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M/S Duro Felguera S.A vs M/S. Gangavaram Port Limited on 10 October, 2017

Therefore, factors such as the relationship of a non-signatory to a party which is a signatory to the agreement, the commonality of subject- matter and the composite nature of the transaction weigh in the balanced The group of companies doctrine is essentially intended to facilitate the fulflment of a mutually held intent between the parties, where the circumstances indicate that the intent was to bind both signatories and non-signatoriesd The efort is to fnd the true essence of the business arrangement and to unravel from a layered structure of commercial arrangements, an intent to bind someone who is not formally a signatory but has assumed the obligation to be bound by the actions of a signatoryd 34d The appellant questions the application of the Chloro Controls [Chloro Controls India (P) Ltd. v. Severn Trent Water Purifcation Inc., (2013) 1 SCC 641 : (2013) 1 SCC (Civ) 689] doctrined Dr Singhvi urged that in Chloro Controls, there was a joint venture agreement; the mother or parent agreement contained an arbitration clause and though the ancillary agreements did not contain an arbitration agreement, they could not have been performed in the absence of the mother agreementd The submission proceeds on a constricted interpretation of the Chloro Coitrols dictumd The principle which underlies Chloro Controls is that an arbitration agreement which is entered into by a company within a group of companies may bind non- signatory afliates, if the circumstances are such as to demonstrate the mutual intention of the parties to bind both signatories and non-signatoriesd In applying the doctrine, the law seeks to eiforce the commoi iiteitioi of the parties, where circumstances indicate that both signatories and non- signatories were intended to be boundd In Duro [Duro Felguera v. Gangavaram Port Ltdd, (2017) 9 SCC 729 : (2017) Page 8 of 18 5th March 2021 11-CARBPL87-2020.DOC 4 SCC (Civ) 764], the case was held to stand on a diferent footing since all the fve diferent packages as well as the corporate guarantee did not depend on the terms and conditions of the original package nor on the memorandum of understanding executed between the parties. The judgment in Duro does not detract from the principle which was enunciated in Chloro Coitrolsd (Emphasis added)
Supreme Court of India Cites 26 - Cited by 476 - R Banumathi - Full Document

Essar House Pvt. Ltd vs Arcelor Mittal Nippon Steel India Ltd. ... on 1 February, 2021

31. Lest it be argued either here or in any other forum that no case has been made out under Order 38 Rule 5 of the Code of Civil Procedure, 1908 ("CPC"), which seems to me more or less the habitual and automatic chanting of every respondent in a Section 9 Petition, this needs to be stated: that is not the lawd The recent decision of the Division Bench of this Court (RD Dhanuka and VG Bhisht JJ) in Essar House Private Limited v Arcellor Mittal Nippon Steel India Ltd9 makes it clear that there is no requirement that for such relief an iron-clad case under Order 38 Rule 5 of the Code of Civil Procedure, 1908 ("CPC") must be made out (or, if not argued, that the Court must hunt for it)d The Division Bench reafrmed the principle that has long been settled, and restated repeatedly, but which seem to be reagitated in the wrong way again and againd The Division Bench said in the clearest terms that the principles of the CPC, including especially Order 38 Rule 5, are guides to a Section 9 Court and the order it makes under that Sectiond They are not fetters upon the Section 9 Court's discretiond On my reading of the Division Bench order, the position in law is that in such a case an order of deposit not only can be made, but ought to be maded In Valentine Maritime Ltd v Kreuz Subsea Pte Ltd & Anr ,10 the Division Bench of this Court reiterated this position regarding Order 38 Rule 5 and also held that in appropriate case, where the defence is prima facie untenable, the Petitioner has a chance of success, and the defence is moonshine, an order of deposit to secure the claim can and indeed should be made under Section 9d This was also the view of another Division Bench of this Court in Jagdish Ahuja & Anr v 92021 SCC OnLine Bom 149d 10 2021 SCC OnLine Bom 75, (paragraphs 88, 95 to 97 and 101)d Page 15 of 18 5th March 2021 11-CARBPL87-2020.DOC Cupino Ltdd11 All three decisions referenced and explained the previous Division Bench decision in Nimbus Communications Ltd v Board of Control for Cricket in India,12 and the Supreme Court decision in Adhunik Steels Ltd v Orissa Manganese & Minerals (P) Ltdd13 I followed the Division Bench decisions (referencing this law) in Parle Agro Pvt Ltd v Shree Aqua Purifer Pvt Ltd 14 and IIFL Finance Ltd v Shrenik Dhirajmal Siroyad15
Bombay High Court Cites 12 - Cited by 12 - R D Dhanuka - Full Document

Valentine Maritime Ltd vs Kreuz Subsea Pte Ltd. And Another on 22 January, 2021

31. Lest it be argued either here or in any other forum that no case has been made out under Order 38 Rule 5 of the Code of Civil Procedure, 1908 ("CPC"), which seems to me more or less the habitual and automatic chanting of every respondent in a Section 9 Petition, this needs to be stated: that is not the lawd The recent decision of the Division Bench of this Court (RD Dhanuka and VG Bhisht JJ) in Essar House Private Limited v Arcellor Mittal Nippon Steel India Ltd9 makes it clear that there is no requirement that for such relief an iron-clad case under Order 38 Rule 5 of the Code of Civil Procedure, 1908 ("CPC") must be made out (or, if not argued, that the Court must hunt for it)d The Division Bench reafrmed the principle that has long been settled, and restated repeatedly, but which seem to be reagitated in the wrong way again and againd The Division Bench said in the clearest terms that the principles of the CPC, including especially Order 38 Rule 5, are guides to a Section 9 Court and the order it makes under that Sectiond They are not fetters upon the Section 9 Court's discretiond On my reading of the Division Bench order, the position in law is that in such a case an order of deposit not only can be made, but ought to be maded In Valentine Maritime Ltd v Kreuz Subsea Pte Ltd & Anr ,10 the Division Bench of this Court reiterated this position regarding Order 38 Rule 5 and also held that in appropriate case, where the defence is prima facie untenable, the Petitioner has a chance of success, and the defence is moonshine, an order of deposit to secure the claim can and indeed should be made under Section 9d This was also the view of another Division Bench of this Court in Jagdish Ahuja & Anr v 92021 SCC OnLine Bom 149d 10 2021 SCC OnLine Bom 75, (paragraphs 88, 95 to 97 and 101)d Page 15 of 18 5th March 2021 11-CARBPL87-2020.DOC Cupino Ltdd11 All three decisions referenced and explained the previous Division Bench decision in Nimbus Communications Ltd v Board of Control for Cricket in India,12 and the Supreme Court decision in Adhunik Steels Ltd v Orissa Manganese & Minerals (P) Ltdd13 I followed the Division Bench decisions (referencing this law) in Parle Agro Pvt Ltd v Shree Aqua Purifer Pvt Ltd 14 and IIFL Finance Ltd v Shrenik Dhirajmal Siroyad15
Bombay High Court Cites 16 - Cited by 20 - R D Dhanuka - Full Document

Purple Medical Solutions Pvt Ltd vs Miv Therapeutics Inc on 27 January, 2015

12. Chloro Controls has never been over-ruledd It has never been held not to be good lawd It was applied in Chatterjee Petrochem Co v Page 6 of 18 5th March 2021 11-CARBPL87-2020.DOC Haldia Petrochemicals Ltdd3 In Purple Medical Solutions (P) Ltd v MIV Therapeutics Inc,4 the Supreme Court observed that the involvement of the 2nd respondent in that case brought it squarely within the frame of Chloro Controlsd
Supreme Court - Daily Orders Cites 6 - Cited by 16 - R Gogoi - Full Document

3. The Hon'Ble Supreme Court In The Case ... vs . Orissa Manganese And Minerals Pvt. ... on 2 April, 2013

31. Lest it be argued either here or in any other forum that no case has been made out under Order 38 Rule 5 of the Code of Civil Procedure, 1908 ("CPC"), which seems to me more or less the habitual and automatic chanting of every respondent in a Section 9 Petition, this needs to be stated: that is not the lawd The recent decision of the Division Bench of this Court (RD Dhanuka and VG Bhisht JJ) in Essar House Private Limited v Arcellor Mittal Nippon Steel India Ltd9 makes it clear that there is no requirement that for such relief an iron-clad case under Order 38 Rule 5 of the Code of Civil Procedure, 1908 ("CPC") must be made out (or, if not argued, that the Court must hunt for it)d The Division Bench reafrmed the principle that has long been settled, and restated repeatedly, but which seem to be reagitated in the wrong way again and againd The Division Bench said in the clearest terms that the principles of the CPC, including especially Order 38 Rule 5, are guides to a Section 9 Court and the order it makes under that Sectiond They are not fetters upon the Section 9 Court's discretiond On my reading of the Division Bench order, the position in law is that in such a case an order of deposit not only can be made, but ought to be maded In Valentine Maritime Ltd v Kreuz Subsea Pte Ltd & Anr ,10 the Division Bench of this Court reiterated this position regarding Order 38 Rule 5 and also held that in appropriate case, where the defence is prima facie untenable, the Petitioner has a chance of success, and the defence is moonshine, an order of deposit to secure the claim can and indeed should be made under Section 9d This was also the view of another Division Bench of this Court in Jagdish Ahuja & Anr v 92021 SCC OnLine Bom 149d 10 2021 SCC OnLine Bom 75, (paragraphs 88, 95 to 97 and 101)d Page 15 of 18 5th March 2021 11-CARBPL87-2020.DOC Cupino Ltdd11 All three decisions referenced and explained the previous Division Bench decision in Nimbus Communications Ltd v Board of Control for Cricket in India,12 and the Supreme Court decision in Adhunik Steels Ltd v Orissa Manganese & Minerals (P) Ltdd13 I followed the Division Bench decisions (referencing this law) in Parle Agro Pvt Ltd v Shree Aqua Purifer Pvt Ltd 14 and IIFL Finance Ltd v Shrenik Dhirajmal Siroyad15
Madras High Court Cites 3 - Cited by 11 - V K Sharma - Full Document

Parle Agro Pvt Ltd vs Shree Aqua Purifier Pvt Ltd on 12 February, 2021

31. Lest it be argued either here or in any other forum that no case has been made out under Order 38 Rule 5 of the Code of Civil Procedure, 1908 ("CPC"), which seems to me more or less the habitual and automatic chanting of every respondent in a Section 9 Petition, this needs to be stated: that is not the lawd The recent decision of the Division Bench of this Court (RD Dhanuka and VG Bhisht JJ) in Essar House Private Limited v Arcellor Mittal Nippon Steel India Ltd9 makes it clear that there is no requirement that for such relief an iron-clad case under Order 38 Rule 5 of the Code of Civil Procedure, 1908 ("CPC") must be made out (or, if not argued, that the Court must hunt for it)d The Division Bench reafrmed the principle that has long been settled, and restated repeatedly, but which seem to be reagitated in the wrong way again and againd The Division Bench said in the clearest terms that the principles of the CPC, including especially Order 38 Rule 5, are guides to a Section 9 Court and the order it makes under that Sectiond They are not fetters upon the Section 9 Court's discretiond On my reading of the Division Bench order, the position in law is that in such a case an order of deposit not only can be made, but ought to be maded In Valentine Maritime Ltd v Kreuz Subsea Pte Ltd & Anr ,10 the Division Bench of this Court reiterated this position regarding Order 38 Rule 5 and also held that in appropriate case, where the defence is prima facie untenable, the Petitioner has a chance of success, and the defence is moonshine, an order of deposit to secure the claim can and indeed should be made under Section 9d This was also the view of another Division Bench of this Court in Jagdish Ahuja & Anr v 92021 SCC OnLine Bom 149d 10 2021 SCC OnLine Bom 75, (paragraphs 88, 95 to 97 and 101)d Page 15 of 18 5th March 2021 11-CARBPL87-2020.DOC Cupino Ltdd11 All three decisions referenced and explained the previous Division Bench decision in Nimbus Communications Ltd v Board of Control for Cricket in India,12 and the Supreme Court decision in Adhunik Steels Ltd v Orissa Manganese & Minerals (P) Ltdd13 I followed the Division Bench decisions (referencing this law) in Parle Agro Pvt Ltd v Shree Aqua Purifer Pvt Ltd 14 and IIFL Finance Ltd v Shrenik Dhirajmal Siroyad15
Bombay High Court Cites 15 - Cited by 10 - G S Patel - Full Document

Iifl Finance Ltd. (Erstwhile India ... vs Shrenik Dhirajmal Siroya on 18 February, 2021

31. Lest it be argued either here or in any other forum that no case has been made out under Order 38 Rule 5 of the Code of Civil Procedure, 1908 ("CPC"), which seems to me more or less the habitual and automatic chanting of every respondent in a Section 9 Petition, this needs to be stated: that is not the lawd The recent decision of the Division Bench of this Court (RD Dhanuka and VG Bhisht JJ) in Essar House Private Limited v Arcellor Mittal Nippon Steel India Ltd9 makes it clear that there is no requirement that for such relief an iron-clad case under Order 38 Rule 5 of the Code of Civil Procedure, 1908 ("CPC") must be made out (or, if not argued, that the Court must hunt for it)d The Division Bench reafrmed the principle that has long been settled, and restated repeatedly, but which seem to be reagitated in the wrong way again and againd The Division Bench said in the clearest terms that the principles of the CPC, including especially Order 38 Rule 5, are guides to a Section 9 Court and the order it makes under that Sectiond They are not fetters upon the Section 9 Court's discretiond On my reading of the Division Bench order, the position in law is that in such a case an order of deposit not only can be made, but ought to be maded In Valentine Maritime Ltd v Kreuz Subsea Pte Ltd & Anr ,10 the Division Bench of this Court reiterated this position regarding Order 38 Rule 5 and also held that in appropriate case, where the defence is prima facie untenable, the Petitioner has a chance of success, and the defence is moonshine, an order of deposit to secure the claim can and indeed should be made under Section 9d This was also the view of another Division Bench of this Court in Jagdish Ahuja & Anr v 92021 SCC OnLine Bom 149d 10 2021 SCC OnLine Bom 75, (paragraphs 88, 95 to 97 and 101)d Page 15 of 18 5th March 2021 11-CARBPL87-2020.DOC Cupino Ltdd11 All three decisions referenced and explained the previous Division Bench decision in Nimbus Communications Ltd v Board of Control for Cricket in India,12 and the Supreme Court decision in Adhunik Steels Ltd v Orissa Manganese & Minerals (P) Ltdd13 I followed the Division Bench decisions (referencing this law) in Parle Agro Pvt Ltd v Shree Aqua Purifer Pvt Ltd 14 and IIFL Finance Ltd v Shrenik Dhirajmal Siroyad15
Bombay High Court Cites 4 - Cited by 10 - G S Patel - Full Document
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