MILKFOOD LTD. vs M/S. GMC ICE CREAM (P) LTD.

The Supreme Court addressed the applicability of the Arbitration Act, 1940 and the Arbitration & Conciliation Act, 1996 in the context of an arbitration agreement dated 7.4.1992. The Court held that the arbitration proceedings commenced under Section 34 of the 1940 Act, but the consent order by the High Court effectively referred the matter to arbitration under the 1996 Act. The Court concluded that the 1996 Act governs the arbitration proceedings, thereby affirming the applicability of the newer statute over the older one.