SICC clarified Infra petita clarified: Ebix fails to set aside SIAC award in Singapore

In Ebixcash Ltd and others v Ashok Kumar Goel and another [2025] SGHC(I) 23, the Singapore International Commercial Court examined whether a partial arbitral award could be set aside for breach of natural justice.

Ebix acquired 80% of an Indian company under a shareholder agreement (SHA), with Goel and Vyoman (G&V) and others holding the remaining 20%. G&V later sought to terminate the SHA and require Ebix to purchase their stake at an enhanced call price determined by an independent valuer. PwC was appointed as the independent valuer over Ebix’s objections, and the SIAC tribunal ultimately sided with G&V.

The Court dismissed Ebix’s application to set aside the award for breach of natural justice. Ebix argued that the tribunal ignored Indian Valuation Rules on valuer independence and failed to consider that the PwC valuation was late.

The Court held that neither point had been properly brought before the tribunal and reaffirmed, with reference to DKT v DKU [2025], that for a successfull infra petita challenge, the issue must have been properly brought before the tribunal and squarely argued. The decision underscores the high threshold for setting aside awards in Singapore.