finance

Recommendations for Establishing an International Arbitration Centre in GIFT City

Introduction

On July 16, 2024, the Expert Committee responsible for drafting institutional arbitral rules for the International Arbitration Centre at GIFT IFSC presented its report to the Chairperson of the International Financial Services Centres Authority (IFSCA). Led by Dr. M. S. Sahoo, the Committee was established following the Finance Minister's announcement in the 2022-23 Budget to create an International Arbitration Centre in GIFT City, aimed at promoting timely dispute resolution under international law. After conducting seven meetings, the Committee examined the frameworks of prominent arbitration bodies, such as SIAC, SICC, HKIAC, LCIA, and DIAC, while engaging with global dispute resolution experts.

Committee Recommendations

The Committee made several key recommendations summarized below:

  • Adoption of Global Best Practices: Integrate international advancements, including technology use and third-party funding, and permit representation by foreign attorneys.
  • Regulatory Revisions: Amend the IFSCA Act, Arbitration and Conciliation Act, and Mediation Act to enhance party autonomy, streamline arbitration processes, and ensure award enforceability.
  • Establishment of a Judicial Framework: Create a dedicated judicial structure within the IFSC to support arbitration and mediation.
  • Development of a Comprehensive ADR Centre: Propose a systematic approach integrating various dispute resolution methods.

These recommendations support the Government of India's objective to position GIFT IFSC as a hub for global financial and technological services, facilitating effective dispute resolution for international businesses and investors. The comprehensive report is available on the IFSCA website.

Context of GIFT City and IFSC

GIFT City is India's inaugural International Financial Services Centre (IFSC), providing a range of financial services including capital markets, insurance, and banking. The Government aims to establish this centre as an innovation hub elevating financial services beyond conventional boundaries. Financial products vary by jurisdiction, influenced by the robustness of institutions supporting contract enforcement and dispute resolution. A reliable dispute resolution mechanism is critical for fostering confidence among businesses and investors, ensuring prompt and equitable outcomes.

Alternative Dispute Resolution Landscape

There is a significant global shift toward Alternative Dispute Resolution (ADR) over traditional judicial systems, with numerous Indian entities seeking ADR services internationally. A pivotal ruling from the Supreme Court of India now permits Indian parties to pursue arbitration in foreign venues, emphasizing the need to foster a competitive ADR environment domestically.

Proposed Statutory Framework for ADRC

Leveraging Existing Legislation

The Committee suggests utilizing four existing statutes: the IFSCA Act, 2019; Arbitration and Conciliation Act, 1996; Mediation Act, 2023; and Special Economic Zones Act, 2005, with limited modifications. Recommended amendments would develop an ADR framework specifically designed for GIFT City.

The Committee advised adjustments to Sections 3(i) and 3(y) of the Mediation Act to exempt IFSC mediators from MCI regulations, allowing for customized guidelines for international commercial mediation.

Governing Law Selection

The proposed framework should stipulate that both domestic and international parties may select IFSC as the arbitration seat while retaining the flexibility to choose relevant laws, thereby preventing restrictions on contract enforcement. The framework may include a proposed 6-month timeline for award issuance or options for document-only arbitration.

Enhancements to Arbitration Procedures

Key provisions will entail:

  • Accelerated arbitration processes.
  • Options for document-only arbitration.
  • A potential regime for third-party funding, in line with established centre practices.

Judicial Oversight and Support

A gradual enhancement of the judiciary is proposed, starting with a dedicated bench in the Gujarat High Court for ADR matters, eventually leading to the establishment of a distinct IFSC International Court with powers akin to a High Court. Concerns about jurisdictional conflicts between the proposed IFSC International Court and the Gujarat High Court have been raised by stakeholders.

ADRC Structure and Governance

Formation as a Non-Profit Entity

The ADRC will be established as a Section 8 company under the Companies Act, 2013, ensuring independence and the avoidance of conflicts of interest. Governance will include a Board of Directors, an International Advisory Council, and an Executive Council to oversee operations.

Self-Regulation

The ADRC will autonomously manage its procedures, continuously adapting its rules and guidelines to reflect evolving practices, prioritizing innovation, efficiency, and adherence to international standards.

Roadmap for Implementation

The Committee recommends an immediate start to the ADRC establishment while concurrently pursuing the necessary statutory amendments. A marketing strategy will include outreach efforts such as workshops and seminars, capitalizing on the presence of prominent ADR professionals to showcase the centre’s capabilities.

Additionally, a centralized database should be implemented to track ongoing cases, enhancing accountability, along with streamlined visa processes for foreign ADR professionals to facilitate their contributions to GIFT City’s dispute resolution framework.