ABSTRACT:
The emergency arbitration has transformed into an essential method for supplying urgent provisional measures in commercial disputes even before the complete arbitration tribunal has been formed. The globalization of business has made it necessary to have quick and certain solutions, which then placed the enforceability of emergency arbitrator orders at the very center of arbitration’s reputation as a legal alternative. This matter is slowly turning out to be a very important one, yet there are still considerable differences among the various jurisdictions regarding the enforceability of these orders. By emphasizing the developing emergency arbitration system in India with the one that has already been established under the Singapore International Arbitration Centre (SIAC), this study spots those gaps.
The presentation of the research is such that although Singapore possesses a coherent and predictable system the support of statutory recognition under the International Arbitration Act, institutional clarity under SIAC Rules, and judicial consistent enforcement is considerable, India’s framework is still very much fragmented. The Draft Arbitration and Conciliation (Amendment) Bill, 2024, which suggests the introduction of emergency arbitrators through the introduced Section 9A, has indeed taken a big leap forward, but at the same time, there are still doubts particularly concerning the enforcement of foreign emergency arbitrator orders under Part II of the Arbitration and Conciliation Act, 1996. In addition to the conflicting institutional practices, procedural uncertainties, and inconsistent High Court attitudes, the situation in India is such that it becomes increasingly difficult to gauge the level of enforcement predictability.
This paper shows that the present emergency arbitration regime of Singapore is more efficient and trustworthy by conducting a comparative analysis of institutional design, statutory support, and judicial attitudes in both jurisdictions. The paper helps contemporary arbitration literature by not only pointing out the structural shortcomings in the Indian system but also placing them within a comparative institutional context.
Keywords:Emergency Arbitration, Enforceability, SIAC, Draft Arbitration Bill 2024, Comparative Arbitration Law.
INTRODUCTION:
In world economy, which is very dynamic, arbitration is gaining ground as the most favored way of resolving disputes due to its advantages like confidentiality, party autonomy, procedural flexibility, and efficiency compared to the courts[1]. Commercial conflicts, especially those between different countries, usually need urgent temporary protection to avoid the damage that cannot be reversed like the disappearance of assets, losing of evidence, or getting rights under contracts frustrated.[2] The setting up of a full arbitral tribunal may take some time and this time may already be enough to destroy the purpose of final relief.[3] Therefore, emergency arbitration has been recognized as an essential procedure that helps both sides to get quick measures by putting in place an emergency arbitrator just before or even soon after the setting of arbitral proceedings.[4] Such orders for relief are in nature temporary and are still to be approved, altered, or cancelled by the full arbitral tribunal that is to be established later, thus, creating a situation where urgency is handled with fairness in procedure.[5]
Emergency arbitration in India has always existed in a statutory inconsistent. The Arbitration and Conciliation Act of 1996 does not denote emergency arbitrators in a direct manner and thus the parties have to either rely on the institutional rules or seek the intervention of the court under Section 9.[6] Amazon.com NV Investment Holdings LLC v. Future Retail Ltd. (2021)[7] partially judiciously cleared the matter where the Supreme Court ruled that the emergency arbitrator’s order under the SIAC Rules during an arbitrated India is enforceable via Sections 17(1) and 17(2) of the Act.[8] Following this judicial pronouncement, the Draft Arbitration and Conciliation (Amendment) Bill, 2024, advocates the introduction of Section 9A which gives express statutory recognition to emergency arbitrators in domestic arbitrations thereby allowing the enforcement of their interim orders as tribunal orders. Nonetheless, the Draft Bill does not address the question of whether or not the orders of emergency arbitrator in foreign-seated arbitrations can be enforced which still relies on judicial discretion under Part II of the Act and the New York Convention framework, thus keeping uncertainty alive.[9]
On the other hand, Singapore has achieved a consistent and well-regulated emergency arbitration system. The International Arbitration Act (Cap. 143A), which was revised in 2012, explicitly acknowledges the existence of emergency arbitration and allows for the enforcement of arbitral awards made by such arbitrator.[10] The courts of Singapore have regularly and consistently supported this framework by giving a pro-arbitration interpretation to the rules which has been reaffirmed in CVV v. CVW (2023)[11]. The Singapore International Arbitration Centre (SIAC) has established receipt of emergency arbitration applications as a highly efficient process with expedited appointments, clearly created timelines, and strong judicial backing, resulting in high compliance and user confidence. [12]
This paper maintains that while Singapore’s emergency arbitration system is smooth, lucid, and enforceable, the one in India is still crooked, uncertain, and fragmented. The paper adopts a doctrinal comparative approach for a thorough investigation of statutory provisions, landmark cases, and rules of various institutions; it manages to pinpoint the areas in India where the enforceability of arbitration awards is lacking and measures them against the more definite framework of Singapore. Following this, the paper elaborates on India’s emerging regime, analyzes Singapore’s model, and engages in a comparative assessment of the two legal regimes to draw attention to the structural shortcomings and the need for reforms.
Development of emergency arbitration:
The evolution of emergency arbitration in legs a significant procedural inversion in innovation in international commercial arbitration it’s.[13] The its development was privately delivered by the lead for the swift interim relief in situation where waiting for a policy constitutional arbitral tribunal for approaching dashboards for defeat the purpose of the remedy international commerce introduce pre arbitral referee procedure this mechanism allowed parties to express the opted into the system to obtain temporary winding orders during critical phases of their contractual relationships.[14]
During the mid-1990s similar reform for explorer explored by the world intellectual property organization which proposed emergency relief provisions tailor to sensitive intellectual property disputes these ideas to formal shape only 2014 yet why the American Arbitration Association further advance the concept by introducing optional rules for emergency measures of protection[15]
Between 2012 in 2015 emergency arbitration became a global law where leading hospitalised suggest Swiss arbitration centre (2012) HKIAC (2013) LCIA (2014)CIETAC(2015) introduce global emergency mechanisms these institutional reforms collectively transformed AA from the experimental procedure into a mainstream feature of disaster arbitrary as mechanism become more widely available so this in some other institution indicates a substantial rise in the number of emergency application filed across sectors such as construction maritime infrastructure corporate transaction investment agreements.[16]
Literature Review:
Scholarly engagement with Emergency Arbitration (EA) has primarily focused on its institutional evolution and procedural design, with comparatively limited attention to questions of enforceability.[17]A detailed and systematic examination of this issue is undertaken in the NUJS Law Review (2021), which critically analyses emergency arbitration mechanisms across major Indian arbitral institutions and identifies significant structural and procedural lacunae in domestic EA rules.[18] The study evaluates frameworks adopted by institutions such as MCIA, NDIAC, ICA, MHCAC, NPAC, BIMACC, and IIAM, demonstrating that Indian EA regimes suffer from the absence of opt-out mechanisms, inadequate procedural flexibility, unclear timelines, limited powers vested in emergency arbitrators, and silence on the availability of parallel court remedies.[19] This work is particularly significant as it situates Indian institutional rules against internationally recognised EA standards and establishes that domestic mechanisms fall short of global best practices.[20]
Early international scholarship by Jan Paulsson conceptualised emergency relief as a procedural necessity arising from the inability of traditional arbitral tribunals to respond to urgent disputes, thereby laying the theoretical foundation for EA mechanisms.[21] Subsequent commentary by Horning and other scholars reinforced the importance of emergency relief in preserving the effectiveness of arbitration, particularly in complex commercial and intellectual property disputes. However, much of this literature assumes effective enforceability in arbitration-friendly jurisdictions and does not sufficiently interrogate enforcement challenges in jurisdictions lacking express statutory recognition.[22]
Institutional literature and practitioner analyses focusing on the Singapore International Arbitration Centre (SIAC) consistently present emergency arbitration as a highly efficient and enforceable mechanism, supported by clear procedural rules and express statutory recognition under Singapore’s International Arbitration Act.[23] These studies explain SIAC’s dominance in global EA usage but are largely descriptive in nature and offer limited critique of cross-border enforceability issues, particularly from the perspective of enforcement in foreign jurisdictions such as India.[24]
Indian academic and judicial discourse gained renewed momentum following the Supreme Court’s decision in Amazon.com NV Investment Holdings LLC v. Future Retail Ltd., which recognised the enforceability of a foreign-seated emergency arbitrator’s order under Section 17 of the Arbitration and Conciliation Act, 1996.[25] While commentators have welcomed this judgment as a pro-arbitration shift, several scholars caution that reliance on judicial interpretation cannot substitute for legislative clarity.[26]Recent commentary on the Draft Arbitration & Conciliation (Amendment) Bill, 2024 reflects cautious optimism, particularly with the proposed introduction of Section 9A recognising emergency arbitrators; however, the literature has not yet comprehensively assessed whether the amendment sufficiently addresses the institutional and enforcement deficiencies identified in earlier scholarship.
RESEARCH QUESTION :
“To what extent does the Draft Arbitration & Conciliation (Amendment) Bill, 2024 enhance the enforceability of Emergency Arbitration orders in Indiaparticularly those arising from foreign-seated emergency arbitrationsand how does this newly enacted statutory framework measure up to the well-established SIAC/Singapore model in terms of legal clarity, procedural efficiency, and judicial backing?”
The Enforcement Framework in India:
Arbitration Draft Bill,2024 :
Pre 2024 status India’s arbitration law development is a reflection of a planned institutionalization agenda, however, the ongoing loophole regarding emergency arbitrator (EA) orders particularly in cross-border disputes has affected both procedural efficiency and investor trust.[27] The revolutionary amendments of 2015 started a new chapter by the application of the territoriality principle which was never the case before when relief under Section 9 was limited to domestic arbitrations only[28]. They did not however grant statutory recognition to EA mechanisms, thereby, leaving a significant enforcement vacuum.[29] While the Supreme Court in Amazon v. Future (2021) recognized foreign-seated EA orders, its logiclinked to the New York Convention through Part II of the Acthas created doctrinal uncertainty for domestic-seated EA and has not been able to develop a coherent enforcement framework[30]. This judicial improvisation, while being virtuous, has exposed India’s dependence on case-by-case solutions instead of a principled statutory regime.[31] On the other hand, Singapore’s 2012 International Arbitration Act amendments unequivocally recognized “arbitral tribunal” to include EAs and provided clear enforcement mechanisms which in effect made it predictable. Thus, India’s pre-2024 situation was still fragmented: the parties could apply for court-appointed provisional measures in support of foreign arbitration but at the same time, they could not depend on a quicker, arbitral alternative within the same litigation for reliable enforcement.[32]
In this case, Bharat Aluminium Co. v. Kaiser Aluminum Technical Services, the Indian courts were ruled to be excluded from granting interim relief prospectively concerning foreign seated arbitration.[33]
The Delhi High Court in Raffles Design International India Pvt. Ltd. v. Educomp Professional Education Ltd. (2016) discussed the scope of interim relief provided under Section 9 of the Arbitration and Conciliation Act, 1996 with respect to foreign seated arbitrations[34]. The Court asserted that Section 9 petitions can be filed even if the arbitration is conducted outside India as long as the parties have not expressly barred its applicability.[35] The Court, in its interpretation of Section 26 of the 2015 Amendment Act, stated that its exclusion only pertains to arbitral proceedings that were already initiated in India before 23 October 2015, and therefore, does not prevent judicial proceedings that are related to foreign seated arbitrations.[36] The Court further clarified that Section 9 petitions are separate from arbitration proceedings thus they are subject to the jurisdiction of Indian courts. Moreover, the Court denied the argument that the selection of Singapore law and SIAC Rules meant the exclusion of Part I of the Act, thereby ruling that Indian courts can still issue interim measures to safeguard the rights of the parties to the contract even if an Emergency Arbitrator’s ruling has been secured abroad.
In the case of Ashwani Minda v. U‑Shin (Delhi High Court, 2020),the Court faced a scenario where the claimants were requesting provisional measures under Section 9 of the Arbitration and Conciliation Act, 1996, despite having already resorted to emergency arbitration as per the JCAA Rules[37]. The emergency arbitrator rejected their application and the claimants tried to bring the same matter back to the court for adjudication. The High Court ruled that it was not permissible to use Section 9 as a way to review or annul the decision of the emergency arbitrator[38]. The parties are not allowed to approach Indian courts for the same relief after having invoked the emergency arbitration mechanism and having received a reasoned order.
In the case of Amazon v. Future Retail (Supreme Court, 2021)[39], the Supreme Court made a remarkable decision by confirming the enforceability of emergency arbitrator awards through Section 17 of the Arbitration and Conciliation Act. Even though the statutory definition provided in Section 2(1)(d) does not clearly state that emergency arbitrators are included in the term “arbitral tribunal”, the Court was guided by the intent of the law and thus, allowed the interpretation that emergency arbitrators under SIAC Rules are governed by Section 17(1) and their orders are enforceable under Section 17(2). This ruling was a turning point in the Indian arbitration system getting in line with the global standards, until there is a legislated recognition like the Draft Bill 2024..
Post-2024, the Draft Arbitration and Conciliation (Amendment) Bill[40] is determined to put to rest the long-standing issues related to the enforcement of emergency arbitration by way of a legislative design that is both subtle and well-crafted.[41] The proposed Section 9A allows emergency arbitrators to receive explicit statutory acknowledgment and, most importantly, stipulates that their decisions will be treated as if they were rendered by a competent arbitral tribunal under Section 17 thus being enforceable. This reform goes further than just legalizing the Supreme Court’s ruling in the Amazon.com NV Investment Holdings LLC v. Future Retail Ltd. case as it has already developed a single, streamlined enforcement path that is not implicitly restricted by the seat of arbitration. The Draft Bill has made the enforcement process in India more pro-arbitration through the 2015 amendments since it allows the enforcement of emergency arbitrator orders in the case of foreign-seated arbitrations without the requirement of a separate award-enforcement process under the Part II of the Act[42]. At the same time, the Draft Bill supports an arbitration model that is more centered on institutions by transferring the control over the procedural matters, including the extension of time limits in accordance with Section 29A[43], from courts to accredited arbitral institutions. This change not only reinforces the authority of the institutions but also increases their efficiency, thus bringing India’s arbitration practices closer to those of the more developed markets like Singapore where emergency arbitration is viewed as an integral and smooth part of the arbitration process rather than a subject of judicial intervention.[44]
The Draft Bill has actively recognised, and this is notably the case with its being changed. The Department of Legal Affairs carried out a post-draft stakeholder consultation process after the bill was published in October 2024, and among the groups involved were arbitral institutions, legal practitioners, corporate users, and academics. The focus of the submissions during this phase was on the practical implementation of Section 9A, the ability of institutions to effectively carry out emergency arbitration, and the lack of any clear statutory guidance on the grounds for resisting enforcement of emergency orders. The various stakeholders also raised concerns about the different capacities of the institutions making it difficult for them to adopt the same procedures, and at the same time pointed out that judicial consistency is necessary for statutory recognition to be able to yield practical effect. The mentioned interpretive issues, including the exact parameters of enforcement objections, will be judicially interpreted. Nevertheless, the consultative phase represents a conscious shift away from case-by-case judicial gap-filling toward underwriting deliberative, institution-driven arbitration reform. The combination of the 2024 Draft Bill and its consultative process indicates India’s move to a more competitive, trustworthy, and internationally compatible arbitration regime that will be characterized by speed, certainty, and cross-border enforceability.
Comparative Analysis Between India and Singapore in Emergency Arbitration:
A comparative assessment of emergency arbitration (EA) between Singapore and India reveals a significant divergence in institutional credibility, practical usage, and enforceability confidence.[45]Empirical indicators from the period 2021–2024 demonstrate that while EA has become an established and routinely invoked mechanism under the Singapore International Arbitration Centre (SIAC), Indian arbitral institutions such as the Delhi International Arbitration Centre (DIAC)and the Mumbai Centre for International Arbitration (MCIA)[46] exhibit minimal observable EA utilisation.[47] This disparity is not merely statistical but reflects deeper structural and systemic differences in how emergency arbitration is positioned within each jurisdiction’s arbitration ecosystem.[48]
SIAC’s published institutional data offers transparent insight into EA usage. According to the SIAC Annual Report 2024, SIAC received 21 applications for the appointment of emergency arbitrators in 2024, all of which were accepted, marking the highest annual figure since the mechanism’s inception.[49] Earlier years show consistent engagement, with SIAC reporting 15 EA applications in 2021, 12 in 2022, and 11 in 2023[50]. Cumulatively, SIAC has administered over 170 emergency arbitration applications since 2010.[51] This sustained and increasing use indicates that EA under SIAC is not an exceptional or experimental remedy but an integral and trusted part of its arbitral framework.[52]
In contrast, Indian arbitral institutions do not publish comparable EA-specific datasets. Publicly available reports and institutional disclosures from DIAC and MCIA primarily focus on aggregate case filings and disposals, without segregating or highlighting emergency arbitration applications.[53] Practitioner commentary and secondary reporting suggest that EA invocation within Indian institutions during the same period has been extremely limited, with only sporadic instances, if any, of formal EA proceedings.[54] While both DIAC and MCIA rules contain provisions for emergency arbitrators, the absence of reported usage indicates that rule-level adoption has not translated into meaningful institutional practice.[55]
This empirical divergence aligns with parties’ demonstrated preferences in high-stakes and time-sensitive disputes. SIAC’s 2025 Annual Report notes that Indian parties constitute approximately 40% of users across SIAC-administered arbitrations, including emergency proceedings.[56] This suggests that Indian corporate entities, particularly those engaged in cross-border transactions, consciously opt for SIAC-seated arbitration when urgent interim relief is anticipated.[57] The preference is attributable to SIAC’s predictable timelinesemergency arbitrators are appointed within 24 hours, and interim orders are generally issued within 14 daysas well as the certainty of enforceability under Singapore law.[58]
The enforceability architecture further explains this trend. Singapore’s International Arbitration Act, amended in 2012, expressly recognises emergency arbitrators within the statutory definition of an arbitral tribunal, enabling their orders to be enforced in the same manner as tribunal-issued interim measures.[59] Singaporean courts have consistently reinforced this approach, as reaffirmed by the Court of Appeal in CVV v. CVW (2023)[60], thereby creating a coherent enforcement environment.
India’s framework, by contrast, has evolved unevenly. Judicial recognition of EA emerged through Amazon.com NV Investment Holdings LLC v. Future Retail Ltd. (2021), where the Supreme Court upheld the enforceability of an emergency arbitrator’s order in an India-seated arbitration under Section 17 of the Arbitration and Conciliation Act, 1996[61]. The Draft Arbitration and Conciliation (Amendment) Bill, 2024, through proposed Section 9A, seeks to codify this position for domestic arbitrations.[62]However, enforcement of foreign-seated emergency arbitrator orders remains dependent on judicial discretion under Part II of the Act, resulting in divergent High Court approaches.[63] Earlier cases such as Raffles Design International India Pvt Ltd v. Educomp Professional Education Ltd. (Delhi High Court, 2016) and Avitel Post Studioz Ltd v. HSBC PI Holdings (Bombay High Court, 2020)[64] illustrate this inconsistency, where courts granted protective relief but stopped short of directly enforcing foreign EA orders as such.[65]
RECOMMENDATION :
To put in place a trustworthy and efficient emergency arbitration (EA) framework in India, the reforms should be directed towards reinforcing procedural certainty, enforceability, and institutional capacity, while at the same time being considerate of India’s federal judicial structure and the varied arbitral ecosystem[66]. Instead of fully importing the SIAC model, India should pick and choose those traits that have been shown to help Singapore.[67]
First, the Indian arbitral institutions should apply stricter procedural rules in the case of emergency arbitration. The SIAC’s experience demonstrates that the emergency arbitrators’ appointment and interim orders’ issuing with clearly set time frames put the user confidence on a higher level[68]. Although a very strict time limit such as a 24-hour appointment may not be practicable in all the cases in India, having reasonable outer limits would create less uncertainty and prevent tactical delays from occurring thus making EA a reliable option for court-based interim relief.[69]
Second, there is a very convincing argument for the adoption of similar procedures throughout the Indian arbitral institutions. The Draft Arbitration and Conciliation (Amendment) Bill, 2024, while introducing statutory recognition of emergency arbitrators through proposed Section 9A, still leaves institutional rules governing EA to vary widely.[70] Disparities in appointment modes, deadlines, and fee arrangements among institutions such as DIAC and MCIA add to the fragmentation and the tendency to choose the forum[71]. Setting up a minimum standard for procedures while allowing freedom for each institution to choose its own way to some extent, will foster uniformity and increase the trust in the institutions.[72]
Thirdly, the statutory changes should definitely involve addressing the confusion around the enforcement of orders of emergency arbitrators based at foreign countries. The interpretation by the courts under Part II of the Arbitration and Conciliation Act has resulted in different High Court rulings.[73] The little legislative clarification on recognition and enforcement would not only reduce litigation risks but would also bring India closer to the international practice in this respect.[74]
In the same way, the creation of judicial capacity is crucial for emergency arbitration to be successful. The differences in the approaches of the High Courts are a clear indication that the legislative change is not enough[75]. Specialized arbitration benches, training programs, and uniform interpretive guidance would contribute to predictability and strengthen the trust in the enforcement of EA orders.[76]
Finally, Indian arbitration institutions should not lose sight of the cost and accessibility issues.Emergency arbitration could not be turn into a ‘luxury remedy’ applicable only to high-value disputes.[77] The adoption of tiered fee structures and the implementation of expedited procedures for domestic disputes would guarantee wider access and continued use.[78]
Conclusively, the reforms mentioned above can change the situation of statutory recognition to operational effectiveness and eventually narrow the gap of enforceability in India’s emergency arbitration system.[79]
[1]Wuraola O Durosaro, ‘The Role of Arbitration in International Commercial Disputes’ (2014) 1(3) International Journal of Humanities Social Sciences and Education 1.
[2]International Chamber of Commerce, Report of the ICC Commission on Arbitration and ADR Task Force on Emergency Arbitrator Proceedings (ICC 2019).
[3]Jan Paulsson, ‘Urgent Interim Relief in International Arbitration’ (1990) 8 Arbitration International 1.
[4]Pallab Das & Sakshi Dara, ‘Emergency Arbitration: Is the Case Really an Emergency?’ (2023) 5(2) CMR University Journal for Contemporary Legal Affairs 70.
[5]Abhinav Gupta &SriroopaNeogi, ‘Emergency Arbitration in India: A Critical Appraisal of the Institutional Framework’ (2021) 14(4) NUJS Law Review 640
[6]Elamathi J, ‘Enforcement of Emergency Arbitration: Indian Standpoint’ (2022) Indian Journal of Integrated Research in Law.
[7]Amazon.com NV Investment Holdings LLC v. Future Retail Ltd., 2021 SCC OnLine SC 204
[8]Draft Arbitration and Conciliation (Amendment) Bill, 2024 (India).
[9] URafael Dean Brown, ‘Challenging the Enforcement of Emergency Arbitrator Decisions’ (2020).
[10]International Arbitration Act 1994 (Cap 143A) (Singapore), s 2 (as amended in 2012).
[11]CVV v CVW [2023] SGCA
[12]Singapore International Arbitration Centre, SIAC Rules (2016); Abhinav Gupta &SriroopaNeogi (n 5).
[13]Gary B Born, International Commercial Arbitration (2nd edn, Kluwer Law International 2014) vol II.
[14]International Chamber of Commerce, Rules for a Pre-Arbitral Referee Procedure (ICC 1990).
[15]World Intellectual Property Organization, WIPO Arbitration Rules (2014);American Arbitration Association, Optional Rules for Emergency Measures of Protection (AAA 2006).
[16]Swiss Chambers’ Arbitration Institution, Swiss Rules of International Arbitration (2012);Hong Kong International Arbitration Centre, HKIAC Administered Arbitration Rules (2013);London Court of International Arbitration, LCIA Arbitration Rules (2014);China International Economic and Trade Arbitration Commission, CIETAC Arbitration Rules (2015).
[17]Gary B. Born, International Commercial Arbitration Kluwer Law International, Alphen aan den Rijn, 2nd edn., 2014.
[18]Abhinav Gupta &SriroopaNeogi, ‘Emergency Arbitration in India: A Critical Appraisal of the Institutional Framework’ (2021) supra.
[19]ibid.
[20]ibid.
[21]Thomas J Horning, ‘Emergency Arbitrators: A Practical Solution for Urgent Interim Relief’ (2012) International Arbitration Law Review.
[22]Gary B Born, International Commercial Arbitration (2nd edn, Kluwer Law International 2014) supra.
[23] Singapore Int’l Arb. Ctr. (SIAC), Arbitration Rules r. 30 & sch. 1 (7th ed. 2016); International Arbitration Act (Cap. 143) (Sing.).
[24] Nicholas Peacock & Jake Savile-Tucker, A Decade of Emergencies in Stockholm, Herbert Smith Freehills (2020)
[25]Amazon.com NV Investment Holdings LLC v. Future Retail Ltd., (2022) 1 SCC 209 supra.
[26]Aritra Gupta and Anushree Neogi, “Emergency Arbitration in India” 14 NUJS Law Review 1 2021 supra.
[27]OECD, Investor Confidence and Dispute Resolution Mechanisms (OECD Publishing 2018).
[28]Law Commission of India, 246th Report on Amendments to the Arbitration and Conciliation Act, 1996 (2014).
[29]UNCITRAL, Model Law on International Commercial Arbitration (1985, as amended 2006).
[30]Amazon.com NV Investment Holdings LLC v Future Retail Ltd (2021) supra.
[31]Sundaresh Menon, ‘International Arbitration: The Coming of a New Age’ (2017) Singapore Academy of Law Journal.
[32]Gary B Born, International Arbitration and Forum Selection Agreements (Kluwer Law International 2018) supra.
[33]Bharat Aluminium Co v Kaiser Aluminium Technical Services Inc (2012) 9 SCC 552
[34]Raffles Design International India Pvt Ltd v Educomp Professional Education Ltd (2016) SCC OnLine Del 5521.
[35]ibid.
[36]ibid.
[37] Japan Commercial Arbitration Association, Commercial Arbitration Rules 2021 Japan Commercial Arbitration Association, Tokyo, 2021
[38]Ashwani Minda v U-Shin Ltd (2020) SCC OnLine Del 244.
[39] Amazon.com NV Investment Holdings LLC v. Future Retail Ltd., (2022) 1 SCC 209 supra.
[40]Ministry of Law and Justice, Explanatory Note to the Draft Arbitration and Conciliation (Amendment) Bill, 2024 (India).
[41]ibid.
[42] Arbitration and Conciliation Act, 1996, Part II
[43] Draft Arbitration Bill 2024, cl. 8 (amending § 29A)
[44] Law Commission of India, 246th Report (2014)
[45]Sundaresh Menon, ‘Transnational Arbitration: The Singapore Experience’ (2018) 30 Singapore Academy of Law Journal 1.
[46] MCIA Rules 2025
[47]Singapore International Arbitration Centre, SIAC Annual Report 2024 (SIAC 2024).
[48]Gary B Born, International Commercial Arbitration (2nd edn, Kluwer Law International 2014) supra.
[49]Singapore International Arbitration Centre, SIAC Annual Report 2024 (SIAC 2024).
[50]Singapore International Arbitration Centre, SIAC Annual Reports 2021–2023 (SIAC).
[51]ibid.
[52]Julian D M Lew, Loukas A Mistelis & Stefan Kröll, Comparative International Commercial Arbitration (Kluwer Law International 2003).
[53]Delhi International Arbitration Centre, Annual Report 2023 (DIAC).
[54]Pallab Das & Sakshi Dara, ‘Emergency Arbitration: Is the Case Really an Emergency?’ (2023) supra.
[55]Abhinav Gupta &SriroopaNeogi, ‘Emergency Arbitration in India: A Critical Appraisal of the Institutional Framework’ (2021) supra.
[56]Singapore International Arbitration Centre, SIAC Annual Report 2025 (SIAC 2025)
[57]OECD, Arbitration and Cross-Border Investment Confidence (OECD Publishing 2020).
[58]Singapore International Arbitration Centre, SIAC Rules (2016).
[59]International Arbitration Act 1994 (Cap 143A) (Singapore), s 2 (as amended in 2012).
[60]CVV v. CVW, [2023] SGCA 43
[61]Amazon.com NV Investment Holdings LLC v Future Retail Ltd (2021) supr
[62]Draft Arbitration and Conciliation (Amendment) Bill, 2024 (India).
[63]UNCITRAL, Guide on the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (2016).
[64]Avitel Post Studioz Ltd v HSBC PI Holdings (Mauritius) Ltd (2020) SCC OnLine Bom 227; Raffles Design International India Pvt Ltd v Educomp Professional Education Ltd (2016) supra.
[66]Gary B Born, International Commercial Arbitration supra.
[67]Sundaresh Menon, ‘Transnational Arbitration: The Singapore Experience’ supra.
[68]Singapore International Arbitration Centre, SIAC Rules supra.
[69]Julian D M Lew, Loukas A Mistelis & Stefan Kröll, Comparative International Commercial Arbitration supra.
[70]Draft Arbitration and Conciliation (Amendment) Bill, 2024 supra.
[71]Abhinav Gupta &SriroopaNeogi supra.
[72]UNCITRAL, Notes on Organising Arbitral Proceedings supra.
[73]UNCITRAL, Guide on the New York Convention supra.
[74]UNCTAD, Reform of Investor–State Dispute Settlement supra.
[75]Law Commission of India, 246th Report supra.
[76]Vidya Drolia v Durga Trading Corporation supra.
[77]Pallab Das & Sakshi Dara supra.
[78]OECD, Arbitration and Cross-Border Investment Confidence supra.
[79]Ministry of Law and Justice, Explanatory Note to the Draft Arbitration and Conciliation (Amendment) Bill, 2024 supra.
