Summary:
In the context of foreign-seated arbitrations, the Supreme Court
of India has clarified that non-signatories to an agreement may be
referred to arbitration in certain circumstances such as in case of
inter-connected agreements meeting certain criteria. In case of
domestic arbitrations, the Supreme Court in Ameet Lalchand Shah and
Others v. Rishabh Enterprises and Another, observed that courts may
refer parties to a single arbitration, if all the agreements are
inter-connected and composite, with a similar underlying commercial
purpose. This is possible even in cases where the parties to the
agreements are not common or all agreements do not have arbitration
clauses.
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