In this judgement, the Supreme Court of India considers whether bias of an arbitrator can be subsumed in S. 48 (2) of the Arbitration Act, 1996 while challenging enforcement of award.
He question of whether S. 9 (interim measures) of the Arbitration and Conciliation Act, 1996 is available for detaining cargo as security for international commercial arbitration outside India.
This interesting issue was decided by the Supreme Court of India while considering whether pre-arbitration negotiations can be excluded in computing limitation.