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“Even as we enjoys usually mentioned, there is a risk during the with a few separate arbitrations when you look at the a great case such as this. It has been said oftentimes...it is really undesirable that there should be contradictory findings by the one or two age question, like causation. It is extremely preferred you to definitely everything ought to be done to cease such a circumstance [Abu Dhabi Energy, op.cit.at the 427]”
83. You will find already described the newest contention out-of Mr. Fali S. Nariman, the fresh read elder counsel appearing for the appellant, your terms of Section forty five of 1996 Act is actually slightly the same as Post II(3) of your own Nyc Convention additionally the expression ‘parties' in this Area would mean that ‘all people on action' before the Legal should be brand new functions on the arbitration agreement.
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