M/S FUERST DAY LAWSON LTD. vs JINDAL EXPORTS LTD.

The Supreme Court held that the enforcement of a foreign award under the Arbitration and Conciliation Act, 1996 is valid if the award was made after the Act's commencement, as established in Thyssen Stahlunion GMBH vs. Steel Authority of India Ltd. (1999). The Court clarified that Section 85 and Section 21 of the Act do not bar enforcement of awards made post-commencement, even if arbitration proceedings began earlier. The appeal was allowed, overturning the High Court's dismissal of the execution petition.