Enforcement of foreign decrees in India (Section 44A of CPC)

“USE OF PUBLIC POLICY DOCTRINE IN ARBITRAL AWARDS”

FACULTY OF LAW

CIVIL PROCEDURE CODE – I CLINICAL COURSE – I

“Enforcement of foreign decrees in India (Section 44A of

CPC)USE OF PUBLIC POLICY DOCTRINE IN ARBITRAL
AWARDS”

SUBMITTED BY: - SUBMITTED TO: -

PRIYAM (s/f) 48 Prof. Rajesh ShardaDr.

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Eqbal Hussain

B.A. LL.B (HONS Civil Procedure Code- I)

PROF. (ADR)

Table Of Content

Acknowledgment…………………………………………………………………………… 3

Introduction…………………………………………………………………………………...4

SECTION 44A AND ITS APPLICABILITY…………………………………………....6

RECIPROCATING AND NONRECIPROCATING TERITORIES……………...8

SECTION 13 AND SECTION 44A………………………………………………………12

CONCLUSION………………………………………………………………………………….

15

Historical Overview of the Public Policy doctrine in India.......................................................6

ANALYSIS OF PUBLIC POLICY DOCTRINE IN INDIA..................................................10

Doctrine OF PUBLIC POLICY in other countries..................................................................15

I. U.S.A.............................................................................................................................15

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II. Russia............................................................................................................................16

III. France............................................................................................................................17

IV. England…………………………………………………………………..18

CONCLUSION.....................………………………………………………………………..19

RECOMMENDATIONS.........................……………………………………………………19

BIBLIOGRAPHY...…………………………………………………………..21

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ACKNOWLEDGMENT

“Project work is an art of doing things in a different manner which requires brainstorming and
a lot of research activities. It is not possible without the help and guidance of a mentor. A
major research project like this is never the work of anyone alone. The completion of the
project could not have been possible without the contribution of so many people who are
sincerely appreciated. Firstly, we would like to express heart full indebtedness and deep sense
of gratitude to our subject teachers Prof. Rajesh ShardaDr. Eqbal Hussain as their input was
crucial for understanding the fundamentals of the project. We also wish to thank our family
and friends as an inspiration and their wishes were always a guiding light for us.”

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INTRODUCTION

A judgment of an Indian court can only be enforced by proceedings in execution. A foreign

judgment, however, may be enforced by proceedings in execution in certain specified cases
only.1 In other cases, a foreign judgment can only be enforced by a suit upon the judgment.
However, it is not to be supposed that Indian courts are bound in all cases to take cognizance of
the suit, and they may refuse to entertain it on grounds of expediency.2
There was at one time difference of opinion as to whether a suit could be maintained in British
India as it was then upon the judgment of a court of an Indian state or whether the plaintiff could
sue only upon the original cause of action. The Madras High Court held that a suit could be
maintained on the judgment,3 while the Bombay High Court held that no such suit was
maintainable4 and that the only remedy was by way of a suit on the original cause of action. It is
submitted that the Bombay view was not correct since it was contrary to the general rule that a
court which entertains a suit on a foreign judgment cannot institute an inquiry into the merits of
the original claim or the propriety of decision.5 With a view to resolve the conflict of views, a
clause was added to section 14 of the Code of 1882, by section 5 of Act 7 of 1888, but that
clause was deleted in 1908 as the raison desire for such a clause was no longer tenable. 6 The
result is that the Madras view prevails.
The “recognition” of a foreign judgment occurs when the court of one country accepts a judicial
decision made by the courts of another “foreign” country, and issues a judgment in substantially

1
Code of Civil Procedure, 1908, § 44, 44A.
2
Monoharlal v. Raghunath, AIR 1957 MB 74.
3
Janoo v. Mahamad, AIR 1925 Mad 155.
4
Himmat Lall v. Shivajirav, (1884) ILR 8 Bom 593.
5
Viswanathan v. Abdul Wajid, AIR 1952 Mysore 94 (2).
6
Vasant v. Dattoba, AIR 1956 Bom 49.
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identical terms without rehearing the substance of the original lawsuit. Recognition of judgment
will be denied if the judgment is substantively incompatible with basic fundamental legal
principles in the recognizing country. The Indian Code of Civil Procedure, 1908 (CPC) lays
down the procedure for enforcement of foreign judgments and decrees in India. The basic
principle which is followed while enforcing a foreign judgment or decree in India is to ensure
that the judgment or decree is a conclusive one, passed on the merits of the case and by a
superior court having competent jurisdiction.
By virtue of section 44A of the CPC, a decree of any superior court of a reciprocating territory
shall be executed in India as a decree passed by the Indian district court. A judgment from a
court

of a reciprocating territory can be directly enforced in India by filing an execution application.

Section 44A (1) of the CPC states that where a certified copy of a decree of any superior court
of a reciprocating territory has been filed in a District Court, the decree may be executed in India
as if it had been passed by the District Court (meaning that the entire scheme of execution of
decrees as laid down in Order 21 of the CPC will be applicable).
An awareness of foreign law in the parallel jurisdiction would be a useful guideline in
determining our notions of justice and public policy. We are a Sovereign Nation within our
territory but it is not derogation of sovereignty to take accounts of foreign law. This research
work will further the applicability of section 44A in enforcement of foreign decrees and awards.

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SECTION 44A AND ITS APPLICABILITYHISTORICAL OVERVIEW OF THE

PUBLIC POLICY DOCTRINE IN INDIA.

A bare reading of the section7 indicates that for a decree of a foreign court of a reciprocating
territory to be executed in India, the foreign country must be notified as a reciprocating territory
by the Government of India in the Official Gazette. Most countries, including UK, have been so
notified by the Indian Government. By a notification dated 1 March 1953, published in the
Gazette of India, the United Kingdom of Great Britain and Northern Ireland has been notified to
be a reciprocating territory under s 44A of the CPC. Hong Kong was recognised as a
reciprocating territory under the provisions of s 44A by a notification dated 18 November1968
issued by the Government of India. Thus, the process of being notified as a reciprocating
territory is a prerequisite to the invoking of s 44A of the Code. 8 Reciprocating and non
reciprocatingnon-reciprocating countries are dealt in detail later in this project.
Section 44A is an independent provision enabling a set of litigants whose litigation has come to
an end by way of a foreign decree and who is desirous of enforcement of the same: It is an
authorization given to the foreign judgments and as noticed above, the Section is replete with
various conditions and as such independently of any other common law rights, an enabling
provision for a foreign decree-holder to execute a foreign decree in this country has been
engrafted on to statute book to wit: Section 44-A of the Code.9
The essence of section 44A was best explained by the Supreme Court in the case, M. V. AL.
Qumar v. tsavliris salvage (international) Ltd.10, where the court held that, S.44A is an
independent provision enabling a set of litigants whose litigation has come to an end by way of a
foreign decree and who is desirous of enforcement of the same. It is an authorization given to
the foreign judgments and the section is replete with various conditions and as such
independently of any other common law rights and is an enabling provision for a foreign
decreeholderdecree holder to execute a foreign decree in this country.
The court further held that, Section 44A gives a new cause of action irrespective of its original
character and as such, it cannot be termed to be emanating from the admiralty jurisdiction as
such and that, enforcement of a foreign decree is different from scheme of domestic execution.
A combined reading of section 13 and 44A makes it clear that a decree of a reciprocating

7
Code of Civil Procedure, 1908, § 44A.
8
Enforcement of Foreign Judgments and Foreign Arbitral Awards in the Indian Civil Jurisdiction, ANIL
MALHOTRA and RANJIT MALHOTRA Commonwealth Law Bulletin Vol. 32, No. 3, 431–442, September 2006.
9
MV Al Quamar v. Tsavliris Salvage (International) Ltd., AIR 2000 SC 2826.
10
MV Al Quamar v. Tsavliris Salvage (International) Ltd., AIR 2000 SC 2826.
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territory can be executed through a district court, and the judgment debtor is entitled to contest
the

execution petition if it can be shown that the judgment is not conclusive, i.e., it comes within
any of the exceptions under section 13 (a) to (f ). 11 The relevance of section 13 will be dealt in
more detail in the next chapter.

11
Yazman Hume Quarries S.D.N, B.H.D v. Chellappan, (1998- 1) 122 Mad 141 (DB)
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RECIPROCATING AND NON-RECIPROCATING AND
TERITORIESANALYSIS OF PUBLIC POLICY DOCTRINE IN INDIA

Section 44A appears to give more levy when it comes to enforcement of decrees from
reciprocating countries. This part deals with the significance of reciprocating and non-
reciprocating territories under the section and studies how the courts have taken their view at
different instances while interpreting the same.
What is a Reciprocating Territory?
The definition, explanation and scope of Reciprocating Territories of India flows from section
44-A of the Code of Civil Procedure, 1908 (the Code). A bare perusal of section 44-A of the
code suggests that a reciprocating territory means any country or territory outside India which
the Central Government may by notification in the official gazette, declare to be a reciprocating
territory for the purpose of section 44-A.
Interestingly, a decree passed by a ‘superior court’ located in any of the reciprocating territories,
as notified by the Union of India, can be executed in India merely by filing a certified copy of
that decree in the concerned District court of India. On filing a certified copy of the decree from
a ‘Superior Court’, the concerned District court in India may treat the decree as if it was passed
by itself. For the purpose of this section, a ‘superior court’ would mean any such court in a
reciprocating territory, as may be specified in the notification for Reciprocating Territories.
Further, as per the explanation given in ‘the code’ a decree for the purpose of this section would
mean any decree or judgment of a superior court under which a sum of money is payable, not
being a sum payable in respect of taxes or other charges of a like nature or in respect of a fine or
other penalty. The section further prescribes that such a decree shall in no case include an
arbitration award, even if such an award is enforceable as a decree or judgment.
In the case of N.P.A.K. Muthiah Chettiar (died) and Ors. v. K.S. Rm. Firm Shwebo, Burma and
Ors.12, the Hon’ble High Court of Madras observed that with regard to decrees of a reciprocating
territory contemplated in the explanation to Section 44-A no suit is necessary but the same can
be executed by the application of the provisions of Section 47, Civil P. C. The distinction that
has to be borne in mind is that reciprocating territories enjoy greater privilege regarding
execution of decrees of their superior Courts in our country than are enjoyed by the non-
reciprocating territories. In the case of Kevin George Vaz v. Cotton Textiles Exports Promotion
Council13, the Hon’ble High Court of Bombay clarified the above-discussed position of the

12
N.P.A.K. Muthiah Chettiar (died) and Ors. v. K.S. Rm. Firm Shwebo, Burma and Ors. AIR 1957 Mad 25.
13
Kevin George Vaz v. Cotton Textiles Exports Promotion Council, 2006 (5) Bom CR 555.
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Indian Legal System

vis-à vis Foreign Awards from Reciprocating and Non- Reciprocating territories of India.

It is also pertinent to highlight that reciprocity is a bilateral arrangement and Reciprocating

Territories are not an exception to this rule. All the reciprocating territories of India mutually
agree to enforce court orders passed by the Indian Courts in their country as well. In the back
drop of globalization and rapid integration of world economies, such mutuality appears to be the
need of the hour. An optimist would like to perceive such mutuality and reciprocity as the
stepping stone towards the ultimate goal of conceptualizing a ‘World Court’.
Judgments from reciprocating and non-reciprocating territories of India
Enforceability of Foreign judgments and awards passed by the courts located outside the
politico-geographical boundary of a country is a grey area of International Law and involves
complex issues of law. The tall and steep walls of Sovereignty protecting the unchallenged
supremacy of the Nations in their international and intra-national affairs are probably the biggest
hurdle in the enforceability of foreign awards and judgments.
As is the case with the third world countries, enforceability of foreign judgments in India has
attracted mixed reactions from the legal experts across the world. If perceiver’s view of reality is
to be believed then enforcing a foreign judgment or award in India is a tough nut to crack.
However, the reality is substantially different from the above-mentioned perceiver’s view of
reality. The position of Indian legal system is crystal clear with respect to enforceability of
Foreign Judgments and awards in India.
The Indian Legal System categorizes Foreign Judgments and Awards from all the quarters of the
world into two groups viz.
(a) Judgments and Awards coming from the ‘Reciprocating Territories’ of India and
(b) Judgments and awards coming from the ‘Non-Reciprocating Territories’ of India.
The Judgments coming from the ‘non-reciprocating territories’ of India are required to pass
through the sieve of ‘Indian Judiciary’ before they could be enforced. In other words, for
enforcing a foreign Judgment or an Award from a ‘Non-Reciprocating Territory’ of India, a
fresh suit in an Indian Court with appropriate Jurisdiction needs to be instituted. Further,
Judgments from a ‘Non-Reciprocating Territory’ only have evidentiary and persuasive value in
the eyes of India Judiciary and they must be filed for enforcement within three years from the
day when they were originally passed.

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However, it does mean that scope of enforceability of Foreign Judgments from ‘Non-
Reciprocating Territories’ in India is limited or the approach of Indian Judiciary is parochial. No
doubt that Foreign Judgments from Non-Reciprocating Territories need to pass through the sieve

of Indian Judiciary but the sieve used is broad and spacious enough to allow the sink in of ‘the

cause of Justice’ upheld by the courts of Foreign Countries.

In the case of Formosa Plastic Corporation Ltd. v. Ashok Chauhan & Ors. 14 the Hon’ble High
Court of Delhi emphatically reiterated the well settled principle of law in India with respect to
foreign Judgments. The principle states, “it is not open to the Court trying the suit on a foreign
judgment to decide whether the decision of the foreign Court on the materials put before it is
right or not”.
The Court further observed that while adjudicating the suit on a foreign judgment, the duty of
the Court is “merely” to see that the foreign Court has applied its mind to the facts of the case
and the law on the point. The Hon’ble High Court of Delhi firmly established this principle by
citing an old Judgment delievereddelivered in the case of Dr. Kulwant v. Dhan Raj Dutt 15. In
this case it was held that if a foreign court has strictly followed ‘the procedure’ and has given
full opportunity to the defendant to appear and raise a defense, then, even if that judgment is
passed ex-parte it shall be considered to have been decided on merits.
In Shalig Ram v. Firm Daulatram Kundanmal,16 a summary suit was instituted in the Bombay
High Court. The defendant, at that point in time, was a resident of the former State of Hyderabad
(a foreign territory). The defendant, however, appeared in obedience to the process of the Court
and applied for leave to defend the suit without any objection to the jurisdiction of the High
Court of Bombay. The defendant was granted the leave to defend.
The Court, within the prescribed time but on the default of the defendant, passed an ex parte
decree against the defendant. The decree was transferred to a Court in Hyderabad, interestingly,
a foreign Court at that juncture of history. The defendant took an objection that the decree of a
foreign court was not executable. It was ultimately decided by the Hon’ble Supreme Court of
India that once the defendant has submitted to the jurisdiction of a foreign Court, a decree
passed by that court, even if ex-parte, is a valid foreign decree.

14
Formosa Plastic Corporation Ltd. v. Ashok Chauhan & Ors, E.A. No. 206 of 1998 in Ex. No. 38 of 1998
15
Dr. Kulwant v. Dhan Raj Dutt, AIR 1935 Lah 396
16
Shalig Ram v. Firm Daulatram Kundanmal, [1963] 2 SCR 574.
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Reciprocating territories of India
In exercise of the power conferred by section 44-A of ‘the code’, the central government of
India has notified 11 territories as Reciprocating Territories of India. The names of these
territories are as follows:

1. United Kingdom
2. Aden
3. Fiji
4. Republic of Singapore
5. Federation of Malaya
6. Trinidad and Tobago
7. New Zealand, the Cook Islands (including Niue) and the Trust Territories of Western
Samoa
8. Hong Kong
9. Papua and New Guinea
10. Bangladesh
11. United Arab Emirates
In addition, India has entered into bilateral treaties with the following countries; however, they
are not yet notified as reciprocating territories: Afghanistan, Azerbaijan, Bahrain, Bulgaria,
France, Kazakhstan, Mongolia, Turkey and Ukraine. Pending notification as reciprocating
territories, the enforcement of judgments and decrees from courts in these jurisdictions follow
the same process as non-reciprocating territories.
Thus, we see that a foreign judgment from a reciprocating territory has a special status in India.
For enforcement of a foreign judgment from a reciprocating territory, a lawsuit is not required to
be instituted. However, it is also pertinent to mention that no foreign judgment shall be held
conclusive if it attracts any of the clauses mentioned in section 13 of ‘the code’.

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SECTION 13 AND SECTION 44ADOCTRINE OF PUBLIC POLICY IN OTHER

COUNTRIES

The recognition and enforcement of foreign judgments and decrees in India are governed by
Section 44-A, read with Section 13 of the Code of Civil Procedure 1908. Section 13 of the code
provides the criteria for recognition of a foreign judgment and is a pre-condition to any
enforcement proceedings. Unless a foreign judgment passes the conclusiveness test under
Section 13 of the Code of Civil Procedures, it cannot be enforced. On the other hand,
enforcement is dealt with under Section 44A of the code in respect of foreign judgments
emanating from both reciprocating territories and non-reciprocating territories.
Therefore, section 13 of the Code of Civil Procedure 1908 is an important criterion. The Indian
courts have held that interlocutory orders on costs, jurisdiction, divorce decrees, monetary
judgments, mandatory injunctions and anti-suit injunctions are enforceable in India. The courts
have also held that ex parte decisions are not unenforceable per se. If the entire established
procedure in trial is followed, the judgment is based on the merits of the dispute and the
judgment holder was directed to prove its case even in the absence of a defence by the
defendant; such an ex parte decision will be enforceable.
On the other hand, default judgments, judgments from summary or special procedures, formal
judgments, judgments imposing punitive damages and penalties or quasi-judicial orders have
been held to be unenforceable in India. There are conflicting views between different high courts
on whether consent and compromise decrees are enforceable.
In light of section 13 of the Code, a litigant from a foreign jurisdiction can make an application
to the civil court within whose jurisdiction the decree is sought to be executed for enforcing the
judgment or decree of the foreign court. Section 14 of the Code states that the court shall
presume upon the production of any document purporting to be a certified copy of a foreign
judgment that such judgment was pronounced by a court of competent jurisdiction, unless the
contrary appears on the record; but such presumption may be displaced by proving that the
foreign court lacked jurisdiction. In defence to the application for execution, the judgment
debtor can use any of the grounds given in s 13 CPC to claim that the foreign judgment is not
conclusive and cannot be executed. The most commonly adopted ground used as a defence
under s 13 of the CPC is that the judgment and decree of the foreign court are not based on the
merits of the case and hence cannot be executed in India.
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The conditions for seeking execution of a foreign decree in India have been very well summed
up

by the Indian Supreme Court in MV AL Quamar v Tsaviliris Salvage (International) Limited.17

The hon’ble court laid down the following conditions that need to be satisfied by the decree
holder:
1. A decree-holder who seeks execution must be armed with a money decree passed by any of
the superior Courts of any reciprocating territory, being any foreign country or territory which
the Central Government may, by notification in official gazette, has declared to be a
reciprocating territory for the purpose of the Section.
2. Such an execution petition can be entertained by the executing Court in India being the
District Court that will be clothed with the legal fiction as if the said foreign decree was passed
by itself and whose aid and assistance are required for executing such a decree.
3. Such a decree can be put up for execution before a District Court in India being the principal
Civil Court of original jurisdiction and which will include the local limits of the original civil
jurisdiction of a High Court.
4. Once such execution petition is filed before the appropriate District Court the entire
machinery of Section 47 for execution of Indian decrees would automatically get attracted.
5. In such execution proceedings, the judgment-debtor of a foreign Court decree will be entitled
to satisfy the executing Court in India that the foreign decree cannot be executed against him as
it is hit by any of the exceptions specified in Clauses (a) to (f) of Section 13 of the CPC.
In the context of what constitutes a judgment on the merits of the case, the law laid down by the
Indian courts, and more particularly by the Supreme Court of India, has dealt with this issue and
in the matter of M/s International Woollen Mills v M/s Standard Wool (UK) Limited18, the Apex
Court stated that It cannot be said that the expression judgment on the merits implies that it must
have been passed after contest and after evidence had been let in by both sides. An ex parte
judgment in favour of the plaintiff may be deemed to be a judgment given on merits if some
evidence is adduced on behalf of the plaintiffs and the judgment, however, brief, is based on a

17
AIR 2000 SC 2826, at 2832, para 6.
18
M/s International Woollen Mills v M/s Standard Wool (decree UK) Limited AIR 2001 SC 2134.
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consideration of that evidence. Where however no evidence is adduced on the plaintiff’s side
and his suit is decreed merely because of the absence of the defendant either by way of penalty
or in a formal manner, the judgment may not be one based on the merits of the case.
Therefore, a decree pronounced by a Court of competent foreign jurisdiction solely on account
of the default of a litigant and by way of penalty, without considering the question on merits and
whether the claim is well founded or not and whether there is any evidence to sustain it or not,

cannot in Indian law be termed to be a decree on merits and cannot be enforced in the Indian

jurisdiction. The views of the Bombay High Court in Algemene Bank Nederland NV v. Satish
Dayalal Choksi19, and those of Punjab and Haryana High Court in Gurdas Mann v Mohinder
Singh Brar20, also follow the above view which has been consistently followed ever since the
decision of the Privy Council in D T Keymer v P Vishwanathan Reddi,21.
Thus, the view is consistent that if the controversy raised in the action has not been the subject
of direct adjudication by the court in the foreign jurisdiction, the decree cannot be executed in
India. However, this does not preclude a litigant from showing to the satisfaction of the Court
that the case falls within any of the other exceptions specified in clauses (a)–(f) of s 13 of the
Code. Once, however, the decree-holder is able to establish their case and none of the conditions
in s 13 are applicable, the decree of the foreign court can be executed in India. Therefore, it is
only where the Indian court is satisfied that the decree of the foreign court can be executed in
India that leave is granted under Ord XXI r 22 of the CPC for the purposes of executing the
decree and every decree of any foreign court cannot be executed simpliciter by approaching an
Indian court. Section 44A thus cannot be attributed to any specific jurisdiction, but is an
independent and an enabling provision available to a foreign citizen who wiseswishes to enforce
a foreign decree.

19
Algemene Bank Nederland NV v. Satish Dayalal Choksi, AIR 1990 Bom 170.
20
Gurdas Mann v. Mohinder Singh Brar AIR 1993 P&H 92.
21
D T Keymer v P Vishwanathan Reddi, AIR 1916 Privy Council 121.
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CONCLUSION

Thus, from the above, it can be inferred that if a judgement is passed by a foreign court
against an Indian person, the decree or award may not be enforceable against him due to the
operation of section 13 of the Civil Procedure Code, 1908. In the said cases the plaintiff is
required to come to the Indian Court either to get the foreign judgement executed or to file a
petition under section 44 A of the Civil Procedure Code, 1908 or should file a fresh suit for
the enforcement of the judgement. Once the said judgement is recognized by a foreign court,
then the procedure for enforcement of the said judgement from a superior court as per section
51 of the Civil Procedure code, 1908 will be initiated.
The ease of execution depends on whether the foreign judgment is from a reciprocating
territory. In terms of Section 44A of the code, judgment from a reciprocating territory should
be executed as if it were passed by a district court in India. On the other hand, executing a
judgment from a non-reciprocating territory requires a civil suit on the foreign judgment to be
filed before the competent court. Therefore, execution of a judgment from a reciprocating
territory is comparatively more efficient.

The last formal reform suggestion that was felt to be brought about in the Code, was passed
in 2009 through the Law Commission of India’s 219 th report entitled “Need for Family Law
Legislations for Non-resident Indians”, which specifically dealt with foreign judgments
relating to divorce and suggested reforms accordingly. However, no specific reform proposal
relating to enforcement and recognition of foreign judgments or decrees is underway.
Thus, analysis of the legal provisions involved in enforcement of foreign decrees in India
emphasizes the need for the Indian courts not to treat the summons received from foreign
courts casually and to efficiently adjudicate whether; the foreign courts had decided that
matter judiciously or not. The same is said to be done in respect of the principle of comity
and leads to a world order in judiciary which is time consuming and world friendly. Lastly, it
can be concluded that foreign decree in India can only be executed if the same is passed by
the courts of reciprocating territory and should pass the tests as laid down in Section 13 of the
Code of Civil Procedure, 1908.

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BIBLIOGRAPHY

Arpan Gupta, A new dawn for India- reducing court intervention in enforcement of foreign
awards.
INTERNATIONAL ARBITRATION AND PUBLIC POLICY by Devin Bray (juris corp, 3rd
Edn.)
RECOGNITION AND ENFORCEMENT OF FOREIGN ARBITRAL AWARDS by Herbert
Kronke (Kluwer Law International, 2nd ed.)
LAW AND PRACTICE OF INTERNATIONAL COMMERCIAL ARBITRATION by Alan
Redfern (Sweet & Maxwell, 3rd ed.).
COMPARATIVE ARBITRATION PRACTICE AND PUBLIC POLICY IN ARBITRATION by
Pieter Sanders (Kluwer Law and Taxation Publishers, 2nd ed.).
Sudhi Ranjan Bagri, Doctrine of Public Policy and Enforcement of Arbitral Award, (I
PLEADERS.)

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