Determining The Relevant Date For Exchange Rate Conversion In International Arbitration Awards: A Comparative Analysis Of Indian, UK And US Approaches

I.  Introduction

In the context of international arbitration, the issue of currency conversion assumes particular significance when an arbitral award rendered in a foreign currency is sought to be enforced in a jurisdiction whose domestic currency differs from that of the award. The timing of such conversion is far from a procedural triviality—it can materially alter the ultimate amount payable, especially in scenarios involving volatile exchange rates. Jurisdictions have adopted divergent approaches to address this issue.

II.  Indian Approach to Currency Conversion in Arbitration Awards

The Indian Arbitration and Conciliation Act, 1996 (“Indian Arbitration Act”) does not contain any express provision stipulating the applicable date for converting the currency of an arbitral award into Indian Rupees. This legislative silence has prompted courts to step in and articulate guiding principles through case law. Indian jurisprudence draws a distinction between domestic and foreign