Fertilizer Corp. of India v. IDI Management
United States District Court for the Southern District of Ohio
517 F. Supp. 948 (1981)
- Written by Alexander Hager-DeMyer, JD
Facts
Fertilizer Corporation of India (Fertilizer) (plaintiff), a company owned by the Republic of India, contracted IDI Management, Inc. (IDI) (defendant), an Ohio corporation, to design a fertilizer plant. The parties’ contract contained an arbitration clause for any disputes arising under the agreement. Disputes arose between the parties and went to two related arbitration proceedings in India. The first arbitration proceeding issued an award for IDI, which Fertilizer appealed in the Indian court system. As a result, the Indian courts refused to fully enforce the award until the appeal was resolved, meaning that IDI was unable to collect. For the second arbitration proceeding, the arbitration tribunal issued an award in favor of Fertilizer, and IDI appealed to set aside the award in Indian court. While the award was on appeal, IDI refused to pay, and Fertilizer sued in a United States federal district court for enforcement. IDI asserted several defenses, including that the award was not considered binding and enforceable under the New York Convention because it had not been reviewed by an Indian court for errors of law. The district court examined and rejected IDI’s other defenses and addressed the binding nature of the award.
Rule of Law
Issue
Holding and Reasoning (Spiegel, J.)
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