Chloro Controls(I) P.Ltd vs Severn Trent Water Purification Inc ... on 28 September, 2012
21. Explaining the legal basis that may be applied to bind a non-
signatory to an arbitration agreement, this Court in Chloro Controls
case [Chloro Controls India (P) Ltd. v. Severn Trent Water
Purification Inc., (2013) 1 SCC 641 : (2013) 1 SCC (Civ) 689] held
thus : (SCC p. 694, paras 103.1, 103.2 & 105)
"103.1. The first theory is that of implied consent, third-party
beneficiaries, guarantors, assignment and other transfer
mechanisms of contractual rights. This theory relies on the
discernible intentions of the parties and, to a large extent, on
good faith principle. They apply to private as well as public
legal entities.