In National Seeds Corporation Ltd. v. National Agro Seed Corporation (India), 2026 INSC 1017, the Supreme Court considered whether deposit of the awarded amount before Court would stop the running of interest. The award-debtor had deposited amounts during the pendency of proceedings challenging the arbitral award, but the award-holder was not free to withdraw and utilise the same without conditions. The Court held that a deposit by itself is not synonymous with payment or satisfaction of the award. For interest to cease under Order XXI Rule 1 CPC, the amount deposited must be unconditionally available to the decree-holder or award-holder for withdrawal. Where withdrawal is made subject to furnishing security, or the award-debtor continues to resist release of the amount, the deposit does not amount to satisfaction of the award. The Court further clarified that if only part of the amount is unconditionally available for withdrawal, interest ceases only to that extent, while the balance continues to carry interest. Applying these principles, the Court held that the award-debtor’s liability to pay interest had not ceased merely because the amounts had been deposited before the Court.
