Sakuma Exports Ltd vs Louis Dreyfus Commodities Suisse S.A

The Supreme Court upheld the Bombay High Court's decision that Indian courts lack jurisdiction under Section 34 of the Arbitration and Conciliation Act, 1996 to challenge an international commercial arbitration award governed by English law. The Court reaffirmed the principle established in Bharat Aluminium Company vs. Kaiser Aluminium Technical Services Inc. (BALCO) that Part I of the Act does not apply to international arbitration held outside India, while clarifying that the arbitration agreement in this case is governed by the earlier ruling in Bhatia International vs. Bulk Trading S.A. The appeal was dismissed, confirming the High Court's order.