ARTICLE
8 December 2025

Supreme Court Affirms That Post-award Fraud Allegations Cannot Impede Enforcement Of Arbitral Awards Under Section 47 CPC.

The Supreme Court through its judgement dated 03.11.2025 in MMTC Limited v. Anglo American Metallurgical Coal Pvt. Ltd. , held that objections to the enforcement of an arbitral award under Section 47 of the Code of Civil Procedure, 1908 ("CPC") lies within a narrow compass.
India Litigation, Mediation & Arbitration
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The Supreme Court through its judgement dated 03.11.2025 in MMTC Limited v. Anglo American Metallurgical Coal Pvt. Ltd.1, held that objections to the enforcement of an arbitral award under Section 47 of the Code of Civil Procedure, 1908 ("CPC") lies within a narrow compass, confined to instances where a decree is inherently void or passed without jurisdiction.

The Supreme Court held that objection petition under Section 47 of the CPC should not invariably be treated as commencement of a new trial and that the objections are not contingent or dependent upon filing of a petition under Section 34 of the Arbitration and Conciliation Act, 1998 ("A&C Act").

Footnote

1 Civil Appeal No. 13321 of 2025.

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