Report No. 76
2.15. Foreign Award Act, 1961.-
At this stage, mention may also be made of the fact that the Foreign Awards (Recognition and Enforcement) Act, 1961 (45 of 1961) section 3, relating to stay of proceedings in respect of matters to be referred to arbitration, makes a distinction between a 'submission' made in pursuance of an agreement and the initial 'agreement'. The Supreme Court has pointed this out in a decision dealing with that Act.1
1. Vo Tractor Export v. Tarapore Co., AIR 1971 SC 1 para. 21.