LegalAware
LegalAware.ai
EMPOWERING LEGAL AWARENESS
Real Judgements, Distilled

Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering — with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway — what a lawyer should factor into case strategy or client advice as a result of this precedent.

Is the full judgment available, or just a summary?+

Both. Each case shows a distilled summary — case type, key holding, and lesson learnt — and links to the full judgment as a PDF for when you need the complete text for research or citation.

Can I filter judgments by date or case type?+

Yes. Use Advanced Filters to narrow results by decision date and by practice area — including Constitutional Law, Criminal Law, Service & Administrative Law, Family Law, Civil Property & Inheritance, and Labour & Industrial Law.

Can I search judgments by a specific judge?+

Yes. You can filter judgments by the judge or bench that decided the case, which is useful for tracking how a particular judge has reasoned on similar issues across multiple rulings.

What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt — with the full judgment available as a PDF for citation or deeper reading.

Arbitration & Commercial LawSupreme Court

Gujarat State Civil Supplies Corporation Ltd. vs Mahakali Foods Pvt. Ltd. (Unit 2) & Anr.

Not available · Not availableDecided 31 Oct 2022

Not available

Uday Umesh Lalit · Bela M. Trivedi

Background

Gujarat State Civil Supplies Corporation Ltd. had a payment dispute with its supplier, Mahakali Foods Pvt. Ltd. (Unit 2), which was referred to the Micro and Small Enterprises Facilitation Council, Bhopal, under the MSMED Act, 2006, resulting in an award against the Corporation. The Corporation's challenge to that award under Section 34 of the Arbitration Act was rejected by the Ahmedabad Commercial Court, and its further appeal under Section 37 was dismissed by the Gujarat High Court, which held that the MSMED Act's provisions override the Arbitration Act. The Corporation appealed to the Supreme Court, and its case was heard together with six other unrelated but legally similar appeals from different High Courts, all raising the common question of whether an independent arbitration agreement between parties can override a supplier's right to approach the statutory Facilitation Council under the MSMED Act.

Decision Breakdown

The Supreme Court held broadly that Chapter V of the MSMED Act, 2006 has an overriding effect over the Arbitration Act, 1996, and that no party to a dispute over money due under Section 17 of the MSMED Act can be precluded from approaching the Facilitation Council merely because an independent arbitration agreement exists between the parties. The Court further held that a Facilitation Council which has conducted conciliation proceedings is nonetheless entitled to act as arbitrator thereafter, despite Section 80 of the Arbitration Act (which ordinarily bars a conciliator from later acting as arbitrator in the same dispute), and that once acting as an arbitral tribunal under Section 18(3) of the MSMED Act, the Council is governed by, and can rule on its own jurisdiction under, the Arbitration Act. Applying these principles specifically to the Gujarat State Civil Supplies Corporation's appeal, the Court found no infirmity in the Gujarat High Court's order upholding the Facilitation Council Bhopal's jurisdiction, and dismissed this appeal (while the other six tagged appeals were disposed of individually — some allowed, some dismissed — applying the same common legal principles to their differing facts).

Lesson Learnt

A supplier registered under the MSMED Act can approach the statutory Micro and Small Enterprises Facilitation Council for recovery of dues even if the underlying commercial contract contains a separate arbitration clause — the MSMED Act's dispute-resolution mechanism for small suppliers overrides private arbitration agreements, and the Facilitation Council can validly act as both conciliator and, if conciliation fails, arbitrator in the same dispute.

Official Source (sci.gov.in)Download Full PDF
Gujarat State Civil Supplies Corporation Ltd. vs Mahakali Foods Pvt. Ltd. (Unit 2) & Anr. – Legal Case Shots | LegalAware