Friday, 7 April 2023

Whether 𝐓𝐡𝐢𝐫𝐝 𝐏𝐚𝐫𝐭𝐲 𝐅𝐮𝐧𝐝𝐢𝐧𝐠 𝐭𝐡𝐞 𝐋𝐢𝐭𝐢𝐠𝐚𝐭𝐢𝐨𝐧 𝐟𝐨𝐫 𝐆𝐚𝐢𝐧 𝐂𝐚𝐧 𝐄𝐬𝐜𝐚𝐩𝐞 its 𝐋𝐢𝐚𝐛𝐢𝐥𝐢𝐭𝐲 𝐢𝐟 𝐭𝐡𝐞 𝐑𝐞𝐬𝐮𝐥𝐭 of litigation 𝐢𝐬 𝐔𝐧𝐟𝐚𝐯𝐨𝐮𝐫𝐚𝐛𝐥𝐞?


 Prima facie, I am in agreement with the above observations. A party having funded the litigation for a gain in the result thereof, cannot escape its liability in case the result is contrary to its expectation. A balance would have to be struck between a need to ensure the access to justice through this funding arrangement and the cost that the defendant would bear in case such litigation fails and is found to be completely meritless, as in the present case. The defendant cannot be left high and dry and be made to bear its own cost for the purposes of defending a litigation, which was found without any merit and which may not have been initiated against such party but for the funding by the third party. In fact, prima facie, the costs which have been levied by the Arbitral Award would become the cost which will

be covered by the Bespoke Agreement itself, as these are costs of

litigation of respondent nos.1 to 4 herein. {Para 17}

18. The fact that the Bespoke Agreement states that it shall stand

terminated in case the claim is not successful, can also, prima facie,

not affect the right of the petitioner inasmuch as the said agreement

would continue till the passing of the Arbitral Award and the costs arepart of the Arbitral Award. Thereafter, the petitioner is only seeking to enforce the Arbitral Award in terms of the Bespoke Agreement.

 IN THE HIGH COURT OF DELHI AT NEW DELHI

O.M.P.(I) (COMM.) 71/2023

SBS HOLDING INC Vs ANANT KUMAR CHOUDHARY & ORS.

CORAM:

HON'BLE MR. JUSTICE NAVIN CHAWLA

Dated:  07.03.2023

I.A. 4645/2023 (Exemption)

1. Allowed, subject to all just exceptions.

O.M.P.(I) (COMM.) 71/2023

2. Issue notice.

3. Notice is accepted by Mr.I.P.S. Oberoi, learned counsel on

behalf of the Official Liquidator appointed for respondent No. 4, and

Mr.Shashank Garg, learned counsel on behalf of respondent No. 5.

4. Notice be served on the remaining respondents through all

modes, returnable on 9th May, 2023.

5. Let reply(ies) be filed within a period of two weeks, as prayed

for. Rejoinder thereto, if any, be filed within a period of two weeks

thereafter.

6. It is the case of the petitioner that the petitioner has succeeded

in the arbitration proceedings held under the aegis of the Singapore

International Arbitration Centre, being SIAC Arbitration No. 105 of

2019, Anant Kumar Choudhary And Ors. vs. Global Enterprise

Logistics Pte Ltd and Anr., by way of an Arbitral Award dated

22.12.2022. The Arbitral Award, while rejecting the claims of the

respondent nos.1 to 4 herein, has also awarded costs of those

proceedings in favour of the petitioner herein, who was the respondent

no.2 in the said proceedings, as under:

“861. The Respondents have succeeded in all

the substantive issues. However, the

Respondents have failed in a number of

jurisdictional objections, namely on Issues 1,

2, 4 and 6. Furthermore, 1R’s case on the

change of ownership of 1R being a bona fide

arms-length transaction is not accepted, and

even though this ultimately had no bearing on

the substantive merits of the case, this aspect

of the case involved a lengthy crossexamination

of Mr Shigemoto. Taking into

account all these factors/circumstances,

including the Tribunal’s costs orders made in

interlocutory applications above, the Tribunal

orders in accordance with Rule 37 of the SIAC

Rules:

(a) The Claimants shall bear 80% of 2R’s

legal and other costs claimed, being SGD

1,212,838.98, USD 246,196.96, and JPY

1,102,612.

xxxxx

863. Having considered all the evidence and

submissions placed before it and for the

reasons set out above, the Tribunal hereby

FINALLY DECLARES and DETERMINES as

follows:

(d) The Claimants are jointly and severally

liable to 2R for, and shall pay to 2R the

amounts of SGD 1,212,838.98, USD

246,196.96, and JPY 1,102,612 within 21 days

of the date of receipt of this Award, after

which simple interest on this amount shall run

at the rate of 5.33% per annum until the costs

ordered are paid in full.”

7. The learned counsel for the petitioner submits that a group

company of the petitioner, namely, SBS Logistics Singapore Pte Ltd.,

had succeeded against the respondent no. 4 in another arbitration

proceedings by way of an Award dated 25.10.2017. In the course of

the enforcement of the said Award against the respondent no.4,

proceedings under the Insolvency and Bankruptcy Code, 2016 were

initiated and the respondent no.4 is now facing liquidation. In the

course of enforcement proceedings, the Court also found that amounts

had been withdrawn by the respondent nos.1 to 4 from the bank

accounts and all fixed assets had been encumbered so as to negate the

enforcement of the Arbitral Award. In this regard, he has also drawn

my attention to the order dated 27.11.2018 passed in Enforcement

Petition, being O.M.P.(EFA)(COMM.) 4/2018, SBS Logistics

Singapore Pte Ltd v. SBS Transpole Logistics Private Limited. He

submits that in case interim protection is not granted to the petitioner,

the petitioner shall suffer the same fate in the enforcement

proceedings of the present Arbitral Award.

8. The learned counsel for the petitioner submits that in the present

arbitration proceedings, the respondent nos.1 to 4 were being funded

by the respondent no.5 under the terms of the Bespoke Funding

Agreement dated 20.12.2018 (hereinafter referred to as the ‘Bespoke

Agreement’). The terms of the said agreement would show that the

funding of the entire litigation, including the costs of the Lawyers, the

Tribunal, the Experts, etc., were borne by the respondent no.5. The

learned counsel for the petitioner further submits that in terms of

Clause 3(f) read with Clause 5(d) of the Bespoke Agreement, the

respondent no. 5 had the exclusive and unsevered prior rights on any

damages that could have been awarded by the Arbitral Award in

favour of the respondent nos. 1 to 4 and against the petitioner. The

said damages, thereafter, would have been distributed amongst the

respondents in the manner prescribed in Clause 3(f) of the Bespoke

Agreement. He submits that, therefore, respondent no. 5 having

funded the arbitration proceedings is equally liable to make good the

costs that have been levied on the respondent nos.1 to 4 in the Arbitral

Award. In support, he places reliance on the following:-

i) Arkin v. Borchard Line Ltd and Others, (2005) EWCA

Civ 655; and

ii) Excalibur Ventures LLC v. Texas Keystone Inc and

Ors., Neutral Citation Number: (2016) EWCA Civ 1144

9. On the other hand, the learned counsel for the respondent no. 5,

who appears on an advance notice, draws reference to Section 46 of

the Arbitration and Conciliation Act, 1996 (hereinafter referred to as

the ‘Act’) to submit that the Foreign Award can be enforced only

against the “persons as between whom it was made”. Hence, it cannot

be enforced against third parties.

10. He further submits that the liability of the respondent no.5

under the Bespoke Agreement is confined only to the costs that are

incurred by the respondent nos.1 to 4 in the arbitration proceedings

and not thereafter. Further, placing reliance on Clause 7A(iv) of the

agreement, he submits that the Bespoke Agreement was to terminate

in case the claim filed by the respondent nos.1 to 4 in the arbitration

proceedings was not a success. The said eventuality having occurred,

the Bespoke Agreement stands terminated and the respondent no.5

cannot be made liable thereunder.

11. In rejoinder, however, the learned counsel for the petitioner,

placing reliance on judgment of the Supreme Court in Gemini Bay

Transcription Private Limited v. Integrated Sales Service Limited

and Another, (2022) 1 SCC 753, submits that the scope of Section 46

of the Act is even wider than Section 35 of the Act, and would include

all persons who claim under the parties to the agreement. In the

present case, as provided in the Bespoke Agreement, the respondent

no. 5 had a right through respondent nos. 1 to 4 in the arbitration

proceedings. They, therefore, are equally liable to make good the

liability that has been imposed under the Arbitral Award.

12. I have considered the submissions made by the learned counsels

for the parties.

13. It cannot be denied that the Arbitral Award, in terms of the

paragraphs that have been quoted hereinabove, have awarded costs of

the arbitration proceedings in favour of the petitioner and against the

respondent nos. 1 to 4. The petitioner, by making reference to the

earlier enforcement proceedings, has also established a prima facie

case in its favour to show that in case an ad interim injunction is not

granted in its favour, the Award may be rendered as a ‘paper decree’.

14. The petitioner by relying upon the Bespoke Agreement has also,

at least prima facie, been able to show that the respondent no.5 had a

vested interest in the outcome of the arbitral proceedings, having

funded the respondent nos.1 to 4 for a benefit of a return therefrom in form of the result of the arbitration proceedings.

15. In Arkin (Supra), in similar circumstances, it has been held as

under:-

“38. While we do not dispute the importance

of helping to ensure access to justice, we

consider that the judge was wrong not to give

appropriate weight to the rule that costs

should normally follow the event. R (on the

application of Factortame) Ltd v Secretary of

State for Transport, Environment and the

Regions (No 2) [2002] 4 All ER 97, [2003] QB

381, on which he strongly relied, was not a

case in which there was any need to take this

balancing factor into account. In our judgment

the existence of this rule, and the reasons

given to justify its existence, render it unjust

that a funder who purchases a stake in an

action for a commercial motive should be

protected from all liability for the costs of the

opposing party if the funded party fails in the

action. Somehow or other a just solution must

be devised whereby on the one hand a

successful opponent is not denied all his costs

while on the other hand commercial funders

who provide help to those seeking access to

justice which they could not otherwise afford

are not deterred by the fear of

disproportionate costs consequences if the

litigation they are supporting does not

succeed.

39. If a professional funder, who is

contemplating funding a discrete part of an

impecunious claimant's expenses, such as the

cost of expert evidence, is to be potentially

liable for the entirety of the defendant's costs

should the claim fail, no professional funder

will be likely to be prepared to provide the

necessary funding. The exposure will be too

great to render funding on a contingency basis

of recovery a viable commercial transaction.

Access to justice will be denied. We consider,

however, that there is a solution that is

practicable, just and that caters for some of

the policy considerations that we have

considered above.

40. The approach that we are about to

commend will not be appropriate in the case of

a funding agreement that falls foul of the

policy considerations that render an

agreement champertous. A funder who enters

into such an agreement will be likely to render

himself liable for the opposing party's costs

without limit should the claim fail. The present

case has not been shown to fall into that

category. Our approach is designed to cater

for the commercial funder who is financing

part of the costs of the litigation in a manner

which facilitates access to justice and which is

not otherwise objectionable. Such funding will

leave the claimant as the party primarily

interested in the result of the litigation and the

party in control of the conduct of the litigation.

41. We consider that a professional funder,

who finances part of a claimant's costs of

litigation, should be potentially liable for the

costs of the opposing party to the extent of the

funding provided. The effect of this will, of

course, be that, if the funding is provided on a

contingency basis of recovery, the funder will

require, as the price of the funding, a greater

share of the recovery should the claim

succeed. In the individual case, the net

recovery of a successful claimant will be

diminished. While this is unfortunate, it seems

to us that it is a cost that the impecunious

claimant can reasonably be expected to bear.

Overall justice will be better served than

leaving defendants in a position where they

have no right to recover any costs from a

professional funder whose intervention has

permitted the continuation of a claim which

has ultimately proved to be without merit.

42. If the course which we have proposed

becomes generally accepted, it is likely to have

the following consequences. Professional

funders are likely to cap the funds that they

provide in order to limit their exposure to a

reasonable amount. This should have a

salutary effect in keeping costs proportionate.

In the present case there was no such cap, and

it is at least possible that the costs that MPC

had agreed to fund grew to an extent where

they ceased to be proportionate. Professional

funders will also have to consider with even

greater care whether the prospects of the

litigation are sufficiently good to justify the

support that they are asked to give. This also

will be in the public interest.

43. In the present appeal we are concerned

only with a professional funder who has

contributed a part of a litigant's expenses

through a non-champertous agreement in the

expectation of reward if the litigant succeeds.

We can see no reason in principle, however,

why the solution we suggest should not also be

applicable where the funder has similarly

contributed the greater part, or all, of the

expenses of the action. We have not, however,

had to explore the ramifications of an

extension of the solution we propose beyond

the facts of the present case, where the funder

merely covered the costs incurred by the

claimant in instructing expert witnesses.

44. While we have confined our comments

to professional funders, it does not follow that

it will never be appropriate to order that those

who, for motives other than profit, have

contributed to the costs of unsuccessful

litigation, should contribute to the successful

party’s costs on a similar basis.”

16. In Excalibur Ventures LLC (Supra), it was reiterated that:-

“23. The argument for the funder boiled

down in essence to the proposition that it is

not appropriate to direct them to pay costs on

the indemnity basis if they have themselves

been guilty of no discreditable conduct or

conduct which can be criticised. Even on the

assumption that the funders were guilty of no

conduct which can properly be criticised, and

I accept that they did nothing discreditable in

the sense of being morally reprehensible or

even improper, this argument suffers from two

fatal defects, both of which were identified by

the judge. First, it overlooks that the conduct

of the parties is but one factor to be taken into

account in the overall evaluation. Second, it

looks at the question from only one point of

view, that of the funder. As the judge pointed

out at paragraph 125, it ignores the character

of the action which the funder has funded and

its effect on the Defendants.

24. The argument is yet further flawed in

that it assumes that the funder is responsible

only for his own conduct. This too is incorrect.

As the judge pointed out at paragraph 60,

where conduct comes into consideration in this

context, the successful party is afforded a more

generous basis for assessing which of his costs

should be paid by his opponent because of the

way in which the latter, or those in his camp,

have acted. Thus as the judge pointed out at

paragraph 118, a litigant may find himself

liable to pay indemnity costs on account of the

conduct of those whom he has chosen to

engage – e.g. lawyers, or experts, which

experts may themselves have been chosen by

the lawyers, or the conduct of those whom he

has chosen to enlist, e.g. witnesses, even

though he is not personally responsible for it.

The position of the funder is directly

analogous. The funder is seeking to derive

financial benefit from pursuit of the claim just

as much as is the funded claimant litigant, and

there can be no principled reason to draw a

distinction between them in this regard. I also

agree with Mr Waller that the analysis here is

not dependent upon rules of agency – expert

and factual witnesses are not agents of the

party on whose behalf they give evidence any

more than they are agents of the funder. The

principle is a broader principle of justice.

Deployment of lawyers, experts and other

witnesses is a necessary part of bringing the

claim to a successful conclusion for the benefit

of the litigant, and it is equally a necessary

part of bringing it to a successful conclusion

for the benefit of the funder. The funder

chooses which claims to back, whereas, as the

judge rightly observed at paragraph 125, a

defendant does not choose by whom to be

sued, or in what manner. The judge continued:

“If, then, the funder’s witnesses

turn out to be liars or the

litigation is conducted

unreasonably, so that the court

awards costs on an indemnity

scale, it is just and equitable that

the funder should pay on that

scale.”

I agree. I can see no principled basis upon

which the funder can dissociate himself from

the conduct of those whom he has enabled to

conduct the litigation and upon whom he relies

to make a return on his investment.”

17. Prima facie, I am in agreement with the above observations. A

party having funded the litigation for a gain in the result thereof,

cannot escape its liability in case the result is contrary to its

expectation. A balance would have to be struck between a need to

ensure the access to justice through this funding arrangement and the

cost that the defendant would bear in case such litigation fails and is

found to be completely meritless, as in the present case. The defendant

cannot be left high and dry and be made to bear its own cost for the

purposes of defending a litigation, which was found without any merit

and which may not have been initiated against such party but for the

funding by the third party. In fact, prima facie, the costs which have

been levied by the Arbitral Award would become the cost which will

be covered by the Bespoke Agreement itself, as these are costs of

litigation of respondent nos.1 to 4 herein.

18. The fact that the Bespoke Agreement states that it shall stand

terminated in case the claim is not successful, can also, prima facie,

not affect the right of the petitioner inasmuch as the said agreement

would continue till the passing of the Arbitral Award and the costs arepart of the Arbitral Award. Thereafter, the petitioner is only seeking to enforce the Arbitral Award in terms of the Bespoke Agreement.

19. The submission of the learned counsel for the respondent no.5

that in terms of Section 46 of the Act, the enforcement of a Foreign

Award can only be against the party to the Agreement, also prima

facie, does not impress me. The Supreme Court Gemini Bay

Transcription Private Limited (Supra), has observed as under:-

“73. Shri Salve argued relying upon three

judgments of this Court, namely, Indowind

Energy Ltd. v. Wescare (India) Ltd., (2010) 5

SCC 306, Chloro Controls (India) (P) Ltd. v.

Severn Trent Water Purification Inc., (2013) 1

SCC 641, Cheran Properties Ltd. v. Kasturi &

Sons Ltd., (2018) 16 SCC 413 that a

comparison between Sections 35 and 46 of the

Arbitration Act, 1996 would show that the

legislature circumscribed the power of the

enforcing court under Section 46 to persons

who are bound by a foreign award as opposed

to persons which would include “persons

claiming under them” and that, therefore, a

foreign award would be binding on parties

alone and not on others.

First and foremost, Section 46 does not speak

of “parties” at all, but of “persons” who may,

therefore, be non-signatories to the arbitration

agreement. Also, Section 35 of the Act speaks

of “persons” in the context of an arbitral

award being final and binding on the

“parties” and “persons claiming under them”,

respectively. Section 35 would, therefore, refer

to only persons claiming under parties and is,

therefore, more restrictive in its application

than Section 46 which speaks of “persons”

without any restriction….”

20. In view of the above, the petitioner has been able to make out a

good prima facie case in its favour. The balance of convenience is also

in favour of the petitioner and against the respondents. The petitioner

is likely to suffer grave irreparable injury in case an ad interim

injunction is not granted in favour of the petitioner and against the

respondents.

21. Accordingly, the respondent nos.1, 2, 3 and 5 are directed to

disclose on affidavit their fixed assets and bank accounts, along with

the credit balance in the same held by them in India or any other

jurisdiction as on date. Such affidavit be filed within a period of four

weeks. The respondent nos.1, 2, 3 and 5 are further restrained from

creating any third-party interest/right/title in respect of any

unencumbered immoveable assets for a sum as has been awarded in

favour of the petitioner by way of the Arbitral Award dated

22.12.2022, till further orders.

22. List on 9th May, 2023.

NAVIN CHAWLA, J

MARCH 7, 2023.

Print Page

No comments:

Post a Comment