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North Karanpura Transmission Company ... vs Central Electricity Regulatory ... on 23 February, 2023

20. The Supreme Court observed that both the courts below had committed a jurisdictional error when they failed to take note of the law laid down in Raman Iron Foundry which governed the controversy, and had instead placed reliance on Himadri Chemicals Industries Ltd. v. Coal Tar Refining Co., (2007) 8 SCC 110 and U.P. State Sugar Corpn. v. Sumac International Ltd., (1997) 1 SCC 568 , which laid down general principle relating to bank guarantees; there could be no quarrel with the proposition laid down in those cases; however, every case had to be decided with reference to the facts involved therein; the case at hand was similar on facts with that of Raman Iron Foundry, and hence the law laid down in that case was applicable to this case; the District Judge, having decided the injunction application in the first instance in the appellant's favour, had erred in rejecting the application made by the appellant the second time; the respondents, despite having suffered the injunction order the first time, did not file any appeal against that order; the said order had thus attained finality and was, therefore, binding on the parties; the appellants had made out a prima facie case in their favour for grant of injunction against the respondents; they had also made out a case of balance of convenience and irreparable loss in their favour as held in Raman Iron Foundry; and they were, therefore, entitled to claim injunction against the respondent in relation to encashment of the Bank Guarantee. The appeal was allowed, the impugned Order was set aside, in consequence, the injunction application submitted by the appellant under Section 9 of the Arbitration Act was allowed, and injunction was granted in the appellant's favour restraining the respondent from encashing the Bank Guarantee.
Appellate Tribunal For Electricity Cites 82 - Cited by 0 - R Ranganathan - Full Document

Mytrah Vayu (Brahamputra) Private ... vs M/S. Solar Energy Corporation Of India ... on 18 March, 2024

After referring to the judgements of the Supreme Court in Supreme Court in Ansal Engg. Projects Ltd. v. Tehri Hydro Development Corpn. Ltd., (1996) 5 SCC 450; Standard Chartered Bank v. Heavy Engg. Corpn. Ltd., (2020) 13 SCC 574; SBI v. Mula Sahakari Sakhar Karkhana Ltd., (2006) 6 SCC 293; Himadri Chemicals Industries Ltd. v. Coal Tar Refining Co., (2007) 8 SCC 110; Gujarat Maritime Board v. Larsen & Toubro Infrastructure Development Projects Ltd., (2016) 10 SCC 46; the Delhi High Court held that it was evident from the aforesaid judgements that Courts should be slow in granting an injunction to restrain realization of a bank guarantee; existence of a dispute between the parties I.A. No. 83/2024 IN A. No. 29/2024 Page 58 of 75 to the contract is not a ground for issuing an injunction to restrain the enforcement of bank guarantees; Courts have carved out only two exceptions, a fraud in connection with such a bank guarantee is the first exception whereas the second exception is that allowing the encashment of an unconditional bank guarantee would result in irretrievable harm or injustice to one of the parties concerned; in Standard Chartered Bank v. Heavy Engg. Corpn. Ltd., the Supreme Court held that irretrievable injury, which is the second exception to the rule against granting of injunctions when unconditional bank guarantees are sought to be realised, must be of the kind which was the subject-matter of the decision in the Itek Corpn. Case; to avail this exception exceptional circumstances, which make it impossible for the guarantor to reimburse himself if he ultimately succeeds, will have to be decisively established; and mere apprehension that the other party will not be. able to pay, is not enough; since in most cases payment of money under such a bank guarantee would adversely affect the bank and its customer at whose instance the guarantee is given, the harm or injustice contemplated under this head must be of such an exceptional and irretrievable nature as would override the terms of the guarantee and the adverse effect of such an injunction on commercial dealings in the country; the two grounds are not necessarily connected, though both may coexist in some cases; and there is a third exception, being that of special equities operating in favour of the party against whom the bank guarantee is being sought to be invoked.
Appellate Tribunal For Electricity Cites 48 - Cited by 0 - R Ranganathan - Full Document

M/S. Shapoorji Pallonji ... vs Central Transmission Utility Of India ... on 18 March, 2024

None of the judgments, in the long list of cases where Courts/Tribunals were called upon to exercise restraint against interference with invocation of bank guarantees (ie in (1) U.P. Cooperative Federation Ltd. v. Singh Consultants and Engineers (P) Ltd., (1988) 1 SCC 174; (2) United Commercial Bank v. Bank of India, (1981) 2 SCC 766; (3) Dwarikesh Sugar Industries Ltd. v. Prem Heavy Engineerings Works (P) Ltd., (1997) 6 SCC 450; (4) SBI v. Mula Sahakari Sakhar Karkhana Ltd., (2006) 6 SCC 293; (5) State of Maharashtra v. National Construction Company, Bombay (1996) 1 SCC 735; (6) Ansal Engineering Projects Ltd. v. Tehri Hydro Development Corporation Ltd. (1996) 5 SCC 450; (7) BSES Ltd. v. Fenner India Ltd., (2006) 2 SCC 728; (8) Gujarat Maritime Board v. L&T Infrastructure Development Projects Ltd. (2016) 10 SCC 46; (9) Vinitec Electronics Private Ltd. v. HCL Infosystems Ltd., (2008) 1 SCC 544; (10) Adani Agri Fresh v. Mehboob Sharif, (2016) 14 SCC 517; (11) Himadri Chemicals Industries Ltd. v. Coal Tar Refining Co., (2007) 8 SCC 110; (12) A.P. Pollution Control Board v. CCL Products (India) Ltd., (2019) 20 SCC 669; (13)Standard Chartered Bank v. Heavy Engg. Corpn. Ltd., (2020) 13 SCC 574, and (14) U.P. State Sugar Corpn. v. Sumac International Ltd) were even brought to the notice of this Tribunal in 'Vaayu Renewable Energy (Kaveri) Put.
Appellate Tribunal For Electricity Cites 32 - Cited by 0 - R Ranganathan - Full Document

The Indure Private Limited vs M/S.Cethar Vessels Limited on 22 November, 2010

(vi) of the Apex Court judgment in the case of Himadri Chemicals Industries Limited v. Coal Tar Refining Co., cited supra. In respect of the conditional bank guarantee, unless the condition is satisfied, the bank guarantee cannot be invoked and also further, other factors like non-payment as well as belated complaint, cannot be disregarded. They all are well interconnected with one another. After considering the facts and circumstances of the case, especially taking into consideration of the following factors, viz.,
Madras High Court Cites 18 - Cited by 0 - P P Raja - Full Document

Inox Green Energy Services Ltd & Ors vs Central Electricity Regulatory ... on 24 February, 2023

29. The Supreme Court observed that both the courts below had committed a jurisdictional error when they failed to take note of the law laid down in Raman Iron Foundry which governed the controversy, and had instead placed reliance on Himadri Chemicals Industries Ltd. v. Coal Tar Refining Co., (2007) 8 SCC 110 and U.P. State Sugar Corpn. v. Sumac International Ltd., (1997) 1 SCC 568, which laid down general principles relating to bank guarantees; there could be no quarrel with the proposition laid down in those cases; however, every case had to be decided with reference to the facts involved therein; the case at hand was similar on facts with that of Raman Iron Foundry, and hence the law laid down in that case was applicable to this case; the District Judge, having decided the injunction application in the first instance in the appellant's favour, had erred in rejecting the application made by the appellant the second time; the respondents, despite having suffered the injunction order the first time, did not file any appeal against that order; the said order had thus attained finality and was, therefore, binding on the parties; the appellants had made out a prima facie case in their favour for grant of injunction against the respondents; they had also made out a case of balance of convenience and irreparable loss in their favour as held in Raman Iron Foundry; and they were, therefore, entitled to claim injunction against the respondent in relation to encashment of the Bank Guarantee. The appeal was allowed, the impugned Order was set aside, in consequence, the injunction application submitted by the appellant under Section 9 of the Arbitration Act was allowed, and injunction was granted in the appellant's favour restraining the respondent from encashing the Bank Guarantee.
Appellate Tribunal For Electricity Cites 44 - Cited by 1 - R Ranganathan - Full Document

Mitsubishi Heavy Industries Limited vs Punj Llyod Limited on 9 August, 2024

The relevant paragraph is as under: (Himadri Chemicals Industries Ltd. case [Himadri Chemicals Industries Ltd. v. Coal Tar Refining Co., (2007) 8 SCC 110], SCC pp. 117-18, para 14) "14. From the discussions made hereinabove relating to the principles for grant or refusal to grant of injunction to restrain enforcement of a bank guarantee or a letter of credit, we find that the following principles should be noted in the matter of injunction to restrain the encashment of a bank guarantee or a letter of credit:
National Company Law Appellate Tribunal Cites 18 - Cited by 0 - A Bhushan - Full Document

M/S Chaitanya Energy Private Limited vs Indian Bank on 3 June, 2024

(b) The observations and the view of the Apex Court in the various judgements i.e., (1) (2016) 10 SCC 46 in "Gujarat Maritime Board Vs. Larsen and Toubro Infrastructure Development Projects Ltd., and another, (2) (2007) 8 SCC 110 in Himadri Chemicals Industries Limited v. Coal Tar Refining Company (3) (1999) 8 SC 436 in Hindustan Construction Company Ltd., Vs. State of Bihar & others, (4) (2000) 6 SCC 293 in Kerala State Electricity Board Vs. Kurien Ekalathil, (5) (2021) 10 SCC 690 in Union of India Vs. Puna Hinda, (6) (2004) 3 SCC 553 in ABL International Ltd., Vs. Export Credit Guarantee Corporation of India Ltd., (7) (2002) 1 SCC 216 in State of Bihar Vs. Jain Plastics & Chemicals Ltd., (8) (2015) 7 SCC 728 in Joshi Technologies International Inc., Vs. Union of India, (9) (2021) 6 SCC 771 in M/s. Radhakrishnan Industries Vs. State of Himachal Pradesh, (10) (1998) 8 SCC 1 in Whirlpool Corporation Vs. Registrar of Trade Marks, (11) 2021 SCC Online SC 801 in "Magadh Sugar & Energy Ltd., Vs. 47 WP_24169_2023 SN,J State of Bihar and others, (referred to and extracted above),
Telangana High Court Cites 20 - Cited by 0 - S Nanda - Full Document
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