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Bhatia International vs Bulk Trading S. A. & Anr on 13 March, 2002

The judgment in Bhatia [Bhatia International v. Bulk Trading S.A., (2002) 4 SCC 105] has been expressly overruled by a five-Judge Bench in BALCO [BALCO v. Kaiser Aluminium Technical Services Inc., (2012) 9 SCC 552 : (2012) 4 SCC 13/54 https://www.mhc.tn.gov.in/judis ( Uploaded on: 25/10/2025 04:04:41 pm ) O.A.No.194 of 2025 (Civ) 810] . Pursuant thereto, a proviso has now been inserted to Section 2(2) which only makes it clear that where, in an arbitration which takes place outside India, assets of one of the parties are situated in India and interim orders are required qua such assets, including preservation thereof, the courts in India may pass such orders. It is important to note that the expression “international commercial arbitration” is specifically spoken of in the context of a place of arbitration being outside India, the consequence of which is an arbitral award to be made in such place, but which is enforced and recognised under the provisions of Part II of the Arbitration Act. The context of this expression is, therefore, different from the context of the definition of “international commercial arbitration” contained in Section 2(1)(f), which is in the context of such arbitration taking place in India, which only applies “unless the context otherwise requires”. The four sub- clauses contained in Section 2(1)(f) would make it clear that the definition of the expression “international commercial arbitration” contained therein is party-centric in the sense that at least one of the parties to the arbitration agreement should, inter alia, be a person who is a national of or habitually resident in any country other than India. On the other hand, when “international 14/54 https://www.mhc.tn.gov.in/judis ( Uploaded on: 25/10/2025 04:04:41 pm ) O.A.No.194 of 2025 commercial arbitration” is spoken of in the context of taking place outside India, it is place-centric as is provided by Section 44 of the Arbitration Act. This expression, therefore, only means that it is an arbitration which takes place between two parties in a territory outside India, the New York Convention applying to such territory, thus making it an “international” commercial arbitration.”
Supreme Court of India Cites 33 - Cited by 263 - S N Variava - Full Document
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