HLV Limited vs PBSAMP Projects Pvt. Ltd 2025 INSC 1148 - S.31(7) Arbitration Act - Award Of Interest

Arbitration and Conciliation Act, 1996 - Section 31(7) -Once parties agree on the interest regime, the arbitrator’s role is confined to enforcing it and the courts would not rewrite or enlarge the award by introducing further interest at the execution stage (Para 30)- The discretion to grant interest would be available to the arbitral tribunal under Section 31(7)(a) only when there is no agreement to the contrary between the parties. When the parties agree with regard to any of the aspects covered under the said clause , the arbitral tribunal would cease to have any discretion with regard to the aspects mentioned in the said provision. Only in the absence of such an agreement, the arbitral tribunal would have the discretion to exercise its powers under the said clause.  (Para 25.3)

Case Info

Case Name and Neutral Citation

  • Case Name: HLV Limited (Formerly Known As Hotel Leelaventure Pvt Ltd.) vs PBSAMP Projects Pvt. Ltd.
  • Neutral Citation: 2025 INSC 1148

Coram

  • Judges: Manoj Misra, Ujjal Bhuyan

Judgment Date

  • Date: September 24, 2025

Caselaws and Citations Referred

  1. Hyder Consulting (UK) Limited vs Governor, State of Orissa
    • Citation: (2015) 2 SCC 189
  2. Morgan Securities and Credits Private Limited vs Videocon Industries Limited
    • Citation: (2023) 1 SCC 602
  3. North Delhi Municipal Corporation vs S.A. Builders Limited
    • Citation: (2025) 7 SCC 132
  4. State of Haryana vs S.L. Arora
    • Citation: (2010) 3 SCC 690
  5. Delhi Airport Metro Express Private Limited vs Delhi Metro Rail Corporation
    • Citation: (2022) 9 SCC 286

Statutes/Laws Referred

  • Arbitration and Conciliation Act, 1996
    • Section 31(7)(a)
    • Section 31(7)(b)
  • Article 227 of the Constitution of India
  • Article 136 of the Constitution of India

Suggested Readings:

Supreme Court: Arbitrator’s Role Confined To Enforcing Interest Regime Once Parties Agree On It; Courts Can’t Rewrite Award By Introducing Further Interest
The Supreme Court said that the discretion of the Arbitral Tribunal to award interest under Section 31(7)(a) of the Arbitration and Conciliation Act, 1996 (A&C Act) is subservient to the agreement…