Report No. 76
2.25. Privy Council Case.-
Recent Indian decisions on the subject present a contrast to the earlier Privy Council ruling in Hirji Mulji' case.1 A later case decided by the House of Lords-Heyman v. Darwins Ltd., 1942 AC 356: (1942) 1 All ER 337 (HL)., also holds that widely drawn arbitration clause could embrace a dispute as to whether a party is discharged from future performance by frustration.
1. Hirji Mulji v. Cheongyue Steamship Co., 1926 AC 97 (PC).