A v B

A v B

The transfer of P's rights to F under the Indian court-sanctioned Scheme constituted universal succession in substance, not an equitable assignment; the tribunal was bound to recognize the effect of the Scheme and Orders, and E's procedural objections were waived under section 73 of the Arbitration Act as they were not raised during arbitration.

Parties
Claimant: E; Defendant: B
Jurisdiction
England and Wales
Judgment Date
25 November 2016
Procedural Posture
Arbitration Claim / Judgment on Challenge to Arbitral Award
Outcome
challenge dismissed
Legal Topics
Party Substitution, Universal Succession, Assignment of Claims, Effect of Foreign Mergers, Arbitral Jurisdiction, Procedural Waiver

Case Brief

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Parties

E

Claimant

B

Defendant

Procedural Posture

Arbitration Claim / Judgment on Challenge to Arbitral Award

  1. 1 Whether the arbitral tribunal had jurisdiction to permit substitution of F for P after P's dissolution under Indian law
  2. 2 Whether the transfer of P's rights to F constituted an equitable assignment or universal succession
  3. 3 Whether notice of assignment was required before P's dissolution

Ratio Decidendi

The transfer of P's rights to F under the Indian court-sanctioned Scheme constituted universal succession in substance, not an equitable assignment; the tribunal was bound to recognize the effect of the Scheme and Orders, and E's procedural objections were waived under section 73 of the Arbitration Act as they were not raised during arbitration.

Court Disposition

challenge dismissed

Orders

  • E’s challenges to the Second Partial Award are dismissed
  • Costs follow the event