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Tag: #DelhiHighCourt

Delhi High Court Upholds Arbitral Award: Scope of Judicial Review u/s 34 of the Arbitration and Conciliation Act, 1996
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 18.08.2026

Delhi High Court Upholds Arbitral Award: Scope of Judicial Review u/s 34 of the Arbitration and Conciliation Act, 1996

This Short Article has been prepared & written by Arbitrator Shobhit Mallik. The views expressed are based on his interpretation of the law. He can be reached at his email id shobhit.Ica23@gmail.com .

A recent judgment by the Delhi High Court has brought clarity to the scope of judicial intervention in arbitral awards under Section 34 of the Arbitration and Conciliation Act, 1996. The case involved a contractual dispute between India Tourism Development Corporation (ITDC) and Bajaj Electricals Ltd. (BEL) regarding specialized illumination work at the Safdarjung Tomb Monument in New Delhi. This article provides a detailed analysis of the dispute, the arbitral award, the grounds for challenge, and the court’s findings.

Background of the Dispute
- Project Overview: ITDC awarded BEL a contract for the supply, installation, testing, and commissioning of state-of-the-art lighting at Safdarjung Tomb, following a competitive tender process.
- Contractual Timeline:
  1. Tender submitted by BEL on 6 February 2007.
  2. Letter of Intent issued on 4 April 2007 for Rs. 2,08,90,095/-.
  3. Detailed work order and contract signed in May 2007, incorporating General Conditions of Contract (GCC).
- Execution Issues:
- During execution, media reports highlighted alleged damage to the monument, prompting the Archaeological Survey of India (ASI) to revise fixture layouts and require new approvals.
- BEL completed the revised work, and ASI took over the installation in June 2009.
- BEL submitted a final bill of Rs. 1,18,95,572/- but faced delays in payment, leading to disputes and eventual arbitration.
The Arbitral Award
- Award Details:
  - Principal amount of Rs. 46,92,298.22/- awarded to BEL.
  - Interest of Rs. 33,27,886/- (from July 2009 to April 2013) and Rs. 31,17,742.91/- as pendente lite interest (April 2013 to October 2018).
  - Future interest from the date of award until payment.
- ITDC’s Challenge:
  - ITDC filed a petition under Section 34 to set aside the award, alleging errors in contract interpretation, non-consideration of deductions, and excessive interest.
Key Contentions and Court’s Analysis

1. Total Value of Work and Deductions
- ITDC’s Argument: The arbitrator ignored legitimate deductions (Rs. 11,07,832/-) for non-execution or substitution of materials, as recorded in the Measurement Book.
- Court’s Finding: The arbitrator based the award on evidence, including ITDC’s own admissions. Deductions recorded after 13 August 2008 (not signed by all parties) were rightly excluded. No patent illegality was found.
2. Statutory Deductions (ESI/EPF, Service Tax, Labour Cess)
- ITDC’s Argument: Amounts withheld for ESI/EPF, service tax, and labour cess were already deposited with authorities, and BEL failed to provide adequate proof.
- Court’s Finding: BEL submitted required indemnity bonds and challans. The arbitrator’s acceptance of these documents was within his discretion and based on contract terms.
3. Interest Rate
- ITDC’s Argument: The 12% per annum interest awarded was excessive.
- Court’s Finding: The arbitrator has wide discretion under Section 31(7) of the Act to award interest. The rate was not so unreasonable as to shock the court’s conscience.
4. Post-Award Payments
- ITDC’s Argument: A payment of Rs. 13,93,368/- made after the award should be adjusted against the principal for future interest calculation.
- Court’s Finding: Such adjustments are to be addressed at the execution stage, not under Section 34 proceedings.
Legal Principles Affirmed
- Limited Scope of Section 34: The court reiterated that it does not sit in appeal over arbitral awards. Interference is limited to grounds such as patent illegality, violation of public policy, or fundamental procedural errors.
- Respect for Arbitrator’s Findings: If the arbitrator’s view is plausible and based on evidence, courts will not substitute their own conclusions, even if another view is possible.
- Interest Awards: Arbitrators have discretion to award reasonable interest unless expressly barred by contract.
Conclusion

The Delhi High Court dismissed ITDC’s petition, upholding the arbitral award in favor of Bajaj Electricals Ltd. This judgment reinforces the principle of minimal judicial interference in arbitral awards and underscores the importance of clear contractual compliance and documentation in public works contracts.

This case serves as a significant reference for parties involved in government contracts and arbitration, highlighting the need for meticulous record-keeping and the finality of arbitral decisions within the statutory framework.

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Delhi High Court

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August 18, 2026
Enforceability of Shareholders’ Agreements in Auditor Appointments
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 17.08.2026

Enforceability of Shareholders’ Agreements in Auditor Appointments

This Short Article has been prepared & written by Arbitrator Shobhit Mallik. The views expressed are based on his interpretation of the law. He can be reached at his email id shobhit.Ica23@gmail.com .

The recent judgment in the case of DHANUKA AGRITECH PRIVATE LIMITED vs. IOTECHWORLD AVIGATION PRIVATE LIMITED & ORS. provides a significant precedent on the interplay between Shareholders’ Agreements (SHA), Articles of Association (AoA), and the rights of investors in private companies. This article explores the background, legal arguments, and implications of the case for corporate governance and shareholder protections in India.

Background of the Dispute
- Investment and Agreements: DHANUKA AGRITECH invested Rs. 30 crores in IOTECHWORLD AVIGATION, with the investment governed by a definitive SHA. The SHA included specific safeguards for the investor, notably requiring an affirmative vote from the investor’s nominee director for key decisions, including the appointment of auditors.
- Board Resolution: Despite these provisions, the Board of IOTECHWORLD appointed M/s SC Verma and Co. as statutory auditors without obtaining the required affirmative vote, leading to a dispute and arbitration.
Key Legal Issues
1. Binding Nature of SHA vs. AoA:
  - The core issue was whether the SHA’s provisions, especially those requiring affirmative votes for certain decisions, are enforceable if not incorporated into the AoA.
2. Waiver of Rights:
  - The respondents argued that the investor had waived its rights by conduct, while the appellant insisted that any waiver must be in writing as per the SHA.
Arguments and Judicial Reasoning

Appellant’s Position (DHANUKA AGRITECH)
- Enforceability of SHA: Clauses 3.3.9 and 3.4.1 of the SHA require written consent from the investor’s nominee director for auditor appointments.
- Company as Party: The SHA was signed by both shareholders and the company, making it binding on all parties.
- No Written Waiver: The SHA explicitly requires any waiver to be in writing, which had not occurred.
Respondents’ Position
- Primacy of AoA: Citing legal precedents, the respondents argued that unless SHA provisions are incorporated into the AoA, they cannot override the AoA.
- Alleged Waiver by Conduct: They claimed the investor had, by its actions, waived the right to an affirmative vote.
Court’s Analysis
- Supreme Court Precedents: The judgment referenced key Supreme Court decisions, including Vodafone International Holdings BV v. Union of India, which clarified that while SHAs are private contracts, their provisions cannot override the AoA unless incorporated.
- Company as Signatory: The court distinguished this case from others by noting that the company itself was a party to the SHA, making its terms binding on the company.
- No Conflict with AoA: There was no inherent conflict between the SHA and AoA; the SHA simply added an extra layer of protection for the investor.
- No Written Waiver: The court found no evidence of a written waiver, as required by the SHA.
Outcome and Immediate Impact
- Stay on Auditor Appointment: The court stayed the board resolution appointing the auditor and the majority arbitral order, pending final disposal of the appeal.
- Regulatory Compliance: The court noted that the company could seek an extension from regulatory authorities if needed due to the stay.
Broader Implications for Corporate Governance
1. Importance of Incorporating SHA Provisions into AoA:
  - While SHAs can provide additional protections, their enforceability against the company is strongest when the company is a signatory and when provisions are reflected in the AoA.
2. Investor Protections:
  - Affirmative vote clauses are common to protect minority or strategic investors. This case reinforces their validity when properly documented and agreed upon by all parties, including the company.
3. Written Waivers:
  - Parties must strictly adhere to contractual requirements for waivers; informal or implied waivers may not be recognized.
Conclusion

The DHANUKA AGRITECH case underscores the need for clarity and diligence in drafting and implementing SHAs, especially regarding their relationship with the AoA. For investors and companies alike, ensuring that key contractual protections are both agreed upon and properly incorporated into company governance documents is essential for enforceability and effective corporate management.

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Source: Delhi High Court

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August 17, 2026
Delhi HC Affirms Importers’ Right to Refund of Excess Customs Duty Paid Without Assessment Order u/s 27 of Customs Act
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 17.08.2026

Delhi HC Affirms Importers’ Right to Refund of Excess Customs Duty Paid Without Assessment Order u/s 27 of Customs Act

This Short Article has been prepared & written by Advocate Ravi Shekhar Jha-Delhi High Court, New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com .

Aman Medical Products Ltd. found itself in a legal dispute after inadvertently paying a higher customs duty on imported goods. The company failed to claim a concessional rate available under Notification No. 6/2002 dated 1.3.2002 due to ignorance and paid the excess duty while filing the Bill of Entry. The central question was whether an importer who pays excess duty by mistake, without an assessment order or contest, can claim a refund under Section 27 of the Customs Act, 1962.

Legal Issue

The Customs, Excise and Service Tax Appellate Tribunal (CESTAT) had previously ruled that a refund could only be claimed if the excess duty was paid “in pursuance to an order of assessment.” According to CESTAT, without an assessment order, the importer could not seek a refund unless an appeal was filed against such an order.

High Court’s Analysis

The Delhi High Court, presided over by Justices A.K. Sikri and Valmiki J. Mehta, examined Section 27 of the Customs Act, 1962. The Court highlighted two key points:
1. Alternative Grounds for Refund: Section 27(1) allows a refund claim for duty “paid by him in pursuance of an order of assessment” or “borne by him.” The use of “or” means these are alternative grounds. Thus, a refund can be claimed even if the duty was not paid under an assessment order.
2. No Assessment Order Required: The Court clarified that if duty is paid without an assessment order—such as in cases of ignorance or inadvertence—the importer is still entitled to claim a refund under Section 27(1)(ii).
The Court distinguished this case from earlier Supreme Court judgments (CCE, Kanpur v. Flock (India) Pvt. Ltd. and Priya Blue Industries Ltd. v. Commissioner of Customs), noting that those cases involved a formal assessment order and a failure to appeal, which was not the situation here.

Judgment and Outcome

The High Court set aside the CESTAT’s order and upheld the order of the Commissioner of Customs (Appeal). The matter was remanded to the Deputy Commissioner of Customs (Refund) to examine the merits of Aman Medical Products Ltd.’s refund claim. The Court confirmed that the company’s claim was maintainable under Section 27 of the Customs Act, even without an assessment order or a prior appeal.

Key Takeaways
1. Importers’ Rights: Importers who pay excess customs duty by mistake, without an assessment order, can claim a refund under Section 27(1)(ii) of the Customs Act.
2. No Appeal Requirement: The absence of an appeal against the Bill of Entry does not bar the importer from seeking a refund.
3. Legal Clarity: The judgment clarifies the scope of Section 27, ensuring that procedural technicalities do not prevent genuine refund claims.
This decision strengthens the rights of importers and provides clear guidance on the interpretation of refund provisions under Indian customs law.

Connected Matter

Delhi High Court Clarifies Limitation Law in Customs Refunds

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Source: Delhi High Court

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August 17, 2026
Delhi High Court Clarifies Limitation Law in Customs Refunds
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 14.08.2026

Delhi High Court Clarifies Limitation Law in Customs Refunds

This Short Article has been prepared & written by Advocate Ravi Shekhar Jha-Delhi High Court, New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com .

A recent batch of appeals before the Delhi High Court has brought significant clarity to the application of limitation law in customs refund cases. Senior India Pvt Ltd, a prominent importer, challenged several orders of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) regarding the classification of imported goods and the timeliness of their refund claims. This article provides a detailed overview of the case, the legal issues involved, and the implications of the Court’s decision.

Background of the Case

Senior India Pvt Ltd imported pressure relief valves, which were initially classified under Customs Tariff Item (CTI) 8481 40 00. From September 2018, the company began declaring these goods under CTI 8409 99 41 and paid a higher duty, reportedly at the insistence of Customs authorities. Fourteen Bills of Entry were assessed between September 2018 and February 2019, with two additional Bills in March and May 2019.

The legal landscape at the time, shaped by earlier Delhi High Court decisions, allowed importers to seek refunds under Section 27 of the Customs Act even if the assessment had not been appealed. Acting on this, Senior India filed two refund applications on 26 August 2019, within the statutory one-year period.

The Turning Point: Supreme Court Judgment in ITC Limited

While the refund proceedings were pending, the Supreme Court delivered a landmark judgment in ITC Limited v. Commissioner of Central Excise, Kolkata-IV (2019), holding that a refund claim could not be entertained unless the assessment was first modified in appeal. This fundamentally changed the legal basis for refund claims.

Within days, Senior India sought to amend the Bills of Entry under Section 149 of the Customs Act and requested that refund proceedings be kept in abeyance. However, the refund authority rejected one claim as premature, and the company subsequently filed appeals under Section 128, seeking exclusion of the period spent on the refund process from the limitation period, invoking principles from Section 14 of the Limitation Act.

Key Legal Issues

The High Court focused on two main questions:
1. Whether the authorities were justified in denying the benefit of Section 14 of the Limitation Act to Senior India, given the change in law by the Supreme Court’s ITC Limited judgment.
2. Whether CESTAT was correct in dismissing an appeal as time-barred when the underlying appeal had been filed within the prescribed period.
The Court’s Analysis and Findings
- Application of Section 14 Principles: The Court recognized that while the Limitation Act does not directly apply to customs appeals, the principles underlying Section 14 (exclusion of time spent in bona fide proceedings) do apply. The Court found that Senior India had acted diligently, pursuing remedies as per the law prevailing at the time, and promptly adjusted its approach after the Supreme Court’s decision.
- Exclusion of Time: The period during which Senior India pursued the refund remedy and sought amendment of Bills of Entry was excluded from the limitation calculation. The Court held that, due to the legal transition caused by the ITC Limited judgment, the authorities should have allowed this exclusion.
- Statutory Extension Due to COVID-19: The Court also noted that the period for filing appeals was further extended by government notifications issued during the COVID-19 pandemic, making Senior India’s appeals timely.
- Error in Dismissing Appeals as Time-Barred: In one case, the Court found that the appeal had been filed well within the statutory period, and its dismissal by CESTAT as time-barred was manifestly erroneous.
Outcome and Directions
- The High Court set aside the orders of CESTAT and the Commissioner (Appeals) that had rejected Senior India’s appeals on limitation grounds.
- The appeals were restored for decision on merits, with instructions to the authorities not to revisit the limitation issue.
- The Court directed that the restored appeals be decided within four months, and that refund and amendment applications be processed in accordance with the final outcome.
Implications of the Judgment

This decision is significant for importers and legal practitioners dealing with customs disputes:
1. Clarifies Limitation Law: The judgment affirms that bona fide pursuit of remedies under the law as it stood can justify exclusion of time from limitation, especially when the legal position changes due to a higher court ruling.
2. Ensures Fairness: The Court’s approach prevents penalizing parties for following the law as it existed before a judicial shift.
3. Guidance for Future Cases: The decision provides a roadmap for handling similar disputes where refund claims or appeals are affected by changes in legal interpretation.
Conclusion

The Delhi High Court’s ruling in the Senior India Pvt Ltd case underscores the importance of judicial flexibility and fairness in applying limitation law, especially in the context of evolving legal standards. Importers and legal professionals should take note of this precedent when navigating refund and appeal processes under the Customs Act.

Connected Matter

Delhi HC Affirms Importers’ Right to Refund of Excess Customs Duty Paid Without Assessment Order u/s 27 of Customs Act

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Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Delhi High Court

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August 14, 2026
Delhi HC on Scope of IP-I Registration, Telecom Licensing, and Arbitral Award Review under Section 34 of the Arbitration and Conciliation Act, 1996
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 13.08.2026

Delhi HC on Scope of IP-I Registration, Telecom Licensing, and Arbitral Award Review under Section 34 of the Arbitration and Conciliation Act, 1996

This Short Article has been prepared & written by Arbitrator Shobhit Mallik. The views expressed are based on his interpretation of the law. He can be reached at his email id shobhit.Ica23@gmail.com .

The Delhi High Court recently delivered a significant judgment in the case between the Union of India (Department of Telecommunications) and Sterlite Technologies Limited, addressing complex issues around telecom infrastructure licensing, regulatory compliance, and the scope of arbitral review. This article provides a detailed analysis of the dispute, the legal arguments, and the implications of the court’s decision.

Background of the Dispute

Sterlite Technologies Limited (STL), a leading provider of digital network solutions, was granted an Infrastructure Providers Category-I (IP-I) Registration Certificate by the Department of Telecommunications (DoT). This certificate authorized STL to provide passive telecom infrastructure, such as fiber ducts and related facilities, but explicitly barred it from dealing with active telecom equipment or providing end-to-end bandwidth services, which require a separate telecom service provider (TSP) license.

STL, through its wholly owned subsidiary Speedon Network Limited (SNL), entered into Master Service Agreements (MSAs) with various TSPs, notably Citycom Networks and Microscan Computers. The payment structure under these agreements was based on subscriber base and revenue sharing, rather than traditional lease rentals for passive infrastructure. The DoT alleged that STL, via these arrangements, was effectively functioning as a TSP without the necessary license, thereby violating the terms of its IP-I registration and causing loss of government revenue.

Key Events Leading to Arbitration
1. Inspection and Allegations:
  - In February 2015, DoT inspected STL’s premises in Pune and concluded that STL was operating beyond its permitted scope by selling bandwidth and managing active equipment through SNL.
  - The inspection report alleged unauthorized services and revenue evasion exceeding Rs. 2.5 crores.
2. Correspondence and Show Cause Notice:
  - STL provided detailed responses, clarifying that active equipment belonged to the TSPs, not STL or SNL.
  - In July 2018, DoT issued a show cause notice for violation of IP-I terms, followed by a demand notice in August 2020 for Rs. 8.55 crores.
3. Arbitration Proceedings:
  - STL challenged the demand, invoking the arbitration clause in the IP-I certificate.
  - The arbitrator ruled in favor of STL, declaring the demand notice illegal, arbitrary, and unjustified.
Legal Arguments Presented

Union of India (Petitioner)
- Ownership and Operation: Argued that STL and SNL, as related entities, owned and operated active equipment without a license, and that billing based on bandwidth proved provision of end-to-end services.
- Damages: Claimed inherent right to seek damages for breach of registration terms, even without explicit contractual provisions.
Sterlite Technologies Limited (Respondent)
- Separation of Entities: Emphasized that SNL and STL are legally distinct, with SNL holding its own IP-I registration and later a unified license.
- Scope of Services: Asserted that STL only provided passive infrastructure, with active equipment and bandwidth services managed and billed by the TSPs.
- Contractual Interpretation: Highlighted that the MSAs and subsequent novation agreements clarified the roles and responsibilities, limiting STL to passive infrastructure.
Court’s Analysis and Findings

The High Court, upholding the arbitrator’s award, made several key observations:
1. Scope of IP-I Registration:
  - The regulatory framework and the IP-I certificate clearly prohibit IP-I holders from providing active services or end-to-end bandwidth.
  - The evidence showed STL provided only passive infrastructure, with TSPs responsible for active equipment and subscriber services.
2. Ownership of Equipment:
  - The court found no conclusive proof that STL owned or operated active equipment. Lease agreements and correspondence supported STL’s position.
3. Billing and Revenue Model:
  - The MSAs did not establish that STL’s charges were based on bandwidth utilization by end subscribers. The arbitrator’s factual findings on this point were upheld.
4. Legal Entity Distinction:
  - SNL and STL were recognized as separate legal entities, each with distinct registrations and licenses. The court rejected the argument that SNL was merely a façade for STL.
5. Demand Notice Validity:
  - The demand notice lacked statutory backing, as there was no provision in the IP-I certificate or the Indian Telegraph Act for such a penalty. The court emphasized that damages under Section 73 of the Indian Contract Act require proof of actual loss, which was absent.
6. Scope of Judicial Review:
  - The court reiterated the limited scope of interference under Section 34 of the Arbitration and Conciliation Act, stating that plausible views taken by arbitrators should not be disturbed unless they are patently illegal or contrary to public policy.
Implications of the Judgment
- Regulatory Clarity: The judgment reinforces the distinction between passive infrastructure providers and licensed TSPs, providing clarity for industry participants.
- Arbitral Autonomy: It underscores the judiciary’s deference to arbitral awards, limiting court intervention to narrow grounds.
- Contractual Precision: The case highlights the importance of clear contractual definitions and compliance with regulatory frameworks in the telecom sector.
Conclusion

The Delhi High Court’s decision in Union of India vs. Sterlite Technologies Limited sets an important precedent for telecom infrastructure regulation and the enforcement of arbitral awards. By upholding the arbitrator’s reasoned findings and emphasizing the limits of judicial review, the court has provided valuable guidance for both industry stakeholders and legal practitioners.

Connected Matter

Supreme Court on Taxation of Offshore Indirect Transfers and Cross-Border M&A

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Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Delhi High Court

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August 13, 2026
Delhi High Court Sets Aside Arbitral Award Due to Unilateral Appointment of Arbitrator by Government Authority
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 11.08.2026

Delhi High Court Sets Aside Arbitral Award Due to Unilateral Appointment of Arbitrator by Government Authority

This Short Article has been prepared & written by Arbitrator Shobhit Mallik. The views expressed are based on his interpretation of the law. He can be reached at his email id shobhit.Ica23@gmail.com .

The Delhi High Court recently delivered a significant judgment in the case of Union of India vs. M/S Goodrich Foodtech Ltd., addressing crucial issues surrounding the unilateral appointment of arbitrators in government contracts. This article provides a comprehensive overview of the dispute, the arbitral proceedings, the legal principles involved, and the implications of the Court’s decision.

Background of the Dispute
1. Tender and Contract Formation
  - The Union of India invited bids for the supply of 1,390 MT of malted milk food with cocoa for the Defence sector for the year 2017-18.
  - M/S Goodrich Foodtech Ltd. emerged as the successful bidder, leading to five separate but identical contracts, each specifying delivery periods and quantities.
  - The respondent furnished performance bank guarantees totaling Rs. 2,49,87,020/- as per contract requirements.
2. Emergence of Disputes
  - After partial fulfillment of the contracts, the Union of India issued a defect notice, alleging the supplied product contained soya protein and non-milk fat (palm oil), contrary to contract specifications.
  - This led to show-cause notices, termination of four contracts, forfeiture and encashment of bank guarantees, and debarment of Goodrich Foodtech Ltd. from future procurements.
3. Arbitration Proceedings
  - Goodrich Foodtech Ltd. invoked the arbitration clause, and a sole arbitrator was appointed by the Competent Financial Authority (CFA) of the Ministry of Defence.
  - The arbitrator ruled largely in favor of Goodrich Foodtech Ltd., awarding substantial sums and quashing the termination, forfeiture, and debarment actions.
Key Legal Issues Examined

1. Unilateral Appointment of Arbitrator
- The core issue was whether the appointment of the sole arbitrator by the CFA (an official of the Union of India, a party to the dispute) was valid under Section 12(5) of the Arbitration and Conciliation Act, 1996.
- The Court examined whether mere participation in arbitration or lack of objection constituted a waiver of the right to challenge such an appointment.
2. Waiver under Section 12(5) of the Arbitration Act
- The Court relied on Supreme Court precedents, emphasizing that a waiver of ineligibility under Section 12(5) must be an “express agreement in writing” after the dispute has arisen.
- Conduct, participation, or implied consent does not amount to a valid waiver.
3. Jurisdiction and Validity of Arbitral Award
- The Court held that an award passed by an ineligible, unilaterally appointed arbitrator is a nullity and can be set aside under Section 34 of the Act.
- Even the party that made the unilateral appointment retains the right to challenge the award on this ground.
Court’s Findings and Decision
- The Court found that the appointment of the arbitrator by the CFA, an official of the Ministry of Defence, was in violation of Section 12(5) and the Seventh Schedule of the Arbitration Act.
- There was no express written waiver by both parties after the dispute arose.
- The arbitral award was declared void ab initio and set aside.
Implications of the Judgment
1. Reinforcement of Party Autonomy and Neutrality
  - The judgment reinforces the principle that both parties must have an equal say in the appointment of arbitrators, ensuring neutrality and fairness in arbitral proceedings.
2. Strict Compliance with Section 12(5)
  - Any arbitration agreement allowing unilateral appointment of arbitrators is invalid unless expressly waived in writing after the dispute arises.
  - Participation in proceedings or silence does not constitute a waiver.
3. Impact on Government Contracts
  - Government agencies must review and revise standard arbitration clauses to comply with the law and avoid similar pitfalls.
  - Awards rendered by unilaterally appointed arbitrators are vulnerable to being set aside, even if both parties participated in the proceedings.
Conclusion

The Delhi High Court’s decision in Union of India vs. Goodrich Foodtech Ltd. is a landmark ruling that clarifies and strengthens the legal framework governing the appointment of arbitrators in India. It underscores the necessity for express, written waivers and equal participation in the appointment process, setting a precedent for future contractual and arbitral practices, especially in government procurement.

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Delhi High Court

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August 11, 2026
Quashing of Criminal Proceedings under the Food Safety and Standards Act, 2006
Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 10.08.2026

Quashing of Criminal Proceedings under the Food Safety and Standards Act, 2006

This Short Article has been prepared & written by Advocate Madhumita Jha-Bombay High Court. The views expressed are based on her interpretation of the law. She can be reached at her email id jhamadhumita27@gmail.com .

A recent judgment by the Delhi High Court has brought closure to long-standing criminal proceedings against various parties involved in the sale and distribution of MAGGI Noodles, stemming from the nationwide food safety controversy of 2015. This article provides a detailed overview of the case, the legal arguments, and the court’s reasoning that led to the quashing of the prosecutions.

Background: The MAGGI Noodles Controversy

In May 2015, Food Safety Officers in Delhi collected samples of MAGGI Noodles from retail outlets as part of a nationwide sampling exercise. The samples were tested, and initial reports from the Food Analyst indicated that the lead content in the masala tastemaker exceeded the permissible limit of 2.5 ppm. Additionally, some samples were alleged to be misbranded due to the “No Added MSG” label.

These findings led to criminal complaints against retailers, suppliers, and the manufacturer, Nestlé India Limited, under the Food Safety and Standards Act, 2006 (FSS Act). The accused sought to quash these proceedings, arguing that the basis for prosecution was no longer valid.

Legal Proceedings and Arguments

Petitioners’ Submissions
1. Invalidity of Laboratory Reports: Petitioners argued that the prosecution relied solely on Food Analyst reports from laboratories that were neither NABL accredited nor notified under Section 43 of the FSS Act, as required by law. This position was supported by the Bombay High Court’s 2015 judgment, which set aside the nationwide ban on MAGGI Noodles for similar reasons.
2. Subsequent Testing and Judicial Findings: Following the Bombay High Court’s directions, fresh samples were tested by accredited laboratories, all of which found the lead content within permissible limits. The Supreme Court also directed testing by the Central Food Technological Research Institute (CFTRI), which confirmed the product’s safety.
3. Supersession of State Laboratory Reports: Under Section 46(4) of the FSS Act, the Referral Food Laboratory’s report supersedes the Food Analyst’s report. Since the Referral Laboratory found the product compliant, the original reports lost evidentiary value.
4. Abuse of Process: Petitioners contended that continuing the prosecution would be an abuse of the court’s process, as the scientific foundation of the case had been undermined by subsequent findings and judicial pronouncements.
State’s Submissions
1. Procedural Compliance: The State argued that all sampling and testing procedures were followed as per the FSS Act, and the accused had the opportunity to seek referral analysis but did not exercise this right.
2. Validity of State Laboratory: The State maintained that, under transitional provisions, State Food Testing Laboratories could continue functioning until formal notification and accreditation, which was later obtained.
3. Independence of Criminal Proceedings: The State asserted that the criminal complaints were independent and should proceed to trial, as the issues involved required evidence and could not be decided summarily.
Court’s Analysis and Findings

The High Court examined the entire sequence of events and legal developments:
1. Judicial Scrutiny of Laboratory Reports: The Bombay High Court and Supreme Court had already scrutinized the validity of the laboratory reports and directed fresh testing by accredited and notified laboratories.
2. Referral Laboratory Findings: The CFTRI, a Referral Laboratory, found the lead content within permissible limits. The Supreme Court directed that these findings should form the basis for adjudication.
3. Erosion of Prosecution’s Foundation: The court noted that the prosecution was based solely on the original Food Analyst’s reports, which had been superseded and discredited by subsequent scientific and judicial review.
4. Abuse of Process: Continuing the criminal proceedings would serve no useful purpose and would amount to an abuse of the court’s process, as the very foundation of the prosecution had eroded.
The court also referenced similar decisions by the Himachal Pradesh and Uttarakhand High Courts, which quashed prosecutions arising from the same controversy.

Conclusion and Impact

The Delhi High Court allowed the petitions, quashing the criminal complaints, summoning orders, and all consequential proceedings. This judgment reinforces the importance of scientific rigor, statutory compliance, and judicial oversight in food safety prosecutions. It also provides clarity for businesses and consumers regarding the standards and processes that must be followed in such cases.

The decision marks a significant closure to the MAGGI Noodles controversy, emphasizing that prosecutions cannot continue when their scientific and legal basis has been invalidated by subsequent authoritative findings.

Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

Source: Delhi High Court

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August 10, 2026
Delhi High Court Strikes Down Retrospective Withdrawal of Export Incentives
Aadrikaa Legal Services (ALS) – IDT Tax I Arbitration I Litigation

Date: 04.07.2026

Delhi High Court Strikes Down Retrospective Withdrawal of Export Incentives

This Short Article has been prepared & written by Advocate Ravi Shekhar Jha-Delhi High Court, New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com .

A recent judgment by the Delhi High Court has significant implications for exporters and the administration of export incentive schemes in India. The case, involving Malik Tanning Industries and M/s Kavish Impex Pvt. Ltd. versus the Union of India, addressed the legality of a retrospective circular issued by the Directorate General of Foreign Trade (DGFT) that curtailed export incentives under the Focus Product Scheme (FPS).

Background: The Focus Product Scheme and the Dispute

The Focus Product Scheme (FPS), part of the Foreign Trade Policy (FTP) 2009-2014, was designed to incentivize exports of products with high export intensity or employment potential. Exporters of notified products, as listed in Appendix 37D of the Handbook of Procedures, were entitled to Duty Credit Scrips equivalent to 2% of the Free on Board (FOB) value of their exports.

Malik Tanning Industries and Kavish Impex exported polyester printed and dyed fabrics, which were classified as “Technical Textiles – Woven Fabrics of Synthetic Filament Yarn” under ITC (HS) Code 5407. These products were eligible for FPS benefits at the time of export, and the exporters had already received and utilized the incentives.

The Controversial Circular

On 21 October 2011, DGFT issued Policy Circular No. 42, which retrospectively limited FPS benefits for “Technical Textiles” to only 33 items, effective from 1 April 2011. This excluded many products, including those exported by the petitioners, from the incentive scheme. The authorities subsequently demanded the return of Duty Credit Scrips or refund of the duty amounts with interest from the exporters.

Legal Issues Examined

The core legal questions addressed by the Court were:
1. Can DGFT issue a circular that retrospectively withdraws export incentives already granted under the Foreign Trade Policy?
2. Does DGFT have the authority to amend the list of eligible products for incentives with retrospective effect?
Court’s Analysis and Findings

1. Nature of DGFT’s Powers
- The Foreign Trade Policy is framed by the Central Government under Section 5 of the Foreign Trade (Development and Regulation) Act, 1992.
- DGFT’s role is limited to implementing the policy and clarifying procedural or interpretational doubts, not making substantive policy changes.
- Section 6(3) of the Act specifically excludes the delegation of policy-making powers under Section 5 to DGFT.
2. Retrospective Policy Changes
- The Court held that neither the Central Government nor DGFT can make or amend policy with retrospective effect unless expressly empowered by the statute.
- The Supreme Court’s precedents were cited, emphasizing that vested or accrued rights cannot be taken away by retrospective policy changes unless clearly authorized by law.
3. Interpretation of “Technical Textiles”
- The Court found the classification of “Technical Textiles – Woven Fabrics of Synthetic Filament Yarn” under ITC (HS) Code 5407 to be clear and unambiguous.
- The impugned circular did not clarify an ambiguity but instead substantively restricted the scope of eligible products, which is beyond DGFT’s powers.
4. Vested Rights and Constitutional Protection
- The benefits already availed by the exporters constituted vested rights, protected under Article 300A of the Constitution (right to property).
- The attempt to recover incentives already granted was found to be unlawful.
Judgment and Impact

The Delhi High Court set aside the DGFT’s circular and the subsequent demand letters, ruling that:
- DGFT cannot retrospectively withdraw export incentives already granted under the Foreign Trade Policy.
- Any substantive change to the list of eligible products must be prospective and made by the Central Government, not DGFT.
- Exporters who had already received FPS benefits for eligible products at the time of export cannot be asked to return them due to later policy changes.
Conclusion

This judgment reinforces the principle that government authorities cannot retrospectively alter or withdraw benefits granted under statutory policies unless explicitly authorized by law. It provides much-needed certainty and protection for exporters relying on government incentive schemes, ensuring that vested rights are not arbitrarily taken away.

Connected Matter

Delhi High Court Quashes Retrospective Withdrawal of MEIS Benefits for FIBC Exporters

Source: Delhi High Court

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July 4, 2026
Delhi HC Ruled on MEIS Benefits: Customs Authorities Cannot Override DGFT Classification for Handcrafted Stone Exporters
Aadrikaa Legal Services (ALS) – IDT Tax I Arbitration I Litigation

Date: 15.06.2026

Delhi HC Ruled on MEIS Benefits: Customs Authorities Cannot Override DGFT Classification for Handcrafted Stone Exporters

This Short Article has been prepared & written by Advocate Ravi Shekhar Jha-Delhi High Court, New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com .

A recent judgment by the Delhi High Court has brought significant clarity to the legal landscape surrounding the classification and export benefits for handcrafted stone articles under the Merchandise Exports from India Scheme (MEIS). This article provides a comprehensive overview of the case, the legal arguments, and the implications for exporters and policymakers.

Background: The Dispute Over Classification and MEIS Benefits

The controversy arose when exporters of handcrafted stone and marble articles, such as rolling boards, mortars, and pestles, faced objections from customs authorities regarding the classification of their products. Exporters had long classified these goods under ITC(HS) 68159990, a residual category for stone articles, and claimed MEIS benefits accordingly. However, a 2019 communication from the Central Board of Indirect Taxes and Customs (CBIC) suggested these products should be classified under CTH 6802, which did not attract MEIS benefits.

This led to audit objections, demands for refund of MEIS benefits, and issuance of summons to exporters, prompting legal challenges by several exporters, including M/s Sharma International and M/s Amit Exports.

Key Legal Issues Examined

1. Classification of Handcrafted Stone Articles
- Exporters argued that their products, being handicrafts, rightfully belonged under ITC(HS) 68159990, which was eligible for MEIS rewards (initially 5%, later increased to 7%).
- Customs authorities contended that these goods should be classified under CTH 6802, which pertains to worked monumental or building stone and does not attract MEIS benefits.
2. Authority to Decide Classification and Benefits
- The court examined whether customs authorities could override the classification accepted by the Director General of Foreign Trade (DGFT) and demand refunds of MEIS benefits.
- The Foreign Trade Policy (FTP) 2015-20 explicitly states that the DGFT’s decision on classification is final and binding.
3. Procedural Fairness and Audit Objections
- The exporters challenged the audit objection letters, arguing they were issued without proper opportunity to be heard and were based on predetermined conclusions.
- The court found that the audit process did not comply with the principles of natural justice or the prescribed audit regulations.
4. Recovery of Benefits Under Customs Act Sections 28 and 28AAA
- The court analyzed whether the recovery of MEIS benefits could be justified under these sections, which require proof of collusion, wilful misstatement, or suppression of facts.
- No such allegations were substantiated against the exporters.
The Court’s Findings and Ruling
1. Finality of DGFT’s Classification: The court held that only the DGFT or the licensing authority under the Foreign Trade (Development and Regulation) Act (FTDR Act) has the power to suspend or cancel MEIS certificates. Customs authorities cannot unilaterally question or override the DGFT’s classification or the validity of MEIS scrips.
2. Invalid Audit Objections and Summons: The audit objection letters and subsequent summons were quashed. The court found that the process was arbitrary, lacked procedural fairness, and did not follow the statutory requirements for audit and recovery.
3. Refund of Amounts Collected: The court directed the authorities to refund amounts collected from the exporters during the disputed proceedings.
4. Scope for DGFT Action: While the court did not make a final determination on the correct classification, it clarified that any future action regarding the validity of MEIS certificates must be initiated by the DGFT, not customs authorities.
Implications for Exporters and Policymakers
- Exporters: Those dealing in handcrafted stone articles can rely on the DGFT’s classification for MEIS benefits unless and until the DGFT itself revises its position through due process.
- Customs Authorities: Cannot independently revoke MEIS benefits or demand refunds without a prior determination by the DGFT regarding misrepresentation or fraud.
- Policy Clarity: The judgment reinforces the need for clear, coordinated action between customs and trade authorities to avoid conflicting interpretations and ensure exporters are not subjected to arbitrary demands.
Conclusion

This judgment is a significant precedent for the export sector, especially for handicraft exporters. It upholds the primacy of the DGFT in matters of export classification and benefit eligibility, ensures procedural fairness, and protects exporters from retrospective and arbitrary recovery actions by customs authorities.

The decision also highlights the importance of inter-agency coordination and adherence to statutory processes in the administration of export incentive schemes.

Connected Matter

CESTAT Chennai Ruled on EPCG Third-Party Export Obligations and Customs Penalties

Source: Delhi High Court

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June 15, 2026
Delhi High Court Ruled on Retrospective Application of Limitation Period for Customs Duty Refunds
Aadrikaa Legal Services (ALS) – IDT Tax I Arbitration I Litigation

Date: 29.05.2026

Delhi High Court Ruled on Retrospective Application of Limitation Period for Customs Duty Refunds

This Short Article has been prepared & written by Advocate Ravi Shekhar Jha-Delhi High Court, New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com .

The Delhi High Court’s decision in the case of Sony India Pvt. Ltd. v. Commissioner of Customs, New Delhi addresses a crucial question in Indian customs law: Can a limitation period for refund claims, introduced by an amending notification, be applied retrospectively to goods imported before the notification was issued? This article provides a detailed analysis of the case, its background, legal arguments, and the implications of the court’s ruling for importers and customs authorities.

Background of the Case

Sony India Pvt. Ltd., a major importer and distributor of electronic and IT products, imported goods between December 1 and December 5, 2007. At the time, Notification No. 102/2007-Cus exempted certain goods from the Special Additional Duty of Customs (SADC) under Section 3(5) of the Customs Tariff Act, 1975, provided specific conditions were met. Notably, this original notification did not specify any time limit for filing refund claims.

On August 1, 2008, Notification No. 93/2008-Cus amended the original notification, introducing a one-year limitation period for filing refund claims from the date of payment of duty. Sony India filed a refund claim on December 11, 2008, for SADC paid on its December 2007 imports. The customs authorities partially allowed the claim but rejected refunds for four Bills of Entry, citing the new one-year limitation period.

Legal Issues and Arguments

The central legal issue was whether the one-year limitation period introduced by the amending notification could be applied retrospectively to imports made before its issuance.

Appellant’s Arguments (Sony India)
- No Limitation in Original Notification: The original notification (102/2007) did not prescribe any time limit for refund claims.
- No Retrospective Application: The amending notification (93/2008) introducing the limitation period should not apply to goods imported before its issuance.
- Accrual of Right: The right to claim a refund arises only after the subsequent sale of imported goods and payment of sales tax/VAT, which is a market-driven event outside the importer’s control.
- Legal Precedents: Cited Supreme Court judgments (e.g., New India Insurance v. Shanti Misra) stating that limitation laws in force at the time of cause of action apply, and new limitation laws cannot extinguish existing rights unless expressly stated.
- Date of Payment: Argued that the date of payment should be the date when the TR-6 challan is stamped (i.e., when the government receives the funds), not the date of the demand draft.
Respondent’s Arguments (Customs Authorities)
- Application of Amending Notification: Insisted that the one-year limitation period applied to all refund claims, including those for goods imported before the notification.
- Section 27 of Customs Act: Argued that the general refund provisions and limitation periods under the Customs Act should apply.
Court’s Analysis and Findings

The High Court undertook a detailed examination of the statutory framework and the intent behind the SADC and the relevant notifications:
- Nature of SADC: The SADC is designed to counterbalance sales tax/VAT on like goods sold in India, ensuring a level playing field for domestic and imported goods.
- Accrual of Refund Right: The right to claim a refund arises only after the importer sells the goods and pays the applicable sales tax/VAT. Thus, imposing a limitation period from the date of duty payment could unfairly extinguish the right before it even accrues.
- Section 3(8) of the Customs Tariff Act: While this section incorporates refund provisions from the Customs Act, it does so only “so far as may be applicable.” The court held that the limitation period under Section 27 does not automatically apply to SADC refunds.
- Legislative Authority: The court emphasized that substantive rights, such as limitation periods affecting refund claims, must be imposed by legislation, not by subordinate notifications.
- Retrospective Application: The amending notification could not retrospectively impose a limitation period on refund claims for goods imported before its issuance.
Key Excerpts from the Judgment

“To uphold a limitation period starting from the date of payment of duty, as prescribed in the amending notification, would amount to allowing the commencement of a limitation period for refund claims before the right of refund has even accrued.”

“The imposition of a period of limitation for the first time, without statutory amendment, through a notification, therefore could not prevail.”

Outcome

The Delhi High Court ruled in favor of Sony India, holding that:
- The one-year limitation period introduced by Notification No. 93/2008-Cus cannot be applied retrospectively to goods imported before its issuance.
- The refund claims for SADC paid on such imports are not time-barred by the amending notification.
- The appeal was allowed, and the limitation period in the amending notification was read down to this extent.
Implications of the Ruling
- For Importers: Importers who paid SADC on goods imported before August 1, 2008, can claim refunds without being restricted by the one-year limitation period introduced later.
- For Customs Authorities: Limitation periods affecting substantive rights must be clearly provided by legislation, not merely by notifications or circulars.
- Legal Precedent: The judgment reinforces the principle that subordinate legislation cannot curtail substantive rights unless expressly authorized by the parent statute.
Conclusion

The Delhi High Court’s decision in the Sony India case is a significant precedent in customs law, clarifying the limits of subordinate legislation and protecting importers’ rights to claim refunds. It underscores the importance of legislative clarity and the protection of accrued rights against retrospective curtailment by administrative notifications.

Source: Delhi High Court

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May 29, 2026