ENFORCEMENT DILEMMA AND LACK OF POLICY: BLOCKCHAIN ARBITRATION, AN INDIAN PERSPECTIVE
Authored by Athira T S, Associate Partner
Co-authored by Pragya Mehta, 3rd year - BA LLB(Hons), Maharashtra National Law University, Mumbai
INTRODUCTION
Despite the growing body of the academic discourse engaging with blockchain arbitration, the same remains largely theoretical, leaving several critical gaps between conceptual promise and practical implementation unaddressed. With a userbase of about 300,000 transactions per day, 1 the blockchain technology has slowly moved beyond experimentation. This technology can be simply defined as a tool which operates on a distributed network of nodes, each maintaining an immutable record of transactions.2 While its mainstream introduction to the world was through Bitcoin in 2009,3 its operation is dependent on decades-old technology: public-private key encryption, consensus mechanisms, and peer-to-peer networks.4 What makes the integration of this technology difficult is its decentralized nature5 and the subsequent difficulty to decide the jurisdiction of disputes involving transactions using this technology. While India has made several attempts to regulate blockchain transactions, its enforcement still remains a hurdle. These attempts include the introduction of taxation of income on Virtual Digital Asset (“VDA”) transactions and withholding taxes in the Indian Income Tax Act,6 Travel Rule related directions by Indian Computer Emergency Response Team (CERT-In)7 and numerous actions on VDA Service Providers by Law Enforcement Agencies8 and PMLA Regulations by Financial Intelligence Unit-India (FIU-IND).9 Many blockchain activities are executed or structured offshore while producing clear economic and consumer harms within India which makes the effects based approach crucial. This approach allows regulatory and judicial attention to shift from the location of the malicious entity to the location where the consequences are felt. This article hence, firstly, examines the challenges posed by the resolution of blockchain-based arbitration disputes in India and analyses how existing statutory mandates hinder their effective functioning. It further transcends these limitations by explaining how this enables malicious entities to evade regulatory scrutiny by leveraging decentralised and foreign-seated dispute resolution mechanisms. Further, the article reviews the extent to which Indian courts have engaged with such disputes, along with providing a discussion on broader international frameworks. It subsequently examines the “effects doctrine” and its potential application to international arbitration disputes involving blockchain systems. Lastly, it provides suggestions which may be made to the statutory framework in India to incorporate the complexities of blockchain in the legal regime.
1.https://www.blockchain.com/explorer/charts
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8 https://www.thehindu.com/sci-tech/technology/how-are-cryptocurrency-exchanges-in-india-vetting-customersexplained/article70508477.ece#:~:text=Cryptocurrency%20exchanges%20in%20India%20use,%2DYour%2DCl ient/Customer
9 https://fiuindia.gov.in
ISSUES INVOLVED
Blockchain arbitration revolutionizes dispute resolution by seamlessly integrating smart contract technology with traditional arbitration processes. When a dispute arises, it is automatically logged onto the blockchain, and proceedings on digital platforms (eg. Kleros, Argon Court)10 get initiated. While these platforms function as self-executing dispute mechanisms, their decentralized nature places them in tension with India’s platform-centric regulatory framework. The new Digital Personal Data Protection (DPDP) Act, 11 introduces compliance requirements for any digital platform handling Indian user data; however, Decentralized Autonomous Organisations (DAOs), which often underpin such platforms, remain unrecognised under Indian law. Under the Cox & Kings (2023) ruling,12 binding a pseudonymous non-signatory requires proving "mutual intention" through conduct. In India, this usually requires showing a "single economic reality" between a known signatory and a pseudonymous party.13 Establishing this link for decentralized entities (like a DAO or a pseudonymous wallet holder) is legally complex. Decentralized finance disputes, stemming from smart contract failures, fraud (like rug pulls), platform crashes, and disagreements over collateral/liquidations, then become difficult to adjudicate due to the absence of a clearly identifiable counterparty. 14 This absence of legal recognition and compliance certainty has a direct bearing on jurisdictional choices in blockchain arbitration.
Arbitration disputes involving pseudonymous parties, particularly in the context of Web 3.0 and blockchain, are predominantly foreign-seated (e.g., Singapore, London, or Zurich).15 Blockchain records, being decentralized and often pseudonymous, frequently face evidentiary objections that are more easily bypassed in tech-friendly foreign seats like Singapore. The Hon’ble Supreme Court in Pasl Wind Solutions Private Limited vs GE Power Conversion India Private16 noted that parties often choose a foreign seat to have two layers of protection: the ability to challenge an award in the foreign seat's courts and again resist enforcement in India. Moreover, evidentiary standards under Indian law present an independent obstacle. Indian courts often require certificates under Section 63 of the Bharatiya Sakshya Adhiniyam (BSA)17 for electronic records, which assumes a centralized authority to verify the record's integrity. Even if evidence is admitted and an award is rendered, executing a decree in India against a pseudonym is difficult because under Indian law, an arbitral award must be enforced through a court as a civil decree under Section 36 of the Arbitration and Conciliation Act, 1996. 18 Indian courts lack a mechanism to order a blockchain network provider or an immutable smart contract to reverse or perform a transaction, making domestic enforcement of on-chain dispute resolution practically impossible. Disputes where the consideration is a private cryptocurrency (as opposed to the RBI's E-Rupee) face risks of being declared void under Section 23 of the Contract Act, 187219 for being contrary to public policy. Beyond legal uncertainty, India’s fiscal treatment of virtual digital assets further incentivizes parties to exit domestic adjudication mechanisms. The 30% flat tax on Virtual Digital Assets (VDA) and 1% TDS on every transfer in India20 incentivizes parties to keep the entire dispute and settlement process in "crypto-friendly" jurisdictions like Dubai or Singapore to avoid triggering local tax reporting or seizure during enforcement.
10 https://vidhilegalpolicy.in/blog/kleros-is-crypto-based-dispute-resolution-thefuture/#:~:text=A%20decentralised%20dispute%20resolution%20mechanism,cooperative%20society%20regist ered%20in%20France.
11chromeextension://kdpelmjpfafjppnhbloffcjpeomlnpah/https://www.meity.gov.in/static/uploads/2024/06/2bf1f0e9f04e6f b4f8fef35e82c42aa5.pdf
12 2023 INSC 1051
13 http://scconline.com/blog/post/2023/03/23/the-group-of-companies-doctrine-in-india-antithetical-to-freeconsent/
14 https://www.nortonrosefulbright.com/en/inside-disputes/blog/202409-decentralised-finance-defi-litigationrisk-and-safeguards
Exploitation by malicious entities
Malicious entities leverage this lack in policy by employing strategies of evading identification and taking advantage of the procedural friction in India. This has led to an increase in the number of cases of human fraud and the facilitation of criminal activity. Scammers continue to adopt and innovate, with the cryptocurrency industry witnessing over $3.4 billion in theft in 2025. 21 Overall, through personation tactics, a staggering 1400% year-over-year growth22 has been seen.
In India, malicious entities therefore choose foreign arbitration seats like Singapore, Dubai or the UK which grants them a veneer of legitimacy. The execution of these awards against any pseudonymous entities is impossible to execute in India. They cause financial damage in the state and then tie it up in enforcement for years. In cases of insolvency, bad actors take advantage of the practical void present due to Section 14 of the Insolvency and Bankruptcy Code, 201623 and proceed with foreign seated arbitrations to siphon off global assets of a debtor and bypass Indian creditor protections. Moreover, Section 2(2) of the Arbitration and Conciliation Act199624 states that the supervisory power of Indian courts only applies where the place of arbitration is in India. Section 4425 defines a foreign award as related to differences between persons. Due to the pseudonymous nature of parties, Indian courts find it difficult to identify it as a person to execute a decree. In the process, the scammers swiftly move funds across different blockchains or fully decentralized exchanges (DEXs), where tracing is extremely difficult, making asset recovery nearly impossible.
15 https://academic.oup.com/ulr/article/30/3/398/8254042
16 https://www.scconline.com/blog/post/2021/08/07/foreign-arbitral-seat/
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19 Section 23 of the Contract Act
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21 https://www.chainalysis.com/blog/crypto- scams2026/#:~:text=In%202025%2C%20cryptocurrency%20scams%20received,more%20effectively%20than%20ev er%20before.
22 https://www.bbc.com/news/articles/c93w30gl5jno
RECOGNITION BY INDIAN AND FOREIGN COURTS
In 2018, RBI circular26 barred banks from servicing crypto exchanges which resulted in mass shutdowns and relocation of exchanges. Subsequently, in the case of Internet and Mobile Association of India v. RBI (2020)27 the Hon’ble Supreme Court struck down the RBI ban as disproportionate. But the RBI still did not recognise cryptocurrency as legal tender. Subsequently, in Nirod Kumar Das v. State of Orissa (2023)28 the court observed that cryptocurrencies do not fall within the statutory definitions of “money” or “deposits” under existing Indian laws. However, in 2025, the Madras High Court verdict in Rhutikumari v. Zanmai Labs Pvt. Ltd. & Ors.29 concluded that cryptocurrency constitutes a property under the Indian Income Tax Act. In the International Conference on Arbitration in the Era of Globalisation held in Dubai,30 Hon’ble Justice D.Y. Chandrachud, former judge of the Supreme Court of India made reference to smart contracts in his speech to demonstrate the technological advancements in the sphere of commercial transactions and identified arbitration as the means to resolve disputes relating to smart contracts. This hesitation in India stands in sharp contrast to the increasing international acceptance and judicial accommodation of blockchain arbitration mechanisms. In 2021, a pivotal moment was reached in the realm of blockchain arbitration when an arbitral award that incorporated blockchain technology was enforced by a Mexican court.31 The case involved Kleros, a decentralised application designed for swift, automated online dispute resolution through which a dispute was resolved. In UK, under the remit of the UK Digital DR Rules,32 disputes relating to smart contracts, can be resolved without the interference of the courts via an automatic dispute resolution process. In Fetch.ai Ltd v Persons Unknown, 33 the English courts granted injunctions to trace misappropriated crypto assets. The landmark case of Hangzhou Huatai Yimei Culture Media Co. Ltd. v. Shenzhen Daotong Technology Development Co. Ltd., 34 decided by the Hangzhou Internet Court in 2018, marked the first judicial recognition of blockchain evidence in China. The High Court of New Zealand, in the case of Ruscoe v Cryptopia, recognized the significance of the internal ledger of Cryptopia, a cryptocurrency exchange, specifically its internal structured query language database, which keeps a definitive record of cryptocurrency transactions and holdings.35 The Hong Kong Court of First Instance, in the Gatecoin case, 36 recognized the significance of the internal Exchange Ledger maintained by Gatecoin as a record of customer transactions and balances. Lastly, in, United States v. Ulbricht, 37 the founder of Silk Road was convicted on multiple counts, in part due to blockchain-based financial records showing transfers of Bitcoin used for illegal purchases. Regulatory bodies like the Virtual Asset Regulatory Authority38 have also introduced guidelines that seamlessly incorporate arbitration into crypto governance frameworks. Additionally, the Abu Dhabi Global Market39 and the Dubai International Financial Centre40 have established mechanisms that facilitate blockchain arbitration, showcasing how proactive and robust regulatory infrastructures can effectively address the complexities of emerging technologies.
23 Section 14 of the IBC
24 Section 2(2) of the Arbitration and Conciliation Act
25 Section 44 of the Arbitration and Conciliation Act
26 https://www.rbi.org.in/commonman/English/scripts/Notification.aspx?Id=2632
27 https://www.sebi.gov.in/enforcement/orders/mar-2020/internet-mobile-association-of-india-vs-rbi_51143.html
28 https://www.scconline.com/blog/post/2024/05/06/orissa-high-court-grants-bail-cryptocurrency-ponzi-schemecase/
29 2025:MHC:2437
30 https://www.livelaw.in/top-stories/justice-dy-chandrachud-arbitration-international-conference-litigationsystem-smart-contracts-194521#:~:text=Sohini%20Chowdhury,arbitration%20has%20become%20inseparable...
31 https://indiacorplaw.in/2022/06/14/blockchain-arbitration-in-india-adopting-the-hybrid-model-envisaged-bymexican-kleros-case/
HOW DOES THE EFFECTS DOCTRINE BECOME RELEVANT
In the context of decentralised, and technologically mediated disputes, the “effects doctrine” assumes particular significance as a jurisdictional tool for addressing harms that transcend territorial boundaries. Also known as the ‘consequence’ or ‘terminatory’ theory, 41 the principle of ‘effects doctrine’ is where an act is done abroad and the criminal effect is produced in the State, the crime is taken to be committed within that territory. Indian courts have adopted an “effects-based” jurisdictional approach in online disputes. In Google India (P) Ltd. v. Visaka Industries42 it was stated that a court can assert jurisdiction over foreign entities if their actions produce tangible effects in India. The Court, relying on the decision of the Bombay High Court in Zanmai Labs v. Bitcipher Labs LLP, 43 also took the view that the holder of the crypto-asset owed a fiduciary duty to the owner of such asset. However, through Art 1 of the New York Convention,44 only a few foreign arbitral awards are enforceable in the country. While there have been certain exceptions, like the case of Transocean Shipping Agency v. Black Sea, 45 where India accepted an award from Ukraine despite not being on the list, India still remains strict. Both English and American courts have exercised this kind of extra-territorial jurisdiction. Especially with regard to American Antitrust Law, the Sherman Act and the Federal Trade Commission Act are applicable over purely extraterritorial foreign trade activity only if the defendant‘s conduct has direct, substantial, and reasonably foreseeable effect‘ on either United States‘ domestic trade, or, United States‘ import trade, or, export trade of a person engaged in United States‘ export trade. 46 The Alcoa case established a two-pronged test for application of the effects doctrine, i.e., firstly, the performance of the foreign agreement must be shown to have some effect in the US, and secondly, the effect must have been so intended. After the United States, Germany had been the harbinger of its acceptance by incorporating the doctrine into §130(2) of the German Act against Restraints on Competition.
47 Under the Indian criminal law, Section 1 of the Bharatiya Nyaya Sanhita48 embodies the effects doctrine, which reads as under:
“(5) The provisions of this Sanhita shall also apply to any offence committed by -
(a) any citizen of India in any place without and beyond India;
(b) any person on any ship or aircraft registered in India wherever it may be;
(c) any person in any place without and beyond India committing offence targeting a computer resource located in India.”
It is well settled that where a sub-standard article is sold and an offence is committed, the place where the same is marketed will equally have jurisdiction to try an offence against the manufacturers as well as the distributors.49 The Cyber Crime Convention of the Council of Europe50 prescribes for the issue of jurisdiction in Article 22.51 It requires that every membernation should adopt legislative measures to establish jurisdiction over any offence established under the Convention, when the offence is committed in its territory. In India, the Information Technology Act delves into the issue of applicable law in computer crimes. It clarifies that any act which is committed either within or outside India would be illegal if it is an offence under the Act.
Section 75 of the Act reads as under:
Act to apply for offence or contravention committed outside India:
1) Subject to the provisions of sub-section (2), the provisions of this Act shall apply also to any offence or contravention committed outside India by any person irrespective of his nationality.
2) For the purposes of sub-section (1), this Act shall apply to an offence or contravention committed outside India by any person if the act or conduct constituting the offence or contravention involved a computer, computer system or computer network located in India.
The above two provisions make it clear that the offence, though committed outside India, is punishable in India. In cyber and competition law, anonymity does not defeat jurisdiction if domestic effects exist. Under competition law, a blockchain can be classified as an "enterprise" or its participants as a "body of individuals", 52 making them amenable to the law despite their pseudonymous status.
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Application to Blockchain arbitration
Applying the effects doctrine to blockchain arbitration permits Indian courts to target on-chain conduct that produces real, foreseeable harms within India. The doctrine supports limited, effects-based judicial intervention without converting India into the supervisory seat. If courts intervene only where the effect is substantial, direct and reasonably foreseeable, it will preserve party autonomy and international enforcement expectations under instruments like the New York Convention. This preserves the BALCO territorial framework53 which states that India remains neutral and not attempt to become the supervisory seat while addressing domestic harm. By focusing on the impact within India, courts can utilize Section 63(4) of the Bharatiya Sakshya Adhiniyam (BSA), 202354 to admit tamper-proof blockchain records as reliable evidence of harm occurred within the country. Courts in jurisdictions like England and Wales, Ireland, and the Cayman Islands frequently utilize Norwich Pharmacal Orders (NPOs)55 and Bankers Trust Orders (BTOs)56 to unmask anonymous participants in decentralized networks. A similar framework could also be developed in India to unmask any wrongdoers and act against pseudonymous entities.
SUGGESTIONS AND WAY FORWARD
The Draft Arbitration and Conciliation Bill, 2024 57 which is largely based on the recommendations from the T.K. Viswanathan Expert Committee58 has laid down the groundwork for emerging judicial trends and integrating blockchain and pseudonymous transactions into the Indian legal system. The Ministry of Electronics and Information Technology (MeitY)59 has developed the National Blockchain Framework (NBF)60 to provide a unified architecture for deploying blockchain solutions across various sectors.61 An indigenous and modular platform named Vishvasya Blockchain Stack62 allows government entities to deploy blockchain-based applications without the need to create or manage their own infrastructure. The stack is deployed across National Informatics Centres (NICs) and is built on a permissioned blockchain, ensuring that only verified and authorized participants can join or validate transactions. While this framework is yet to be enforced, under the current law, the identification of parties is critical for the enforcement of an arbitration agreement. For this an amendment of Section 2 of the act63 to include a definition of "Digital Identity" or "Pseudonymous Party," recognizing that a wallet address or a decentralized identifier (DID) can represent a legal "person" for the purposes of arbitration is needed. Moreover, including "self-executing code" within the definition of a written arbitration agreement under Section 7(4)64 as having the same legal weight as signed, written agreements would make the regulation of these disputes much easier. Recognition of digital awards or “on-chain blockchain awards” provided they meet a high standard of security could also help in the reduction of such disputes. While private blockchains may still require manual certification, public, decentralized ledgers (such as Bitcoin, Etherium) should be granted a “presumption of integrity" due to their immutable nature. A crucial reform that is much needed is the inclusion of local arbitration clauses for any blockchain protocol that might end up impacting Indian users on which Indian courts may exercise supervisory jurisdiction in line with Indian public policy. Moreover, as has been suggested by the T. K. Vishwanathan Committee Report, a separate law is much needed for enforcement of certain foreign awards to suit India’s local conditions while promoting internation arbitration.
https://www.scconline.com/blog/post/2019/12/11/google-india-fails-to-gain-protection-under-section-79-ofthe-it-act-2000-to-face-trial-in-a-2008-defamation-case/
https://www.scconline.com/blog/post/2025/10/29/madras-hc-crypto-currency-is-property-that-can-be-held-intrust/ 44 Art 1 of the New York Convention,
Transocean Shipping Agency v. Black Sea
EFFECTS DOCTRINE: A jurisdictional study of USA, EU and India, Anindita Jaiswal
§ 130 (2) of the German Act against Restraints on Competition
Section 1 of the Bharatiya Nyaya Sanhita
State of Punjab v Nohar Chand, (1984) 3 SCC 512; State of Rajasthan v Rajesh Medical Agencies. 1987 SCC Supp 242.
Cyber Crime Convention of the Council of Europe
Article 22Cyber Crime Convention of the Council of Europe
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Section 7(4)
CONCLUSION
Blockchain arbitration, while still an upcoming field, is in a dire need to be regulated by the Indian legislative framework. With its rapid growth seen since 2009, a systematic framework for the protection of Indian consumers while balancing international principles is much needed, an incorporation of the effects doctrine in arbitration as well as the legal recognition of cryptocurrency and its trading platforms would provide much needed legitimacy and confidence to the consumers and promote the growth of crypto trading in India. Recognising the inherently decentralised and cross-border nature of blockchain disputes, the adoption of the effects doctrine would provide a workable jurisdictional basis by allowing India to respond to harms and consequences experienced within its territory, even when the underlying activity originates elsewhere. A coherent regulatory approach that integrates jurisdictional tools like the effects doctrine alongside formal recognition of crypto-assets would promote legal certainty, encourage responsible innovation,
26 January 2026
