In the matter of MMTC Limited versus Anglo American Metallurgical Coal Pvt. Ltd, the Apex Court reiterated and reaffirmed the position that objections against the execution of an award lie in a narrow compass, such as only when a decree is inherently void or passed without jurisdiction.  

The Supreme Court held that at the stage of execution, an objection as to executability of the decree can be raised, limited to the ground of jurisdictional infirmity or voidness. It has been further held that errors of facts and law cannot be the subject matter of objection under Section 47 of the Code of Civil Procedure, 1908 (CPC).  

Accordingly, the Apex Court upheld the Delhi High Court’s decision dismissing Appellant-MMTC’s objections under Section 47 of CPC and its application under Order XXI Rule 29 seeking a stay on enforcement of a multi-million-dollar arbitral award in favour of Respondent-Anglo American Metallurgical Coal Pvt. Ltd., since the objections raised for staying the enforcement of arbitral award do not fall within the narrow compass of jurisdictional infirmity or voidness.