JSA
This edition of the JSA Brief showcases JSA authored articles, updates & newsletters and achievements such as deals and events in all practice area over the preceding month (April 2025).
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Watch the insightful discussion on the evolving landscape of real estate investment in India. Our Partner and Co-Chair of the Disputes Practice, Farid Karachiwala, engages in a compelling conversation with Ali Lokhandwala, Managing Director of Lokhandwala Infrastructure, exploring the next phase of property investment opportunities and challenges in the region.
In this exclusive video, filmed on the sidelines of the JSA Mint India Investment Summit, Farid and Ali dissect the key trends that are set to shape the future of real estate investment in India. Their expert analysis provides valuable perspectives for industry professionals keen on understanding market dynamics and strategic investment approaches.
Watch this enlightening exchange and gain a deeper understanding of India’s property market trajectory.
Please click here to download the document.
A single judge of the Delhi High Court (“Delhi HC”) in San Nutrition Private Limited vs. Arpit Mangal and Ors.[1], while rejecting grant of an interim injunction, has held that influencers are not liable for defamation or disparagement when the information shared by them is true, not misleading and without malicious intent.
Brief facts
Arpit Mangal (“Defendant No. 1”), a social media influencer, published videos on the YouTube platform inter alia reviewing DC Doctor’s Choice Iso Pro (“Product”) marketed by San Nutrition Private Limited (“Plaintiff”). Defendant No. 1’s videos on the Product were based on independent laboratory reports (“Lab Reports”) and comparison with other competitor products in the market. Relying solely upon Defendant No. 1’s videos, Kabir Grover (“Defendant No. 2”) and Manish Keswani (“Defendant No. 3”) posted similar videos on YouTube. Avijit Roy (“Defendant No. 4”) also published videos on the Product after self-testing it with a kit developed by a competitor brand and used Plaintiff’s mark in the thumbnail of the videos.
Being aggrieved by these videos published by Defendant Nos. 1 to 4 (“Impugned Videos”) which showed the Plaintiff and the Product in negative light, the Plaintiff filed a suit along with an interim injunction application. While Defendant No. 1 appeared and opposed the interim injunction application, Defendant Nos. 2 to 4 did not appear before the Delhi HC.
In the interim injunction application, the Plaintiff inter alia contended that: (a) the Impugned Videos contained false, malicious and misleading statements about the Plaintiff and the Product with an attempt to defame and disparage; (b) the damage caused to the Plaintiff was visible from the negative comments/reviews on the Impugned Videos, e-commerce websites along with the decline in the sales of the Product; and (c) the Impugned Videos contain the name/pictures/videos of the Product and also shows the Plaintiff’s mark which amounts to unauthorised and wrongful use of Plaintiff’s trademark and copyright.
Defendant No. 1 inter alia contended that the statements made in his videos were: (a) fair comments issued in public interest, based on scientific evidence, and were protected under the right to exercise freedom of speech and expression under Article 19(1)(a) of the Constitution of India (“Constitution”); and (b) based on truth substantiated by verifiable Lab Reports accredited under applicable laws. Defendant No. 1 also contended that the use of Plaintiff’s marks in his videos was covered under fair use and does not violate the Plaintiff’s intellectual property rights.
Issue
Whether the Impugned Videos were defamatory, disparaging and infringed upon the Plaintiff’s trademarks?
Findings and Analysis
The Delhi HC rejected the Plaintiff’s interim application and inter alia observed as follows:
Based on the above principles and in the facts of the case, the Hon’ble Delhi HC prima facie held that the Plaintiff had failed to discharge its burden of proof in establishing that the statements made in the Impugned Videos were palpably false, misleading, malicious and/or were bound to fail at the stage of trial. Further, the Delhi HC also ruled that the Plaintiff had failed to establish a case for infringement of its intellectual property rights. Accordingly, the Delhi HC held that Defendant Nos. 1 to 4 were entitled to protection of free speech under the Constitution.
Conclusion
This decision highlights the need to strike a careful balance between protecting the right to freedom of speech and expression of social media influencers and preserving the reputation of businesses in an increasingly digital landscape. It underscores the importance of fostering a harmonious coexistence between individual expression and corporate honesty in the era of social media. Notably, the ruling gains further significance as it deals with circumstances for grant of an interim injunction, a form of immediate relief that businesses often seek when facing potential defamation or brand disparagement.
This Prism is prepared by:
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Farhad Sorabjee |
Pratik Pawar |
Shanaya Cyrus Irani |
Sanjana Pandey |
For more details, please contact [email protected]
[1] 2025 SCC OnLine Del 2701
[2] Pankaj Oswal vs. Vikas Pahwa, 2024 SCC OnLine Del 1193
[3] 2006 SCC OnLine Del 14
[4] Tata Sons vs. Greenpeace, 2011 SCC OnLine Del 466
[5] Tata Press vs. Mahanagar Telephone Nigam Limited, (1995) 5 SCC 139,
[6] Dabur India vs. Colortek Meghalaya, 2009 SCC OnLine Del 3940
[7] Bloomberg Television vs. Zee Entertainment, (2025) 1 Supreme Court Cases 741; Bonnard vs. Perryman, [1891] 95 All ER 965.
[8] Tata Sons vs. Greenpeace, 2011 SCC OnLine Del 466
Please click here to download the document.
The Supreme Court of India (“Supreme Court”) has in Rutu Mihir Panchal and Ors. vs. Union of India and Ors.[1] held that the determination of the pecuniary jurisdiction of the District, State, and National Consumer Commissions (“Consumer Commissions”) based on the consideration paid for the purchase of goods and services under Sections 34 (1), 47 (1)(a)(i) and 58 (1)(a)(i) of the Consumer Protection Act, 2019 (“2019 Act”) (“Provisions”) is constitutional and not violative of Article 14 of the Constitution of India (“Constitution”).
This judgement deals with questions of law arising out of – (a) Writ Petition under Article 32 of the Constitution (“Writ Petition”)[2]; and (b) Civil Appeal[3] challenging an order passed by the National Consumer Disputes Redressal Commission (“NCDRC”) (“Civil Appeal”). The facts of each case are as follows:
Writ Petition
The husband of Rutu Mihir Panchal (“Petitioner”) purchased a Ford Endeavour (“Vehicle”) from an authorised dealer of Ford India Private Limited for INR 31,19,000 (Indian Rupees thirty-one lakh nineteen thousand). On November 20, 2018, the Vehicle caught fire, leading to the death of the Petitioner’s husband. The Petitioner filed a consumer complaint before the District Consumer Disputes Redressal Commission (“DCDRC”), Vadodara seeking compensation of INR 51,49,00,000 (Indian Rupees fifty-one crore forty-nine lakh) along with interest. Pending the disposal of the complaint, the Petitioner filed the Writ Petition seeking that the Provisions be declared unconstitutional. This was on the basis that the Petitioner was compelled to approach the DCDRC, Vadodara because of the statutory regime under the 2019 Act, i.e., the pecuniary jurisdiction being determined according to the value of the goods or services paid as consideration. It was alleged that the Petitioner could have directly approached the NCDRC under the repealed Consumer Protection Act, 1986 (“1986 Act”) where the pecuniary jurisdiction was based on the compensation claimed.
Civil Appeal
The husband of Gurjeet Kaur Saini (“Appellant”) passed away due to COVID-19. When the Appellant’s claim based on an insurance policy offered by Lions International Club was denied, she filed a consumer complaint before the NCDRC seeking compensation of INR 14,94,00,000 (Indian Rupees fourteen crore ninety-four lakh). The NCDRC rejected the Appellant’s complaint on the ground that the consideration for the insurance policy did not exceed INR 10,00,00,000 (Indian Rupees ten crore) and thus, the NCDRC did not have pecuniary jurisdiction to entertain the complaint.
Before the Supreme Court, the Petitioner/Appellant contended that: (a) the 2019 Act replaced the pecuniary jurisdiction of the Consumer Commissions from the value of compensation claimed under the 1986 Act to the value of consideration paid, which is unconstitutional; (b) the present statutory regime gives rise to an anomalous situation wherein a consumer claiming a large compensation for a lower consideration would be relegated to the district or state commissions whereas a consumer seeking a lower compensation may be entitled to approach the NCDRC even in the event of a higher consideration paid; (c) the new criterion for determining pecuniary jurisdiction is discriminatory since consumers that claim identical compensation but have paid different considerations are treated differently; (d) given that the definition of a ‘consumer’ under the 2019 Act does not discriminate on the basis of consideration paid, the restriction of access to judicial remedies on the basis of consideration paid is illegal and arbitrary; and (e) there is no rational for introducing a new criterion for determining the pecuniary jurisdiction of the Consumer Commissions.
The respondents inter alia contended that the: (a) pecuniary classifications created on the basis of value of goods and services paid as consideration has a rational nexus with the object sought to be achieved, i.e., timely settlement of consumer disputes; and (b) the Provisions are not manifestly arbitrary and were introduced to prevent exaggerated claims.
Whether empowering the Consumer Commissions to exercise jurisdiction based on the value of the goods or services paid as consideration is violative of Article 14 of the Constitution?
The Supreme Court held that the Provisions of the 2019 Act are constitutional for the following reasons:
Apart from upholding the validity of the Provisions, the Supreme Court directed the Central Consumer Protection Council and the Central Consumer Protection Authority to take such measures as may be necessary for survey and review and advise the government about necessary measures for the effective and efficient working of the 2019 Act.
The classifications set forth in the Provisions (which have been further revised by the Consumer Protection (Jurisdiction of the District Commission, the State Commission and the National Commission) Rules, 2021) prescribe a reasonable and rationale determination of the pecuniary jurisdiction of consumer courts. These Provisions prevent consumers from approaching Consumer Commissions solely on the basis of self-assessed claims for damages.
This Prism has been prepared by:
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Farhad Sorabjee |
Pratik Pawar |
Shanaya Cyrus Irani |
Siddhesh Pradhan |
Meher Mistri |
Jatin Asrani |
|
For more details, please contact [email protected].
[1] 2025 SCC OnLine SC 974
[2] Writ Petition (Civil) No. 282 of 2021
[3] Civil Appeal No. 5670 of 2025 arising out of SLP (C) No. 1738 of 2022
[4] State of West Bengal vs. Anwar Ali Sarkar (1952) 1 SCC 1
Please click here to download the document.
On April 30, 2025, a 5 (five) judge constitution bench of the Hon’ble Supreme Court of India (“Supreme Court”) in Gayatri Balasamy vs. M/s. ISG Novasoft Technologies Limited[1] held that the courts possess a limited power to modify arbitral awards under Sections 34 and 37 of the Arbitration and Conciliation Act, 1996 (“Arbitration Act”). The Supreme Court further clarified that this power is not absolute and may only be exercised in specific circumstances, such as when the arbitral award is severable, to correct clerical or computational errors, or to modify post-award interest. However, the Supreme Court stated that such power is always subject to the express statutory framework and legislative intent and cautioned that it may not be exercised to rewrite the award or to conduct a merits-based evaluation.
Brief facts
In the present case , the Supreme Court referred a pivotal legal question to a 5 (five) judge constitution bench viz. whether courts possess the authority to modify arbitral awards under Sections 34 and 37 of the Arbitration Act. The brief facts leading to the lead reference are as follows:
Key issue
Are Indian courts jurisdictionally empowered to modify an arbitral award under Sections 34 and 37 of the Arbitration Act? If so, to what extent?
Legal provision
Section 34 of the Arbitration Act reads as follows:
Analysis and findings
By a majority of 4:1, the Supreme Court held that courts have a limited power to modify awards under Sections 34 and 37 of the Arbitration Act. The decision was centred around the following issues:
The findings rendered by the majority judgment and the minority judgment regarding each of these issues are summarised below:
| Issue | Majority view
“The limited power under Section 34 allows the court to vary or modify the award” |
Minority view
“…what is sought to be done is virtual mutilation of the fabric and not just the ironing out of the creases” |
| Severability
[concurrence] |
Authority to sever the invalid portion of the award from the valid portion is inherent in the jurisdiction to set aside an award. Modification and setting aside have different consequences – one is alteration, the other is annulment. | The consistent view has been that if claims falling foul of Section 34 of the Arbitration Act are not inseparably intertwined with the good portion of the award, the award can be severed. The power to set aside will include the power to partially set aside. |
| Hardship of parties
[dissent] |
Denying courts the power to modify awards would impose significant hardship, escalate costs and lead to unnecessary delays. This would defeat the objective of arbitration as parties would be compelled to undergo extra rounds of arbitration, in addition to the stages of challenge under Sections 34 and 37 of the Arbitration Act and special leave petition. | Recommencement of proceedings being expressly contemplated in the statute, the same cannot be brushed aside on the grounds of hardship of parties. When parties agree to arbitrate, they consciously agree with open eyes to step out of the normal judicial process and submit to being governed by the Arbitration Act. |
| Errors
[concurrence] |
Courts under Section 34 of the Arbitration Act possess the authority to rectify computational, clerical or typographical errors “as well as other manifest errors, provided that such modification does not necessitate a merits-based evaluation”. Court must have no uncertainty or doubt in this regard – if the error is not apparent on the face of the record, the court cannot modify. | Courts under Section 34 of the Arbitration Act can invoke the power to correct computational errors, clerical or typographical errors or any other errors of similar nature “without modifying, altering or adding to the original award” – hence, a limited exception to M Hakeem’s judgement[2] is made. |
| Interest
[dissent] |
For pendente lite interest, court may set aside the award of interest or remand the matter to the arbitrators. For post-award interest, courts will retain the power to modify the interest rate. Courts may increase or decrease the post-award interest, but only where there are compelling and well-founded reasons to do so. | Court under Section 34 of the Arbitration Act cannot modify the interest. The correct course would be to remit the matter to the arbitrator to make course correction. If the matter comes to court again and the grounds for setting aside are still present, there would be no choice but to set aside the award. |
| Article 142 of the Constitution
[dissent] |
This power should not be exercised where the effect would be to rewrite or modify the award on merits. However, the power can be exercised where required and necessary to bring the dispute to an end. | This power cannot be used to supplant substantive law, as express statutory provisions cannot be ignored and what cannot be achieved directly cannot be achieved indirectly. The power cannot be exercised as it will derogate from the core aspects of the Arbitration Act and breach a pre-eminent prohibition in the Arbitration Act. |
Conclusion
This Prism is prepared by:
|
Varghese Thomas |
Divyam Agarwal |
Fatema Kachwalla |
Aniket Aggarwal |
Virgil Braganza |
|
For more details, please contact [email protected]
[1] Special Leave Petition (Civil) Nos. 15336 of 2021
[2] Project Director, National Highways No. 45 E and 220 National Highways Authority of India Vs. M. Hakeem and Anr., (2021) 9 SCC 1
Please click here to download the document.
The Supreme Court of India (“Supreme Court”) has in Adavya Projects Private Limited vs. M/s. Vishal Structurals Private Limited and Ors.[1] inter alia clarified that issuing a notice under Section 21[2] of the Arbitration and Conciliation Act, 1996 (“Arbitration Act”) is mandatory as it fixes the date of commencement of arbitration, determines limitation, and is a pre-requisite for a petition seeking appointment of an arbitrator[3]. However, mere non-service of the arbitration notice upon a person does not deprive the jurisdiction of the arbitral tribunal under Section 16[4] of the Arbitration Act to determine whether they are a party to the arbitration agreement and to implead them.
Adavya Projects Private Limited (“APPL”) and Vishal Structurals Private Limited (“VSPL”) executed a limited liability partnership agreement (“LLP Agreement”) to form a limited liability partnership namely Vishal Capricorn Energy Services LLP (“LLP”) to carry out oil and gas sector projects. The LLP Agreement envisaged that the director of VSPL, Mr. Kishore Krishnamoorthy (“Kishore”), would be the chief executive officer of the LLP. Clause 40 of the LLP Agreement provided for dispute resolution through arbitration.
In 2013, APPL and VSPL executed a supplementary agreement and a memorandum of understanding for undertaking a project through the LLP (“Project”).
In 2018, disputes arose when APPL sought information from VSPL to audit the accounts of the LLP in relation to the Project. APPL issued demand notices calling VSPL to pay monies towards reconciliation of the accounts of the LLP.
Eventually, APPL invoked the arbitration clause of the LLP Agreement by issuing a notice of arbitration to VSPL. APPL then filed an application under Section 11 of the Arbitration Act before the Delhi High Court (“Delhi HC”) seeking appointment of an arbitrator to adjudicate the disputes between the parties. VSPL was named as the only respondent in the petition. The Delhi HC appointed an arbitrator to adjudicate the disputes between APPL and VSPL arising out of the LLP Agreement.
APPL filed its statement of claim before the arbitrator and named VSPL, the LLP and Kishore as parties to the arbitration. The LLP and Kishore filed an application under Section 16 of the Arbitration Act challenging the jurisdiction of the arbitral tribunal contending that the arbitration agreement contained in Clause 40 of the LLP Agreement does not bind the LLP, which is a creature of the LLP Agreement, and Kishore, as he was not a party to the LLP Agreement in his individual capacity.
The arbitral tribunal allowed the Section 16 application (“Section 16 Order”) and held that arbitration proceedings against the LLP and Kishore were not maintainable since – (a) the notice of arbitration under Section 21 of the Arbitration Act was not served upon the LLP and Kishore; and (b) the Delhi HC did not refer the LLP and Kishore to arbitration while allowing APPL’s Section 11 application. The arbitral tribunal also rejected APPL’s prayer in its application under Section 23(3)[5] of the Arbitration Act seeking to bring on record a detailed memo of parties which named the LLP and Kishore as parties and also seeking to amend its prayer in its statement of claim to include the LLP and Kishore.
APPL filed an appeal under Section 37(2)(a) of the Arbitration Act assailing the Section 16 Order before the Delhi HC.
By an order dated July 8, 2024, the Delhi HC dismissed this appeal and upheld the Section 16 Order (“Impugned Order”).
Being aggrieved by the Impugned Order, APPL filed the present proceedings before the Supreme Court.
The Supreme Court allowed the appeal and inter alia held the following:
In the facts of the present case, the LLP and Kishore, despite being non-signatories, had through their conduct, consented to perform contractual obligations under the LLP Agreement and thus, the Supreme Court found them to be parties to the arbitral proceeding.
By the present decision, the Supreme Court has held that the arbitral tribunal is the master of its own jurisdiction under Section 16 of the Arbitration Act and its jurisdiction to implead parties to an arbitration proceeding is based solely on determining whether such person/persons is/are a party to the arbitration agreement. Even the issuance of the mandatory arbitration notice under Section 21 of the Arbitration Act is not a prerequisite for the arbitral tribunal to exercise its jurisdiction to determine the parties to an arbitral proceeding. This decision shows the continuous effort of the judiciary in reposing faith in arbitral tribunals and recognising arbitration as an effective means of dispute resolution.
This Prism is prepared by:
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Farhad Sorabjee |
Dhirendra Negi |
Shanaya Cyrus Irani |
Tanya Tiwari |
|
Siddhesh Pradhan |
Isha Singhal |
Meher Mistri |
Jatin Asrani |
For more details, please contact [email protected]
[1] 2025 SCC OnLine SC 806
[2] Section 21 of the Arbitration Act provides that arbitral proceedings commence on the date a party (respondent) receives a claimant’s request seeking reference of a dispute to arbitration. The request for reference is commonly known as notice of arbitration.
[3] Section 11 of the Arbitration Act.
[4] Section 16 of the Arbitration Act provides that the arbitral tribunal may rule upon its own jurisdiction.
[5] Section 23(3) of the Arbitration Act provides that if the arbitral tribunal considers it appropriate, it may allow any party to supplement or amend their claim, during the course of the arbitral proceedings.
[6] 2017 SCC OnLine Del 7228
[7] Section 7 of the Arbitration Act specifies what constitutes an arbitration agreement.
[8] (2024) 4 SCC 1
Our Partner, Divyam Agarwal, recently participated in a distinguished panel discussion on the television programme “Legally Speaking with Tarun Nangia.” The topic of this insightful discussion was “On Powers of Court to Modify Arbitral Awards,” an area of significant relevance and interest within the legal community in the wake of Constitution Bench decision in Gayatri Balasamy v. ISG Novasoft Technologies Ltd. This episode was broadcast on NewsX and is now available for viewing online.
Divyam was honoured to share the panel with:
Mr. Tarun Nangia moderated the panel.
We invite you to watch this engaging discussion through the link provided below, where you will gain valuable insights into the nuances of arbitral awards and court powers.
The Hon’ble Bombay High Court (“High Court”) vide its order dated April 29, 2025, granted interim relief to its client, who filed a Writ Petition challenging a Look Out Circular (“LOC”) barring him from leaving India. The LOC was issued at the behest of the Serious Fraud Investigation Office (“SFIO”) in connection with an ongoing investigation into the affairs of IL&FS. Earlier, JSA succeeded in securing permission for the client to travel overseas for two months, with the LOC suspended during that period, subject to compliance with conditions imposed by the High Court. In the subsequent application, the client sought a suspension of the LOC for 6 months to enable travel abroad for both business and personal reasons.
The SFIO, through its counsel, confirmed that the applicant had complied with the previous conditions imposed by the Court. Accordingly, the High Court, comprising of Hon’ble Ms. Justice R. M. Dere and Hon’ble Dr. Justice N. K. Gokhale, allowed the interim application on the following terms:
Our disputes team comprised Lead Partner, Varghese Thomas, Partner, Hormuz Mehta and Senior Associate, Virgil Braganza.
JSA successfully defended UltraTech Cement Limited (“UltraTech”) before the Division Bench of the Hon’ble Karnataka High Court against the Distribution Licensee’s Writ Appeal, in effect, securing stay on recovery of alleged electricity dues and disconnection of electricity supply by the Distribution Licensee.
The dispute emanated because, after 18 years of the operation of UltraTech’s Bulk Terminal (cement packing unit) as an ‘Industrial’ Unit, Mangalore Electricity Supply Company Limited (“MESCOM”) i.e., the Distribution Licensee, issued a Demand Notice alleging ‘Commercial Use’ and demanded UltraTech to pay the differential of ‘Commercial’ and ‘Industrial’ tariff retrospectively. In absence of such payment, MESCOM threatened to disconnect electricity supply at UltraTech’s Bulk Terminal.
UltraTech filed a Writ Petition before the Ld. Single Judge, Hon’ble High Court of Karnataka seeking the Demand Notice to be quashed. JSA represented UltraTech. UltraTech inter alia contended that all along UltraTech’s Bulk Terminal was billed under ‘Industrial’ tariff category, there being NO change in circumstances, it was not open for MESCOM to unilaterally and retrospectively raise a demand for the differential of ‘Commercial’ and ‘Industrial’ tariff from UltraTech. Alongside highlighting the fact that Bulk Terminal has NOT been specifically categorized under any particular tariff category by the Karnataka Electricity Regulatory Commission, UltraTech also highlighted the Disconnection Notice is time barred in view of Section 56(2) of the Electricity Act, 2003.
By Order dated 08.08.2024, Ld. Single Judge, Hon’ble High Court of Karnataka passed a favourable interlocutory order in favour of UltraTech, directing MESCOM not to take any coercive action against UltraTech either qua the Demand Notice (i.e., recovery of the differential of ‘Commercial’ and ‘Industrial’ tariff) or Disconnection Notice.
Aggrieved by Order dated 08.08.2024 passed by the Ld. Single Judge, Hon’ble High Court of Karnataka, MESCOM filed a Writ Appeal before the Ld. Division Bench, Hon’ble High Court of Karnataka. JSA represented UltraTech and successfully defended UltraTech.
By Judgment dated 04.04.2025, Ld. Division Bench, Hon’ble High Court of Karnataka dismissed MESCOM’s Writ Appeal and did NOT interfere the interlocutory order passed in UltraTech’s favour by Ld. Single Judge, Hon’ble High Court of Karnataka. By virtue of this Judgment, the direction to MESCOM not to take any coercive action against UltraTech either qua the Demand Notice (i.e., recovery of the differential of ‘Commercial’ and ‘Industrial’ tariff) or Disconnection Notice remains intact.
The interlocutory order by the Ld. Single Judge, as upheld by the Division Bench provides necessary relief to UltraTech, an industrial consumer, alongside keeping in check the whimsical unilateral and arbitrary decision making by Distribution Licensee (here MESCOM).
Our disputes team comprised Lead Partner Poonam Verma Sengupta, Partner, Prasanth V.G., Principal Associate, Saunak Kumar Rajguru and Associate, Pradyumn Amit Sharma.
This edition of the JSA Brief showcases JSA authored articles, updates & newsletters and achievements such as deals and events in all practice area over the preceding month (March 2025).
To read further details, click here or refer to the below document.
For more details, please contact [email protected]
*In case the document is not visible on the device you are using, please click the link above.
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