Supreme Court of India (Full Bench (FB)- Three Judge)

Appeal (Civil), 3148 of 2012, Judgment Date: Nov 25, 2014

                                                                  Reportable


                        IN THE SUPREME COURT OF INDIA

                        CIVIL APPELLATE JURISDICTION


                        CIVIL APPEAL NO. 3148 OF 2012



M/S. HYDER CONSULTING (UK) LTD.                               ... APPELLANT                  




                                   VERSUS


GOVERNOR, STATE OF ORISSA THROUGH CHIEF                                    

ENGINEER                                                      ... RESPONDENT                    




                                    WITH


                        CIVIL APPEAL NO. 3147 OF 2012

                        CIVIL APPEAL NO. 3149 OF 2012

                        CIVIL APPEAL NO. 1390 OF 2013

                        S.L.P. (C) NO. 19895 OF 2008

                        S.L.P. (C) NO. 20282 OF 2008

                        S.L.P. (C) NO. 21896 OF 2010

                        S.L.P. (C) NO. 18614 OF 2012


                                  JUDGMENT


H.L. Dattu, CJI.



1.          In view of the reference  order  dated  13.03.2012,  this  Civil

Appeal and the matters connected therewith are placed before  a  three-Judge

Bench of this Court for consideration  and  decision.  The  question  before

this Court is, whether the decision of this Court in State  of  Haryana  and

Others v. S.L. Arora and Company., (2010) 3 SCC  690,  wherein  it  is  held

that an award of interest  on  interest  from  the  date  of  award  is  not

permissible under sub- section (7) of section  31  of  the  Arbitration  and

Conciliation Act, 1996 (for short, "the Act, 1996"), is in  consonance  with

earlier decisions of this Court. A two-Judge Bench of  this  Court,  by  the

said reference order, is    of the opinion that the present appeal  and  the

connected matters would need to be heard by a Bench of three Judges of  this

Court.




2.          By the referral order dated 13.03.2012, it  is  found  that  the

learned counsel for the appellants therein would doubt  the  correctness  of

the  decision  in  the  S.L.  Arora  case  (supra)  in  light  of  McDermott

International INC v. Burn Standard Co. Ltd. and Others, (2006) 11  SCC  181;

Uttar Pradesh Cooperative Federation Limited v.  Three  Circles,  (2009)  10

SCC 374; Oil and Natural Gas Commission v.  M.C.  Clelland  Engineers  S.A.,

(1999) 4 SCC 327; and Central Bank of India v. Ravindra and  Others,  (2002)

1 SCC 367. Therein, the appellants would contend that,  in  accordance  with

the decision of  this  Court  in  the  aforementioned  cases,  the  interest

awarded on the  principal  amount  upto  the  date  of  award,  becomes  the

principal amount for the purposes of  awarding  future  interest  under  the

Act, 1996. The appellants would contend that the decision in the S.L.  Arora

case (supra) inadvertently and erroneously assumed that  the  aforementioned

cases would not be applicable to it. Since the decision in  the  S.L.  Arora

case (supra) negated  the  above  stated  principle,  the  appellants  would

contend that the said case would require reconsideration by a  larger  Bench

of this Court.


FACTS :


Civil Appeal No.3148 of 2012


3.          The present civil appeal came before a two-Judge Bench  of  this

Court against a judgment and final order dated  28.07.2010,  passed  by  the

High Court of Orissa at Cuttack in Writ Petition (Civil) No. 5302  of  2009.

The said Writ Petition was filed challenging  the  orders  dated  19.02.2009

and 26.03.2009, passed by the District Judge, Khurda in  Execution  Petition

No. 17 of 2006, whereby the learned District  Judge  had  issued   order  of

attachment in favour of the appellant herein. The  claim  in  the  execution

petition was for the payment of Rs.8,92,15,993/-. The  said  claim  included

in itself post award interest on  the  aggregate  of  the  principal  amount

awarded by the arbitral award and interest pendente lite thereon. By  virtue

of arbitral award dated 26.04.2000, which was upheld by the  Division  Bench

of the High Court of Orissa by  its  order  dated  28.06.2006,  a  principal

amount of Rs.2,30,59,802/- was awarded in favour of  the  appellant  herein.

The said impugned judgment of the High Court  of  Orissa  dated  28.07.2010,

inter alia, relied upon the decision of this Court in the  S.L.  Arora  case

(supra) and quashed  the  orders  passed  by  the  learned  District  Judge,

whereby Rs.8,92,15,993/-  was  awarded  in  favour  of  the  appellant.  The

learned Judges of the High Court, vide the impugned judgment,  directed  the

executing court to re-calculate the total amount  payable  under  the  award

keeping in view the principles laid down in the S.L. Arora case (supra).




4.           According  to  the  referral  order   dated   13.03.2012,   the

appellants contended that the S.L.  Arora  case  (supra)  was  based  on  an

inadvertent erroneous assumption that McDermott case (supra) and  the  Three

Circles case (supra) were per incuriam in holding that interest  awarded  on

the principal amount upto the date of award  becomes  the  principal  amount

and, therefore, award of future interest thereon would not amount  to  award

of interest on interest. The S.L. Arora case (supra) held  contrary  to  the

aforementioned principle. To support their contention, the  appellants  also

made a reference to the ONGC case (supra) and  the  Central  Bank  of  India

case (supra).




ISSUES :




5.          The issues that arise for the consideration of  this  Court  are

firstly, whether in light of the Three Circles case  (supra)  and  McDermott

case (supra) there exists any infirmity in the  decision  rendered  by  this

Court in the S.L. Arora case (supra); and secondly to determine whether sub-

 section (7) of section 31 of the Act, 1996 could be interpreted to  include

interest pendente lite within the sum payable as  per  the  arbitral  award,

for the purposes of awarding post-award interest.




SUBMISSIONS :




6.          Shri K.K. Venugopal, learned Senior Counsel  appearing  for  the

appellants herein, in the first instance, would submit that the decision  in

the S.L. Arora case (supra) was incorrect in ignoring the earlier  decisions

of this Court, namely the Three Circles case  (supra),  the  McDermott  case

(supra), the ONGC case (supra) and the Central Bank of India  case  (supra).

In light of the aforesaid latter cases, it is contended that the S.L.  Arora

case (supra) wrongly held that the interest as envisaged  under  clause  (b)

of sub- section (7) of section 31 of the Act, 1996 would apply only  on  the

principal amount awarded by  the  arbitral  tribunal.  Shri  K.K.  Venugopal

would further refer to the 246th Report  of  the  Law  Commission  of  India

titled as 'Amendments to the Arbitration  and  Conciliation  Act,  1996'  in

support of the above contention.




7.          The submissions of Shri K.K. Venugopal could  be  summarized  as

follows- firstly, that under clause (a) of sub- section (7)  of  section  31

of the Act, 1996, the award is for money and the sum for which the award  is

made would include within it, the interest  that  may  be  awarded  for  the

period from the date of cause of action to  the  date  of  award;  secondly,

that under clause (b) of sub- section (7) of section 31 of  the  Act,  1996,

the sum directed to be paid by the arbitral award is the sum awarded,  which

is  inclusive  of  interest  pendente  lite;  thirdly,  that  there  may  be

scenarios wherein an award would be made only  for  interest  as  the  claim

would relate only to interest and in such a  case  18%  per  annum  interest

would  automatically  attach  to  the  given  award;  fourthly,   that   the

transaction on which the claim is made and the money is so  awarded,  merges

with the award and ceases to be  the  principal  amount,  so  that  interest

under clause (b) would be the totality; fifthly, that the comparison of  the

amended section 34 of the Code of Civil  Procedure,  1908  would  show  that

unless the phrase 'principal amount' is used in clause  (a)  for  'sum'  and

again 'principal amount' is used in clause (b) for  'sum',  the  word  'sum'

would be the aggregate of the principal amount and interest;  sixthly,  that

the entirety of commercial transactions would be  seriously  affected  if  a

judgment debtor were to delay the payment of interest on the  total  amount,

as the gain to the judgment debtor on that element of interest is a loss  to

the claimant for which he has no recourse; seventhly, the  S.L.  Arora  case

(supra) was wrongly decided as the judgment is contrary to the Act, 1996  on

the grounds, inter alia, that it would be a misnomer to state that  interest

would not be applicable on substantive claims as the same finds  no  mention

in the given  provision;  and  lastly,  18%  interest  would  be  applicable

proprio vigore unless stopped by the award itself.




8.          Per contra, Shri L. Nageshwara Rao, learned Senior  Counsel  and

Additional Solicitor General  of  India  would  submit  that  there  was  no

infirmity whatsoever in the S.L. Arora case  (supra)  and  that,  therefore,

the present reference was not required. Furthermore, the learned  Additional

Solicitor General would submit that the term "sum" as found in sub-  section

(7) of section 31 of the Act, 1996 should be read as "principal  amount"  as

held in the S.L. Arora case (supra).




DISCUSSION :




9.          At the outset, it would be necessary to discuss the  correctness

of the reference order in light of the S.L. Arora case (supra). This  Court,

in the S.L. Arora case (supra), was required to adjudicate upon two  primary

issues namely- firstly, whether sub- section (7) of section 31 of  the  Act,

1996 authorised the arbitral tribunal to award  interest  on  interest  from

the date of award; and secondly, whether the arbitral tribunal  could  grant

future interest from the date of award.




10.         In the S.L.  Arora  case  (supra),  this  Court  had  sought  to

clarify whether the arbitral tribunal's power to grant  post-award  interest

extended only on the principal amount or on the aggregate of  the  principal

amount and the interest, as determined to be payable from the date of  cause

of action to the date of award. On perusal of sub- section  (7)  of  Section

31 of the Act, 1996, this Court observed:


"18. Section 31(7) makes no reference to payment  of  compound  interest  or

payment of interest upon interest. Nor does it require  the  interest  which

accrues till the date of the award, to be treated as part of  the  principal

from the date of award for calculating the post-award interest. The  use  of

the words "where and insofar as an arbitral award  is  for  the  payment  of

money" and use of the words "the Arbitral Tribunal may include  in  the  sum

for which the award is made, interest ... on the whole or any  part  of  the

money" in Clause (a) and use of the words "a sum directed to be paid  by  an

arbitral award shall ... carry interest" in Clause (b)  of  Sub-section  (7)

of Section 31 clearly indicate that the section contemplates award  of  only

simple interest and not compound interest or interest upon interest. "A  sum

directed to be paid by an arbitral award" refers to the  award  of  sums  on

the substantive claims and does not refer to interest awarded  on  the  "sum

directed to be paid by the award". In  the  absence  of  any  provision  for

interest upon interest in the contract, the arbitral tribunals do  not  have

the power to award interest upon interest, or compound interest, either  for

the pre-award period or for the post-award period."


                                                      (emphasis in original)




11.         In the S.L. Arora case  (supra),  this  Court  highlighted  that

there was a tendency among contractors to elevate the  claims  for  interest

and costs to the level of substantive disputes, by categorizing  them  under

independent  heads  of  claim.  Further,  it   was   noticed   that,   since

arbitrations  usually  have  a  high  pendency  period  owing  to  prolonged

arbitration  proceedings  or  intervening   as   well   as   post   arbitral

litigations, the interest payable on the amount awarded often  increases  to

substantial amounts, sometimes even exceeding  the  actual  amount  awarded.

The Court, in the S.L. Arora case (supra), then sought to set out the  legal

position on the award  of  interest  to  understand  the  authority  of  the

tribunal as envisioned in sub- section (7) of Section 31 of the Act, 1996.




12.         The present reference requires  this  Court  to  reconsider  the

decision in S.L. Arora case (supra), in light of previous decisions of  this

Court in the McDermott case (supra) and the Three Circles case  (supra).  It

may be reiterated that the referral order dated  13.03.2012  takes  note  of

the  contention  of  the  appellants  that  the  S.L.  Arora  case   (supra)

erroneously held the Three Circles  case  (supra)  and  the  McDermott  case

(supra) to  be  per  incuriam  in  holding  that  interest  awarded  on  the

principal amount upto the date of award becomes the principal amount.




13.          Before  I  consider  the  correctness  of  the   aforementioned

decisions, it would be necessary to  elaborate  upon  the  concept  of  "per

incuriam". The  latin  expression  per  incuriam  literally  means  'through

inadvertence'. A decision can be said to be  given  per  incuriam  when  the

Court of record has acted in ignorance of any previous decision of its  own,

or a subordinate court has acted in ignorance of a decision of the Court  of

record. As regards the judgments of this Court  rendered  per  incuriam,  it

cannot be said that this Court has "declared the law"  on  a  given  subject

matter, if the relevant law was not duly considered by  this  Court  in  its

decision. In this  regard,  I  refer  to  the  case  of  State  of  U.P.  v.

Synthetics and Chemicals Ltd.,  (1991)  4  SCC  139,  wherein  Justice  R.M.

Sahai, in his concurring opinion stated as follows:




"40. 'Incuria' literally means  'carelessness'.  In  practice  per  incuriam

appears  to  mean  per  ignoratium.  English  courts  have  developed   this

principle in relaxation of the rule of stare decisis. The 'quotable in  law'

is avoided and ignored if it is rendered, 'in ignoratium  of  a  statute  or

other binding authority'. ..."




14.         Therefore, I am of the considered view that a prior decision  of

this Court on identical facts and law binds the Court on the same points  of

law in a later case. In exceptional circumstances, where  owing  to  obvious

inadvertence or oversight, a judgment fails  to  notice  a  plain  statutory

provision or obligatory authority  running  counter  to  the  reasoning  and

result reached, the principle of per incuriam may apply. The said  principle

was also noticed in the case of Fuerst Day Lawson  Ltd.  v.  Jindal  Exports

Ltd., (2001) 6 SCC 356.




15.         I would now analyse the decisions noticed by the referral  order

dated 13.03.2012, to determine the correctness or otherwise of  the  present

reference, and consequently determine the power of an arbitral  tribunal  to

award interest under section 31 of the Act, 1996.




16.         This Court in  the  Three  Circles  case  (supra),  placing  its

reliance on  earlier  decisions,  by  its  judgment,  allowed  the  arbitral

tribunal to pass an  award,  enforcing  interest  on  interest.  This  Court

observed that:


"31. Now the question comes which is related to  awarding  of  'interest  on

interest'. According to the appellant, they  have  to  pay  interest  on  an

amount which was  inclusive  of  interest  and  the  principal  amount  and,

therefore, this amounts to a liability to pay 'interest on  interest'.  This

question is no longer res integra at the present point of time.  This  Court

in McDermott International Inc. v. Burn Standard Co. Ltd and Ors.,(2006)  11

SCC 181 has settled this question in which it had observed as  follows  (SCC

p.207, para 44):


"44. ...The  Arbitrator  has  awarded  the  principal  amount  and  interest

thereon upto the date of award and future interest thereupon  which  do  not

amount to  award  on  interest  on  interest  as  interest  awarded  on  the

principal amount upto the date of award became the  principal  amount  which

is permissible in law."


The High Court on this question has also rightly relied  on  a  decision  of

this Court in the case of Oil and Natural Gas Commission  v.  M.C.  Clelland

Engineers S.A. (1999) 4 SCC 327. That being the position, we are  unable  to

find any ground to set aside the judgment of the Division Bench of the  High

Court while considering the ground of 'interest on interest'."




17.         It  would  be  crucial  to  note  that  the  reliance  upon  the

McDermott case (supra) by this Court in the Three Circles  case  (supra)  is

not in consonance with the doctrine of  precedents.  On  a  perusal  of  the

McDermott case (supra), it is observed that the substantive  proposition  of

that case did not address the issue on the power of the  tribunal  to  award

'interest on interest' or compound interest. The  proposition  on  'interest

on interest' was made only in one  of  the  submissions  of  the  respondent

therein.  The  ratio  decidendi  of  that  decision  merely  laid  down  the

discretion of the arbitrator to decide the rate of  interest  awarded  under

sub- section (7) of section 31 of the Act, 1996, on a part or whole  of  the

award money. In this regard, the Court observed as follows:


"154. The power of the arbitrator to award interest  for  pre-award  period,

interest pendent lite and interest post-award  period  is  not  in  dispute.

Section 31(7)(a)provides that the arbitral tribunal may award  interest,  at

such rate as it deems reasonable, on the whole or any  part  of  the  money,

for the whole or any part of the period between the date on which the  cause

of action arose and the  date  on  which  award  is  made,  i.e.,  pre-award

period. This, however, is subject to the agreement as  regard  the  rate  of

interest on unpaid sum between the  parties.  The  question  as  to  whether

interest would be paid on the whole or part of  the  amount  or  whether  it

should be awarded in the pre-award period would depend upon  the  facts  and

circumstances of each case. The arbitral tribunal in this behalf  will  have

to exercise its discretion as regards (i) at what rate  interest  should  be

awarded; (ii) whether interest should be awarded on whole  or  part  of  the

award money; and (iii) whether interest should be awarded for whole  or  any

part of the pre-award period.


155. The 1996 Act provides for award of 18% interest. The arbitrator in  his

wisdom has granted 10% interest both for the principal amount  as  also  for

the interim. By reason of the award, interest was awarded on  the  principal

amount. An interest thereon was upto the date of award as  also  the  future

interest at the rate of 18% per annum.


156. However, in some  cases,  this  Court  has  resorted  to  exercise  its

jurisdiction under Article 142 in order to do complete justice  between  the

parties."




18.         From the above-quoted paragraphs of the McDermott case  (supra),

it is abundantly clear that the decision  neither  makes  any  reference  to

awarding of compound interest nor does it allow post-award  interest  to  be

imposed on the aggregate of the principal claim and interest pendente  lite.

This Court had merely sought to clarify the position  with  respect  to  the

rate of interest awarded and further the  power  of  this  Court  to  invoke

Article 142 of the Constitution of India, 1950 to alter  the  said  rate  of

interest in  order  to  do  complete  justice.  Thus,  it  is  evident  from

paragraphs 154 to 156 of the McDermott case (supra),  that  the  proposition

surrounding  arbitral  tribunal's  authority  to  award  of   'interest   on

interest' was not deliberated upon but  merely  argued  by  the  respondents

therein. However, this argument was erroneously relied  upon  in  the  Three

Circles case (supra) to  decide  upon  the  issue  related  to  awarding  of

'interest on interest' or compound interest.




19.         This Court, therefore,  in  the  S.L.  Arora  case  (supra)  has

disagreed with the reasoning laid down in  the  McDermott  case  (supra)  as

well as the Three Circles case  (supra).  This  Court,  on  perusal  of  the

relevant paragraphs in the aforesaid decisions, held that  the  observations

therein must be treated as per incuriam on  the  issue  around  awarding  of

'interest on interest' or compound interest. It was observed that:


"28. ...But a careful reading of the decision in Mcdermott, shows  that  the

portion of Mcdermott extracted in Three Circles, assuming it to be  the  law

laid down in Mcdermott, is not a finding or conclusion of  this  Court,  nor

the ratio decidendi of the case, but is only a reference to  the  contention

of the respondent in Mcdermott.


29. Paras 1 to 27 (of  the  SCC  report)  in  Mcdermott  state  the  factual

background. Paras 28 and 29 contain the submissions of the  learned  Counsel

for BSCL, the respondent therein. Paras 30 to  44  contain  the  submissions

made by the learned Counsel for Mcdermott, the appellant therein,  in  reply

to the submissions made on behalf of BSCL. The passage that is extracted  in

Three Circles is part of para 44 of the decision  which  contains  the  last

submission  of  the  learned  Counsel  for  Mcdermott  on  the  question  of

interest. The reasoning in the decision starts  from  para  45.  This  Court

considered the several questions seriatum in paras 45 to 160.  The  question

relating to interest was considered in paras 154 to  159  relevant  portions

of which we have  extracted  above.  Therefore,  the  observation  in  Three

Circles that Mcdermott held that interest awarded on  the  principal  amount

upto the date of award becomes the principal amount and therefore  award  of

future interest therein does not amount to award of  interest  on  interest,

is per incuriam due to an inadvertent erroneous assumption."




20.         I am in agreement with the aforesaid  view  in  the  S.L.  Arora

case (supra). The decision in  the  McDermott  case  (supra)  would  not  be

applicable, since it does not pertain to  the  issue  of  granting  compound

interest on  the  post-award  claim.  This  Court,  in  the  McDermott  case

(supra), did not consider the issue pertaining to award  of  'interest  upon

interest' or compound interest. It merely held that  the  interest  must  be

awarded on the principal amount upto the date of award. Thus, the  McDermott

case (supra) would be wholly inapplicable to the issue for consideration  by

this Bench.




21.         Further, the decision of Three  circles  case  (supra)  did  not

place reliance on the ratio decidendi of  the  McDermott  case  (supra)  but

merely re-stated the contention raised by the respondent therein  to  decide

upon the issue of 'interest on interest' or  compound  interest.  Therefore,

in my considered view, the Three Cirlces case (supra)  would  be  deemed  as

per incuriam in regard to the concept of awarding 'interest on interest'  or

compound interest, due to such an inadvertent erroneous  reliance  upon  the

McDermott case (supra).




22.          At  this  stage,  it  would   be   necessary   to   take   into

consideration, the decisions of this Court in the ONGC case (supra) as  well

as the Central Bank of India  case  (supra).  It  was  argued,  as  per  the

referral order, that these decisions  would  support  the  proposition  that

arbitral tribunals have the authority to award 'interest on  interest'  from

the date of the award.




23.         On perusal of the ONGC case (supra), I find that this Court  has

recognised and accepted the power of arbitral tribunals  to  award  interest

upon interest. This Court has  considered  such  an  award  as  a  requisite

compensatory measure for delayed payment and included  such  interest  along

with the principal amount in the 'sum' so awarded. This  Court  observed  as

follows:


"4. There cannot be any doubt that the  Arbitrators  have  powers  to  grant

interest akin to Section 34 of the CPC which is the power of  the  court  in

view of Section 29 of the Arbitration Act, 1940. It is clear  that  interest

is not granted upon interest awarded but upon  the  claim  made.  The  claim

made in the proceedings is under two heads - one is the  balance  of  amount

claimed under invoices and letter dated February 10,  1981  and  the  amount

certified and paid by the appellant  and  the  second  is  the  interest  on

delayed payment. That is how the  claim  for  interest  on  delayed  payment

stood crystallized by the time the claim was filed before  the  Arbitrators.

Therefore, the power of the Arbitrators to grant interest on the  amount  of

interest which may, in other words, be termed  as  interest  on  damages  or

compensation for delayed  payment  which  would  also  become  part  of  the

principal. If that is the correct position in law,  we  do  not  think  that

Section 3 of the Interest Act has  any  relevance  in  the  context  of  the

matter which we are dealing with in the present case. Therefore,  the  first

contention raised by Shri Datta, though interesting, deserves to be  and  is

rejected."




24.         However, it would be  pertinent  to  note  that  the  ONGC  case

(supra) as well as the Three Circles case (supra),  both  pertained  to  the

awards under the Arbitration Act, 1940 (for  short  "the  Act,  1940").  The

Act,  1940  did  not  contain  any  specific  provision  dealing  with   the

arbitrator's power to grant interest. Further,  it  is  a  settled  position

that the decisions of this Court regarding award of interest made under  the

Act, 1940 are not applicable to arbitration held under  the  Act,  1996.  In

this regard, I place reliance on the decision of this Court in Sayeed  Ahmed

& Co. v. State of U.P. & Ors., (2009) 12 SCC 26,  wherein  it  was  observed

that:


"14. The decisions of this Court with reference to the awards under the  old

Arbitration Act making a distinction between the  pre-reference  period  and

pendente lite period and the observation therein  that  arbitrator  has  the

discretion to award interest during pendente lite period inspite of any  bar

against interest contained in the  contract  between  the  parties  are  not

applicable to arbitrations governed by the Arbitration and Conciliation  Act

1996."




25.         Pursuant to the enactment of sub- section (7) of section  31  of

the Act, 1996, the difference  between  pre-reference  period  and  pendente

lite period has been removed insofar as it relates to the award of  interest

by arbitrator, unlike the position as under the Act, 1940. It would  not  be

appropriate for this Court, in matters pertaining to the Act, 1996, to  rely

upon decisions which interpreted the arbitrator's power  to  award  interest

under the Act, 1940. This position was further reiterated in  Sree  Kamatchi

Amman Constructions v. The Divisional Railway Manager (Works),  Palghat  and

Ors., (2010) 8 SCC 767.




26.         Furthermore, I take note of the  fact  that  the  aforementioned

principle was applied by this Court in the S.L. Arora case (supra).  It  was

explicitly stated that since the ONGC case (supra) and  Three  Circles  case

(supra) related to awards under the Arbitration Act, 1940, they  can  be  of

no assistance in interpreting sub- section (7) of section  31  of  the  Act,

1996. I concur with the above reasoning to show the inapplicability  of  the

ONGC case (supra) and the Three Circles case (supra) to the present case.




27.         The last case relied  upon  by  the  appellants  herein  is  the

Central Bank of India case (supra). This Court in the Central Bank of  India

case (supra), under Section 34 of the Code of  Civil  Procedure,  1908  (for

short, "the Code"),  sought  to  determine  whether  the  liability  of  the

borrower to pay interest on the principal sum, would include  interest  that

became merged with the  principal  sum  adjudged.  This  aforesaid  decision

discussed the scope for charging compound interest under Section 34  of  the

Code. The  Court  sought  to  determine  the  meaning  attached  to  phrases

'principal sum adjudged' and 'such principal  sum',  pursuant  to  the  1956

amendment to the Code. Further, the Court sought to determine  whether  such

'principal sum' would include liability to pay  compound  interest  thereon.

However, the issue with respect to award of  interest  upon  interest  under

sub- section (7) of Section 31 of the Act, 1996 was not the  subject  matter

in the aforesaid decision.




28.         In my considered view, the Central Bank of  India  case  (supra)

cannot be  relied  upon  by  the  appellants  herein  in  support  of  their

contention that the arbitral tribunal possessed the power to award  interest

on interest. The Central Bank of India case (supra) dealt  with  section  34

of the Code, and therefore may not be said to be wholly applicable to  cases

under the Act, 1996. However, even if the principle  in  the  said  case  is

held to be applicable to the Act, 1996,  it  would  only  support  the  view

endorsed by the S.L. Arora case (supra).




29.         Lastly, it would be necessary to  highlight  the  views  of  the

246th Report of the Law Commission of India, which suggested  amendments  to

the Act, 1996. On the question of 'Interest on Sums Awarded' at page  33  of

the said Report, the Commission was of the opinion that the  words  used  in

sub- section (7) of Section 31 of the Act, 1996 are of wider import and  the

scheme of the relevant provisions indicated that the award  of  interest  on

interest is not only permitted but is also the norm. The Commission  was  of

the view  that  the  decision  in  the  S.L.  Arora  case  (supra)  required

reconsideration on the issue  of  awarding  future  interest  on  both,  the

principal sum as well as the interest accrued till date  of  the  award.  In

light of the preceding discussion, I do not agree with the said  view  taken

by the Commission. It is my considered opinion that  the  decision  in  S.L.

Arora case (supra) is sound and wholly conclusive on the  interpretation  of

sub- section (7) of Section 31 of the Act, 1996 on  the  issue  of  awarding

'interest on interest'. The Law Commission had erred  in  relying  upon  the

ONGC case (supra) as well as the Three Circles  case  (supra),  since  these

decisions are not applicable to the present arbitration held under the  Act,

1996.




30.         Thus, I am of the considered opinion that,  since  the  position

on the interpretation of sub- section (7) of Section 31  of  the  Act,  1996

regarding award of interest upon interest has been correctly decided in  the

S.L. Arora case (supra), the present reference  may  not  be  required.  The

decision of this Court in the Three Circles case (supra)  was  rightly  held

to be passed on inadvertent erroneous assumption,  as  stated  in  the  S.L.

Arora case (supra). The  McDermott  case  (supra)  did  not  deal  with  the

question pertaining to  awarding  of  'interest  on  interest'  or  compound

interest. Furthermore, the decision in the ONGC case  (supra)  pertained  to

the Act, 1940, and, therefore, in light of the  settled  principle  of  law,

would not be applicable to cases under the Act, 1996. Lastly,  the  decision

in the Central Bank of India case  (supra)  did  not  deal  with  the  issue

around interpretation of sub- section (7) of Section 31 of  the  Act,  1996,

nor did the principle laid down therein hold contrary  to  the  decision  in

S.L. Arora case (supra).




31.         However, out of sheer deference to the learned  two-Judge  Bench

of this Court, I would clarify the apparent controversy around sub-  section

(7) of section 31 of the Act, 1996. The said provision reads as follows:




"31. Form and contents of arbitral award.-


...


(7) (a) Unless otherwise agreed by the parties, where and in so  far  as  an

arbitral award is for the  payment  of  money,  the  arbitral  tribunal  may

include in the sum for which the award is made interest, at such rate as  it

deems reasonable, on the whole or any part of the money, for  the  whole  or

any part of the period between the date on which the cause of  action  arose

and the date on which the award is made.


(b) A sum directed to be paid by an arbitral award shall, unless  the  award

otherwise directs, carry interest at the rate of  eighteen  per  centum  per

annum from the date of the award to the date of payment."




32.         On a bare perusal of the said section, I find that in the  first

instance, it applies only to an arbitral award which is for the  payment  of

money. The power to  award  interest  by  the  arbitral  tribunal  has  been

divided into two stages- firstly, from the date of cause of  action  to  the

date on which the arbitral award is made, and secondly,  from  the  date  of

award to the date of payment. The said classification was  also  noticed  by

this Court in the Sayeed Ahmed case (supra). I will deal with  these  stages

separately as has been provided under the said provision itself.




33.         Under clause (a) of sub- section (7) of section 31 of  the  Act,

1996, I find that it relates to  the  power  of  the  arbitrator  to  impose

interest in the first stage as mentioned  hereinabove,  that  is,  from  the

date of cause of action to the date  of  arbitral  award.  The  said  clause

begins with "Unless otherwise agreed by the parties", thereby at  the  onset

of the sub-section itself, the legislature has provided  for  a  restriction

on the application of the said sub-  section.  In  the  event  there  is  an

agreement between the parties to the arbitration, regarding the  payment  of

interest from the date on which the cause of action arose till the  date  on

which the award was made, the terms of  the  said  agreement  would  prevail

over clause (a) of sub- section (7) of section 31 of  the  Act,  1996.  This

Court, in the Sree Kamatchi Amman Constructions case  (supra),  observed  as

follows:


"19. Section 37(1)(sic) of the new Act by using the words "unless  otherwise

agreed by the parties" categorically clarifies that the arbitrator is  bound

by the terms of the contract insofar as the award of interest from the  date

of cause of action to the date of award. Therefore, where  the  parties  had

agreed that no interest shall  be  payable,  the  Arbitral  Tribunal  cannot

award interest between the date when the cause of action arose to  the  date

of award."




34.         In the context of the Act, 1996, the  phrase  "unless  otherwise

agreed by the parties" was explained in the case of N.S.  Nayak  &  Sons  v.

State of Goa, (2003) 6 SCC 56. This Court observed that:


"14. ...The phrase "unless otherwise agreed by the parties" used in  various

sections, namely, 17, 21, 23(3),  24(1),  25,  26,  29,  31,  85(2)(a)  etc.

indicates that it is open to the parties  to  agree  otherwise.  During  the

arbitral proceedings, right is given to the  parties  to  decide  their  own

procedure. So if there is an agreement between the parties  with  regard  to

the procedure to be followed by the arbitrator, the arbitrator  is  required

to follow the said procedure. Reason being, the arbitrator is  appointed  on

the basis of the contract between the parties and is required to act as  per

the contract. However, this would  not  mean  that  in  appeal  parties  can

contend that the appellate procedure should be as per their agreement. ..."




35.          In  the  event  that  the  terms  of  the  given  contract,  as

applicable to the parties to the arbitration proceedings, are silent on  the

question of interest payable in the first stage, as given under  clause  (a)

of sub- section (7) of section 31 of the Act,  1996,  only  then  would  the

provisions of the said clause apply. The said clause  thereafter  gives  the

arbitral tribunal the discretion to include the  interest  in  the  sum  for

which the award was made. The  principles  for  levying  such  interest  are

found in the said clause itself. They are as follows:


(1) Interest to be imposed at such  rate  as  the  arbitral  tribunal  deems

reasonable;


(2) The interest may be either on the whole or any part of the money; and


(3) The interest may be for the whole or any part of the period between  the

date on which the cause of action arose and the date on which the  award  is

made.




36.         I take note that  the  arbitral  tribunal  has  been  given  the

discretionary power of not only imposing interest, but also for  determining

the rate of interest that could be imposed from the date of cause of  action

to the date of the award.  The  arbitral  tribunal  has  the  discretion  to

decide whether such interest would be imposed on the whole or a part of  the

money awarded, and further whether  it  would  be  imposed  for  the  entire

duration from the date of cause of action to the date  of  award,  or  on  a

part  of  it.  However,  such  discretion  is  not  unfettered  and  is  not

exercisable upon the mere whims and fancies of the tribunal.  In  Principles

of Statutory Interpretation, Justice G.P. Singh, Thirteenth  Edition,  2012,

at p.482, it has been stated as follows:


"Even where there is not much indication in  the  Act  of  the  ground  upon

which discretion is to be exercised it does not mean that  its  exercise  is

dependent upon mere fancy of the Court or Tribunal or  Authority  concerned.

It must be exercised in the words of Lord Halsbury, 'according to the  rules

of reason and justice, not according to private opinion;  according  to  law

and not humour; it is to be not arbitrary, vague  and  fanciful,  but  legal

and regular'."




37.         It can be  concluded  that  the  discretion,  whether  to  award

interest by the arbitral tribunal under clause (a),  is  necessarily  to  be

exercised as per  the  facts  and  circumstances  of  each  case.  The  said

discretion must be within the parameters of the statute  and  in  accordance

with the rule of law. Furthermore, the said clause states that the  rate  of

interest, if such interest is awarded by the arbitral tribunal, must  be  as

the said tribunal deems reasonable. It is settled law that  discretion  must

always be exercised lawfully.




38.         At this stage, it would be relevant to consider the  meaning  of

the words "sum" and "interest" as used in clause (a) of sub- section (7)  of

section 31 of the Act, 1996. It is settled principle  of  interpretation  of

statutes that while interpreting the words of  a  statute,  the  context  in

which they appear would be necessary to  be  taken  into  consideration.  In

support of the said principle of contextual interpretation,  I  refer  to  a

Constitution Bench decision of this Court in Darshan Singh Balwant Singh  v.

State of Punjab, 1953 SCR 319, wherein it was observed as follows:


"10. ...It is a cardinal rule of interpretation that the  language  used  by

the legislature is the true depository of the legislative intent,  and  that

words and phrases occurring in a statute are to be taken not in an  isolated

or detached manner  dissociated  from  the  context,  but  are  to  be  read

together and construed in the light of the purpose and  object  of  the  Act

itself."




39.         In the absence of a definition in the Act, 1996, I would  notice

that the word "sum",  would  simply  refer  to  money  in  common  parlance.

Further,  the  dictionary  meaning  of  the   word   may   be   taken   into

consideration. Webster's Third  New  International  Dictionary,  Volume  III

defines "sum" to mean, inter alia, the following:


"Sum: An indefinite or specified amount of money."


Black's Law Dictionary, Seventh Edition, 1999, defines "sum" as:


"sum. 1. A quantity of money."


P. Ramanatha Aiyar's Advanced Law Lexicon,  Third  Edition,  2005,  Book  4,

defines "sum", inter alia, as the following:


"Sum. When used with reference to values, 'sum' imports a sum of money."


Corpus Juris Secundum, Volume LXXXIII, defines the word "sum" as follows:


"Sum. While the  word  'sum'  must  be  construed  in  connection  with  the

context, it has a definite meaning appropriate  to  use  with  reference  to

dollars and cents, and, except where a different  meaning  plainly  appears,

it is restricted in its application to money, and in sense it  is  lexically

defined as meaning money, and this is said to be  the  sense  in  which  the

word is most commonly used."


40.         Therefore, I find that the word "sum", in  its  natural  meaning

and as per its most common usage, would mean money.  The  term  "money"  has

also been used in  sub-  section  (7)  of  section  31  of  the  Act,  1996.

Therefore, I would not hesitate in finding that the terms "sum" and  "money"

have been used by the legislature, in the given provision,  interchangeably.

In this light, it would be pertinent to take note of the given  clause  once

again. The said clause states that interest may be awarded on the "sum"  for

which the arbitral award is made, or the same could  be  read  as-  interest

may be awarded on the "money" for which the arbitral  award  is  made.  This

"money" for which the award is made, necessarily would refer  to  the  money

as adjudicated by  the  arbitral  tribunal,  based  on  the  claims  of  the

parties, to be paid under the award. In other words, it would  simply  refer

to the principal amount so awarded.




41.         It would be necessary to understand the  meaning  of  "interest"

as used under  the  said  clause  as  well.  Again,  in  the  absence  of  a

definition under the Act, 1996, I would rely  upon  its  meaning  in  common

parlance. For this, support of dictionaries can be taken.




42.         Wharton's Law Lexicon, Fourteenth  Edition,  defines  "interest"

as follows:


"Interest. 1. Money paid at a fixed rate per cent for the  loan  or  use  of

some other sum, called the principal."


Black's Law Dictionary, Seventh Edition, 1999, defines "interest" as:


"interest. 1. Advantage or profit, esp. of a financial nature."


Webster's Third New International Dictionary, Volume III defines  "interest"

to mean, inter alia, the following:


"interest. The price paid for  borrowing  money  generally  expressed  as  a

percentage of the amount borrowed paid in one year."


Corpus Juris  Secundum,  Volume  XLVII,  explains  the  word  "interest"  as

follows:


"Interest is the compensation allowed by law, or fixed by the  parties,  for

the use or forbearance of money, or as damages for its detention."


Stroud's Judicial Dictionary, Seventh Edition,  2008,  Volume  2,  p.  1385,

defines the term "interest" as follows:


"Interest  is  compensation  paid  by  the  borrower  to  the   lender   for

deprivation of the use of his money."




43.          Therefore, in light of  the  above,  "interest"  would  be  the

return or compensation for the use or retention by one person of  a  sum  of

money belonging to or owed to another. It may  be  understood  to  mean  the

amount which one has contracted to pay for the use of borrowed money. It  is

a consideration paid either for the use  of  money  or  for  forbearance  in

demanding it, after it has fallen due, and thus, it could be said  to  be  a

charge for the use or forbearance of a particular amount of money.  In  this

sense, it is a compensation allowed in law for use  of  money  belonging  to

another or for the delay in paying  the  said  money  after  it  has  become

payable. This principle has also been  noticed  in  the  Central  Bank  case

(supra).




44.         It may be pertinent to take note  of  the  approach  of  English

Courts to interpret the term "interest". In Westminster Bank Ltd v.  Riches,

[1947] A.C. 390, the House of Lords elaborated upon the term "interest"  for

payment of moneys. Lord Wright observed that:


"The essence of interest is that it is a payment which becomes  due  because

the creditor has not had his money at the  due  date.  It  may  be  regarded

either as representing the profit he might have made if he had had  the  use

of the money, or conversely the loss he suffered because  he  had  not  that

use. The general idea is  that  he  is  entitled  to  compensation  for  the

deprivation. From that point of view it would seem  immaterial  whether  the

money was due to him under a contract express or implied  or  a  statute  or

whether the money was due for any other reason in law."




45.         In the case of  Nicholas  Pike  v.  The  Commissioners  for  Her

Majesty's Revenue and Customs, [2013] UKUT 0225 (TCC), the  House  of  Lords

observed as follows:


"15. First, interest is calculated by reference to an  underlying  debt.  As

Megarry J put it in Euro Hotel (supra) at p 1084 b-f:-


"It seems to me that running through the cases there is the concept that  as

a general rule two requirements must be satisfied for payment to  amount  to

interest, and a fortiori to amount to  "interest  of  money".  First,  there

must be a sum of money by reference to which the payment which  is  said  to

be interest is to be ascertained. ... Second, those sums of  money  must  be

sums that are due to the person entitled to the alleged interest  ...  I  do

not,  of  course,  say  that  in  every  case  these  two  requirements  are

exhaustive, or that they are inescapable. Thus I do  not  see  why  payments

should not be "interest of money" if A lends money to B and stipulates  that

the interest should be paid not to him but to X: yet for the  ordinary  case

I think they suffice".


...


20. Sixth, the mere fact  that  the  payment  by  way  of  interest  may  be

aggregated with a payment of a different  nature  does  not  "denature"  the

payment that is interest. This point was made in Chevron  Petroleum  UK  Ltd

v. BP Petroleum Development Ltd [1981] STC 689 at p 694  g-j  where  Megarry

VC is reported as saying:-




"If in its nature a sum is "interest of  money"  I  think  it  retains  that

nature even if the parties to a contract provide for it  to  be  wrapped  up

with some other sum and the whole paid in the  form  of  single  indivisible

sum. The wrappings may conceal the nature of the contents, but they  do  not

alter them ... If the true nature of a sum of money is that it is  "interest

of money" that sum will not  be  denatured,  or  transmuted  into  something

different, simply by being incorporated into some larger  sum  before  being

made payable under the terms of the contract".


..."




46.         It may be inferred from the aforesaid  decisions,  that  for  an

amount to be referred as "interest",  it  must,  prima  facie,  fulfill  two

conditions-


(1) There must be a sum of money  by  reference  to  which  the  payment  of

interest may be ascertained.


(2) The sum of money must, generally, be due to the person entitled  to  the

interest.


Furthermore, it would be gainsaid in stating  that  the  mere  fact  that  a

payment of interest may be aggregated with a payment of a different  nature,

the said aggregation would not alter the distinct nature  of  interest  from

the money on which it is levied.




47.         Further, this Court in the case of Bhai  Jaspal  Singh  v.  CCT,

(2011) 1 SCC 39, observed that:


"36. Interest is compensatory in character and is  imposed  on  an  assessee

who has withheld payment of any tax as and when it is due and  payable.  The

interest is levied on the actual amount of tax withheld and  the  extent  of

delay in paying the tax on the due date.  Essentially,  it  is  compensatory

and different from  penalty  which  is  penal  in  character  [see  Pratibha

Processors v. Union of India, (1996) 11 SCC 101]."




48.         Therefore,  it  may  be  concluded  that  the  term  "interest",

appears to be distinct from the principal amount on  which  it  is  imposed.

Furthermore, the imposition of an interest is stated to be for  the  purpose

of providing compensation for withholding the said principal amount  or,  as

in the case of clause (a) of sub- section (7) of  Section  31  of  the  Act,

1996, for withholding the money awarded as per the claim, as  determined  by

the arbitral tribunal, from the date the cause  of  action  arose  till  the

date when such award was made.  In  other  words,  interest  is  imposed  to

compensate for the denial to one party, by the other  party,  of  the  money

which rightfully belongs  to  the  said  former  party  under  the  relevant

agreement governing the arbitration proceedings.




49.         Having clarified sub-section (a) of sub- section (7) of  section

31 of the Act, 1996, I would now consider clause (b) of the said  provision.

As noticed above, clause (b) is applicable for the period from the  date  of

award to the date of payment. The applicability of clause (b) has also  been

qualified by the legislature. The said clause uses the  phrase  "unless  the

award otherwise directs", which would mean that in the  event  the  arbitral

tribunal, in its award, makes a provision for  interest  to  be  imposed  in

this second stage as envisaged by sub- section (7)  of  section  31  of  the

Act, 1996, clause (b) would become inapplicable.  By  the  said  award,  the

arbitral tribunal has the power to impose an  interest  for  the  post-award

period which may be higher or  lower  than  the  rate  as  prescribed  under

clause (b). Even if the award states that no interest shall  be  imposed  in

the post-award period, clause (b) cannot be invoked.




50.         If the arbitral award is  silent  on  the  question  of  whether

there would be any post-  award  interest,  only  in  that  situation  could

clause (b) be made applicable. In the said situation, it would be  mandatory

as per law that the award would carry interest at the rate of 18% per  annum

from the date of the award to the date of payment.  The  term  used  in  the

given clause  is  "shall",  therefore,  if  applicable,  the  imposition  of

interest as per clause (b) would be mandatory.




51.         It would be relevant also to take  note  of  the  case  of  H.P.

Housing & Urban Development Authority v. Ranjit Singh  Rana,  (2012)  4  SCC

505. In the Ranjit Singh Rana  case  (supra),  this  Court  dealt  with  the

meaning of the word "payment" as under clause (b) of  sub-  section  (7)  of

section 31 of the Act, 1996 to ascertain when the  liability  to  pay  post-

award interest would come to an end. After making a reference  to  the  S.L.

Arora case (supra), this Court went into the dictionary meaning of the  word

"payment". The Court explained as follows:


"15. The word "payment" may have different meaning in different context  but

in  the  context  of  Section  37(1)(b);  it  means  extinguishment  of  the

liability arising under the award. It signifies satisfaction of  the  award.

The deposit of the award amount into the court is nothing but a  payment  to

the credit of the decree-holder. In this view, once  the  award  amount  was

deposited by  the  appellants  before  the  High  Court  on  24-5-2001,  the

liability of post-award interest from  24-5-2001  ceased.  The  High  Court,

thus, was not right in directing the appellants to pay the  interest  @  18%

p.a. beyond 24-5-2001."




52.         Clause (b) of sub- section (7) of section 31 of  the  Act,  1996

further states that the interest  as  envisaged  under  the  said  provision

would be on the sum directed to be paid by an arbitral award. As noticed  in

the discussion hereinabove, the term "sum", as in clause (a), refers  simply

to the money directed to be paid as per the award, that  is,  the  money  as

adjudicated by the arbitral tribunal.




53.         It is a settled principle of law that if the same word  is  used

more than once in the same provision of a  statute,  the  intention  of  the

legislature must be to give the same meaning  to  the  word  at  each  place

where it is repeated. There would be a presumption that  the  said  word  is

used in the same sense throughout the given provision. According to  Bennion

on Statutory Interpretation, Fifth Edition, 2008, p. 1160:


"Same words to be given same meaning. It is presumed that a word  or  phrase

is not to be taken as having different meanings within the same  instrument,

unless this fact is made clear. Where therefore the context makes  it  clear

that the term has a particular meaning in one place, it  will  be  taken  to

have that meaning elsewhere."




54.         In support of this principle, I refer to the Central  Bank  case

(supra), wherein a Constitution Bench of this Court observed as follows:


"42. ... Ordinarily, a word or expression used  at  [pic]several  places  in

one enactment should be assigned the same meaning so as to avoid "a  head-on

clash" between  two  meanings  assigned  to  the  same  word  or  expression

occurring at two places in the same enactment.  It  should  not  be  lightly

assumed that "Parliament had given with one hand what it took away with  the

other" (see Principles of Statutory Interpretation, Justice G.P. Singh,  7th

Edn. 1999,  p.  113).  That  construction  is  to  be  rejected  which  will

introduce uncertainty, friction or confusion into the working of the  system

(ibid,  p.  119).  While  embarking  upon  interpretation   of   words   and

expressions used in a statute it is possible to find a  situation  when  the

same word or expression may have somewhat  different  meaning  at  different

places depending on the subject or context. This  is  however  an  exception

which can be resorted to only in the event of repugnancy in the  subject  or

context being spelled out. It has been the consistent view  of  the  Supreme

Court that when the legislature used same word or  expression  in  different

parts of the same section or statute, there is a presumption that  the  word

is used in the same sense throughout (ibid, p. 263). More correct  statement

of the rule is, as held by the House of Lords in Farrell  v.  Alexander  All

ER at p. 736b, "where the draftsman uses the same word or phrase in  similar

contexts, he must be presumed to intend it in each place to  bear  the  same

meaning".  The   court   having   accepted   invitation   to   embark   upon

interpretative expedition shall identify on its radar the contextual use  of

the word or expression and then determine its direction  avoiding  collision

with icebergs of inconsistency and repugnancy."


55.         It can be concluded that it is  a  sound  rule  of  construction

whereby the same word appearing in the same  section  of  the  same  statute

must be given the same meaning, unless there is  anything  to  indicate  the

contrary. The only exception to this rule of construction, whereby the  said

principle may be rebutted, is by making reference to the  context  in  which

the words are used. The word may be understood in a different sense, if  the

context so requires that to be done. The  context  herein,  that  is,  under

clause (a) and under clause (b) of sub- section (7) of  section  31  of  the

Act, 1996, does not appear to be divergent from one another. The word  "sum"

has been used in both clauses in the context of what is to be  paid  as  per

the arbitral award.




56.         Before I conclude, it would be profitable to take  note  of  the

Central Bank of India case (supra) with  regard  to  the  limited  issue  of

imposition  of  compound  interest.  While  describing  the  role   of   the

legislature to relieve burdened debtors from being charged  with  oppressive

compound interest rates, this Court  in  the  Central  Bank  of  India  case

(supra),  stated  that  the  practice  of   imposing   such   interest   was

permissible, legal and judicially correct, if it  was  a  consequence  of  a

voluntary  agreement  between  the  parties,  except  when  the   same   was

superseded  by  legislation.  Furthermore,  this  Court  observed  that  the

interest would be included as part of the principal amount only once  it  is

capitalised. This  Court,  in  the  Central  Bank  of  India  case  (supra),

observed as follows:


"36. ...There is nothing wrong in  the  parties  voluntarily  entering  into

transaction, evidenced by deeds incorporating covenant  or  stipulation  for

payment of compound  interest  at  reasonable  rates,  and  authorising  the

creditor to capitalise the interest on remaining  unpaid  so  as  to  enable

interest being charged at the agreed rate on the interest component  of  the

capitalised sum for the succeeding period. Interest once capitalised,  sheds

its colour of being interest and becomes a part of principal so as  to  bind

the debtor/borrower."




57.         To support the  above  principle,  whereby  it  is  stated  that

compound interest is permissible  only  as  a  consequence  of  an  explicit

statutory provision, I take note of the case  of  Union  of  India  v.  Tata

Chemicals Ltd., (2014) 6 SCC 335 wherein this Court observed as follows:


"38. Providing for payment of interest in case of refund of amounts paid  as

tax or deemed tax or advance tax is a  method  now  statutorily  adopted  by

fiscal legislation to ensure that the aforesaid  amount  of  tax  which  has

been duly paid in prescribed time and provisions in that  behalf  form  part

of the recovery machinery provided in  a  taxing  statute.  Refund  due  and

payable to the assessee  is  debt-owed  and  payable  by  the  Revenue.  The

Government, there-being  no  express  statutory  provision  for  payment  of

interest on the refund  of  excess  amount/tax  collected  by  the  Revenue,

cannot shrug off its apparent obligation to reimburse the  deductors  lawful

monies with the accrued interest for the period of undue retention  of  such

monies. ..."




58.         I may also take note of the decision in Parkside Leasing Ltd  v.

Smith (Inspector of Taxes) [1985] 1 WLR 310, wherein the Chancery  Division,

while discussing the difference between the receipt of proceeds by  cash  or

by cheque, was of the view that it would be  the  actual  "receipt"  of  the

proceeds, in either case, that places such proceeds at the  disposal of  the

payee. The said decision relied upon D&C Builders  Ltd.  v.  Rees  [1966]  2

Q.B. 617, wherein Lord Denning observed that:


"...The cheque, when given, is conditional payment.  When  honoured,  it  is

actual payment. ..."


In other words, the Parkside Leasing Ltd. case (supra) was of the view  that

money would be "paid" only when the  recipient  would  have  the  option  to

utilise the said money and exercise willful discretion.




59.         For the purposes of the Act, 1996, interest  could  be  included

within the principal amount only when the said aggregate amount is  paid  to

the party in whose favour the arbitral award was  passed.  In  other  words,

once the interest amount is within the physical  and  actual  possession  of

the party so entitled to it, only then could the interest amount be said  to

have merged with the principal amount. Therefore, in the  present  scenario,

the appellants would not be entitled to claim  post-award  interest  on  the

aggregate of the principal amount and  interest  pendente  lite,  since  the

said aggregate sum  was  not  in  the  actual  physical  possession  of  the

appellants herein. Further, I take note that sub- section (7) of section  31

of the Act, 1996, neither makes reference to compounding  of  interest,  nor

to awarding interest on interest.




60.         Therefore, in my considered view, the  term  "sum"  as  used  in

clause (b) of sub- section (7) of section 31 of the  Act,  1996  would  have

the same meaning as assigned to the  word  under  clause  (a)  of  the  same

provision. It would refer to  the  money  as  adjudicated  by  the  arbitral

tribunal based on the claim of the parties to the arbitral  proceedings.  It

has already been  noticed  that  this  money  would  be  distinct  from  the

interest as may have been awarded by the arbitral tribunal under clause  (a)

of sub- section (7) of section 31 of the Act, 1996. Therefore, the  interest

under clause (b) would be imposed on money awarded by the arbitral  tribunal

on the basis of the claims of the parties, and the said money  cannot  merge

within it any interest as imposed in the period from the date  of  cause  of

action to the date of the award.




61.         In light of the above discussion, the reference is  answered  in

the following terms-


      I find no infirmity with the S.L. Arora case (supra), whereby  it  was

held that if the arbitral award is silent about interest from  the  date  of

award till the date of payment, the person in  whose  favour  the  award  is

made will be entitled to interest at 18% per annum on the  principal  amount

awarded, from the date of award till the date of payment.




62.         In view of the above, while answering the referral order,  Civil

Appeal No. 3148 of 2012, along with all connected matters, is remanded  back

to an appropriate two-Judge Bench of this Court for adjudication.


                                                          ..............CJI.

                                                                [H.L. DATTU]

NEW DELHI,

NOVEMBER 25, 2014.








                                                                  REPORTABLE


                        IN THE SUPREME COURT OF INDIA


                        CIVIL APPELLATE JURISDICTION


                        CIVIL APPEAL No. 3148 OF 2012



M/S. HYDER CONSULTING (UK) LTD.             .... APPELLANT




                                   VERSUS


GOVERNOR STATE OF ORISSA TH. CHIEF ENG. .. RESPONDENT


                                    WITH


                           SLP (C) No. 19895/2008


                            SLP (C) No. 20282/2008


                       CIVIL APPEAL No.  3149 OF 2012


                       CIVIL APPEAL No.  3147 OF 2012


                            SLP (C) No. 18614/2012


                       CIVIL APPEAL No.  1390 OF 2013


                            SLP (C) No. 21896/2010


                                      1



                            2           JUDGMENT




S. A. BOBDE, J.


1.    I have had the advantage of reading  the  Judgment  of  my  Lord,  the

Chief Justice.  I entirely agree that the findings of this  Court  in  State

of Haryana and Others v. S.L. Arora and  Company,  (2010)  3  SCC  690  that

Uttar Pradesh Cooperative Federation Limited v.  Three  Circles,  (2009)  10

SCC  374  was  incorrectly  founded   upon   the   decision   in   McDermott

International INC v. Burn Standard Co. Ltd., (2006)  11  SCC  181  and  that

such reliance was not in consonance with  the  doctrine  of  precedent.  The

McDermott case is not an authority on the question  whether  the  Arbitrator

may award compound interest  nor  does  that  decision  sanction  post-award

interest be imposed on the aggregate sum and  interest  pendent  lite.   The

Arbitral Tribunal's authority  to  award  "interest  on  interest"  was  not

discussed therein. This Court, therefore, while deciding  State  of  Haryana

and Others v. S.L. Arora and Company, (2010) 3 SCC 690, rightly  refused  to

treat the McDermott case as well as the Three Circles  case  as  authorities

for awarding  "interest  on  interest"  and  held  that  both  were  wrongly

decided. Further, the decisions in ONGC v.  M.C.  Clelland  Engineers  S.A.,

(1999) 4 SCC 327 as well as the Three  Circles  case  pertain  to  an  Award

under the Arbitration Act, 1940, which did not contain a specific  provision

dealing with the  arbitrator's  power  to  grant  interest.   Likewise,  the

Central Bank of India v. Ravindra and Others, (2002) 1 SCC  367  case  arose

under Section 34 of the Code of Civil Procedure, 1908 (hereinafter  referred

to as "the CPC"), and cannot  be  treated  as  an  authority  for  award  of

interest under clause (7)  of  Section  31  of  the  Arbitration  Act,  1996

(hereinafter referred to as "the Act").


2.    It is not possible to agree with  the  conclusion  in    S.L.  Arora's

case that Section 31(7) of the Act does not  require  that  interest,  which

accrues till the date of the Award, be included in the "sum" from  the  date

of Award for calculating the post-award interest. In my  humble  view,  this

conclusion does not seem to be in consonance  with  the  clear  language  of

Section 31(7) of the Act.


3.    Sub-section (7) of Section 31 of the Act, which deals with  the  power

of the Arbitral Tribunal to award interest, reads as follows:


        "Sub-section (7)


(a) Unless otherwise agreed by the parties,  where  and  in  so  far  as  an

arbitral award is for  the  payment  of money,  the  Arbitral  Tribunal  may

include in the sum for which the award is made interest, at such rate as  it

deems reasonable, on the whole or any part of the money, for  the  whole  or

any part of the period between the date on which the cause of  action  arose

and the date on which the award is made.


(b) A sum directed to be paid by an arbitral award shall, unless  the  award

otherwise directs, carry interest at the rate of  eighteen  per  centum  per

annum from the date of the award to the date of payment."



4.    Clause (a) of sub-section (7) provides that where  an  Award  is  made

for the payment of money, the Arbitral Tribunal may include interest in  the

sum for which the Award is made.  In plain terms, this provision  confers  a

power upon the Arbitral Tribunal  while  making  an  Award  for  payment  of

money, to include interest in the sum for which the Award is made on  either

the whole or any part of the money and for the whole  or  any  part  of  the

period for the entire pre-award period between the date on which  the  cause

of action arose and the date  on  which  the  Award  is  made.   To  put  it

differently, sub-section (7)(a) contemplates that  an  Award,  inclusive  of

interest for the pre-award period on the entire amount directed to  be  paid

or part thereof, may be passed.  The "sum" awarded may be  principal  amount

and such interest as the Arbitral Tribunal deems fit.   If  no  interest  is

awarded, the "sum" comprises only  the  principal.   The  significant  words

occurring in clause (a) of sub-section (7) of Section  31  of  the  Act  are

"the sum for which the award is made."  On a plain reading, this  expression

refers to the total amount or sum for the payment for  which  the  Award  is

made.  Parliament has not added a  qualification  like  "principal"  to  the

word "sum," and therefore, the word "sum" here simply  means  "a  particular

amount of money."  In Section 31 (7), this particular amount  of  money  may

include interest from the date of cause of action to the date of the award.


5.    The Oxford Dictionary gives the following meaning to the  word  "sum":



Sum, 'if noun':- A particular amount of money.


Sum, 'if verb':- The total amount resulting from  the  addition  of  two  or

more numbers, amounts, or items.


6.    In Black's Law Dictionary, the  word  "sum"  is  given  the  following

meaning:-


"SUM. In English law- A summary or abstract;  a  compendium;  a  collection.

Several of the old law treatises are called "sum."  Lord  Hale  applies  the

term to summaries of statute law. Burrill.  The sense in which the  term  is

most commonly used is "money"; a quantity of money or currency;  any  amount

indefinitely, a sum of money, a small sum, or a  large  sum.   U.S.  v.  Van

Auken, 96 U.S. 368, 24 L.Ed. 852; Donovan v. Jenkins, 52 Mont. 124,  155  P.

972, 973."


7.    Thus, when used as a noun, as it seems  to  have  been  used  in  this

provision, the word "sum" simply means "an amount  of  money";  whatever  it

may include -  "principal" and "interest" or  one  of  the  two.   Once  the

meaning of the word "sum" is clear, the same meaning  must  be  ascribed  to

the word in clause (b) of sub-section (7) of Section 31 of  the  Act,  where

it provides that a sum directed to be  paid  by  an  Arbitral  Award  "shall

carry interest ........"  from the date of the Award  to  the  date  of  the

payment i.e. post-award.  In other words, what  clause  (b)  of  sub-section

(7) of Section 31 of the Act directs is that the "sum,"  which  is  directed

to be paid by the Award, whether inclusive or exclusive of  interest,  shall

carry interest at the rate of eighteen per cent  per  annum  for  the  post-

award period, unless otherwise ordered.


8.    Thus, sub-section (7) of Section 31  of  the  Act  provides,  firstly,

vide clause (a) that  the  Arbitral  Tribunal  may  include  interest  while

making an award for payment of money in the sum for which the Award is  made

and further, vide clause (b) that the sum so directed  to  be  made  by  the

Award shall carry interest at a certain rate for the post award period.


9.    The purpose of enacting this  provision  is  clear,  namely,  viz.  to

encourage early payment of the awarded  sum  and  to  discourage  the  usual

delay, which accompanies the execution of the Award in the  same  manner  as

if it were a decree of the court vide Section 36 of the Act.


10.   In this view of the matter, it is clear that  the  interest,  the  sum

directed to be paid by the Arbitral Award under clause  (b)  of  sub-section

(7) of Section 31 of the Act is inclusive of interest pendent lite.


11.   At this juncture, it may be useful to refer to Section 34 of the  CPC,

also enacted by Parliament and conferring the same power  upon  a  court  to

award interest  on  an  award  i.e.  post-award  interest.   While  enacting

Section 34, CPC, Parliament conferred power on a  court  to  order  interest

"on the principal sum adjudged" and not on merely the "sum" as  provided  in

the Arbitration Act.  The departure from the language of Section 34  CPC  in

Section 31 (7) of the Act, 1996 is significant and shows  the  intention  of

Parliament.


12.    It  is  settled  law  that  where  different  language  is  used   by

Parliament, it is intended to have a different effect.  In  the  Arbitration

Act, the word "sum" has deliberately not been qualified by  using  the  word

"principal" before it.  If it had been so used, there  would  have  been  no

scope for the contention that the word "sum"  may  include  "interest."   In

Section 31(7) of the Act, Parliament has deliberately used  the  word  "sum"

to refer to the aggregate of the amounts that may be directed to be paid  by

the Arbitral Tribunal and not merely the "principal" sum without interest.


13.   Thus, it is apparent that  vide  clause  (a)  of  sub-section  (7)  of

Section 31 of the Act, Parliament intended that  an  award  for  payment  of

money may be inclusive of interest, and the "sum" of  the  principal  amount

plus interest may be directed to be paid by the Arbitral  Tribunal  for  the

pre-award period.  Thereupon, the Arbitral Tribunal may direct  interest  to

be paid on such "sum" for the post-award period  vide  clause  (b)  of  sub-

section (7) of Section 31 of the Act, at which stage  the  amount  would  be

the sum arrived at after the merging of interest  with  the  principal;  the

two components having lost their separate identities.


14.  In fact this is a case where the language of sub-section 7  clause  (a)

and (b) is so plain and unambiguous that no question of  construction  of  a

statutory provision arises. The language itself provides  that  in  the  sum

for which an award is made, interest  may  be  included  for  the  pre-award

period and that for the  post-award  period  interest  up  to  the  rate  of

eighteen per cent per annum may be awarded on such sum directed to  be  paid

by the Arbitral Award.


In such a situation one is reminded of the decision in  Ganga  Prasad  Verma

(Dr.) v. State of Bihar, 1995 Supp (1) SCC 192  Para  5,  where  this  Court

held that, "Where the language of the Act is clear and explicit,  the  court

must give effect to it, whatever may be the consequences, for in  that  case

the  words  of  the  statute  speak  the  intention  of  the   Legislature."

Similarly, in Keshavji Ravji & Co. v. CIT, (1990) 2 SCC 231,  a  three-Judge

Bench of this Court explained the rule of literal  interpretation  as  under

(SCC p.242, Para 11): "If the intendment is not in  the  words  used  it  is

nowhere else. The need for interpretation arises when the words used in  the

statute are, on their terms, ambivalent and do not  manifest  the  intention

of the legislature."


We may also refer to the decision of the Privy Council  in  Pakala  Narayana

Swami v. Emperor, AIR 1939 PC 47, wherein Lord Atkin  observed  that,  "when

the meaning of words is plain,  it  is  not  the  duty  of  courts  to  busy

themselves with supposed intentions."  This  view  was  upheld  recently  by

this  Court  in  T.N.  State  Electricity  Board  v.   Central   Electricity

Regulatory Commission, (2007) 7 SCC 636.


In fact the settled view on this  subject  has  been  to  admit  results  of

construction even if they  be  strange  or  surprising[1],  unreasonable  or

unjust or oppressive[2]. The Privy Council in Emperor v.  Benoarilal  Sarma,

AIR 1945 PC 48 (p.  53),  emphasised,  "Again  and  again,  this  Board  has

insisted that in construing enacted words we  are  not  concerned  with  the

policy involved or with  the  results,  injurious  or  otherwise  which  may

follow from giving effect to the language used."


In the case of Nasiruddin v. Sita Ram Agarwal, (2003) 2 SCC 577  (Para  37),

a  three-Judge  Bench  of  this  Court,  made  it  clear  that  the  Court's

jurisdiction cannot be invoked to interpret  a  statute  so  as  to  add  or

subtract words or read something into a provision which is not there.


Infact, Maxwell on  the  Interpretation  of  Statutes,  states,  "where  the

language is plain and admits of but one meaning, the task of  interpretation

can hardly be said to arise. "The decision in this case," said  Lord  Morris

of Borth-y-Gest in a revenue case, "calls for a full  and  fair  application

of  particular  statutory  language  to  particular  facts  as  found.   The

desirability or the  undesirability  of  one  conclusion  as  compared  with

another cannot furnish a guide in reaching a decision." [3]  Where,  by  the

use of clear and unequivocal language capable of only one meaning,  anything

is enacted by the legislature, it must be enforced however harsh  or  absurd

or contrary to common sense the result may be. [4] The interpretation  of  a

statute is not to be collected from any notions which may be entertained  by

the court as to  what  is  just  and  expedient:[5]  words  are  not  to  be

construed, contrary to  their  meaning,  as  embracing  or  excluding  cases

merely because no good reason appears why they should  not  be  embraced  or

excluded.[6]


Tindal, C.J. in the Sussex Peerage[7] case,  summarised  this  principle  as

follows: "If the  words  of  the  Statute  are  in  themselves  precise  and

unambiguous then no more can be necessary than to  expound  those  words  in

their natural and ordinary sense. The words  themselves  do  alone  in  such

cases best declare the intent of the law giver." This cardinal principle  of

construction was first  stated by the United States  Supreme  Court  in  its

landmark decision of Caminetti v. United States, 242 U.S. 470,  485  (1917),

whereby Justice Day observed, "where the language is plain and admits of  no

more than one meaning the duty of interpretation does not arise."


15.   In the result, I am of the view that  S.L.  Arora's  case  is  wrongly

decided in that it holds that a sum directed  to  be  paid  by  an  Arbitral

Tribunal and the reference to the Award on the substantive  claim  does  not

refer to interest pendente lite awarded on the  "sum  directed  to  be  paid

upon Award" and that in the  absence  of  any  provision  of  interest  upon

interest in the contract, the Arbitral Tribunal does not have the  power  to

award interest upon interest, or compound interest either for the  pre-award

period or for the post-award period. Parliament has the undoubted  power  to

legislate on the subject and provide that the Arbitral  Tribunal  may  award

interest on the sum directed  to  be  paid  by  the  Award,  meaning  a  sum

inclusive of principal sum adjudged and the  interest,  and  this  has  been

done by Parliament in plain language.





                        ..................................................J.

                                                             [S.A. BOBDE]




NEW DELHI,

NOVEMBER  25th, 2014































                                                                  REPORTABLE


                        IN THE SUPREME COURT OF INDIA

                        CIVIL APPELLATE JURISDICTION


                        CIVIL APPEAL NO.3148 OF 2012




       M/s Hyder Consulting (UK) Ltd.                    Appellant(s)




                 VERSUS




      Governor State of Orissa


through Chief Engineer                      Respondent(s)


                                    WITH


                 Special Leave Petition (C) No.19895 of 2008


                 Special Leave Petition (C) No.20282 of 2008


                        Civil Appeal No.3149 of 2012


                        Civil Appeal No.3147 of 2012


                 Special Leave Petition (C) No.18614 of 2012


                        Civil Appeal No.1390 of 2013


                 Special Leave Petition (C) No.21896 of 2010


                               J U D G M E N T


Abhay Manohar Sapre, J.




1.    I have had the benefit of reading the scholarly Judgments of  My  Lord

the Chief Justice as also my learned brother Bobde J.


2.    With great respect, I find  myself  in  complete  agreement  with  the

reasoning and the eventual conclusion arrived at by brother Bobde  J.   Even

though, the judgment delivered by brother Bobde J.  encapsulates  everything

of what is required to be said, I, however, looking to  the  point  involved

and very ably argued by all learned senior counsel, wish to  record  my  own

reasons, in addition to what has already been laid down.


3.    Reiteration of facts is unnecessary. The  only  question  that  arises

for determination in the instant lis is, "Whether grant of interest  by  the

Arbitral Tribunal under Section 31(7) of the  Arbitration  and  Conciliation

Act, 1996 (hereinafter  referred  to  as  'the  Act")  amounts  to  granting

"interest on interest"?


4.    The aforesaid question can be answered by a plain and  simple  reading

of Section 31(7) of the Act which reads as under:


 "31(7)(a) Unless otherwise agreed by the parties, where and in  so  far  as

an arbitral award is for the payment of money,  the  arbitral  tribunal  may

include in the sum for which the award is made interest, at such rate as  it

deems reasonable, on the whole or any part of the money, for  the  whole  or

any part of the period between the date on which the cause of  action  arose

and the date on which the award is made.




(b) A sum directed to be paid by an arbitral award shall, unless  the  award

otherwise directs, carry interest at the rate of  eighteen  per  centum  per

annum from the date of the award to the date of payment."




5.    Section 31(7)(a) of the Act deals with  grant  of  pre-award  interest

while sub-clause (b) of Section 31(7) of the Act deals with grant  of  post-

award interest.  Pre-award interest is to ensure that  arbitral  proceedings

are concluded without unnecessary delay.  Longer the proceedings,  would  be

the period attracting interest. Similarly, post-award interest is to  ensure

speedy payment in compliance of the award.  Pre-award  interest  is  at  the

discretion of Arbitral  Tribunal,  while  the  post-award  interest  on  the

awarded sum is mandate of statute - the only difference being that  of  rate

of interest to be awarded by the Arbitral Tribunal. In other words,  if  the

Arbitral Tribunal has awarded post-award interest payable from the  date  of

award to the date of payment at a particular rate in its discretion then  it

will prevail else the party will be entitled to  claim  post-award  interest

on the awarded sum at the statutory rate specified in clause (b) of  Section

31(7) of the Act, i.e., 18%.   Thus, there is a clear  distinction  in  time

period and the intended purpose of grant of interest.


6.    Section 31(7)(a) employs  the  words  "...the  arbitral  tribunal  may

include in the sum for which the award  is  made  interest...".   The  words

"include in the sum" are of utmost importance. This  would  mean  that  pre-

award interest is not independent of the "sum"  awarded.  If  in  case,  the

Arbitral Tribunal decides to award  interest  at  the  time  of  making  the

award, the interest component will not be awarded separately  but  it  shall

become part and parcel of the award. An award is thus made in respect  of  a

"sum" which includes within the "sum" component of interest, if awarded.


7.    Therefore, for the purposes of  an  award,  there  is  no  distinction

between a "sum" with interest,  and  a  "sum"  without  interest.  Once  the

interest is "included in the sum" for which the award is made, the  original

sum and the interest component cannot be segregated and be seen  independent

of each other. The interest  component  then  looses  its  character  of  an

"interest" and takes the colour of "sum" for which the award is made.




8.    There may arise a situation  where,  the  Arbitral  Tribunal  may  not

award any amount towards principal claim but  award  only  "interest".  This

award of interest would itself then become the "sum" for which an  award  is

made under Section 31(7)(a) of the Act.  Thus, in  a  pre-award  stage,  the

legislation seeks to make no distinction  between  the  sum  award  and  the

interest component in it.




9.    Therefore, I am inclined to hold that the amount award  under  Section

31(7)(a) of the Act, whether with interest or without interest,  constitutes

a "sum" for which the award is made.




10.   Coming now to the post-award interest, Section  31(7)(b)  of  the  Act

employs the words, "A sum directed to be  paid  by  an  arbitral  award...".

Sub-clause (b) uses  the  words  "arbitral  award"  and  not  the  "arbitral

tribunal". The arbitral award, as held above, is made in respect of a  "sum"

which includes the interest. It is, therefore,  obvious  that  what  carries

under Section 31(7)(b) of the Act is the "sum directed  to  be  paid  by  an

arbitral award"  and not any other amount much less by  or  under  the  name

"interest".  In such situation,  it  cannot  be  said  that  what  is  being

granted under Section  31(7)(b)  of  the  Act  is  "interest  on  interest".

Interest under sub-clause (b) is granted on the "sum" directed  to  be  paid

by an arbitral award wherein the "sum" is nothing more than what is  arrived

at under sub-clause (a).


11.   Therefore, in my view, the expression "grant of interest on  interest"

while exercising the power under Section 31(7) of the Act   does  not  arise

and, therefore, the Arbitral Tribunal is well empowered  to  grant  interest

even in the absence of clause in the contract for grant of interest.




12.   My aforesaid interpretation of Section 31 (7) of the Act is  based  on

three golden rules of interpretation as explained by Justice  G.P.  Singh  -

Interpretation of Statute (13th Edition- 2012) where the learned author  has

said that while interpreting any Statue, language of  the  provision  should

be read as it is and the intention of the  legislature  should  be  gathered

primarily from the language used  in  the  provision  meaning  thereby  that

attention should be paid to what has been said as also to what has not  been

said; second, in selecting out  of  different  interpretations   "the  Court

will adopt that which is just, reasonable, and  sensible  rather  than  that

which is none of those things" ; and third, when the words  of  the  Statute

are clear, plain or unambiguous, i.e., they are  reasonably  susceptible  to

only one meaning , the Courts are bound  to  give  effect  to  that  meaning

irrespective of the consequence (see pages 50, 64, and 132).   I  have  kept

these principles in mind while interpreting Section 31(7) of the Act.



                       ........................................J.


                                  [ABHAY MANOHAR SAPRE]


      New Delhi;


      November 25, 2014.






























-----------------------

[1]




      [2] London Brick Company Ltd. v. Robinson, [1943] 1 ALL ER 23, p. 26

(HL).

[3]


      [4] IRC v. Hinchy, [1960] 1 ALL ER 505, pp. 508, 512 (HL).

[5]


      [6] Shop and Store Developments Ltd. v. I.R.C. [1967] 1 A.C. 472, per

Lord Morris of Borth-y-Gest at p. 493. But see I.R.C. v. Bates [1965] I

W.L.R. 1133, per Lord Denning M.R., affirmed in H.L. at [1967] 2 W.L.R. 60

sub. Nom. Bates v. I.R.C.; Luke v. I.R.C. [1963] A.C. 557, per Lord Reid.

[7]


      [8] Cartledge v. E. Jopling & Sons, Ltd. [1963] A.C. 758. Cf. Miller

v. Salomons [1853] 7 Ex. 475, per Pollock C.B.; Re British Farmers', etc.,

Co. (1878) 48 L.J.Ch. 56, per Jessel M.R.; Magor and St. Mellons R.D.C. v.

Newport Corporation [1952] A.C. 189.

[9]


      [10] Gwynne v. Burnell (1840) 7 Cl. & F. 572 per Coleridge J.

[11]


      [12] Whitehead v. James Stott Ltd. [1949] 1 K.B. 358; Galashiels Gas

Co., Ltd. v. O'Donell [1949] A.C. 275.

[13]


      [14] [1844] 11 Cl & F 85, p. 143.



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