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Documents citing Chloro Controls(I) P.Ltd vs Severn Trent Water Purification Inc ... on 28 September, 2012

The State Of Karnataka vs M/S Siddharth Infotech Pvt Ltd on 18 September, 2025

(e) performance of the contract, are the factors to determine whether the non-signatory is a party. [Id, para 40] These factors emphasise mutual intention and draw from the tests laid down in Chloro Controls [Chloro Controls India (P) Ltd. v. Severn Trent Water Purification Inc., (2013) 1 SCC 641 : (2013) 1 SCC (Civ) 689] and Reckitt Benckiser [Reckitt Benckiser (India) (P) Ltd. v. Reynders Label Printing (India) (P) Ltd., (2019) 7 SCC 62 : (2019) 3 SCC (Civ) 453] but do not include the test of single economic reality as a determinative factor, as 51 held in MTNL [MTNL v. Canara Bank, (2020) 12 SCC 767].
Karnataka High Court Cites 85 - Cited by 0 - Full Document

Ashish Kapur & Anr. vs Deepak Seth & Ors. on 3 February, 2025

This observation was made prior to the decision of this Court in Chloro Controls [Chloro Controls India (P) Ltd. v. Severn Trent Water Purification Inc., (2013) 1 SCC 641 : (2013) 1 SCC (Civ) 689] and is no longer relevant in light of the current position of law. Thus, when a non-signatory person or entity is arrayed as a party at Section 8 or Section 11 stage, the referral court should prima facie determine the validity or existence of the arbitration agreement, as the case may be, and leave it for the Arbitral Tribunal to decide whether the non-signatory is bound by the arbitration agreement.
Delhi High Court Cites 22 - Cited by 0 - S Prasad - Full Document

Techchef Consulting India Private ... vs Himanshu Mishra & Anr. on 25 October, 2024

This observation was made prior to the decision of this Court in Chloro Controls [Chloro Controls India (P) Ltd. v. Severn Trent Water Purification Inc., (2013) 1 SCC 641 : (2013) 1 SCC (Civ) 689] and is no longer relevant in light of the current position of law. Thus, when a non-signatory person or entity is arrayed as a party at Section 8 or Section 11 stage, the referral court should prima facie determine the validity or existence of the arbitration agreement, as the case may be, and leave it for the Arbitral Tribunal to decide whether the non-signatory is bound by the arbitration agreement.
Delhi High Court Cites 17 - Cited by 0 - S Datta - Full Document

Amazon.Com Nv Investment Holdings Llc vs Future Coupons Private Limited & Ors. on 18 March, 2021

189. Respondent No.2 is a proper party to the arbitration proceedings and the Emergency Arbitrator has rightly invoked the Group of Companies doctrine by applying the well settled principles laid down by the Supreme Court in Chloro Controls (supra), Cheran Properties (supra) and MTNL (supra). The respondents have raised a plea contrary to the well settled law relating to Group of Companies doctrine laid down by the Supreme Court.
Delhi High Court Cites 64 - Cited by 1 - J R Midha - Full Document

Monika Oli vs M/S Cl Educate Ltd. on 18 January, 2023

51. In view of the aforesaid discussion, we feel it appropriate to refer the aspect of interpretation of "claiming through or under" as occurring in amended Section 8 of the Arbitration Act qua the doctrine of group of companies to a larger Bench to provide clarity on this aspect. The law laid down in Chloro Controls case [Chloro Controls India (P) Ltd. v. Severn Trent Water Purification Inc., (2013) 1 SCC 641 : (2013) 1 SCC (Civ) 689] and the cases following it, appear to have been based, more on economics and convenience rather than law. This may not be a correct approach.
Delhi High Court Cites 53 - Cited by 0 - C D Singh - Full Document
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