to zero, on the Project Highway.
                                          Though CW-2 (Mr. Venkat Subbarao Chunduru) had
                                          referred to such a study having been conducted, no
                                          details, thereof, were forthcoming on record.


                                          (q) The claim of GMR, to compensation on the ground
                                          of reduction of vehicular traffic, was founded,
                                          principally, on the Halcrow Report, dated 22nd January,
                                          2009. The report, expressly, related to "Toll Traffic and
                                          Revenue      Forecasting   Study    for   Hyderabad       to
                                          Vijayawada Section of NH-9 in the State of Andhra
                                          Pradesh". The "Objective and Scope of Work", as set
                                          out in the Halcrow Report, was described as "estimating
                                          the tollable traffic and toll revenue on the Malkapur-
                                          Nandigama section {km 40.000 - km 221.500} of NH-9
                                          the State of Andhra Pradesh". Further, the objective of
                                          the study was stated to be "to formulate projections for
                                          the project road in the end of the concession period of
                                          25 years".     The ingredients of this objective were
                                          enumerated thus, in the Halcrow Report:

                                               "(a) Undertake traffic surveys on the highway
                                               section and its competing roads, if any, in the
                                               project influence area.

                                               (b)   To identify competing routes and analyse
                                               the networks conditions, traffic characteristics
                                               and level of tolls charged, if any on the
                                               competing corridors.

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                                                (c)    A review of past traffic data and other
                                               relevant reports as may be available.

                                               (d)  Undertake inventory of project road and
                                               competing/alternative routes, if any.

                                               (e)    Preparation of traffic projections based
                                               on above analysis for 20 years concession
                                               period.

                                               (f)    Estimation of tollable traffic streams for
                                               different categories of traffic streams paying
                                               normal and concessional toll rates.

                                               (g)    Estimation of projected toll revenue as
                                               per categories of traffic streams."

                                         Though NHAI was the custodian of all highways in the
                                         country, and had the largest database of traffic across the
                                         highways, it chose not to lead any evidence to throw any
                                         light and/or contradict the Halcrow Report. The Halcrow
                                         Report referred to actual count of existing traffic during
                                         the financial year 2008-09 including passenger cars,
                                         commercial vehicles and thereafter projected the future
                                         traffic based on normal indices including economic
                                         activities, social economic development in the area for
                                         which purpose it took an average rate of growth for
                                         passenger traffic and commercial traffic 6.1% and 6.2%
                                         respectively for a period of 25 years. Based on the traffic
                                         study for a period of 25 years and a reasonable return of
                                         16% on investment and the concession period of 25
                                         years, the consortium had offered a premium of 32.6% of
                                         Realizable Fee from the Commercial Operation Date
                                         (COD), to be augmented by 1% every year.
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                                          (r)    Clause 24.1.2 of the Concession Agreement
                                         mandated, as a condition precedent, submission of the
                                         Financial Model along with the Financing Agreement.
                                         Even prior to execution of the Financing Agreement,
                                         GMR was required to, and in fact did, provide, to NHAI,
                                         the approved Financial Model. The said clause read thus:

                                                "24.1.2       The Concessionaire shall, upon
                                                occurrence of Financial Close, notify the
                                                Authority forthwith, and shall have provided to
                                                the Authority, at least 2 (two) days prior to
                                                Financial Close, 3 (three) true copies of the
                                                Financial Package and the Financial Model,
                                                duly attested by a Director of the
                                                Concessionaire, along with 3 (three) soft copies
                                                of the Financial Model in MS Excel version or
                                                any substitute thereof, which is acceptable to the
                                                Senior Lenders."


                                          (s)   It was not, however, sufficient for GMR to
                                          establish that a change in law had occurred; it was
                                          further required to prove that, owing to such change in
                                          law, reduction of revenue had taken place, resulting in
                                          GMR suffering a substantial financial burden, entitling
                                          it to compensation under Article 41.1 and 41.3. For this
                                          purpose, GMR relied on the Halcrow Report, the views
                                          expressed by the independent engineer in its letter dated
                                          14th October, 2016, which quantified the compensation
                                          payable to GMR at ₹ 185.54 crores, and the Financial
                                          Model, which was defined in Article 48 of the
                                          Concession Agreement and which was provided, by
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                                           GMR to NHAI in terms of Clause 4.1.3 (f) thereof -
                                          which was broadly the same has Clause 24.1.2,
                                          reproduced supra. GMR had pointed out that, among
                                          the documents which were required to be filed by it,
                                          with NHAI, as conditions precedent, to be fulfilled prior
                                          to the appointed date, was the Financial Model (as per
                                          Article 4.1.3). Adoption of the Financial Model, which
                                          determined the financial viability of the project, by the
                                          Senior Lenders was, even as contemplated in the
                                          Concession Agreement, one of the prerequisites for
                                          achieving Financial Close and execution of the
                                          Financing Agreements.


                                          (t)   NHAI placed reliance on the recommendations of
                                          the Committee of CGMs, constituted by it, to examine
                                          the grievances of GMR, and the rejection, by the said
                                          Committee, of the grievances, as intimated vide letter
                                          dated 8th June, 2017. A perusal of the letter revealed
                                          that it related to GMR‟s application for deferment of
                                          premium. It baldly alleged that GMR had "deliberately"
                                          added induced traffic. It also referred to a traffic survey
                                          conducted during the period 16th to 22nd September,
                                          2015, and to the target traffic, as per Clause 29.1.1 of
                                          the Concession Agreement, on the target date of 1st
                                          December, 2019. The relevance, of these observations,
                                          to the issue of reduction of traffic due to change in law,
                                          consequent on the Sand Mining Policy, was not clear.
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                                           (u) The observation, in the communication, dated 29th
                                          September, 2016, from Sheladia, to the effect that "the
                                          DPR, for the project, did not mention the percentage of
                                          vehicles carrying sand, as it was not the general practice
                                          to mention the number of vehicles commodity-wise",
                                          was cited as a ground to discredit the Halcrow Report.
                                          This       was   unsustainable.     Merely   because   the
                                          Independent Engineer had stated that it was not the
                                          general practice to mention the number of vehicles
                                          commodity-wise, the Halcrow Report, which did so,
                                          could not be discredited.


                                          (v) Even while relying on the said observation, in the
                                          communication dated 29th September, 2016, from
                                          Sheladia, NHAI discarded the view, expressed by
                                          Sheladia itself, in its letter communication dated 8 th
                                          October, 2016, which computed compensation, in
                                          favour of GMR, by comparing the DPR with actual
                                          traffic.


                                          (w) GMR had never been informed that the approach
                                          of Sheladia was impermissible, vis-à-vis the tender
                                          conditions.


                                          (x) The reliance, by NHAI, on the affidavit of Mr. W.
                                          V. Chandra Shekar, Joint Director, Directorate of Mines
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                                           & Geology, Government of Andhra Pradesh, was also
                                          misplaced. There was no reference, in the Statement of
                                          Defence of NHAI, to any document emanating from Mr.
                                          Chandra Shekar. No such document found reference in
                                          any of the communications addressed by NHAI to
                                          GMR. As such, the statements of Mr. Chandra Shekar,
                                          in his affidavit, were merely his opinions, without any
                                          supporting factual data. The fact that he was not cross-
                                          examined could not lend any additional credibility to the
                                          said opinion.


                                          (y) The Halcrow Report could not be said to be of no
                                          relevance, as it provided the foundation of GMR‟s claim
                                          regarding reduction in traffic.     While the evidentiary
                                          value of the said Report was a different matter, it could
                                          not be contended that the report had no contractual
                                          relevance.


                                          (z)   Similar was the position with respect to the
                                          Financial Model, tendered by GMR. NHAI ought to
                                          have considered the data provided therein and,
                                          thereafter,      drawn   conclusions     regarding     the
                                          acceptability, or otherwise, of the said data. This was
                                          also not done.


                                          (aa) Following on the above discussion, the majority
                                          award, by Dr. Pasayat, J and Lt. Gen. Y.P. Narula, held
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                                           that the existence of change in law, and the entitlement,
                                          of GMR, to compensation, as a consequence thereof,
                                          could not be denied.        In rejecting the said claim,
                                          therefore, it was held that NHAI had erred. Even so, the
                                          majority Award held that the extent, to which GMR had
                                          been able to establish its claim, was required to be
                                          factually determined by taking into account all factors
                                          for adjudicating the claim. The following findings and
                                          directions were issued, in paras 292 to 296 of the
                                          majority Award, as a consequence of the above
                                          discussion:

                                               "292. Though the Tribunal is of the view that
                                               the decision of the Respondent in denying the
                                               claim is erroneous, the natural consequence is
                                               not that the Claimant's claims to be allowed. To
                                               what extent the Claimant has been able to
                                               establish its claim has to be factually
                                               determined by the Respondent by taking into
                                               account all factors for and against the claim.

                                               293. Therefore, while holding that the
                                               decision of the Respondent to deny Claimant's
                                               claims on the ground of non-consideration of
                                               relevant material/consideration of the irrelevant
                                               material and attempt to justify the denial on
                                               materials which were not considered while
                                               taking the decision is erroneous and
                                               indefensible, the Tribunal is of the view that the
                                               Respondent has to take a fresh decision.

                                               294. The Claimant when called upon by the
                                               Respondent to produce material in support of its
                                               plaint is shall be required to do so.

                                               295. Keeping in view the nature of the
                                               Contract where the figures are required to be
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                                                considered qua the target date i.e. 01.12.2019
                                               for variation of the contract period, the
                                               Respondent can call for the details and the data
                                               from the Designated Agency who provides
                                               figures in that context. That also would be
                                               relevant data for dealing with the claims of the
                                               Claimant. It would be open for the Respondents
                                               to ask the said Designated Agency for data
                                               relating to the subject period (to which the
                                               claims relate).

                                               296. The Respondent shall constitute the
                                               Committee within three weeks from today and
                                               on being notified about the Constitution of the
                                               Committee shall furnish all data, details,
                                               documents which according to have relevance
                                               and bearing to its claims. If the Respondent
                                               intends to rely on any document, material and/or
                                               data to deny such claims, needless to say it shall
                                               furnish them to the Claimant."

                            15.   C.M.    Nayar, J., penned a partly dissenting award.              While
                            agreeing with the majority Award, insofar as the entitlement, in
                            principle, of GMR, to compensation, on account of change in law that
                            had taken place, Nayar, J disagreed with the decision to remand the
                            matter, for a fresh look, to NHAI, observing that the independence and
                            impartiality of NHAI was unclear. Nayar, J observed that the learned
                            Arbitral Tribunal ought to have itself adjudicated the compensation
                            payable to GMR, or appointed an eminent body of Chartered
                            Accountant/Auditors, or of Engineers, to consider the competing
                            claims and assess the merits of the claims of GMR, on the basis of the
                            material on record. Section 26 of the 1996 Act, it was observed,
                            empowered the learned Arbitral Tribunal to do so.




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                             16.     As noted towards the commencement of this judgement, the
                            aforesaid Award, dated 31st March, 2020, has been challenged both by
                            GMR, as well as by NHAI, to the extent and on the aspects already set
                            out in para 3 supra.


                            Rival Contentions and Analysis


                            17.     I have heard detailed and elaborate arguments, by Dr. Abhishek
                            Manu Singhvi, arguing on behalf of GMR, and by the learned
                            Solicitor General, appearing on behalf of NHAI.


                            Scope of Interference


                            18.     Before proceeding to identify the issues that arise, and analyse
                            the comparative merits of submissions of learned Senior Counsel, it
                            would be appropriate to delineate the scope of interference, by this
                            Court, in exercise of its powers under Section 34 of the 1996 Act, with
                            arbitral awards, and findings returned therein.


                            19.     The Division Bench of this Court has, in N.H.A.I. v.
                            Hindustan Construction Co Ltd.9 and M.T.N.L. v. Finolex Cables
                            Ltd10, analysed several earlier decisions, of the Supreme Court, on the
                            scope of interference, under Section 34 of the 1996 Act, as rendered in
                            D.D.A. v. R.S. Sharma & Co.11, Mc Dermott International Inc. v.
                            Burn Standard Co. Ltd12, N.H.A.I. v. J.S.C. Centrodorstroy13, M.

                            9
                              2017 (5) ARBLR 258 (Delhi)
                            10
                               2017 (166) DRJ 1
                            11
                               (2008) 13 SCC 80
                            12
                               (2006) 11 SCC 81
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                             Ansuya Devi v. M. Manik Reddy14, N.H.A.I. v. I.T.D. Cementation
                            India Ltd.15 (which itself digests several earlier decisions), Swan Gold
                            Mining Ltd v.             Hindustan Copper Ltd 16, Navodaya Mass
                            Entertainment Ltd v. J.M. Combines17 and what may be regarded as
                            the high watermark of the law relating to Section 34, Associated
                            Builders v. D.D.A.18, and has, thereafter, culled out the following clear
                            principles, as emanating therefrom:

                                     "(i) The four reasons motivating the legislation of the Act,
                                     in 1996, were
                                           (a)     to provide for a fair and efficient arbitral
                                           procedure,
                                           (b)     to provide for the passing of reasoned awards,
                                           (c)     to ensure that the arbitrator does not transgress
                                           his jurisdiction, and
                                           (d)     to minimize supervision, by courts, in the
                                           arbitral process.

                                     (ii)   The merits of the award are required to be examined
                                     only in certain specified circumstances, for examining
                                     whether the award is in conflict with the public policy of
                                     India.

                                     (iii) An award would be regarded as conflicting with the
                                     public policy of India if
                                            (a)    it is contrary to the fundamental policy of Indian
                                            law, or
                                            (b)    it is contrary to the interests of India,
                                            (c)    it is contrary to justice or morality,
                                            (d)    it is patently illegal, or
                                            (e)    it is so perverse, irrational, unfair or
                                            unreasonable that it shocks the conscience of the court.



                            13
                               (2016) 12 SCC 592
                            14
                               (2003) 8 SCC 565
                            15
                               (2015) 14 SCC 21
                            16
                               (2015) 5 SCC 739
                            17
                               (2015) 5 SCC 398
                            18
                               (2015) 3 SCC 49
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                                   (iv) An award would be liable to be regarded as contrary to
                                  the fundamental policy of Indian law, for example, if
                                         (a)     it disregards orders passed by superior courts, or
                                         the binding effect thereof, or
                                         (b)     it is patently violative of statutory provisions, or
                                         (c)     it is not in public interest, or
                                         (d)     the arbitrator has not adopted a "judicial
                                         approach", i.e. has not acted a fair, reasonable and
                                         objective approach, or has acted arbitrarily,
                                         capriciously or whimsically, or
                                         (e)     the arbitrator has failed to draw an inference
                                         which, on the face of the facts, ought to have been
                                         drawn, or
                                         (f)     the arbitrator has drawn an inference, from the
                                         facts, which, on the face of it, is unreasonable, or
                                         (g)     the principles of natural justice have been
                                         violated.

                                  (v)    The "patent illegality" had to go to the root of the
                                  matter. Trivial illegalities were inconsequential.

                                  (vi)   Additionally, an award could be set aside if
                                         (a)     either party was under some incapacity, or
                                         (b)     the arbitration agreement is invalid under the
                                         law, or
                                         (c)     the applicant was not given proper notice of
                                         appointment of the arbitrator, or of the arbitral
                                         proceedings, or was otherwise unable to present his
                                         case, or
                                         (d)     the award deals with a dispute not submitted to
                                         arbitration, or decides issues outside the scope of the
                                         dispute submitted to arbitration, or
                                         (e)     the composition of the Arbitral Tribunal was not
                                         in accordance with the agreement of the parties, or in
                                         accordance with Part I of the Act, or
                                         (f)     the arbitral procedure was not in accordance
                                         with the agreement of the parties, or in accordance
                                         with Part I of the Act, or
                                         (g)     the award contravenes the Act, or
                                         (h)     the award is contrary to the contract between the
                                         parties.

                                  (vii) "Perversity", as a ground for setting aside an arbitral
                                  award, has to be examined on the touchstone of the
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                                    Wednesbury principle of reasonableness. It would include a
                                   case in which
                                          (a)    the findings, in the award, are based on no
                                          evidence, or
                                          (b)    the Arbitral Tribunal takes into account
                                          something irrelevant to the decision arrived at, or
                                          (c)    the Arbitral Tribunal ignores vital evidence in
                                          arriving at its decision.

                                   (viii) At the same time,
                                          (a)    a decision which is founded on some evidence,
                                          which could be relied upon, howsoever compendious,
                                          cannot be treated as "perverse",
                                          (b)    if the view adopted by the arbitrator is a
                                          possible view, it has to pass muster,
                                          (c)    neither quantity, nor quality, of evidence is open
                                          to re-assessment in judicial review over the award.

                                   (ix) "Morality" would imply enforceability, of the
                                   agreement, given the prevailing mores of the day.
                                   "Immorality", however, can constitute a ground for
                                   interfering with an arbitral award only if it shocks the judicial
                                   conscience.

                                   (x)    For examining the above aspects, the pleadings of the
                                   parties and materials brought on record would be relevant.

                                   (xi) The court cannot sit in appeal over an arbitration
                                   award. Errors of fact cannot be corrected under Section 34.
                                   The arbitrator is the last word on facts."


                            20.    A point which, at times, courts tend to overlook, despite the
                            afore-quoted decisions of the Supreme Court having reiterated it, time
                            and again, is that, even on questions of law, the arbitrator, or the
                            arbitral tribunal, is the final word, absent, in its findings in that regard,
                            perversity or "patent illegality". Patent illegality may be said to exist,
                            in the interpretation of the law, by the arbitrator, only where such
                            interpretation is, ex facie, erroneous as well as unacceptable, and not

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                             The court is concerned with the possibility of the view expressed by
                            the arbitrator, and not the plausibility thereof. Absent impossibility,
                            implausibility, ordinarily, is no ground to set aside, or interfere with,
                            an arbitral award, under Section 34 of the 1996 Act. One of the rare
                            cases where the rigour of this principle has been relaxed, it may be
                            noted for the sake of clarity, is to be found in N.H.A.I. v.
                            Progressive-MVR (JV)19, which advocated exercise of jurisdiction, by
                            the High Court, under Section 34, even where the view taken by the
                            arbitrator was possible, in a situation in which different arbitrators,
                            interpreting like provisions in different contracts entered into, by the
                            NHAI across the country, were adopting different interpretations.
                            Needless to say, no such exigency exists, in the present case.


                            21.     The position stands further underscored by the following
                            passages, from Dyna Technologies Pvt Ltd v. Crompton Greaves
                            Ltd20 (which were reiterated in South East Asia Marine Engineering
                            and Constructions Ltd v. Oil India Ltd 21):

                                    "26. There is no dispute that Section 34 of the Arbitration
                                    Act limits a challenge to an award only on the grounds
                                    provided therein or as interpreted by various Courts. We need
                                    to be cognizant of the fact that arbitral awards should not be
                                    interfered with in a casual and cavalier manner, unless the
                                    Court comes to a conclusion that the perversity of the award
                                    goes to the root of the matter without there being a possibility
                                    of alternative interpretation which may sustain the arbitral
                                    award. Section 34 is different in its approach and cannot be
                                    equated with a normal appellate jurisdiction. The mandate
                                    under Section 34 is to respect the finality of the arbitral award
                                    and the party autonomy to get their dispute adjudicated by an

                            19
                               (2018) 14 SCC 688
                            20
                               2019 SCC OnLine SC 1656
                            21
                               2020 SCC OnLine SC 451
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                                        alternative forum as provided under the law. If the Courts
                                       were to interfere with the arbitral award in the usual course on
                                       factual aspects, then the commercial wisdom behind opting
                                       for alternate dispute resolution would stand frustrated.

                                       27.    Moreover, umpteen number of judgments of this Court
                                       have categorically held that the Courts should not interfere
                                       with an award merely because an alternative view on facts
                                       and interpretation of contract exists. The Courts need to be
                                       cautious and should defer to the view taken by the Arbitral
                                       Tribunal even if the reasoning provided in the award is
                                       implied unless such award portrays perversity unpardonable
                                       under Section 34 of the Arbitration Act."

                            22.        Paras 11, 12, 14, 15 and 16 of the report in M.M.T.C. Ltd v.
                            Vedanta Ltd.22 are also relevant, in this context:

                                       "11. As far as Section 34 is concerned, the position is well-
                                       settled by now that the Court does not sit in appeal over the
                                       arbitral award and may interfere on merits on the limited
                                       ground provided under Section 34(2)(b)(ii) i.e. if the award is
                                       against the public policy of India. As per the legal position
                                       clarified through decisions of this Court prior to the
                                       amendments to the 1996 Act in 2015, a violation of Indian
                                       public policy, in turn, includes a violation of the fundamental
                                       policy of Indian law, a violation of the interest of India,
                                       conflict with justice or morality, and the existence of patent
                                       illegality in the arbitral award. Additionally, the concept of
                                       the "fundamental policy of Indian law" would cover
                                       compliance with statutes and judicial precedents, adopting a
                                       judicial approach, compliance with the principles of natural
                                       justice, and Wednesbury [Associated Provincial Picture
                                       Houses v. Wednesbury Corpn., (1948) 1 KB 223 (CA)]
                                       reasonableness. Furthermore, "patent illegality" itself has
                                       been held to mean contravention of the substantive law of
                                       India, contravention of the 1996 Act, and contravention of the
                                       terms of the contract.

                                       12.    It is only if one of these conditions is met that the
                                       Court may interfere with an arbitral award in terms of Section
                                       34(2)(b)(ii), but such interference does not entail a review of
                            22
                                 (2019) 4 SCC 163
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                                   the merits of the dispute, and is limited to situations where the
                                  findings of the arbitrator are arbitrary, capricious or perverse,
                                  or when the conscience of the Court is shocked, or when the
                                  illegality is not trivial but goes to the root of the matter. An
                                  arbitral award may not be interfered with if the view taken by
                                  the arbitrator is a possible view based on facts. (See Associate
                                  Builders v. DDA, (2015) 3 SCC 49 : (2015) 2 SCC (Civ) 204.
                                  Also see ONGC Ltd. v. Saw Pipes Ltd., (2003) 5 SCC 705;
                                  Hindustan Zinc Ltd. v. Friends Coal Carbonisation, (2006)
                                  4 SCC 445; and McDermott International Inc. v. Burn
                                  Standard Co. Ltd., (2006) 11 SCC 181)

                                                            *****

                                  14.    As far as interference with an order made under
                                  Section 34, as per Section 37, is concerned, it cannot be
                                  disputed that such interference under Section 37 cannot travel
                                  beyond the restrictions laid down under Section 34. In other
                                  words, the court cannot undertake an independent assessment
                                  of the merits of the award, and must only ascertain that the
                                  exercise of power by the court under Section 34 has not
                                  exceeded the scope of the provision. Thus, it is evident that in
                                  case an arbitral award has been confirmed by the court under
                                  Section 34 and by the court in an appeal under Section 37,
                                  this Court must be extremely cautious and slow to disturb
                                  such concurrent findings.

                                  15.     Having noted the above grounds for interference with
                                  an arbitral award, it must now be noted that the instant
                                  question pertains to determining whether the arbitral award
                                  deals with a dispute not contemplated by or not falling within
                                  the terms of the submission to arbitration, or contains
                                  decisions on matters beyond the scope of the submission to
                                  arbitration. However, this question has been addressed by the
                                  courts in terms of the construction of the contract between the
                                  parties, and as such it can be safely said that a review of such
                                  a construction cannot be made in terms of reassessment of the
                                  material on record, but only in terms of the principles
                                  governing interference with an award as discussed above.

                                  16.    It is equally important to observe at this juncture that
                                  while interpreting the terms of a contract, the conduct of
                                  parties and correspondences exchanged would also be
                                  relevant factors and it is within the arbitrator's jurisdiction to
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                                      consider the same. [See Mc Dermott International Inc. v.
                                     Burn Standard Co. Ltd., (2006) 11 SCC 181; Pure Helium
                                     India (P) Ltd. v. ONGC, (2003) 8 SCC 593 and D.D. Sharma
                                     v. U.O.I., (2004) 5 SCC 325]"


                            23.      The peripheries of Section 34 stand, thereby, well-demarcated.


                            Issues


                            24.      Fundamentally, the following specific issues may be delineated,
                            as arising for consideration in the present case, both before the learned
                            Arbitral Tribunal, as well as before this Court:


                                     (i)    The first issue is whether "change in law" had taken
                                     place, within the meaning of the expression as defined in Clause
                                     48 of the Concession Agreement. The learned Arbitral Tribunal
                                     has answered this issue in the affirmative, holding that the
                                     change in the Sand Mining Policy, as introduced vide various
                                     GOMs issued by the states of Andhra Pradesh and Telangana,
                                     as well as the bifurcation of the state of Andhra Pradesh into the
                                     states of Andhra Pradesh and Telangana, were both events
                                     which resulted in "change in law". NHAI has disputed this
                                     finding.


                                     (ii)   The second issue is whether Article 28, or Article 41, of
                                     the Concession Agreement, applies in the present case. The
                                     learned Arbitral Tribunal has held that Article 41 applies and
                                     that, by virtue of Clauses 41.1 and 41.3 thereof, GMR is entitled
                                     to compensation.     NHAI contends, in its challenge under
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                                   Section 34 of the 1996 Act, that Article 41 has no application at
                                  all, and that, even if it were to be assumed that there had been a
                                  fall in commercial traffic, that exigency stood covered by
                                  Article    28,    whereunder     no    provision    for     awarding
                                  compensation, to GMR, existed.


                                  (iii)   The third issue is the extent, if at all, to which GMR has
                                  suffered financial prejudice, as a consequence of the aforesaid
                                  "change in law". The learned Tribunal has not pronounced on
                                  this issue, holding that the extent to which GMR has been able
                                  to establish its claim would have to be factually determined.
                                  While, on the first and second issues aforesaid, the majority,
                                  and minority, awards, are ad idem, on this third issue, there is a
                                  difference of view, of the learned dissenting arbitrator, vis-à-vis
                                  the view of the majority. While the majority Award directs
                                  GMR       to   establish,   before    NHAI,   its   entitlement     to
                                  compensation, under Clause 41.1 and 41.3 of the Concession
                                  Agreement, the dissenting Award opines that, instead of
                                  allowing NHAI to adjudicate thereon, the exercise ought to be
                                  delegated to an independent authority, such as a reputed firm of
                                  Chartered Accountants, or the like. This third issue does not
                                  impact the petition, under Section 34 of the 1996 Act, filed by
                                  NHAI (O.M.P. (COMM.) 426/2020), as NHAI questions the
                                  very entitlement, of GMR, to compensation. The petition of
                                  GMR, under Section 34 (O.M.P. (COMM.) 425/2020),
                                  however, is concerned only with the third issue, with GMR


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                                   contending that the minority Award deserves acceptance, in
                                  preference to the majority Award.


                            Addressing the issues, seriatim


                            Was there "change in law"?


                            25.   The definition of the expression "change in law", as contained
                            in Clause 48 of the Concession Agreement, has already been
                            reproduced in sub-para (xvii) of para 7 supra.


                            26.   The findings of the learned Arbitral Tribunal, on this aspect, are
                            to be found in paras 232, 233 and 238 to 242 of the impugned Award,
                            which are, therefore, reproduced, in extenso, thus:

                                  "232. The said Article defines "Applicable Laws" to mean
                                  all laws, brought into force and effect by GOI or the State
                                  Government including rules, regulations and notifications
                                  made thereunder, and judgments, decrees, injunctions, writs
                                  and orders of any court of record, applicable to this
                                  Agreement and the exercise, performance and discharge of
                                  the respective rights and obligations of the Parties hereunder,
                                  as may be in force and effect during the subsistence of this
                                  Agreement.

                                  233. Article 48 has to be read conjointly with Article 1.2.1
                                  (b) which provides that references to laws of India or Indian
                                  law or regulation having the force of law shall include the
                                  laws, acts, ordinances, rules, regulations, bye laws or
                                  notifications which have the force of law in the territory of
                                  India and as from time to time may be amended, modified,
                                  supplemented, extended or re-enacted.

                                                              *****

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                                   238. As noted supra, sub-articles (a), (c) and (d) deal with
                                  enactment of any new Indian law, commencement of any
                                  Indian law which has not entered into effect until the date of
                                  bid and a change in the interpretation of application of any
                                  Indian law by a judgment which has become final, conclusive
                                  and binding as compared to such interpretation or application
                                  prior to the date of the bid, by a court of record. The
                                  amendment notifications / Govt Orders issued by the
                                  undivided State of Andhra Pradesh and the States of Andhra
                                  Pradesh and Telangana are covered by clauses (b) and (d) of
                                  the definition of Change in Law.

                                  239. It is emphasized by the Respondent that the changes in
                                  Sand Mining Policy and other measures taken by the
                                  erstwhile State of Andhra Pradesh on account of court order
                                  etc. from March - April 2012 to November 2012 are not
                                  covered by the definition of Change in Law because no act
                                  either by the State Legislative Assembly or the Parliament
                                  was enacted. The expression "modification" has to be
                                  interpreted by application of the principles of "ejusdem
                                  generis" and the doctrine of "noscitur-a-socis". Modification
                                  of any "existing Indian law" has to be construed as "an
                                  amendment of an existing Indian law". This plea is clearly
                                  untenable. If that was the intention, it is not explained, as to
                                  why the expression "amendment" was not used and the
                                  expression "modification" was used. The further stand that
                                  the subordinate legislations in the form of statutory
                                  notifications are not covered under (b) as that is already
                                  covered by (d) relating to change in rates of taxes. This stand
                                  is untenable because clauses (b) and (d) envisaged different
                                  situations and it cannot be amalgamated or crystallized into
                                  one category. Additionally the position regarding subordinate
                                  legislations and statutory rules has been highlighted in detail
                                  supra.

                                  240. Coming to the stand of the Respondent that the
                                  decision in Deepak Kumar v. State of Haryana, (2012) 4
                                  SCC 629 was only clarifying the position in law and did not
                                  impose new obligations needs to be considered in the
                                  background of what was the effect of the judgment. Prior to
                                  the judgment, there was no obligation for obtaining
                                  environment clearance for sand reaches of less than 5
                                  hectares. This direction was given in exercise of powers under
                                  Article 141 of the Constitution of India, 1950 (in short "the
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                                   Constitution"). Prior to this judgment, sand reaches of less
                                  than 5 hectares did not require any environmental clearance
                                  and, therefore, sand reaches of less than 5 hectares did not
                                  require obtaining of environmental clearance and such
                                  clearances were not being taken. Post Deepak Kumar‟s case
                                  that was required to be taken. Therefore, Deepak Kumar‟s
                                  judgment brought about a situation which is covered under
                                  the definition of Change in Law. The consequential directions
                                  given by the Hon‟ble Andhra Pradesh High Court reiterating
                                  the directions of the Hon‟ble Supreme Court in Deepak
                                  Kumar‟s case amounted to and constituted Change in Law.

                                  241. It has been emphasized by the Claimant that the
                                  Respondent changed its position after initiation of arbitration
                                  proceedings though prior to that, Independent Engineer acting
                                  on its behalf and the Respondent itself accepted the position
                                  that orders of the Hon‟ble Supreme Court and amendments to
                                  the Andhra Pradesh Miner Mineral Concession Rules
                                  constituted a Change in Law under the Concession
                                  Agreement. Referring to a decision of the Hon‟ble Supreme
                                  Court in Godhra Electricity Co. Ltd. v. State of Gujarat,
                                  (1975) 1 SCC 199, it is submitted that such interpretation
                                  which has been consistently applied should be determinative.

                                  Emphasis is made on para 11 of the decision which reads as
                                  follows:

                                         "11. In the process of interpretation of the terms
                                         of a contract, the court can frequently get great
                                         assistance from the interpreting statements
                                         made by the parties themselves or from their
                                         conduct in rendering or in receiving
                                         performance under it. Parties can, by mutual
                                         agreement, make their own contracts; they can
                                         also by mutual agreement remake them. The
                                         process of practical interpretation application,
                                         however, is not regarded by the parties as a
                                         remaking of the contract; nor do the courts so
                                         regard it. Instead, it is merely further expression
                                         by the parties of the meaning that they give and
                                         have given to the terms of their contract
                                         previously made. There is no good reason why
                                         the courts should not give great weight to these
                                         further expressions by the parties, in view of the
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                                          fact that they still have the same freedom of
                                         contract that they had originally. The American
                                         Courts receive subsequent actions as admissible
                                         guides in interpretation. It is true that one party
                                         cannot build up his case by making an
                                         interpretation in his own favour. It is the
                                         concurrence therein that such a party can use
                                         against the other party. This concurrence may
                                         be evidenced by the other party‟s express assent
                                         thereto by his acting in accordance with it, by
                                         his receipt without objection of performances
                                         that indicate it, or by saying nothing when
                                         knows that the first party is acting on reliance
                                         upon the interpretation (see Corbin on contracts,
                                         Vol.III, pp.249 and 254-55)".

                                  242. Another factor which assumes importance is that the
                                  Independent Engineer on the basis of legal opinions clearly
                                  notified the Respondent that there was a Change in Law
                                  situation but the dispute was only relating to quantum of
                                  compensation. As rightly contended by learned counsel for
                                  the Claimant, the first aspect was never disputed and on the
                                  other hand was being accepted all through that there was a
                                  Change in Law situation. "


                            27.   Neither before the learned Arbitral Tribunal, nor before this
                            Court, has NHAI sought to urge that the bifurcation of the state of
                            Andhra Pradesh, into the states of Andhra Pradesh and Telangana, and
                            the enactment of the Andhra Pradesh Reorganisation Act, 2014, did
                            not constitute "change in law". It was, however, seriously contended,
                            by NHAI, that the introduction of new Sand Mining Policies, and the
                            change in the existing Sand Mining Policy, by the various GOMs
                            issued by the States of Andhra Pradesh and Telangana, from time to
                            time, as also the judgement of the Supreme Court in Deepak Kumar1
                            did not constitute "change in law". The manner in which the learned


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                             Arbitral Tribunal has interpreted the expression "change in law" has,
                            therefore, been criticised, by NHAI, as perverse.


                            28.   "Change in law", as defined in Article 48 of the Concession
                            Agreement, it is sought to be contended by NHAI, was intended to
                            cover only "primary legislation", by way of statute, subordinate
                            legislation being included within the ambit of the said definition only
                            to the extent it related to taxation. It is sought to be contended that, if
                            changes introduced by subordinate legislation were to be included
                            within the ambit of the definition of "change in law", there would be
                            no necessity for sub-clause (e) in Clause 48.1 of the Concession
                            Agreement which would, therefore, be reduced to a redundancy - or,
                            more appropriately, a superfluity. The expression "existing Indian
                            Law", as employed in sub-clause (b) of Clause 48.1, it is contended,
                            refers only to primary legislation. The expression "modification", as
                            employed in the same sub-clause, equivalently, it is sought to be
                            contended, is to be read as "amendment". Reference has also been
                            made, in the written submissions filed by NHAI, to certain judicial
                            authorities - which, incidentally, found "change in law" to have, in
                            fact, taken place in those cases - to contend that the said cases related
                            to primary legislation. NHAI would seek to contend, by relying on
                            the said decisions, that, where the instrument in question was not
                            "primary legislation", it could not be said to result in "change in law".
                            In a somewhat contradictory vein, it is also sought to be contended, by
                            NHAI, in its written submissions, that the learned Arbitral Tribunal
                            erred in relying on judicial decisions to understand the expression


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                             "change in law", as the said expression stands defined in Clause 48.1
                            of the Concession Agreement.


                            29.     To my mind, no exception, whatsoever, can be taken, to the
                            findings, of the learned Arbitral Tribunal, as contained in the paras
                            extracted hereinabove, to the effect that the judgement of the Supreme
                            Court in Deepak Kumar1, and the change in the Sand mining policy,
                            as it occurred from time to time by the issuance of various GOMs by
                            the states of Andhra Pradesh and Telangana, constituted "change in
                            law".    I do not find, in the Concession Agreement, anything to
                            indicate, either expressly or by necessary implication, that the
                            expression "existing Indian Law" has necessarily to be limited to
                            "primary legislation", and would not embrace subordinate legislation,
                            or executive orders having the force of law. Nor do I find any basis
                            for the submission, of NHAI, that the expression "modification", as
                            used in sub-clause (b) of Clause 48.1, has to be read as "amendment".
                            It is hardly necessary to cite any authority, for the proposition that the
                            exercise of interpretation of the covenants of a contractual document
                            cannot, at any time, extend to modification, or rewriting thereof.


                            30.     I agree with the submission, of the learned Solicitor General,
                            articulated on behalf of NHAI, that, in view of the express definition
                            of the expression "change in law", as contained in Clause 48.1 of the
                            Concession Agreement, no recourse is needed, to any judicial
                            authority, which interprets the said expression. At the same time, the
                            expression "existing Indian Law", as used in the said sub-clause, does
                            not find definition in the Concession Agreement. To my mind, it is
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                             axiomatic that the judgement in Deepak Kumar1 constitutes "law",
                            and one need look no further, for this, than Article 141 of the
                            Constitution of India. It cannot be denied that, by the said judgement,
                            sand mining, over areas of less than 5 Ha, were held to require
                            environmental clearance. It is also not denied that, prior to the said
                            decision, this requirement did not exist. That the judgement of the
                            Supreme Court in Deepak Kumar1 resulted in a "change in law"
                            cannot, therefore, in my view, be denied.


                            31.   Equally, the resultant interim orders, dated 21st March, 2012, of
                            the High Court of Andhra Pradesh, and the order, dated 7 th May, 2012,
                            of the Supreme Court in SLP (C) 15301-15305/2012 in Annam
                            Sivaiah (supra), which specifically directed the State Government to
                            require obtaining of environmental clearance even for mining areas of
                            less than 5 Ha, obviously, constituted "law", and resulted in a change
                            in the then existing law. The GOMs, dated 13th October, 2012 and
                            15th November, 2012, having been issued in compliance of the
                            directives of the Supreme Court, equally, therefore, constituted "law".
                            If at all it was required, one may refer, in this context, to clause (29) in
                            Section 3 of the General Clauses Act, 1897, which defines "Indian
                            Law" to mean any "Act, Ordinance, regulation, rule, order or bye-law
                            which, before the commencement of the Constitution had the force of
                            law in any Province of India or part thereof and hereafter has the force
                            of law in any Part A State Part C State or part thereof, but does not
                            include any Act of Parliament of the United Kingdom or any Order in
                            Council, rule or other instrument made under such Act." Referring to
                            the said provision, it was held, by the High Court of Madhya Pradesh,
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                             in State of Madhya Pradesh v. Ramcharan 23, that "under our legal
                            order „law‟ does not include only legislative enactment is but it also
                            includes rules, orders, notifications etc. made or issued by the
                            Government or any subordinate authority in the exercise of dedicated
                            legislative power." At the same time, purely administrative orders,
                            not issued in exercise of any statutory authority, were held, in
                            Jayantilal Amratlal v. F. N. Rana24, not to constitute "law". These
                            decisions stand noted, and approved, by the Supreme Court in Sudhir
                            Shantilal Mehta v. C.B.I.25. It has not been contended, by NHAI, that
                            the GOMs, issued by the States of Andhra Pradesh and Telangana,
                            were devoid of any statutory authority, so as to stand excluded from
                            the ambit of the expression "Indian Law".


                            32.     The submission, of NHAI, that subordinate legislation, or
                            executive orders, would tantamount to "Indian Law", for the purposes
                            of Clause 48.1 of the Concession Agreement, only to the extent they
                            fall within sub-clause (e) thereof, i.e. they relate to rates of taxes, too,
                            fails to impress. Indeed, there is no reference, in sub-clause (e), either
                            to subordinate legislation, or to any executive orders or instructions.
                            If such subordinate legislation, or executive instructions, to the extent
                            they change the rates of taxes, applicable to the Project, were to be
                            included within the expression "change in law", by invocation of sub-
                            clause (e) of Clause 48.1, I see no reason why such subordinate
                            legislation, or executive instructions, issued in exercise of statutorily



                            23
                               AIR 1977 MP 68
                            24
                               AIR 1964 SCC 648: 1964 (5) SCR 294
                            25
                               (2009) 8 SCC 1
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                             conferred powers and authority, would not qualify as "Indian Law",
                            for the purposes of sub-clause (b) of Clause 48.1.


                            33.   Nor am I convinced with the contention, of NHAI, that
                            extending the scope of sub-clause (b) of Clause 48.1, to GOMs, issued
                            by the states of Andhra Pradesh and Telangana, and to the
                            modification and change of the Sand Mining Policy affected thereby,
                            would result in sub-clause (e) being rendered superfluous or
                            redundant.   Sub-clause (e) of Clause 48.1 deals with a specific
                            exigency, i.e. change of taxes, having a direct impact on the project.
                            The mere fact that Clause 48.1 may have chosen to specify this
                            exigency by way of a separate category thereunder, i.e. sub-clause (e)
                            cannot, in my view, detract from the ambit and scope of sub-clause
                            (b). The principle against tautology, often invoked while interpreting
                            legislative instruments, does not, necessarily, apply to covenants in
                            contractual documents, and instances where clauses have been
                            engrafted, in a contract, ex abundanti cautela, are not unknown.


                            34.   In any event, it is obvious that the reasoning of the learned
                            Arbitral Tribunal, as contained in the passage as extracted
                            hereinabove, cannot be said to suffer from any legal infirmity, as
                            would justify interference by this Court, in exercise of its limited
                            jurisdiction, under Section 34 of the 1996 Act. The issue is purely one
                            of law, and of interpretation of Clause 48.1 of the Concession
                            Agreement. The learned Arbitral Tribunal has interpreted the clause
                            to hold that the change in the Sand Mining Policy, as effected by the
                            GOMs issued by the States of Andhra Pradesh and Telangana from
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                             time to time, and the bifurcation of the state of Andhra Pradesh,
                            constituted "change in law", within the meaning of the said Clause.
                            No case, for interference therewith, under Section 34 of the 1996 Act,
                            can be said to exist.


                            Re. Clause 41.1


                            35.   The learned Arbitral Tribunal has held the reduction in
                            commercial traffic, consequent on the restrictions and prohibitions,
                            imposed on Sand mining, by the aforesaid "change in law" incidents,
                            to justify invocation, by GMR, of Clause 41.1 and 41.3 of the
                            Concession Agreement, and the rejection, by NHAI, of the claim of
                            GMR, under the said heads, to be unjustified. It is also categorically
                            observed, in para 257 of the impugned Award, that NHAI had "not ...
                            clarified how increasing cost is the only operated expression", in
                            Article 41.


                            36.   A plain reading of Clause 41.1 of the Concession Agreement
                            discloses that it applies, expressly, where "as a result of Change in
                            Law, the Concessionaire suffers an increase in costs or reduction in
                            net after-tax return or other financial burden". Though NHAI sought
                            to contend, before the learned Arbitral Tribunal - as it has sought to
                            contend, before this Court as well - that this Clause was intended to
                            apply only where the change in law had resulted in increase in costs,
                            to the concessionaire. The submission, quite obviously, flies in the
                            face of the wording of the Clause itself.     Acceptance of the said
                            submission would render the words "or reduction in net after-tax
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                             return or other financial burden", especially the words "or other
                            financial burden", otiose. On this aspect, the learned Solicitor General
                            sought to contend that the words "reduction in net after-tax return"
                            could not be equated with "reduction in revenue", and dealt, instead,
                            solely with a situation of increase in cost, or other expenditure, which
                            the concessionaire, i.e. GMR, had to suffer as a result of the change in
                            law. Equally, it was submitted, the words "other financial burden"
                            related to financial liability on account of increase in cost and
                            expenditure.   These words, submits the learned Solicitor General,
                            were required to be interpreted noscitur a sociis with the words
                            "increase in cost" and "reduction in net after-tax return".         Thus
                            interpreted, submits the learned Solicitor General, the words "other
                            financial burden" would also require, for their application, increase in
                            costs incurred by GMR. Any other interpretation, contends NHAI,
                            would result in an "over expansionist" construction being extended, to
                            Clause 41.1, which would, in turn, result in GMR becoming insured
                            against any kind of financial loss, or hardship, suffered by it,
                            irrespective of the cause thereof. It is submitted that Clause 41.1
                            could never have been intended to provide such an omnibus insurance
                            to GMR, for all financial constraints suffered by it. Reliance was also
                            placed, by the learned Solicitor General, in this context, on the
                            heading of Clause 41.1, which reads "increase in costs".


                            37.   Adverting to this last contention first, the learned Tribunal has,
                            in para 257 of the impugned Award, dwelt, at some length, on the
                            inadvisability of limiting the construction of Clause 41.1, on the basis
                            of its heading. Certain judicial authorities have also been cited, in this
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                             context. In my opinion, the finding of the learned Arbitral Tribunal is
                            obviously unexceptionable, and no reference, to any judicial authority,
                            is necessary in this regard. As is apparent from a plain reading, while
                            the heading of Clause 41.1 read "Increase in costs", the clause itself
                            refers to "increase in costs or reduction in net after-tax return or other
                            financial burden". Where the words used in the clause are, on their
                            face, broader than the heading, it is obviously impermissible to limit
                            the words in the clause, on the basis of the heading. To reiterate, if the
                            submission of NHAI, in this regard, is to be accepted, it would result
                            in rendering, completely redundant, the words "or reduction in net
                            after-tax return or other financial burden", in Clause 41.1.


                            38.   That apart, the claim of GMR would, in my opinion, sustain,
                            even on the anvil of "increase in costs", to which NHAI would crave
                            limitation of Clause 41.1. I would deal with this aspect a little later.


                            39.   For the present, the words "other financial burden", as
                            employed in Clause 41.1, are, in my view, expansive and
                            comprehensive in equal measure, and would encompass any kind of
                            financial burden, to which GMR would be subjected, as a
                            consequence of the "change in law". I do not deem it necessary to
                            discuss, at any length, the etymological connotations of the expression
                            "financial burden", as they are well understood. NHAI has, however,
                            sought to invoke, as noted above, the noscitur a sociis doctrine, to
                            limit the ambit of the expression "other financial burden", to
                            "financial burden" akin to "increase in cost" or "reduction in net after-
                            tax return". Thus viewed, submits NHAI, mere reduction in revenue
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                             realisation, consequent to decrease in traffic, would not qualify as
                            "other financial burden", for the purposes of Clause 41.1.


                            40.        The reliance, by NHAI, on the noscitur a sociis principle is, in
                            my view, fundamentally unsound. It is axiomatic that the recourse, to
                            interpretative aids, to understand provisions of the statute, or contract,
                            is justified - and, indeed, is necessary - only where the provision does
                            not admit of interpretation, plainly read, or presents ambiguous
                            choices.         There is no ambiguity, in my view, in the expression
                            "increase in costs or reduction in net after-tax return or other financial
                            burden". The intention, of the framers of the contract, in using the
                            expression "other financial burden" is, quite clearly, to encompass all
                            financial burdens, as would befall the concessionaire, as it would be
                            impossible to predict, in anticipation, the possible adverse financial
                            consequences which could befall the concessionaire, consequent to
                            "change in law", even before the law has changed. The expression
                            "other financial burden" does not, etymologically, admit of more than
                            one interpretation. It would be folly to employ the noscitur a sociis
                            principle to deliberately constrict the scope of an expression of words
                            of wide import, consciously used. The following words, from State of
                            Bombay v. Hospital Mazdoor Sabha26 explain the concept thus:

                                       "It is, however, contended that, in construing the definition,
                                       we must adopt the rule of construction noscuntur a sociis.
                                       This rule, according to Maxwell, means that, when two or
                                       more words which are susceptible of analogous meaning are
                                       coupled together they are understood to be used in their
                                       cognate sense. They take as it were their colour from each
                                       other, that is, the more general is restricted to a sense

                            26
                                 AIR 1960 SC 610:1960 (2) SCR 866
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                                   analogous to a less general. The same rule is thus interpreted
                                  in Words and Phrases (Vol. XIV, p. 207): "Associated words
                                  take their meaning from one another under the doctrine
                                  of noscuntur a sociis the philosophy of which is that the
                                  meaning of a doubtful word may be ascertained by reference
                                  to the meaning of words associated with it; such doctrine is
                                  broader than the maxim Ejusdem Generis." In fact the latter
                                  maxim "is only an illustration or specific application of the
                                  broader maxim noscuntur a sociis". The argument is that
                                  certain essential features or attributes are invariably
                                  associated with the words "business and trade" as understood
                                  in the popular and conventional sense, and it is the colour of
                                  these attributes which is taken by the other words used in the
                                  definition though their normal import may be much wider.
                                  We are not impressed by this argument. It must be borne in
                                  mind that noscuntur a sociis is merely a rule of construction
                                  and it cannot prevail in cases where it is clear that the wider
                                  words have been deliberately used in order to make the scope
                                  of the defined word correspondingly wider. It is only where
                                  the intention of the legislature in associating wider words
                                  with words of narrower significance is doubtful, or otherwise
                                  not clear that the present rule of construction can be usefully
                                  applied. It can also be applied where the meaning of the
                                  words of wider import is doubtful; but, where the object of the
                                  legislature in using wider words is clear and free of
                                  ambiguity, the rule of construction in question cannot be
                                  pressed into service. As has been observed by Earl of
                                  Halsbury, L.C., in Corporation of Glasgow v. Glasgow
                                  Tramway and Omnibus Co. Ltd. [(1898) AC 631 at p. 634]
                                  in dealing with the wider words used in Section 6 of
                                  Valuation of Lands (Scotland) Act, 1854, "the words „free
                                  from all expenses whatever in connection with the said
                                  tramways‟ appear to me to be so wide in their application that
                                  I should have thought it impossible to qualify or cut them
                                  down by their being associated with other words on the
                                  principle of their being ejusdem generis with the previous
                                  words enumerated"."
                                                                             (Emphasis supplied)


                            41.   There is some amount of flexibility in the legal position, qua
                            the applicability of the noscitur a sociis - or ejusdem generis -
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                             principle, where the general expression uses the word "other". In
                            Uttar Pradesh S. E. Board v. Hari Shanker 27, while interpreting the
                            words "other rules or regulations", as used in Section 13B of the
                            Industrial Employment (Standing Orders) Act, 1946, which read
                            "Nothing in this Act shall apply to an industrial establishment insofar
                            the workman employed therein are persons to whom the Fundamental
                            and Supplementary Rules, Civil Services (Classification Control and
                            Appeal) Rules, Civil Services (Temporary Service) Rules, Revised
                            Leave Rules, Civil Service Regulations, Civilians in Defence Service
                            (Classification, Control and Appeal) Rules or the Indian Railway
                            Establishment Code or any other rules or regulations that may be
                            notified in this behalf by the appropriate Government in the Official
                            Gazette apply", the Supreme Court held that though the rules, to
                            which reference was made in the preceding portion of the provision,
                            were all applicable to Government servants, that specification could
                            not be extended to the broad-based genus "other rules or regulations",
                            so as to narrow the scope of the said expression. For that reason, the
                            Supreme Court held that the words "any other rules or regulations"
                            referred to all statutory rules governing the workman, and not merely
                            to rules applicable to Government servants.


                            42.        Clause 41.1 in the Concession Agreement is in the nature of an
                            indemnity clause. It seeks to indemnify the concessionaire, for the
                            financial burden, suffered by its going through unforeseeable changes
                            in law. The use of the omnibus expression "other financial burden",
                            thus viewed, appears, to me, to be intended at covering all financial

                            27
                                 AIR 1979 SC 65 : (1978) 4 SCC 16
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                             burden, that the concessionaire may undergo, owing to change in law.
                            This also demonstrates the fallacy of the contention, of NHAI, that,
                            were such an "over-expansionist" interpretation to be accorded to
                            Clause 41.1, it would operate as an omnibus insurance, covering the
                            financial hardship that the concessionaire would suffer. The learned
                            Solicitor General submitted that the clause was never intended to
                            operate as an insurance, to GMR, covering all its financial risks. The
                            submission, in my view, misses the wood for the trees. Interpreting
                            the words "other financial burden", as I have done hereinabove, does
                            not convert Clause 41.1 into an omnibus insurance clause, covering all
                            financial burden that the concessionaire would suffer. The clause is,
                            expressly, limited only to financial burden suffered owing to "change
                            in law".     The intent is, quite obviously, to indemnify the
                            concessionaire, for the financial burden suffered by it, owing to
                            change in law, for the simple reason that changes in law are
                            unpredictable, unforeseeable, and beyond the control both of GMR
                            and NHAI. Viewed thus, imparting, to the expression "other financial
                            burden", any restricted interpretation would, in my view, in fact defeat
                            the very intent of using the said expression. The submission, of the
                            learned Solicitor General, that the expression "other financial burden",
                            as employed in Clause 41.1, is required to be interpreted noscitur a
                            sociis with the preceding expressions "increase in cost" and
                            "reduction in net after-tax return", therefore, in my view, does not
                            commend acceptance.


                            43.   The learned Solicitor General also relied, in the aforesaid
                            context, on the concluding sentence in Clause 41.1 of the Concession
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                             Agreement, which stated, "for the avoidance of doubt", "that this
                            Clause 41.1 shall be restricted to changes in law directly affecting the
                            Concessionaire‟s costs of performing its obligations under this
                            Agreement." In this context, I am in agreement with the submission,
                            of NHAI, that the cost, for any concessionaire, comprises of two
                            fundamental components, viz., of debt and of equity. Diminishing
                            revenue returns are bound, inescapably, to result in increased costs.
                            The interlink between costs and revenue is, in my view, completely
                            obfuscated, in the submissions advanced by the NHAI. It would be
                            wholly unrealistic, in my view, to interpret Clause 41.1 to mean that,
                            even where the monies received, by operating the toll, are severely
                            diminished, owing to an exponential fall in the traffic volume on the
                            highway, the concessionaire would not be entitled to any recompense,
                            merely because its "costs" have not increased. Such an interpretation
                            would amount to viewing "costs" as merely an arithmetical figure,
                            taking no stock of the financial impact that the costs have on the
                            concessionaire, consequent on decrease in commercial traffic.
                            Commercial contracts, as NHAI itself correctly contends, are required
                            to be advanced a business-like interpretation.       So advanced, the
                            interconnect between costs suffered, and revenue realised, cannot be
                            overlooked.


                            44.   That apart, in my opinion, it would be fallacious to isolate the
                            last sentence in the proviso to Clause 41.1 of the Concession
                            Agreement, and place sole reliance thereon, ignoring the main body of
                            the said Clause. The manner in which NHAI chooses to rely, in
                            isolation, on the said sentence, would amount to doing away with the
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                             reference, in the main body of Clause 41.1, to "reduction in net after-
                            tax return" and "other financial burden".         This, in my view, is
                            impermissible.    As NHAI has itself contended, the Concession
                            Agreement was required to be read as a whole, and the intent of the
                            parties thereto, defined therefrom.      The caveat entered, at the
                            conclusion of the proviso to Clause 41.1, "for the avoidance of
                            doubts" cannot, therefore, be torn away from the main Clause, so as to
                            constrict the scope thereof.


                            45.   Significantly, Clause 41.1 requires the concessionaire, in the
                            event of the application of provision, to "propose amendments to this
                            Agreement so as to place the Concessionaire in the same financial
                            position as it would have enjoyed had there been no such Change in
                            Law resulting in the cost increase, reduction in return or other
                            financial burden as aforesaid".      Nothing more, in my view, is
                            required, to indicate that the Clause was never intended to be limited
                            to cost increase. The submission of the NHAI, to the said effect has,
                            therefore, to be regarded as misconceived.


                            46.   The applicability of Clause 41.1, to the facts of the present case
                            cannot, therefore, in my view, be gainsaid.


                            Clause 41.3


                            47.   Clause 41.3 of the Concession Agreement is a sequel to Clause
                            41.1. It states that, pursuant to the provision of, inter alia, Clause
                            41.1, for the purposes of placing the concessionaire in the same
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                             financial position at it would have enjoyed had it not suffered
                            financial burden on account of change in law, the concessionaire
                            "shall rely on the Financial Model" to establish a net present value
                            (NPV) of the net cash flow, and make necessary adjustments in", inter
                            alia, compensation, so as to ensure that the NPV was the same as it
                            would have been, had there been no change in law. In this context,
                            NHAI has sought to discredit the Halcrow Report, as well as the
                            Financial Model, on which GMR placed reliance. The findings, in the
                            impugned Arbitral Award, in this regard, as contained in para 78
                            thereof, read thus:

                                  "278. One of the stands taken by the Respondent is that the
                                  Halcrow Report, the so called origin-destination study has not
                                  been shared with it. According to Claimant, IRC SP 19-2001
                                  has so recommended carrying out commodity wise analysis of
                                  traffic. Since Respondent is the custodian of all highways in
                                  the country and has the largest data base of traffic across the
                                  highway it is but natural to assume and believe that the
                                  Respondent would have the largest data base of traffic across
                                  all the highways. But it chose not to aduce any evidence to
                                  throw any light and / or contradict the Halcrow Report. The
                                  Halcrow Report refers to actual count of the existing traffic
                                  during the financial year 2008-09 including passenger cars,
                                  commercial vehicles and thereafter project the future traffic
                                  based on normal indices including economic activities, social
                                  economic        development       in      the       area      it
                                  took an average rate of growth for passenger traffic and
                                  commercial traffic as 6.1% and 6.2% respectively for a period
                                  of 25 years. In the Financial Model, the growth rate was
                                  reduced. Based on the traffic study for a period of 25 years
                                  and a reasonable return of 16% on investment and the
                                  concession period of 25 years, the consortium had submitted
                                  its offering a premium of 32.6% of Realizable Fee from
                                  Commercial Operation Date (COD) which increases by 1%
                                  every year on every anniversary of the appointed date.
                                  Claimant has highlighted the importance of the Financial
                                  Model. It is pointed out that 24.1.2 of the Concession
                                  Agreement mandates as a condition precedent, the submission
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                                   of Financial Model along with Financing Agreement. Even
                                  prior to the execution of the Financing Agreement, the
                                  Claimant was required to and in fact provided to the
                                  Respondent the approved Financial Model. The relevant
                                  provision 24.1.2 reads as follows:

                                         "24.1.2 The Concessionaire shall, upon occurrence of
                                         Financial Close, notify the Authority forthwith, and
                                         shall have provided to the Authority, at least 2 (two)
                                         days prior to Financial Close, 3 (three) true copies of
                                         the Financial Package and the Financial Model, duly
                                         attested by a Director of the Concessionaire, along
                                         with 3 (three) soft copies of the Financial Model in MS
                                         Excel version or any substitute thereof, which is
                                         acceptable to the Senior Lenders" "


                            48.   In making the necessary adjustments, including payment of
                            compensation, so as to restore the concessionaire to the financial
                            position enjoyed by its prior to the happening of the change in law,
                            Clause 41.3 of the Concession Agreement expressly requires the
                            parties to rely on the Financial Model. It is not open, therefore, to
                            NHAI, to discredit the Financial Model. Indeed, as has rightly been
                            observed by the learned Arbitral Tribunal, Clause 24.1.2 of the
                            Concession Agreement requires the concessionaire, i.e. GMR, to
                            provide, upon occurrence of Financial Close, to NHAI, three true
                            copies of the Financial Model, duly attested by its Director, along
                            with three soft copies thereof, as acceptable to the senior lenders.
                            Besides, the Halcrow study, resulting in the Halcrow Report, was
                            undertaken, by GMR, in accordance with Clause 2.1.3 of the RFP,
                            which required the bidders to carry out their own survey before
                            submitting their bids. Clause 1.2 (g) of the Report observed that the
                            purpose of the study was "estimation of projected toll revenue as per
                            the categories of traffic streams". As such, the Halcrow Report was a
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                             category-wise report.    Clause 4.1.3 of the Concession Agreement,
                            particularly sub-clause (f) thereof, required the Concessionaire to
                            deliver, to the authority, three copies of the Financial Model, as one of
                            the conditions precedent, to be satisfied by the concessionaire prior to
                            the appointed date. The authority to waive this condition precedent
                            vested in the NHAI, by the proviso to the said Clause, but no such
                            waiver was ever granted. As such, in accordance with the mandate of
                            the said sub-clause, GMR submitted its Financial Model to NHAI on
                            6th April, 2010. The ingredients of the Financial Model were also
                            provided in Clause 48.1 of the Concession Agreement, which clearly
                            stated that the financial viability of the project was determined, by the
                            senior lenders, on the basis of the said Financial Model.          As is
                            correctly noted by the learned Arbitral Tribunal in para 278 of the
                            impugned Award, NHAI, despite being the custodian of all highways
                            in the country, with the largest database of traffic across all highways,
                            did not adduce any evidence, on the basis of which the Halcrow
                            Report, or the Financial Model, could be discredited. In fact, the
                            premium, offered by GMR and sought to be realised by NHAI, was
                            also based on the Realisable Fee, based on the traffic study resulting
                            in the Halcrow Report.


                            49.   Ironically, while seeking to discredit the Halcrow Report in the
                            Financial Model, which were in existence prior to finalisation of the
                            Concession Agreement, and the providing of the latter of which was a
                            condition precedent, NHAI seeks to rely (in its written submissions)
                            on data, allegedly collected by it, regarding traffic movement on
                            highways closed to NH-9, and on a Pavement Design Report. The
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                             learned Arbitral Tribunal has correctly found the reliance, by NHAI,
                            on this material, to be inexplicable. When actual data, relating to
                            movement of traffic on the Project Highway, was available, it defeats
                            comprehension as to how NHAI could choose to discredit that data,
                            and rely on data relating to the movement on "proximate" highways.


                            50.   Much has been sought to be made, in the written submissions of
                            NHAI, on the non-availability of any commodity-wise traffic study,
                            for the period after the change in law. Exception has been taken to the
                            fact that the plea, of GMR, for the decline in traffic is sought to be
                            based on a comparison of the total commercial vehicular traffic,
                            before and after the change in law. Having perused the Concession
                            Agreement, I can find no basis for this submission. The Concession
                            Agreement does not require any commodity-wise study to be
                            undertaken. Any claim to entitlement for compensation, under Clause
                            41.1 of 41.3, requires, a priori, establishment of the existence of
                            financial burden, on the concessionaire, i.e. GMR, as a consequence
                            of the change in law. The reduction in commercial traffic was shown,
                            by GMR, as evidence of the fact that it had, in fact, suffered financial
                            burden as a result of the change in law. If this plea, of reduction in
                            commercial traffic, was found to be correct, in the absence of any
                            material, adduced by NHAI, to justify such reduction, GMR would
                            have succeeded in establishing the causal connection between the
                            change in law, and financial burden, arising from the reduction in
                            commercial traffic. This exercise has, both by the majority, as well as
                            by the minority, awards, been directed to be undertaken de novo.


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                             51.   In this context, and given the tenor of the submissions of NHAI,
                            I deem it appropriate to observe that, unlike a statutory instrument, a
                            contract is, entered into, between the parties thereto, with open eyes,
                            and with the wherewithal to include, in the contract, all such
                            covenants as would manifest their intention. The intent of parties, to a
                            contract has, therefore, to be discerned from the provisions of the
                            contract, and cannot be inferred - unlike a statutory instrument, in
                            which the parties, who are required to interpret the statute, are not
                            privy to the framing thereof.


                            Re. Clause 29


                            52.   NHAI has contended that the clause, which would apply in the
                            case of production of flow of traffic, would be Clause 29.1 of the
                            Concession Agreement, and not Clause 41.1, or 41.3. It has also been
                            sought to be pointed out that, unlike Article 41, traffic flow, under
                            Article 29, is based on the number of Passenger Car Units (PCUs),
                            and not on the basis of the number of commercial vehicles. Though
                            Article 29, and the various clauses thereunder, do not refer to Change
                            in Law, NHAI contends that the said Article caters to all cases of
                            reduction in traffic, for any reason. In all such cases, Clause 29.1
                            requires increasing the concession period, so as to result in increase in
                            revenue. It is contended, by NHAI, that, if Article 41 were to be
                            treated as catering to the same exigency, GMR would get a double
                            benefit. It is also sought to be contended that Article 29 is a more
                            specific provision, which deals with reduction in traffic flow, as
                            compared to Article 41 and that, therefore, applying Clause 1.4.2 of
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                             the Concession Agreement, the case of GMR would fall,
                            appropriately, under Article 29.


                            53.   Dr. Singhvi, meeting the said submissions, pointed out that
                            Article 29 does not deal, at all, with change in law. That, in my view,
                            is a complete answer to the submissions of NHAI, relying on Article
                            29. "Change in law", clearly, had taken place, and the claims, of
                            GMR, were consequent thereupon. Article 41 specifically dealt with
                            "change in law", and the consequences thereof. Article 29 did not
                            make any reference, at all, to "change in law". If, therefore, the
                            learned Arbitral Tribunal relied on Article 41.1 and 41.3, in
                            preference to Article 29, that was, in my view, eminently in
                            accordance with the express terms of the Concession Agreement.


                            54.   In this context, Clause 1.4.2, on which NHAI sought to place
                            reliance, actually furthers the cause of GMR.        Sub-clause (a) of
                            Clause 1.4.2 specifically states that, "in case of ambiguities or
                            discrepancies within this Agreement, ... between two or more Clauses
                            of this Agreement, the provisions of a specific Clause relevant to the
                            issue under consideration shall prevail over those in other Clauses".
                            The issue under consideration being the entitlement, of GMR, to
                            compensation, on account of financial difficulties faced consequent to
                            change in law, it is obvious that the specific Clauses, engrafted in the
                            Concession Agreement to deal with such an exigency, is Clause 41.1,
                            and Clause 41.3, and not Clause 29.1.



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                             55.    Clause 29.1, in fact, does not deal with such a specific exigency
                            at all. Clause 29.1.1 is, expressly, engrafted "for determining the
                            modifications to the Concession Period under this Article 29".
                            Modifications to the Concession Period, under Article 29, is covered
                            by Clause 29.2. Sub- clause 29.2.1, thereunder, stipulates that, if the
                            actual traffic is found to have fallen short of the Target Traffic then,
                            for every 1% shortfall, the Concession Period shall, subject to
                            payment of Concession Fee in accordance with the Concession
                            Agreement, be increased by 1.5% thereof, subject to a maximum
                            increase of 20%. The manner in which it is to be ascertained, as to
                            whether Actual Traffic has, or has not, fall short of the Target Traffic,
                            is prescribed in Clause 29.1.1. The Target Traffic is estimated on the
                            Target Date (1st December, 2019), by the said Clause, as 36666 PCUs
                            per day.    The Clause goes on to require traffic sampling to be
                            undertaken on the date one year prior to the Target Date, on the Target
                            Date and one year after the Target Date. On each occasion, the traffic
                            sampling is to be undertaken for 7 continuous days. The average of
                            the traffic flow, on the said 7 days, would be deemed to be the actual
                            traffic.   Clause 29.1.2 specifies that, if the actual traffic, thus
                            reckoned, fall short of the Target Traffic by more than 2.5%, or
                            exceeds the Target Traffic by more than 2.5%, the Concession Period
                            would be modified in accordance with Clause 29.2.



                            56.    It is obvious that Clause 29 is not even intended to cater to
                            financial hardship, resulting to the Concessionaire, much less where
                            such financial hardship is attributable to change in law.       Adverse
                            financial consequences, resulting from change in law, are specifically
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                             covered by Clause 41.1 and 41.3.       The invocation, by NHAI, of
                            Clause 29 of the Concession Agreement is, therefore, thoroughly
                            misconceived.



                            57.   In view thereof, no exception can be taken, to the finding, of the
                            learned Arbitral Tribunal, that the rejection, by NHAI, of the claim, of
                            GMR, to compensation, predicated on Clauses 41.1 and 41.3, was not
                            in accordance with the terms of the contract, and could not sustain in
                            law. The learned Arbitral Tribunal has correctly held that the adverse
                            financial consequences, which have been claimed, by GMR, to have
                            visited it, as a result of the change in law, justify invocation of
                            Clauses 41.1 and 41.3 of the Concession Agreement. As the said
                            finding is obviously in accordance with the terms of the Concession
                            Agreement, and, on its face, Article 29 does not apply to such a
                            situation, the mere fact that no detailed discussion, regarding
                            inapplicability of Article 29 of the Concession Agreement, is to be
                            found in the impugned Award, cannot, in my view, vitiate it to any
                            extent.



                            58.   As the view, of the learned Arbitral Tribunal, that "change in
                            law" did exist, and that the claim of GMR, to compensation, was
                            maintainable under Clauses 41.1 and 41.3 of the Concession
                            Agreement, merit acceptance, for the reasons stated hereinabove, I do
                            not deem it necessary to enter, in any detail, into the issue of force
                            majeure, on which, too, the learned Arbitral Tribunal has founded its
                            decision, especially in view of sub-clause (a) of Clause 34.4, which

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                             makes "change in law" a "political event", for the purposes of force
                            majeure, "only if consequences thereof cannot be dealt with under and
                            in accordance with the provisions of Article 41 and its effect, in
                            financial terms, exceeds the sum specified in Clause 41.1". No claim
                            to compensation has been laid, by NHAI, attributable to "change in
                            law", beyond the effect of such change, in financial terms, as
                            contemplated by Clause 41.1.




                            Resultantly


                            59.     As a result, the findings, of the learned Arbitral Tribunal, that
                            (i) the amendments in the Sand Mining Policy, as effected, from time
                            to time, by the States of Andhra Pradesh and Telangana, as also the
                            judgement of the Supreme Court in Deepak Kumar1, and the
                            bifurcation of the state of Andhra Pradesh, amounted to "change in
                            law", within the meaning of Clause 48 of the Concession Agreement
                            and (ii) the decision of NHAI, to reject the claim, to compensation, by
                            GMR, by relying on Article 29 of the Concession Agreement, could
                            not sustain in law, stands affirmed. Clearly, the claim of GMR would
                            have to be assessed on the basis of Clauses 48.1 and 48.3, and not on
                            the basis of Clause 29.


                            60.     Having thus held, the learned Arbitral Tribunal has also held,
                            correctly, that GMR would not, merely by virtue of these findings,
                            become, ipso facto, entitled to compensation under Clause 48.1 or
                            48.3.    It would be necessary for GMR to establish the "financial
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                             burden", suffered by its as a consequence of the aforesaid changes in
                            law, in order to be entitled to compensation under the said Clauses.
                            This finding, of the learned Arbitral Tribunal, too, is eminently in
                            order, and does not call for interference.


                            61.      O.M.P. (COMM) 426/2020 stands disposed of, in the aforesaid
                            terms.


                            O.M.P. (COMM.) 425/2020 and I.A. 3714/2020



                            62.      On the issue of the authority, to whom the task of determining
                            the actual entitlement of GMR, to compensation, should be assigned,
                            the opinions of the learned arbitrators diverge. The majority award
                            remits this issue to NHAI, for consideration, whereas the minority
                            Award (per Nayar, J.), disagrees therewith, and opines that the learned
                            Arbitral Tribunal ought to have itself decided the actual entitlement of
                            GMR, or assigned the task to an independent expert/body of experts.


                            63.      O.M.P. (COMM.) 425/2020, by GMR, assails the decision, by
                            the majority Award dated 31st March, 2020, to leave the exercise of
                            determining     and   quantifying   the      entitlement,   of   GMR,      to
                            compensation, under Clauses 41.1 and 41.3 of the Concession
                            Agreement, to NHAI.


                            64.      In this regard, a perusal of the reliefs sought by GMR, in its
                            Statement of Claim, filed before the learned Arbitral Tribunal, reveals
                            that GMR had specifically claimed ₹ 752.32 crores, under Clauses
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                             41.1 and 41.3 of the Concession Agreement, as the amount due to it,
                            consequent to the aforesaid "change in law". Interest, on the said
                            amount, also stands claimed.


                            65.   The actual amount, payable to GMR on account of the aforesaid
                            "change in law", therefore, constitutes an inalienable part of the
                            dispute, which was referred to the learned Arbitral Tribunal.         As
                            Nayar, J., correctly observes, the learned Arbitral Tribunal could itself
                            have decided the issue. Having said that, there can be no cavil with
                            the decision, of the learned Arbitral Tribunal, to assign the task of
                            deciding the actual amount payable to GMR, to another body, as it
                            could involve disputed facts and figures. Any such body, however,
                            would be, in effect, an extension of the learned Arbitral Tribunal
                            itself, as it would be deciding the dispute, which stood referred to the
                            learned Arbitral Tribunal.       GMR and NHAI having been at
                            loggerheads, throughout, regarding the entitlement of GMR, I find
                            myself in agreement with Nayar, J., that NHAI itself could not be
                            assigned the task of adjudicating on the claim of GMR. There is,
                            prima facie, substance in the submission, of Dr. Singhvi, that any such
                            delegation would be bound to result in futility.         That impression
                            stands underscored by the emphasis with which NHAI has, before this
                            Court, contested the entitlement, of GMR, to any compensation and,
                            in fact, the very existence of "change in law" itself.


                            66.   I may refer, with advantage, in this regard, to Section 12 (5) of
                            the 1996 Act, which specifically disentitles any person "whose
                            relationship, with the parties or Council or the subject-matter of the
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                             dispute, falls under any of the categories specified in the Seventh
                            Schedule", to be ineligible for appointment as an arbitrator. It is
                            hardly necessary to refer to the various categories of persons, who
                            were disentitled, by operation of Section 12 (5), read with the Seventh
                            Schedule to the 1996 Act, from acting as arbitrators, as, in the present
                            case, the majority Award as assigned the task of determining the
                            entitlement of GMR, to NHAI itself.               In my view, this is
                            impermissible.


                            67.   While, therefore, issuing notice on this petition, returnable on
                            15th March, 2021, I deem it appropriate to appoint D. K. Jain, J. (r/o
                            C-3/5, Ground floor, Safdurjung Development Area, New Delhi -
                            1100016 Tel. No. 9999922288), one of the most respected retired
                            Judges of the Supreme Court, who has also adorned the bench of this
                            Court, the High Court of Punjab and Haryana (as Chief Justice) and of
                            the National Consumer Disputes Redressal Commission, as its
                            Chairperson, to undertake and complete the task which stands
                            assigned, by the Majority Award the present case, to the NHAI.
                            Inasmuch as D. K. Jain, J., would be effectively taking off from where
                            the learned Arbitral Tribunal passed its Award in the present case, and
                            solely for that reason, he would be referred to, hereinafter, as "the
                            learned Sole Arbitrator". The learned Sole Arbitrator would undertake
                            the task in accordance with paras 293 to 297 of the impugned Award.


                            68.   For this purpose, GMR is directed to file, before the learned
                            Sole Arbitrator, a clear statement of its claim to compensation, under


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                             Clauses 41.1 and 41.3 of the Concession Agreement, with all
                            particulars thereof.


                            69.   GMR is directed to contact the learned Sole Arbitrator at the
                            contact information provided hereinabove within 48 hours, so as to fix
                            a schedule for the proceedings and furnishing its statement of claim.


                            70.   The discretion, on whether to permit GMR, or NHAI, to
                            introduce any further documents, beyond those which were already
                            filed during the arbitral proceedings conducted thus far, would rest
                            with the learned Sole Arbitrator. Needless to say, the learned Sole
                            Arbitrator would afford an adequate opportunity of hearing to both
                            sides, before arriving at his decision.


                            71.   Given the magnitude of the task involved, I deem it appropriate
                            to enhance the time, available with the learned Sole Arbitrator, to
                            arrive at his decision, to six months, from the date of presentation, of
                            its claim, by GMR, to the learned Sole Arbitrator. Should the time
                            prove insufficient, it would be open to either party to apply to this
                            Court, for extension of time.


                            72.   The learned Sole Arbitrator would be entitled to conduct the
                            proceedings at a venue suitable to him, subject to consent by GMR
                            and NHAI.       He shall also be entitled to charge, for the said
                            proceedings, the fees being paid to the learned Presiding Arbitrator, in
                            the proceedings conducted thus far.       The learned Sole Arbitrator
                            would also be entitled to requisition the services of an expert, or a
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                             team of experts, such as a reputed firm of Chartered Accountants,
                            should he deem it necessary. In such an eventuality, the learned Sole
                            Arbitrator would be entitled to fix the fees of such expert(s), after
                            consultation with both sides.


                            73.   The decision, of the Sole Arbitrator, regarding the entitlement,
                            if at all, of GMR to compensation, would be provided to the parties,
                            and forwarded, to this Court, by the learned Sole Arbitrator.


                            74.   Notice of this petition is accepted by Mr. Manish Bishnoi,
                            learned counsel for NHAI. Renotify on 15th March, 2021.


                            75.   In view of the aforesaid direction, I.A. 3714/2020 does not
                            survive for further consideration, and stands disposed of.


                            O.M.P. (I) (COMM) 92/2020



                            76.   Issue notice, returnable on 15th March, 2021.             Notice is
                            accepted by Mr. Manish Bishnoi on behalf of the respondent.


                            77.   Counter affidavit, in response to this petition, be filed within a
                            period of four weeks with advance copy to the petitioner who may file
                            rejoinder thereto if any, within a period of four weeks thereof.


                            78.   This petition assails a communication, dated 16 th April, 2020,
                            by NHAI, demanding premium from GMR, in the context of the
                            Concession Agreement, dated 9th October, 2009 supra. GMR, in turn,
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                             contends that it was entitled to compensation, from NHAI, under
                            Clauses 41.1 and 41.3 of the Concession Agreement.           Vide my
                            judgement and order hereinabove, I have upheld the applicability of
                            the aforesaid Clauses 41.1 and 41.3, to the claim of GMR, and have
                            appointed a learned Sole Arbitrator to adjudicate on the actual
                            entitlement of GMR, to compensation under the said clauses.
                            Inasmuch as the claim to premium, by NHAI, and the claim to
                            compensation, by GMR, constitute rival monetary claims, emanating
                            from the same Concession Agreement, the interests of justice, in my
                            view, would justify staying the recovery, from GMR, by NHAI, of
                            premium, in terms of the impugned letter dated 16 th April, 2020,
                            pending the decision of the learned Sole Arbitrator on the entitlement,
                            of GMR, to compensation.          The considerations of balance of
                            convenience and irreparable loss would also, in my view, justify this
                            decision, given the amounts involved, and the fact that, were NHAI
                            ultimately to succeed, it would be open to NHAI to recover the
                            amount of premium, if recoverable, with or without interest, even at
                            that stage.


                            79.    Accordingly, till the next date of hearing, the operation of the
                            impugned letter No. NHAI/PIU-Hyd/NH-65/Hyd-Vij/2020/430, dated
                            16th April, 2020, issued by NHAI to GMR, would stand stayed.




                                                                         C. HARI SHANKAR, J.

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