HLV Limited (Formerly known as Hotel LeelaVenture Pvt. Ltd.) v. PBSAMP Projects Pvt. Ltd.
Court – Supreme Court
Citation – SLP (Civil) No. 10732 of 2024
Date – 24.09.2025
The Hon’ble Supreme Court has held that additional post-award interest cannot be claimed under Section 31(7)(b) if Award fixed interest rate till payment.
The Court held,
“30. Therefore, reliance placed by the respondent on Hyder Consulting (supra) to claim post-award interest is misplaced. That principle would apply only when the arbitral tribunal leaves a matter unqualified or is silent. In the present case the arbitral tribunal bound by the MoU and exercising its statutory discretion had already specified the interest rate (21% per annum) and the duration (until repayment). As held in Morgan Securities and Credits Private Limited (supra), reaffirmed in Delhi Airport Metro Express Private Limited (supra) and explained in S.A. Builders Limited (supra), 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.
31. The MoU did not stipulate compounding of interest; the arbitral tribunal did not award compoundinterest; therefore, respondent cannot at the stage of execution seek to introduceclaim of compound interest bydrawing on general principles. Allowing such a claim would amount to rewriting the award at the stage of execution which is impermissible.”
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