Mere Deposit of Award Amount Does Not Stop Interest Unless It Is Unconditionally Available to the Award-Holder

  1. Home
  2. /
  3. Publications
  4. /
  5. Case Snippets
  6. /
  7. Mere Deposit of...

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.

Let us help you!

If you need any help, please feel free to contact us. We will get back to you within one business day. Alternatively, if you're in a hurry, you can call us now

+91 9052538538
info@karavadi.in

Recent Case Snippets

Supreme Court Upholds Post-Delivery Penalty for Mis declared Goods by Railways

In Union of India v. M/s Kamakhya Transport Pvt. Ltd. (2025 INSC 805), the Supreme Court held that Indian Railways can recover penalties for misdeclared consignments even after delivery under Section 66 of the Railways Act, 1989. Overturning the Gauhati High Court, it clarified that the law sets no time Read more »

Has ‘Limitation’ Become Limitless? Rethinking the Boundaries for Initiating Arbitration Proceedings

Introduction In the recent ruling in M/s Arif Azim Co. Ltd. Vs. M/s Aptech Ltd., Arbitration Petition No. 29 of 2023, the Hon’ble Supreme Court undertook an exhaustive exercise of tracing the law and identifying the existing legislative vacuum regarding the limitation for both the initiation of arbitration proceedings and Read more »

Supreme Court: No State-Specific Domicile in India, Strikes Down Domicile-Based PG Medical Reservations

In Tanvi Behl & Shrey Goel v. The State of Uttar Pradesh & Others, the Supreme Court reaffirmed that under Article 5 of the Indian Constitution, all Indians have a single domicile—the "Domicile of India." The concept of state or provincial domicile is not recognized in Indian law. This ruling Read more »

Disclaimer

The Rules and Regulations set forth by the Bar Council of India under Advocates Act, 1961 prohibit Advocates or Law Firms from advertising or soliciting work through public domain communications. This website is intended solely to provide information. Karavadi & Associates (“K&A”) does not aim to advertise or solicit clients through this platform. K & A disclaim any responsibility for decisions made by readers/visitors based solely on the content of this website.

By clicking 'AGREE,' readers/visitors agree and acknowledge that the information provided herein (a) does not constitute advertising or solicitation, and (b) is intended solely for their understanding of K & A services. By continuing to use this site, you consent to the use of cookies on your device as outlined in our Cookie Policy.