Lord Denning, giving wisdom regarding English Court regarding Interest, plainly wished you to an order might possibly be produced combining both categories of arbitral proceedings in order to save your time and cash also to steer clear of the threat of inconsistent honors:
“Even as we possess commonly mentioned, there is a risk inside with a couple of separate arbitrations inside a instance like this. It has been said in some instances…it is most unwelcome there might be contradictory results of the a couple of age concern, particularly causation. It is extremely trendy one everything ought to be done to quit such a situation [Abu Dhabi Energy, op.cit.during the 427]”
This will be against the public rules off India one to Indian process of law gives effect to the overseas prizes being in conflict that have view of Indian courts
83. I’ve already described new contention out of Mr. Fali S. Nariman, the brand new read older counsel appearing to your appellant, the provisions from Section 45 of your 1996 Work is a little like Blog post II(3) of one’s New york Seminar therefore the phrase ‘parties’ where Part will mean you to ‘all of the people on the action’ until the Court must be new functions towards arbitration arrangement. In the event that a number of them are parties toward contract, because anybody else aren’t, Point 45 will not contemplate brand new appropriate procedure while the condition of one’s non-signatories. […]