VidhiSangh

Supreme Court of India · 17/12/2020

AMERICAN METALLURGICAL COAL PTY LTD. versus MMTC LTD.

[2020] 14 S.C.R. 510 · 2020 INSC 705

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Summary

The Court restored a majority arbitral award for damages arising from MMTC’s failure to lift contracted coal. Applying the pre-2015 review standard, it held that the tribunal’s findings on breach, availability of coal and market-price loss were possible views supported by oral evidence and the correspondence as a whole. The Division Bench improperly isolated three emails and treated contextual inferences as unsupported. Evidence-law principles did not require the correspondence to be read without its commercial setting.

Issues

  1. Whether the majority award was perverse or unsupported by evidence, permitting interference under sections 34 and 37.
  2. Whether the Evidence Act prevented contextual interpretation of the parties’ correspondence and consideration of explanatory evidence.

Provisions considered

Held

Result

Appeal allowed; Division Bench judgment set aside, restoring the majority award dated 12 May 2014 and the Single Judge judgment rejecting the section 34 challenge.

Judgment PDF: Supreme Court of India, [2020] 14 S.C.R. 510.