INDEX

I

Background Facts

2

II

Relevant Terms of the Production Sharing Contract

3

III

Genesis of Dispute

8

IV

Challenge to the Award before the Seat Courts at Kuala Lumpur

13

V

Submissions on behalf of the Appellants

15

VI

Submissions on behalf of the Respondents

22

VII

Discussion and Analysis

28

Part A

Limitation for filing an enforcement/ execution petition of a foreign award under Section 47 of the 1996 Act

28

Part B

Scheme of the 1996 Act for enforcement of New York Convention awards

37

Part C

Whether the Malaysian Courts were justified in applying the Malaysian law of public policy while deciding the challenge to the foreign award?

44

Part D

Whether the foreign award is in conflict with the Public Policy of India?

54