Israeli companies should use arbitration for disputes with Indian parties, because Israeli court judgments are not directly enforceable in India. A foreign-seated award is enforceable in India under Part II of the Arbitration and Conciliation Act 1996 if the seat is in a New York Convention country notified by India. Indian courts can refuse enforcement only on limited grounds. India-seated arbitration is also possible, with Indian courts supervising it.
- Document route
- Israeli notary, then apostille
- Time difference
- IST is 2.5 to 3.5 hours ahead
- Law
- Arbitration and Conciliation Act 1996
- Foreign awards
- Part II, sections 44 to 49
International Arbitration from Israel: how it works
At the drafting stage we advise on the seat, institution, number of arbitrators, language and governing law, and whether Indian courts' interim relief powers should remain available. For a dispute already underway, we advise on notices, interim relief in India to protect assets, and coordination with your arbitration counsel. We can act as Indian counsel in a foreign-seated arbitration, giving evidence on Indian law, or lead an India-seated case.
Once an award is made, we file for enforcement in the appropriate Indian High Court or court with jurisdiction over the Indian party's assets. The Indian party may object on grounds such as public policy, which Indian courts now read narrowly. If enforcement succeeds, the award is executed like a decree, by attaching bank accounts, property or receivables. Watch limitation periods and whether the Indian party is moving assets.
What clients in Israel should know
- Confirm that the chosen seat is notified by India under Part II; Singapore and London seats are commonly used for Israeli-Indian contracts.
- Investment treaty arbitration under the bilateral investment treaty is separate from commercial arbitration and has its own conditions.
- Indian courts may grant interim measures, such as freezing bank accounts, in support of a foreign-seated arbitration unless the contract excludes it.
Step by step from Israel
Video consultation
A call at a time that suits Israel, after we have read your documents.
Documents signed in Israel
Israeli notary, then apostille
Work in India
Our team files, appears and follows up in India, and shares scans of everything filed.
Result and handover
Certified copies and originals are couriered to you in Israel where needed.
The full guide
This page covers what changes when you are in Israel. For the law, the documents and the step-by-step procedure, read our main page on International Arbitration, or see all services for clients in Israel and the Disputes & Enforcement practice area.
Questions from clients in Israel
Can we enforce a Tel Aviv-seated award in India?
Israel is a New York Convention state. Enforcement under Part II also depends on Indian notification; we confirm this for your case.
How long does enforcement take in India?
Contested enforcement can take one to several years, though courts have become quicker in commercial matters.
Can the Indian party challenge the award in India?
Only on the limited grounds in the Act. An Indian court does not review the merits of a foreign award.