In Chloro
Controls India (P) Ltd. v. Severn Trent Water Purification Inc.
(supra), the Supreme Court had explained that non-signatories or third
parties could be subjected to Arbitration without their prior consent in
certain exceptional circumstances. In that case, the Supreme Court was
examining a composite transaction, which was effected through various
Signature Not VerifiedDigitally Signed ARB.P. 175/2020 Page 15 of 24By:DUSHYANTRAWAL
subsidiary agreements. It is in that context, the Supreme Court had
observed as under:-
22. He also countered the contention that since GAIL had made
allegations of fraud against petitioner no.1, the disputes could not be
referred to Arbitration. He referred to the decision of a Coordinate
Bench of this Court in Rajesh Gupta v. Smt. Mohit Lata Sunda & Ors.: