The Delhi High Court in the matter of Super Blastech Solutions vs. Rajasthan Explosives and Chemicals Limited observed that a dispute arising out of an Memorandum of Understanding (MOU) or Memorandum of Settlement (MoS), wherein no arbitration clause is present, can be referred to arbitration if these agreements were directly linked to the main agreement.

The Delhi High Court held that dispute arising out of any subsequent agreement that arises out of the main agreement containing the arbitration clause can be referred to arbitration. The Court further reiterated that the arbitration clause survives the termination of the main agreement, therefore, the arbitration clause would remain effective despite the termination of the principal agreement in which it is embedded.