Thursday, 3 February 2022

Whether court can punish defendant for breach of injunction if he has not wilfully disobeyed injunction order?

Viewed differently, contempt of a civil nature can be made out

under Order XXXIX Rule 2A CPC not when there has been

mere “disobedience”, but only when there has been “wilful

disobedience”. The allegation of wilful disobedience being in

the nature of criminal liability, the same has to be proved to

the satisfaction of the court that the disobedience was not

mere “disobedience” but “wilful” and “conscious”. This Court

in the case of Ram Kishan v. Tarun Bajaj, (2014) 16 SCC

204, considering the implication of exercise of contempt

jurisdiction, held that the power must be exercised with

caution rather than on mere probabilities. While delineating

the conduct which can be held to be “wilful disobedience”, this

Court held that:

“12. Thus, in order to punish a contemnor, it

has to be established that disobedience of the

order is “wilful”. The word “wilful” introduces a

mental element and hence, requires looking

into the mind of a person/contemnor by

gauging his actions, which is an indication of

one's state of mind. “Wilful” means knowingly

intentional, conscious, calculated and

deliberate with full knowledge of consequences

flowing therefrom. It excludes casual,

accidental, bona fide or unintentional acts or

genuine inability. Wilful acts does not

encompass involuntarily or negligent actions.

The act has to be done with a “bad purpose or

without justifiable excuse or stubbornly,

obstinately or perversely”. Wilful act is to be

distinguished from an act done carelessly,

thoughtlessly, heedlessly or inadvertently. It

does not include any act done negligently or

involuntarily. The deliberate conduct of a

person means that he knows what he is doing

and intends to do the same. Therefore, there

has to be a calculated action with evil

motive on his part. Even if there is a

disobedience of an order, but such

disobedience is the result of some

compelling circumstances under which it

was not possible for the contemnor to

comply with the order, the contemnor

cannot be punished. “Committal or

sequestration will not be ordered unless

contempt involves a degree of default or

misconduct.”

(Emphasis supplied)

REPORTABLE

 IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

CIVIL APPEAL NOS. 859-860 OF 2022


FUTURE COUPONS PRIVATE LIMITED & ORS Vs AMAZON.COM NV INVESTMENT HOLDINGS LLC

Author: N.V. RAMANA, CJI .

1. Leave granted in all matters.

2. These appeals are against various orders of Delhi High Court

connected to the AmazonFuture

dispute. Civil Appeals arising

out of SLP (C) No. 1354748

of 2021 and SLP (C) No. 1355657

of 2021, impugns order dated 02.02.2021 and 18.03.2021

passed in OMP (ENF) (Comm) 17 of 2021 and Civil Appeals

arising out of SLP (C) Nos. 18089 and 18080 of 2021, are

against impugned orders dated 29.10.2021 passed in Arb. A

(Comm.) No. 63 of 2021 and I.A. No. 14285 of 2021 in Arb. A

(Comm.) No. 64 of 2021 respectively.

3. At the outset, it is necessary for this Court to have a brief

background before indulging in analyzing the issue at hand.

On 22.08.2019, Amazon entered into Shareholder and ShareSubscription

Agreements with Future Coupon Private Limited

(FCPL). Through these instruments, Amazon intended to

acquire 49% stake in FCPL. The aforesaid agreements

contained an arbitration agreement, wherein parties resolved

to settle their disputes in accordance with the Arbitration

Rules of the Singapore International Arbitration Center (SIAC).

The parties had further resolved to have the seats at New

Delhi.

4. On 12.08.2019, FCPL and its promoters entered into a

Shareholder Agreement with Future Retail Limited (FRL).

Through this Agreement, FCPL was granted certain protective

rights. One such right is produced as under:

Clause 10 of SHA:

10. TRANSFER OF RETAIL ASSETS

10.1 As of the Execution Date, the Company has

set up an aggregate of at least 1,534 (one

thousand five hundred and thirty four) retail

outlets/formats including without limitation

the Small Store formats across India and

such retail outlets/stores are an integral part

of the business conducted by the Company

representing a significant and substantial

part of the business conducted by the

Company. The Existing Shareholders and

the Company further agree, covenant and

undertake to FCL that the Company shall be

the sole vehicle for the conduct of such

current business comprising of a widespread

network of the retail outlets/formats

including without limitation the Small Store

formats that the Company has established

and is operating across India and

consequently such business shall continue

to be an integral part of the Company’s

business.

10.2 Accordingly, any sale, divestment, transfer,

disposal, etc., of such retail outlets/ formats

including without limitation the Small Store

Formats shall be in accordance with this

Agreement, and the company and the

Existing shareholders covenant and

undertake that during the subsistence of this

Agreement, the company shall not transfer,

or dispose off the Retail Assets except as

otherwise mutually agreed between the

Company, the Existing Shareholders and

FCL in writing.

10.3 Notwithstanding anything contained herein,

the Company and the Existing Shareholders

agree that the Retail Assets shall not be

transferred, Encumbered divested, or

disposed of, directly or indirectly, in favour of

a Restricted Person.

There is no dispute that one of the restricted persons included

the Reliance Group.

5. As in March 2020, FRL submitted that there was business

downturn due to Covid19

lockdowns as there were

restrictions on retail sale through brickandmortar

shops. In

light of the same, the Board of FRL decided to sell, retail

businesses and assets to Reliance, for a consideration in

excess of Rs. 25,000 crores. Further, it is contended by FRL

that there were outstanding loans of about Rs.20,000 crores

with a serious and tangible risk of becoming insolvent. It is

submitted that it was in this context that the subsequent

transaction was entered into to alleviate its financial position

and protect employment of around 25,000 employees of the

Future Group.

6. Aggrieved by the aforesaid sale transaction, Amazon initiated

arbitration proceedings before the SIAC. Amazon filed an

application for emergency relief with the Registrar of the SIAC

Court of Arbitration seeking interim prohibitory injunction to

prevent FRL and FCPL from taking further steps in the

aforesaid transaction with the Reliance Group. Parallelly, FRL

filed a suit before the Delhi High Court registered as

CS(COMM) No. 493 of 2020, against Amazon for tortious

interference in the Scheme for the sale of assets.

7. On 25.10.2020, the Emergency Arbitrator passed an Interim

Award in favor of Amazon. It may be noticed that the

Emergency Arbitrator and the Single Bench came to

diametrically opposite conclusions which are juxtaposed

herein below:Order

of Emergency Arbitrator

dated 25.10.2020

Order of Single Judge Bench

in I.A. No. 10376 of 2020 in

CS(COMM) No. 493 of 2020

dated 21.12.2020

285. In the result, I award, direct,

and order as follows:

(a) the Respondents are

injuncted from taking

any steps in furtherance

or in aid of the Board

Resolution made by the

Board of Directors or

FRL on 29 August 2019

in relation to the

Disputed Transaction,

including but not limited

to filing or pursuing any

application before any

person, including

regulatory bodies or

agencies in India, or

requesting for approval

at any company meeting;

(b) the Respondents are

injuncted from taking

any steps to complete

the Disputed

Transaction with entities

that are part of the MDA

12.3 Thus the trinity of the

principles for grant of interim

injunction i.e. prima facie case,

irreparable loss and balance of

convenience are required to be

tested in terms of principles as

noted above. Since this Court

has held that prima facie the

representation of Amazon

based on the pea that the

resolution dated 29th August,

2020 of FRL is void and that

on conflation of the FCPL SHA

and FRL SHA, the ‘control’ that

is sought to be asserted by

Amazon on FRL is not

permitted under the FEMA FDI

Rules, without the

governmental approvals, this

Court finds that FRL has made

out a prima facie case in its

favour for grant of interim

injunction. However, the main

tests in the present case are in

respect of “balance of

Group;

(c) without prejudice to the

rights of any current

Promoter Lenders, the

Respondents are

injuncted from directly

or indirectly taking any

steps to

transfer/dispose/alienat

e/encumber FRL’s Retail

Assets or the shares

held in FRL by the

Promoters in any

manner without the

prior written consent of

the Claimant;

(d) the Respondents are

injuncted from issuing

securities of FRL or

obtaining/securing any

financing, directly or

indirectly, from any

Restricted Person that

will be in any manner

contrary to Section

13.3.1 of the FCPL SHA;

(e) the orders in (a) to (d)

above are to take effect

immediately and will

remain in place until

further order from the

Tribunal, when

constituted; and

(f) the Claimant is to

provide within 7 days

from the date hereof a

crossundertaking

in

damages to the

Respondents. If the

Parties are unable to

agree on its terms, they

convenience” and “irreparable

loss”. Even if a prima facie

case is made out by FRL, the

balance of convenience lies

both in favour of FRL and

Amazon. If the case of FRL is

that the representation by

Amazon to the statutory

authorities/regulators is based

on illegal premise, Amazon has

also based its representation

on alleged breach of FCPL SHA

and FRL SHA, as also the

directions in the EA order.

Hence it cannot be said that

the balance of convenience lies

in favour of FRL and not in

favour of Amazon. It would be

a matter of trial after parties

have led their evidence or if

decided by any other

competent forum to determine

whether the representation of

Amazon that the transaction

between FRL and Reliance

being in breach of the FCPL

SHA and FRL SHA would

outweigh the plea of FRL in the

present suit. Further in case

Amazon is not permitted to

represent its case before the

statutory

authorities/Regulators, it will

suffer an irreparable loss as

Amazon also claims to have

created preemptive rights in its

favour in case the Indian law

permitted in future. Further

there may not be irreparable

loss to FRL for the reason even

if Amazon makes a

are to refer their

differences to me qua EA

for resolution; and

(g) the costs of this

Application be part of

the costs of this

Arbitration.

representation based on

incorrect facts thereby using

unlawful means, it will be for

the statutory

authorities/Regulators to

apply their mind to the facts

and legal issues therein and

come to the right conclusion.

There is yet another aspect

as to why no interim

injunction can be granted in

the present application for

the reason both FRL and

Amazon have already made

their representations and

counter representations to

the statutory

authorities/regulators and

now it is for the Statutory

Authorities/Regulators to

take a decision thereon.

Therefore, this Court finds

that no case for grant of

interim injunction is made

out in favour of the FRL and

against Amazon.

13. Consequently, the

present application is disposed

of, declining the grant of

interim injunction as prayed

for by FRL, however, the

Statutory

Authorities/Regulators are

directed to take the decision on

the applications/objections in

accordance with law.

8. In the meanwhile, CCI and SEBI approved the composite

Scheme proposed by FRLReliance.

Thereafter, FRL filed for

sanction of the composite Scheme of arrangement under the

provisions of Sections 230 to 232 of the Companies Act, 2013

before National Company Law Tribunal (NCLT).

9. Amazon filed a Petition for enforcement of the Emergency

Arbitrator Award, under Section 17(2) of the Arbitration and

Conciliation Act, 1996, before the Delhi High Court on

25.01.2021 and the same was heard for the first time on

28.01.2021. As the appellants herein challenge the impugned

order on the ground of failure to adhere to the principles of

natural justice, it is apt to reproduce certain procedural orders

passed by the learned Single Judge, Justice Midha, in OMP

(ENF) (COMM) No.17 of 2021. On 28.01.2021, the following

order was passed:

“1. The hearing has been conducted

through video conference.

2. Arguments partly heard.

3. List for continuation of the arguments

on 29th January, 2021 at the end of

the Board.

4. The order be uploaded on the website of

this Court forthwith.”

On 29.01.2021, the following order was passed:

“1. The hearing has been conducted through

video conference.

2. Issue notice. Learned counsels for

respondents accept notice.

3. Further arguments heard from 02:45 PM to

04:30 PM.

4. List for continuation of the arguments on

01st February, 2021.

5. Both the parties have submitted brief note

of submissions.

6. Learned senior counsel for the respondent

No.2 submits that he shall file additional

note of submissions on the factual aspect

by tomorrow afternoon with advance copy

to the counsel for the petitioner by

tomorrow evening. Respondent No.2 shall

also respond to the brief note of

submissions of the petitioner relating to the

facts.

7. The order be uploaded on the website of

this Court forthwith.”

On 01.02.2021, the following order was passed:

“1. Respondent No.2 has filed additional

submissions to which the petitioner has

filed the response.

2. Learned senior counsels for the

respondents have concluded the oral

arguments.

3. List for rejoinder submissions of the

petitioner on 02nd February, 2021.

4. It is clarified that no further written

submissions shall be filed by any of the

parties.”

10. On 02.02.2021, the first substantive order [1st impugned

Order] was passed in the following manner:

“8. This Court is of the prima facie view that

the Emergency Arbitrator is an Arbitrator; the

Emergency Arbitrator has rightly proceeded

against the respondent No.2; the order dated

25th October, 2020 is not a nullity; the order

dated 25th October, 2020 is an order under

Section 17(1) of the Arbitration and Conciliation

Act. This Court is of the view that the order dated

25th October, 2020 is appealable under Section

37 of the Arbitration and Conciliation Act. This

Court is of the clear view that the order dated

25th October, 2020 is enforceable as an order of

this Court under Section 17(2) of the Arbitration

and Conciliation Act. The detailed reasons shall

be given in the reserved order.

9. This Court is satisfied that immediate

orders are necessary to protect the rights of the

petitioner till the pronouncement of the reserved

order. In that view of the matter, the respondents

are directed to maintain status quo as on today

at 04.50 P.M. till the pronouncement of the

reserved order. The respondents are directed to

file an affidavit to place on record the actions

taken by them after 25th October, 2020 and the

present status of all those actions, within 10

days. All the concerned authorities are directed to

maintain status quo with respect to all matters in

violation of the order dated 25th October, 2020

and shall file the status report with respect to the

present status within 10 days of the receipt of

this order. The other prayers of the petitioner

shall be considered in the reserved order.

10. Copy of this order be given dasti under

signatures of the Court Master to counsels for the

parties. Copy of this order be also given dasti

under signatures of the Court Master to Mr.

Kirtiman Singh, learned Central Government

Standing Counsel who shall send the same to all

the concerned authorities dealing with the

actions initiated by the respondents in violation

of the order dated 25th October, 2020. The

petitioner shall send the list of all the authorities

to Mr. Kirtiman Singh, learned Central

Government Standing Counsel within three

days.”

11. Aggrieved by the stay order granted by the learned Single

Judge, while reserving the matter, FRL filed an intracourt

appeal before the Division Bench in FAO OS (Comm.) No. 21 of

2021. The Division Bench vide Order dated 08.02.2021,

passed the following order:

“12. It is made clear that the observations made

in this order are only a prima facie view for the

purpose of grant of interim relief and shall not

come in the way of the learned Single Judge in

passing the final order in OMP(ENF)(Comm)

No.17/2021 and needless to state that the order

shall be passed uninfluenced by any

observations made hereinabove.”

12. Amazon appealed against this Order before the Supreme Court

in SLP (C) No. 285657

of 2021. Vide order dated 22.02.2021,

this Court interalia

held as under:

“In the meantime, the NCLT proceedings will

be allowed to go on but will not culminate in

any final order of sanction of scheme.”

(Emphasis supplied)

13. Again on 18.03.2021, the learned Single Judge in OMP (ENF)

(COMM) No.17 of 2021, passed the 2 nd impugned order with

aforesaid directions:

“188. The Emergency Arbitrator is an Arbitrator

for all intents and purposes; order of the

Emergency Arbitrator is an order under Section

17(1) and enforceable as an order of this Court

under Section 17(2) of the Arbitration and

Conciliation Act.

…………

190. The respondents have raised a vague plea

of Nullity without substantiating the same. The

interim order of the Emergency Arbitrator is not a

Nullity as alleged by respondent No.2.

191. Combining/treating all the agreements as a

single integrated transaction does not amount to

control of the petitioner over FRL and therefore,

the petitioner’s investment does not violate any

law.

192. All the objections raised by the respondents

are hereby rejected with cost of Rs.20,00,000/to

be deposited by the respondents with the Prime

Minister Relief Fund for being used for providing

COVID vaccination to the Below Poverty Line

(BPL) category senior

citizens of Delhi. The cost

be deposited within a period of two weeks and the

receipt be placed on record within one week of

the deposit.

193. The respondents have deliberately and

wilfully violated the interim order dated 25th

October, 2020 and are liable for the

consequences enumerated in Order XXXIX Rule

2A of the Code of Civil Procedure.

194. In exercise of power under Order XXXIX

Rule 2A(1) of the Code of Civil Procedure, the

assets of respondents No.1 to 13 are hereby

attached. Respondents No.1 to 13 are directed to

file an affidavit of their assets as on today in

Form 16A, Appendix E under Order XXI Rule

41(2) of the Code of Civil Procedure within 30

days. Respondent No.1, 2, 12 and 13 are directed

to file an additional affidavit in the format of

Annexure B1

and respondents No.3 to 11 are

directed to file an additional affidavit in the

format of Annexure A1

to the judgment of M/s

Bhandari Engineers & Builders Pvt. Ltd. v.

M/s Maharia Raj Joint Venture, (supra) along

with the documents mentioned therein within 30

days.”

14. In the interregnum, the FCPL and FRL approached the Division

Bench of the Delhi High Court in FAO (OS) (COM) No.50 and

51 of 2021 respectively against the 2nd impugned order

passed by the learned Single Judge which was stayed vide

Order dated 22.03.2021.

15. Subsequently, Amazon filed SLP (C) Nos. 61136114

of 2021

before this Court against the order dated 22.03.2021 passed

by the Division Bench of the High Court.

16. This Court consolidated all the appeals filed by Amazon before

this Court, heard the matters together and passed a final

judgment dated 06.08.2021, answering only the following two

legal questions:

i. Whether an Emergency Arbitrator’s Award can be

said to be within the contemplation of the Arbitration

Act?

ii. Whether an order passed under Section 17(2) of

the Arbitration Act, in enforcement proceedings, is

appealable under Section 37 of the Arbitration Act?

17. This Court answered the first question in the following

manner:

“41. We, therefore, answer the first question by

declaring that full party autonomy is given by the

Arbitration Act to have a dispute decided in

accordance with institutional rules which can

include Emergency Arbitrators delivering interim

orders, described as “awards”. Such orders are

an important step in aid of decongesting the civil

courts and affording expeditious interim relief to

the parties. Such orders are referable to and are

made under Section 17(1) of the Arbitration Act.”

The second question was answered thus:

“76. The second question posed is thus answered

declaring that no appeal lies under Section 37 of

the Arbitration Act against an order of

enforcement of an Emergency Arbitrator’s order

made under Section 17(2) of the Act. As a result,

all interim orders of this Court stand vacated. The

impugned judgments of the Division Bench, dated

8th February, 2021 and 22nd March, 2021, are

set aside. The appeals are disposed of

accordingly.”

18. It may be noted that this Court, in the aforesaid judgment of

06.08.2021, did not adjudicate upon the merits of the case

and limited its reasoning only to answer the legal questions

which arose therein. On a reading of this judgment, the

contention of the learned Senior Advocate Mr. Gopal

Subramanium, that this Court has upheld the Emergency

Arbitrator Award and did not interfere with the enforcement

orders in OMP (ENF)(Comm.) No. 17 of 2021, on merits, is not

correct. Although, the judgment narrates the facts leading up

to the appeal, the Court neither returned any findings on

facts, nor adjudicated on merits of the Order passed by

Justice Midha in the enforcement proceedings. It is this gap

which has led to the current round of litigation on merits of

the case for the second time before this Court.

19. In the meanwhile, FRL filed an application under Para 10 of

Schedule 1 of the SIAC Rules for vacating the Award of the

Emergency Arbitrator before the Arbitral Tribunal. The oral

submissions on the vacate petitions were heard between 12th16th

of July 2021 and orders were reserved.

20. Contemporaneously, aggrieved by the merits of the orders of

the Single Judge dated 02.02.2021 and 18.03.2021, FCPL and

FRL preferred appeals directly before this Court in SLP (C) No.

1354748

of 2021 and SLP (C) No. 1355657

of 2021,

respectively. On 09.09.2021 the following interim order was

passed by this Court:“

Heard learned senior counsel for the

parties at length and carefully perused the

material placed on record.

Issue notice.

Taking into consideration the

submissions advanced by the learned senior

counsel for the parties and particularly the

fact that the parties have approached the

Singapore International Arbitration Centre for

vacating the Emergency Award passed by the

Emergency Arbitrator and the arguments in

the said matter have been ssconcluded and

the order is going to be pronounced shortly,

we think it fit to balance the interest of both the

parties by staying all further proceedings before

the Delhi High Court for the time being. Ordered

accordingly. We further direct to all the

authorities i.e. NCLT, CCI and SEBI not to

pass any final order for a period of four weeks

from today. This order has been passed with

the consent of both the parties.

List these matters after four weeks.”

(Emphasis supplied)

21. Thereafter, the applications filed by FRL and FCPL for vacating

the award of the Emergency Arbitrator was dismissed by the

Arbitral Tribunal by Order dated 21.10.2021.

22. The aforesaid order of the Arbitral Tribunal, rejecting the

vacate petition, was challenged by FCPL and FRL before the

Delhi High Court in Arb. Pet. No. 63 of 2021 and Arb. Pet. No.

64 of 2021. In Arb. Pet. No. 64 of 2021, FRL had filed IA No.

14285/2021, seeking the following prayers:

a. Stay the operation of the impugned Order dated

21.10.2021 passed by the Hon’ble Arbitral Tribunal.

b. Alternatively, pass an order allowing the Appellant

to take steps pursuing the scheme, subject to the

condition that it shall not invite the passing of any

final orders of approval of the scheme by the NCLT.

23. While issuing notice in both matters, by orders dated

29.10.2021 (3rd impugned Order), the Delhi High Court

(Justice Suresh Kumar Kait) refused any immediate relief to

FRL in the following words:

“15. During the course of hearing, this Court

time and again referred that when the subject

matter of this appeal is pending subjudice

before the Hon’ble Supreme Court in Special

Leave Petition (Civil) No. 1354748/

2021 and

infact, by virtue of order dated 09.09.2021

proceedings before this Court have been stayed

and also directions have been passed to NCLT,

CCI, SEBI to not pass any final order, then how

interim relief, that too without therebeing

any

hearing or any reply from side opposite on

record, application for interim stay can be heard

and orders be passed. Upon this, Mr. Harish

Salve, learned senior counsel submitted in such

eventuality, this Court may dismiss the

application.

16. In view of the above, the application seeking

interim stay being IA No. 14285/2021 (u/S 151

CPC) is accordingly dismissed.”

24. Aggrieved by the aforesaid order, FCPL and FRL have

approached this Court in SLP (C) Nos. 18089 and 18080 of

2021 respectively.

25. Mr. Harish Salve, learned Senior Counsel appearing for FRL

submitted that the orders in the enforcement proceedings have

been rendered while completely disregarding the order dated

21.12.2020 passed by the learned Single Judge of the Delhi

High Court in CS(Comm) No. 493 of 2020, particularly, the

finding that FRL does not have any arbitration agreement with

the respondent. He further submitted that although an appeal

has been filed against the aforesaid order of the learned Single

Judge, there is no stay operating against the said order.

26. The learned Senior counsel also submitted that the impugned

orders passed in the enforcement proceedings merit setting

aside as the said proceedings have been conducted contrary to

the principles of natural justice. He submitted that the

procedure adopted has caused serious prejudice to the

appellants as, after denying them an opportunity to file a reply

affidavit, the impugned orders in the Enforcement proceedings

recorded that FRL had not made any plea on the issue as to

why were the orders of the Emergency Arbitrator a nullity.

27. Thirdly, the learned Senior counsel contended that the

impugned orders passed in the Enforcement proceedings

extended beyond the scope of the Emergency Arbitrator’s

interim Award, by directing recall of the approvals granted by

the Statutory Authorities.

28. Lastly, while relying upon the Singapore Arbitration Rules,

learned Senior counsel submitted that the Tribunal’s interim

order dated 21.10.2021, overrides the Emergency Arbitrator’s

interim Award which are the subject matter of the impugned

enforcement proceedings. As a result, the enforcement

proceedings and the impugned order have lost their relevance

due to the subsequent events.

29. Mr. Mukul Rohatgi, learned Senior Counsel appearing for

FCPL and their promoters, while supplementing the

submissions of Mr. Salve, specifically contended that the

impugned order merits setting aside due to grave injustice

caused to the appellants due to the principles of natural

justice being given a goby.

No opportunity was granted for

filing of any response which has resulted in various factual

and legal errors creeping in the impugned order. He further

submitted that considering the procedure followed by it, the

penal orders passed by the High Court in the impugned order,

merit a reconsideration.

30. Learned Senior counsel further submitted that no prejudice

would be caused to Amazon by setting aside the impugned

order passed in the enforcement proceedings or by the passing

of an interim measure allowing continuation of the

proceedings before the NCLT. In fact, this Court, vide order

dated 22.02.2021, has already created an interim arrangement

by allowing the NCLT proceedings to continue with a direction

to the NCLT not to pass any final order. On the other hand,

the impugned order dated 18.03.2021, directed recall of the

approvals granted by the statutory authorities.

31. Mr. Gopal Subramanium, learned Senior Counsel appearing

for Amazon, submitted that the appellants, by their conduct

have demonstrated willful and intentional disobedience of the

Emergency Arbitrator’s interim Award, after agreeing for the

Emergency Arbitrator. While he fairly stated that Amazon is

not interested in pursuing the punitive directions imposed on

FCPL and others, he submitted that the Emergency

Arbitrator’s interim Award stands confirmed by the Arbitral

Tribunal, which must be abided by the appellants. Learned

Counsel argued that when no stay has been granted against

the interim protection afforded to them by the Arbitral

Tribunal, the appellants cannot operate in contravention of the

same and proceed to effectuate the scheme before the NCLT.

He lastly submitted that pending any challenge, the interim

orders passed by the Tribunal needs to be maintained and

given effect to, so as to uphold the effectiveness and sanctity of

the arbitration process.

32. Mr. Aspi Chinoy, learned Senior Counsel appearing for

Amazon contended that the appellants’ reliance on the order

dated 21.12.20, passed by the learned Single Judge of the

Delhi High Court in the suit proceeding is misplaced. He

submitted that, in the first instance, the suit instituted by FRL

before the Delhi High Court was of the nature of an antiarbitration

suit and a collateral challenge to the arbitration

proceedings which is in contravention to Section 5 of the

Arbitration Act. He further submitted that the observations

being relied upon by the appellants were made in an order

declining the relief sought by them before the Delhi High

Court. Finally, the learned Senior counsel submitted that no

relief should be granted to the appellants by this Court as they

have not approached this Court with clean hands having failed

to comply with any judicial order that has been passed.

33. Having heard learned counsel for both the parties and on

perusing voluminous documents submitted before the Court,

the following questions arise for our consideration :

I. Whether the orders dated 02.02.2021 and 18.03.2021,

passed by the learned Single Judge in OMP (ENF) (COM)

No.17 of 2021, are valid in law?

II. Whether the orders dated 29.10.2021, passed by the

learned Single Judge in Arb. A (Comm.) No. 64 and 63 of

2021, is valid in law?

Question No. I

34. The orders of the learned Single Judge [Justice Midha] in OMP

(ENF) (COMM) No.17 of 2021, is impugned on the grounds of

lack of an opportunity granted to FCPL and FRL to file a

counter to establish their defense. Mr. Rohatgi, learned Senior

Advocate appearing on behalf of FCPL and its promoters has

submitted that no time was granted by the learned Single

Judge to respond. He added that a 200page

order has been

passed without any reply being filed on record and holding

everyone guilty of contempt of court. He has further submitted

that punitive directions could not have been passed even in

contempt jurisdiction without affording the party a proper

opportunity of filing a reply.

35. In this context, our attention has been drawn to a catena of

procedural orders passed by the High Court in OMP (ENF)

(COMM) No.17 of 2021. From the record, we observe that FRL

and FCPL were not provided sufficient time or opportunity to

file their counter or raise their defense. On 29.01.2021, they

were allowed to file a brief note of submission within twentyfour

hours, before orders were passed on 02.02.2021.

36. On a perusal of the orders, we find that serious procedural

errors were committed by the learned Single Judge. Natural

justice is an important facet of a judicial review. Providing

effective natural justice to affected parties, before a decision is

taken, is necessary to maintain the Rule of law. Natural justice


is usually discussed in the context of administrative actions,

wherein procedural requirement of a fair hearing is read in to

ensure that no injustice is caused. When it comes to judicial

review, the natural justice principle is built into the rules and

procedures of the Court, which are expected to be followed

meticulously to ensure that highest standards of fairness are

afforded to the parties.

37. It is well known that natural justice is the sworn enemy of

unfairness. It is expected of the Courts to be cautious and

afford a reasonable opportunity to parties, especially in

commercial matters having a serious impact on the economy

and employment of thousands of people. Coming to the facts

herein, the opportunity provided to the appellants herein was

insufficient, and cannot be upheld in the eyes of law.

38. Whenever an order is struck down as invalid being in violation

of the principles of natural justice, there is no final decision of

the case and fresh proceedings are left open. All that is done is

to vacate the order assailed by virtue of its inherent defect.

Such proceedings are not terminated and are usually remitted

back. [See Canara Bank v. Debasis Das, (2003) 4 SCC 557]

However, in this case, much water has flown under the bridge,


since the passing of the order by the learned Single Judge,

which has now been rendered redundant, for the following

reasons :

 Initially, this Court by order dated 22.02.2021, had

allowed proceedings to continue before the NCLT without

finalization of the scheme.

 Thereafter, learned Single Judge passed the 2nd

impugned order on 18.03.2021, without considering the

order of this Court dated 22.02.2021.

 Subsequently, the Division Bench in FAO (OS)(COM) No.

50 and 51 of 2021, had stayed the aforesaid order of the

Single Judge, which was taken in appeal again before

this Court.

 This Court finally disposed of the case, answering only

two legal questions, without adjudicating on the merits of

the matter.

 In the meanwhile, FRL and FCPL had moved the Arbitral

Tribunal, for vacating the interim injunction granted by

the Emergency Arbitrator.

 In view of the pendency of the aforesaid application

before the Arbitral Tribunal, this Court again through

interim order dated 09.09.2021, allowed continuation of

proceedings before the NCLT, without final authorization

on the scheme.

39. One aspect which may be highlighted is the punitive directions

ordered by the learned Single Judge in the order dated

18.03.2021, which are extracted below:

“192. All the objections raised by the

respondents are hereby rejected with cost of

Rs.20,00,000/to

be deposited by the

respondents with the Prime Minister Relief

Fund for being used for providing COVID

vaccination to the Below Poverty Line (BPL)

category senior

citizens of Delhi. The cost be

deposited within a period of two weeks and

the receipt be placed on record within one

week of the deposit.

193. The respondents have deliberately and

wilfully violated the interim order dated 25th

October, 2020 and are liable for the

consequences enumerated in Order XXXIX

Rule 2A of the Code of Civil Procedure.

194. In exercise of power under Order XXXIX

Rule 2A(1) of the Code, the assets of the

respondents No.1 to 13 are hereby attached.

Respondents No. 1 to 13 are directed to file

an affidavit of their assets as on today in

Form 16A, Appendix E under Order XXI Rule

41(2) of the Code of Civil Procedure within 30

days. Respondent No. 1, 2, 12 and 13 are

directed to file an additional affidavit in the

format of Annexure B1

and respondents no.

3 to 11 are directed to file an additional

affidavit in the format of Annexure A1

to the

judgment of M/s. Bhandari Engineers &

Builders Pvt. Ltd. v. M/s. Maharia Raj

Joint Venture, (supra) along with the

documents mentioned therein within 30

days.”

40. Our attention is drawn to the fact that the learned Single

Judge had relied on M/s. Bhandari Engineers & Builders

Pvt. Ltd. v. M/s. Maharia Raj Joint Venture, 2019 SCC

Online Del. 11879, which has been overruled by a Division

Bench order in Delhi Chemical and Pharmaceutical Works

Pvt. Ltd. & Anr. v. Himgiri Realtors Pvt. Ltd. & Anr., EFA

(OS) (Comm.) No. 4 of 2021.

41. Viewed differently, contempt of a civil nature can be made out

under Order XXXIX Rule 2A CPC not when there has been

mere “disobedience”, but only when there has been “wilful

disobedience”. The allegation of wilful disobedience being in

the nature of criminal liability, the same has to be proved to

the satisfaction of the court that the disobedience was not

mere “disobedience” but “wilful” and “conscious”. This Court

in the case of Ram Kishan v. Tarun Bajaj, (2014) 16 SCC

204, considering the implication of exercise of contempt

jurisdiction, held that the power must be exercised with

caution rather than on mere probabilities. While delineating

the conduct which can be held to be “wilful disobedience”, this

Court held that:

“12. Thus, in order to punish a contemnor, it

has to be established that disobedience of the

order is “wilful”. The word “wilful” introduces a

mental element and hence, requires looking

into the mind of a person/contemnor by

gauging his actions, which is an indication of

one's state of mind. “Wilful” means knowingly

intentional, conscious, calculated and

deliberate with full knowledge of consequences

flowing therefrom. It excludes casual,

accidental, bona fide or unintentional acts or

genuine inability. Wilful acts does not

encompass involuntarily or negligent actions.

The act has to be done with a “bad purpose or

without justifiable excuse or stubbornly,

obstinately or perversely”. Wilful act is to be

distinguished from an act done carelessly,

thoughtlessly, heedlessly or inadvertently. It

does not include any act done negligently or

involuntarily. The deliberate conduct of a

person means that he knows what he is doing

and intends to do the same. Therefore, there

has to be a calculated action with evil

motive on his part. Even if there is a

disobedience of an order, but such

disobedience is the result of some

compelling circumstances under which it

was not possible for the contemnor to

comply with the order, the contemnor

cannot be punished. “Committal or

sequestration will not be ordered unless

contempt involves a degree of default or

misconduct.”

(Emphasis supplied)

42. Considering the fact that in the suit instituted by FRL, the

learned Single Judge had earlier allowed FRL and Amazon to

continue their pursuit before various regulatory authorities,

and in view of the interim orders of this Court dated

22.02.2021 and 09.09.2021, and the Courts below, we are

inclined to setaside

aforesaid directions as the precondition

of ‘sufficient mental element for wilful disobedience’ is not

satisfied. Moreover, Mr. Gopal Subramanium, learned Senior

Advocate appearing for Amazon, has fairly stated that Amazon

is not interested in proceeding with the punitive directions.

Taking note of the aforesaid submission, we set aside the

punitive directions issued in the impugned orders of learned

Single Judge dated 02.02.2021 and 18.03.2021.

43. Coming to the merits of the case, we would like to mention a

disconcerting aspect wherein the interim order enforcing the

Emergency Award has adopted a standard beyond ‘prima facie

view’, as required under law. It is expected of Courts to be

cautious while making observations on the merits of the case,

which would inevitably influence the Arbitral Tribunals

hearing the matters on merit.

44. Therefore, we set aside the order of the learned Single Judge

dated 02.02.2021 and 18.03.2021 passed in OMP (ENF)

(COMM.) No.17 of 2021.

Question No. II

45. At the outset, it is agreed by learned advocates appearing on

both side that the impugned order dated 29.10.2021 in IA No.

14285/2021 moved in Arb. A (Comm.) No. 64 of 2021, needs

to be set aside for nonconsideration

of the orders of this

Court in the proper perspective. Our order dated 09.09.2021,

imposed no bar on the High Court to adjudicate the issue

concerning legality of the vacate application order by the

Arbitral Tribunal. In our opinion, adjudication of the

applications under Section 37(2), Arbitration Act filed by the

appellants before the Delhi High Court are distinct from the

earlier appeals filed before this Court.

46. Further, certain important questions of law concerning the

effect of the award of an Emergency Arbitrator and the

jurisdiction of an Arbitral Tribunal qua such awards arise in

the present matter. Therefore, these matters need to be

remitted back for adjudication on its own merits.

47. In view of the above, we order:

I. Setting aside of impugned orders dated 02.02.2021 (1st

impugned Order) and 18.03.2021 (2nd impugned order) in

OMP (ENF)(Comm.) No. 17 of 2021.

II. Setting aside of 3rd impugned order dated 29.10.2021 in

Arb. A. (Comm.) No. 64 and 63 of 2021.The learned

Single Judge shall reconsider the issues and pass

appropriate orders on its own merits, uninfluenced by

any observation made herein.

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

(N.V. RAMANA)

..............................................J.

(A.S. BOPANNA)

..............................................J.

(HIMA KOHLI)

NEW DELHI;

FEBRUARY 01, 2022



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