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Wednesday, May 4, 2022

Can a Non-Signatory be bound by an Arbitration Agreement? - View of the Supreme Court


INTRODUCTION

 

Today, we will discuss the case of Oil and Natural Gas Corporation Ltd. (ONGC) v. Discovery Enterprises Pvt. Limited (DEPL) & Another, 2022 SCC OnLine SC 522. This case involved three important aspects relating to the Law of Arbitration in India: -

 

1. Can a Non-Signatory be bound by an Arbitration Agreement?

 

2. When can an Arbitral Award be said to be in conflict with Public Policy of India for adjudicating under S. 34 of the Arbitration & Conciliation Act, 1996 (In short, “Arbitration Act”)?

 

3. What is Section 37 of the Arbitration Act, and does it include the power to adjudicate on an issue relating to jurisdiction of an Arbitral Tribunal?

 

I will divide these with these aspects in three posts, the links for which could be accessed here (Post – I, Post – II and Post – III). But before adverting any further, let us first understand the facts of the present case.

 

FACTS IN BRIEF

 

In the year 2006, ONGC awarded a contract to DEPL for operating a Floating Production Storage Offloading Vessel, by the name of Crystal Sea. Such Contract contained an Arbitration Clause. Pursuant to the Contract, Crystal Sea, the vessel, was imported by ONGC by paying the customs duty for it, on the understanding that Crystal Sea would be re-exported after the work is done under Duty Drawback to be completed by the DEPL. Duty Drawback is essentially a Scheme that provides refund of custom duty paid to the exporters on unused imported goods or goods that may be used for export.

 

However, in the year 2008, the ONGC invoked the Arbitration Clause by contending that DEPL failed to complete Duty Drawback Formalities as a result of which ONGC claimed that that it had suffered massive losses.

 

The ONGC also invoked the Arbitration Clause against a non-signatory, namely, Jindal Drilling and Industries Limited (JDIL), on the ground that the DEPL and JDIL belonged to the same group of companies constituting a single economic entity and therefore, the corporate veil should be lifted to compel the non-signatory JDIL to arbitrate. In the same breath, to prove this assertion, ONGC also moved an Application before the Arbitral Tribunal seeking Discovery and Inspection of the Documents that would reveal that DEPL is an Alter Ego of JDIL.

 

The JDIL contested this by moving an Application under Section 16 of the Arbitration Act seeking deletion of its name from Arbitral Proceedings on the ground that it is not a party to the Arbitration Agreement. The Arbitral Tribunal decide to hear JDIL’s Application first since according to itself, without deciding the jurisdiction of the Arbitral Tribunal, it cannot direct for any discovery or inspection.

 

Thereafter an Interim Award was passed by the Arbitral Tribunal holding that it lacked jurisdiction to investigate JDIL since it was not a signatory to the Arbitration Clause and the Arbitral Tribunal also held that unless it is held that it has jurisdiction to investigate JDIL, it cannot adjudicate on the Application moved by ONGC seeking Discovery and Inspection of the Documents that would reveal that DEPL is an Alter Ego of JDIL.

 

This Interim Award became a subject-matter of challenge in an appeal before the High Court under Section 37 (Appealable Orders) of the Arbitration Act. However, in another set of proceedings, ONGC also challenged in respect of some other contracts it had with JDIL under Section 34 (Application for Setting Aside Arbitral Award) of the Arbitration Act. Since such Appeals and Petitions were dismissed by the High Court, the matter traversed to the Supreme Court.

 

Keeping this factual matrix in mind, let us first answer whether a non-Signatory can be bound by an Arbitration Agreement?

 

CAN A NON-SIGNATORY BE BOUND BY AN ARBITRATION AGREEMENT?

 

Basic Doctrines and Principles

 

To answer this question, the Court relied on the following doctrines and principles: -

 

a. Group of Companies Doctrine and Lifting of Corporate Veil

 

“A non-signatory may be bound by an arbitration agreement where the parent or holding company, or a member of the group of companies is a signatory to the arbitration agreement and the non-signatory entity on the group has been engaged in the negotiation or performance of the commercial contract, or made statements indicating its intention to be bound by the contract, the non-signatory will also be bound and benefitted by the relevant contracts.”

 

This Doctrine could be invoked based on the following factors: -

 

“(i) The mutual intent of the parties;

(ii) The relationship of a non-signatory to a party which is a signatory to the agreement;

(iii) The commonality of the subject matter;

(iv) The composite nature of the transaction; and

(v) The performance of the contract.”

 

It can also be invoked where there is a tight group structure with strong organisational and financial links, so as to constitute a single economic unit, or a single economic reality. In such a situation, signatory and non-signatories have been bound together under the arbitration agreement.”

 

b. Alter Ego Principle in Arbitration–

 

According to this rule or principle, “shareholders will be treated as owners of a corporation’s property, or as the real parties in interest, whenever it is necessary to do so to prevent fraud or to do justice.” Basically, ‘alter ego’ is “a corporation used by an individual in conducting personal business, the result being that a court may impose liability on the individual by piercing the corporate veil when fraud has been perpetuated on someone dealing with the corporation.” (Black’s Law Dictionary, Eighth Edition)

 

The Court explained the application of the Alter Ego Principle in Arbitration by noting that a party who has not assented to a contract containing an arbitration clause may nonetheless be bound by the clause if that party is an ‘alter ego’ of an entity that did execute, or was otherwise a party to, the agreement.”

 

View of the Court

 

According to the Court, though the general principles of contract stipulate that every company or individual is a distinct legal entity, yet a Signed Written Agreement to submit a present or future dispute to arbitration does not exclude the possibility of an arbitration agreement” and a non-signatory may very well be bound by an Arbitration Agreement by invoking and applying the Group of Companies Doctrine and the Alter Ego Principle.

 

In the present case, the Court held that though the Group of Companies Doctrine and the Alter Ego Principle may be applied in the present case; however, such chance was denied to ONGC as its Application for Discovery and Inspection of Documents to prove the necessity for impleading JDIL was not considered by the Arbitral Tribunal and such fundamental failure on part of the Arbitral Tribunal led to a situation where the Arbitral Tribunal was not able to properly decide whether it had the jurisdiction to investigate JDIL or not.

 

Held by the Court

 

Hence, Supreme Court set aside the earlier Interim Award and the Orders of the High Court and directed the Arbitral Tribunal to conduct a fresh hearing on the issue of its jurisdiction to investigate JDIL. ONGC was also given liberty to move appropriate applications seeking Discovery and Inspection of Documents from JDIL and DEPL.

 

 

CONCLUDING REMARKS

 

Therefore, we see that a non-Signatory may indeed be bound by an Arbitration Agreement. My own view after reading this case that the law of corporations, the law of contract and the law of arbitration, seems to have a Spaghetti Bowl Effect on the alternate dispute resolution mechanisms like that of arbitration. The Spaghetti Bowl Effect is a phenomenon observed in the Trade Law where the increasing number of Free Trade Agreements (FTAs) between various countries seem to have decelerated and slowed down the trade relations and the volume of trade between them. Drawing a similar analogy, the law of arbitration has become so intricate that every now and then new interpretations keep coming up that somehow intend to preserve the sanctity of the process of Arbitration. With more laws and more interpretations like this, the parties seem to be witnessing an endless litany of litigations, claims and counterclaims. I sincerely feel that the entire of law of arbitration needs a revisit. It has not at all remained accessible to the common populace and it has become a rich man’s domain for all practical purposes.

 

As a lawyer, many times people approach me asking if their disputes could be resolved by way of arbitration. When I tell them about the general fee structure of the Arbitrators and the Counsels, they lose all the motivation and simply ask for a mechanism where the Courts could adjudicate their disputes. Had there been a solid foundation of institutional arbitrations at local level in India, the burden of the Courts could be decreased.

 

If we look at the present case, we see that even after a decade of litigation, the parties are back to square one. Due to the complexity of laws, now again the Arbitral Tribunal will hear on the question of jurisdiction. Big corporates can afford these expenses but are they worth it?  

 

With respect to issues relating to Section 34 and Section 37, the posts can be accessed by clicking here (Post – II and Post – III).

 

POST – I - CAN A NON-SIGNATORY BE BOUND BY ANARBITRATION AGREEMENT?

POST – II – PUBLIC POLICY AND SECTION 34 OFARBITRATION ACT

POST – III – SECTION 37 OF THE ARBITRATION ACT ANDTHE ISSUE OF JURISDICTION

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