ORDER :

1. The petitioner is before this Court seeking for the following reliefs:

“i. To enforce the Award dated 18 August 2021 passed by the Sole Arbitrator in SIAC.ARB.903/2020 and registered with the SIAC Registry of Awards as Award No.087/2021 (Annexure-A) and execute the Award in the Execution Petition annexed herewith.

ii. Pass such other order as this Hon'ble Court may deem fit and proper in the interest of justice.”

2. The international commercial arbitral award dated 18.08.2021 has been delivered by the Sole Arbitrator in international arbitration proceedings held in Singapore, the final award being registered with the Singapore International Arbitration Centre (SIAC) Registry of Awards as Award No.87 of 2021. It is the said award that is sought to be enforced in these proceedings.

3. A perusal of the award as also cause title of the present proceedings indicates that both the petitioner and respondent are body corporates which are incorporated outside India, the petitioner having its registered office at Korea and the respondent having its registered office at Vietnam. It is in this background that a question has arisen as to whether an international commercial arbitral award