S. 31(7)(b) Arbitration Act | Claim for Additional Post-Award Interest Barred When Award Fixes Rate Until Payment: Supreme Court

The Supreme Court held that when an arbitral award specifies a composite interest rate covering the entire period from the cause of action until payment, the award-holder cannot claim additional post-award interest under Section 31(7)(b) of the Arbitration and Conciliation Act, 1996. The section provides that arbitral awards carry interest unless the tribunal directs otherwise. In this case, a Memorandum of Understanding required repayment with 21% interest from disbursement to repayment. The arbitral tribunal awarded repayment at the same composite rate until payment. The award-holder sought additional compound interest at 18% under Section 31(7)(b), but this was rejected. The Court held that once an award prescribes a full and final rate covering the entire duration, no further statutory interest is available. The ruling clarified that Section 31(7)(b) operates only when the award is silent on post-award interest. This decision underscores that arbitral autonomy prevails, and parties cannot claim layered or supplementary interest beyond what has been expressly awarded.