The Hon'ble Supreme Court in the landmark decision of Amazon.com NV Investment Holdings LLC v. Future Retail Ltd. & Ors.1 has held that emergency arbitral awards are orders under Section 17(1) of the Arbitration and Conciliation Act, 1996 (Arbitration Act). The Apex Court also held that an order passed under Section 17(2) of the Arbitration Act in enforcement of an award of an emergency arbitration was not appealable. In this article, we briefly analyze the findings of the Hon'ble Supreme Court which led to the aforementioned conclusions.

The Hon'ble Supreme Court in the recent matter of Rahul S. Shah v. Jinendra Kumar Gandhi and Ors.1 while deciding upon a property dispute empathetically discussed the plight of the decree holders and the challenges they face in the execution of the decrees. The three-judge bench of former Chief Justice of India S.A. Bobde and Justices L. Nageswara Rao and S. Ravindra Bhatt issued a landmark decision involving 14 (fourteen) directions to all courts that dealt with suits and execution of decrees to expedite the execution of decrees. The directions aim to allow a decree-holder to enjoy the fruits of litigation without any inordinate delay and unnecessary hurdles.