Gmr Energy Limited vs Doosan Power Systems India Private ... on 14 November, 2017
In particular, the observations made in paras 50-52
and 54 in Yograj Infrastructure case [Yograj Infrastructure
Ltd. v. Ssang Yong Engg. & Construction Co. Ltd., (2011) 9
SCC 735 : (2011) 4 SCC (Civ) 864] , if read together, indicate
that, although, when the seat of arbitration was in Singapore,
the SIAC Rules would apply, the same included Rule 32 which
provides that it is the Singapore International Arbitration Act,
2002, which would be the law of the arbitration. Accordingly,
it is clarified that while mention had been made in paras 50 to
52 that the curial law of the arbitration would be the SIAC
Rules, what has been subsequently indicated in para 54 of the
judgment is that the Singapore International Arbitration Act,
2002 would be the law of the arbitration.