Introduction The question of whether multiple agreements forming part of the same commercial transaction can be referred to a single arbitration continues to arise frequently in complex commercial arrangements. The Gujarat High Court, in its CAV judgment dated 13 September 2024 in Adani Enterprise Ltd v. M/s SMS Carbon & Minerals Pvt. Ltd. (C/ARBI.P/76/2023), delivered a detailed exposition on this issue, reaffirming the principle that arbitration must be interpreted in a co

Background and Prior Proceedings The case centered on the execution of an Arbitral Award dated September 26, 2000, which had undergone a complex series of judicial modifications 3 . Initially, the Award directed the Judgment Debtor (BSNL) to pay the Decree Holder (BWL Limited) a sum of Rs. 6,07,56,342/-, inclusive of interest at 18.5% per annum compounded quarterly. The Award was subsequently set aside by a Single Judge of the Calcutta High Court under Section 34 of the Act.