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 of India

M/S Unibros vs All India Radio

Not available · 2023 INSC 931Decided 19 Oct 2023
Not available
S. Ravindra Bhat · Dipankar Datta

Background

Unibros, a contractor, was awarded a construction contract by All India Radio for a building in Delhi that was supposed to finish in 12 months but was delayed by about 42.5 months due to the respondent's fault. An Arbitrator twice awarded Unibros roughly Rs. 1.44 crore for "loss of profit" during the delay period, calculated using Hudson's formula, but the Delhi High Court (both the Single Judge and the Division Bench) set aside this part of the award both times, finding that Unibros had produced no real evidence to prove it had actually lost profitable opportunities because of the delay. Unibros appealed to the Supreme Court, arguing that courts have very limited power to interfere with an arbitrator's factual findings and that Hudson's formula is a legally accepted method for calculating such losses.

Decision Breakdown

The Supreme Court held that while courts indeed have limited scope to interfere with arbitral awards, an award based on no evidence at all is "patently illegal" and conflicts with the fundamental public policy of India, which is a valid ground to set it aside under Section 34 of the Arbitration and Conciliation Act. The Court clarified that a claim for loss of profit due to delay requires the claimant to prove, with credible independent evidence (such as other projects declined, tendering opportunities lost, or financial records), that it actually had a viable alternative opportunity to earn profit elsewhere: a bare formula like Hudson's estimates the amount of loss but cannot itself substitute for proof that a loss occurred. Since Unibros never produced such evidence in either round of arbitration, the Court upheld the setting aside of the loss-of-profit award and dismissed the appeal, though it waived the costs earlier imposed by the Single Judge.

Lesson Learnt

A contractor cannot recover damages for "loss of profit" from a delayed contract simply by applying a standard formula; they must independently prove, with real evidence, that they actually lost a specific profitable opportunity because their resources were tied up: an arbitral award granting such damages without any such proof can be struck down as legally unsustainable.

M/S Unibros vs All India Radio – Legal Case Shots | LegalAware