Comparative Analysis of UK & Indian Courts in Granting Relief and Challenging Arbitral Awards

This paper aims to endeavour to execute a comparative analysis of the legal frameworks, constructs and judicial pathways taken up by the courts in the United Kingdom and India, with primary viewpoint on the requisitioning of relief grants and the contemporary challenges raised against the fora of arbitral awards. India and United Kingdom have a dedicated arbitration statute entrenched in the UNCITRAL Model Law; this exposition earmarks significant discrepancies in the interpretation, analysis and usage implementation of the UNICITRAL Model Law's alongside the principle of non-intervention between two different independent territorial jurisdictions. The primary focus of the comparative analysis identifies similarity and disparity of grounds for granting relief and challenging arbitral awards by examining Arbitration act of 1996 (UK) and The Arbitration and conciliation act 1996. Further the paper examines how both jurisdiction of UK & India handles recognition and enforcement under the New York convention. Comparative study between two states will open the minds of the makers of legislation which leads to mould a question about how statutory design directly impacts in shaping judicial attitude, judicial consistency and predictability. The ultimate endeavour of this comparative investigatory scrutiny is to illuminate and make a plain sight of pre-existing ambiguities, depreciate redundant and futile judicial intervention and illuminate varies ways to surmount remissions in enforcement, while consigning the exigency for concurrence and reform to strengthen arbitration's role as a reliable global dispute resolution mechanism.