JUDGMENT

1. These petitions, preferred under Section 9 of the Arbitration and Conciliation Act, 1996 (the 1996 Act) arise out of the same set of agreements. They are, therefore, being disposed of by a common judgement though, as the disputes in the petitions are distinct, they would be dealt with separately.

OMP (I) (COMM) 308/2020

2. Given the nature of the dispute in this petition, it would be appropriate, at the outset, to introduce the dramatis personae.

3. The petitioner provides clean energy solutions and, inter alia, sets up and implements Solar Power Projects. Kindle Engineering and Construction Pvt Ltd, Responsive SUTIP Ltd and Ujjawala Power Pvt Ltd, Respondents 3, 4 and 5, are three of 18 Special Purpose Vehicles (SPVs), set up by the petitioner for executing 18 Solar Power Projects. Respondents 1 and 2, by agreement with the petitioner, purchased the Solar Power Projects. Respondent 6 is a Debenture Trustee, which holds in trust the Kindle Pledge constituting the Kindle restricted shares of Respondent 3, for the benefit of Respondent 1.

4. Respondents 1 and 2 are Investment Management Firms incorporated in Singapore. They have no official presence in India, though they a