The reasoning which is given in Bhatia International V/S Bulk Trading was limited and
confined to its own understanding but instead of evolving the understanding, the court reverse
the whole notion in the BALCO case, the author tried to give an understanding while analysing
the reason the need of Part I to be applied even when the Arbitration Dispute was chaired
outside India, with giving the peculiar reasoning for it. However, the fallacies continued and
narrowed the role of the judiciary in an arbitration proceeding. Thus, the non-provision of Interim measures can often result in making the whole arbitration meaningless
1Arunima Jha , Bhatia International V/S Bulk Trading, < https://www.legalserviceindia.com/article/l445-BhatiaInternational-Vs.-Bulk-Trading-S.A.html> Accessed on 6 January 2022
2 Vidhu Gupta, Stretching The Limit Of Statutory Interpretation: Critical Review Of Bhatia International V Bulk
Trading Accessed on 6 January 2022