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Supreme Court Rejects MMTC Fraud Claim, Clears Enforcement of $78 Million Coal Arbitration Award in Anglo American Dispute

Vivek G.

Supreme Court dismisses MMTC’s fraud objection and clears enforcement of Anglo American coal arbitration award. Court stresses limits on challenging final awards.

Supreme Court Rejects MMTC Fraud Claim, Clears Enforcement of $78 Million Coal Arbitration Award in Anglo American Dispute

In a closely watched commercial dispute, the Supreme Court on Monday dismissed an appeal filed by state-run MMTC Limited, refusing to halt the enforcement of a long-standing arbitral award in favour of Anglo American Metallurgical Coal Pvt. Ltd. The ruling came after several days of arguments that stretched across multiple hearings this year. The bench, while acknowledging the seriousness of allegations raised, ultimately found no prima facie evidence of fraud sufficient to block execution of the award.

हिंदी में पढ़ें

Background

The dispute traces back to a 2007 long-term agreement between MMTC and Anglo for supply of coking coal. When market prices dropped sharply during the global financial crisis, MMTC lifted only a fraction of the contracted quantity during the fifth delivery period (2008–2009). Anglo invoked arbitration and, in 2014, secured an award of roughly USD 78.7 million plus interest.

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MMTC challenged the award at every stage but the arbitral decision was eventually restored by the Supreme Court in 2020. In 2022, MMTC deposited about ₹1,087 crore in the Delhi High Court as part of ongoing enforcement proceedings.

However, in 2024, MMTC filed objections under Section 47 of the Civil Procedure Code, claiming the award was tainted by fraud. The allegation: senior MMTC officials had colluded with Anglo to secure coal at an inflated price. The company also pointed to a subsequent CBI preliminary inquiry to support this narrative.

Court’s Observations

The bench engaged with both sides' arguments in detail. MMTC insisted that its officers acted against the company’s interest and that only after leadership changes could the alleged misconduct be uncovered. The company framed the issue as a fraud that "unravels everything."

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Anglo sharply disputed this, stating that the pricing was aligned with government-negotiated rates applicable to other major public sector buyers like SAIL and RINL during the same period. Counsel for Anglo argued bluntly that accusations surfaced only after MMTC exhausted all legal options: “The suggestion of collusion falls flat when one sees that MMTC itself did not lift the coal and has fought this case for more than a decade,” the bench recounted from submissions.

The judges noted that Section 47 objections can only succeed if a decree is a nullity. Allegations of internal misjudgment, hindsight disagreement, or pricing mistakes are not grounds to block execution of a final arbitral award.

In a pointed remark, the bench observed, “A decision taken during commercial operations cannot be viewed later with a jaundiced eye. Business judgment requires room for discretion.”

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Decision

Finding no substantial evidence of fraud or collusion capable of nullifying the award, the Supreme Court dismissed MMTC’s appeal. With this, Anglo American is now entitled to withdraw the deposited amount along with accrued interest.

The matter ends at that.

Case: MMTC Ltd. vs. Anglo American Metallurgical Coal Pvt. Ltd. (Supreme Court, 2025)

Court & Date: Supreme Court of India, judgment delivered in 2025.

Parties: MMTC Limited (Appellant) vs. Anglo American Metallurgical Coal Pvt. Ltd. (Respondent).

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