{"id":308761,"date":"2023-12-09T09:00:30","date_gmt":"2023-12-09T03:30:30","guid":{"rendered":"https:\/\/www.scconline.com\/blog\/?p=308761"},"modified":"2023-12-10T09:28:39","modified_gmt":"2023-12-10T03:58:39","slug":"recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2","status":"publish","type":"post","link":"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/","title":{"rendered":"Recap of Group Companies Doctrine in Indian Arbitration: Must Read Before Season 2"},"content":{"rendered":"
\n

Introduction<\/h4>\n

Arbitration is an alternate dispute resolution mechanism, whereby the mode, manner, and choice of going through the route of arbitration is always through the consent of the parties who have agreed to be bound by it. As global commerce continues to grow, and businesses become more complex, commercial transactions can also become more complicated. In some cases, this \u201cconsent\u201d may then be implied rather than express. This essentially means that even if a \u201cthird party\u201d has not expressly signed and stamped the arbitration agreement, but because they benefit from it, they are deemed to be bound by it.<\/p>\n

However, how and when third parties are bound to arbitration is an area of jurisprudence that is being slowly developed and refined by the courts world over, including Indian courts. A subset of such jurisprudence is the applicability of the group companies doctrine (the doctrine) to the arbitration jurisprudence.<\/p>\n

Simply put, the group companies doctrine is a legal principle that recognises a group of companies as a single economic entity for the purpose of determining their liability and obligations. In other words, when companies in a group have a common economic interest and operate as a single entity, they can be held jointly liable for the actions of any one of the companies. The doctrine is often used in cases of international arbitration involving companies with multiple subsidiaries or affiliates in different countries.<\/p>\n

In fact, one of the most challenging areas of the jurisprudence relates to multi-party and multi claim proceedings. This doctrine becomes even more complicated and intricate when international elements are involved.<\/p>\n

The aim of this article is to narrow down on the development of the doctrine, the current scenario and how the Supreme Court is still to clarify various aspects to consolidate the doctrine especially considering the fact that it is not expressly included in the Arbitration and Conciliation Act, 1996<\/a>1<\/sup><\/a> (the A&C Act), with a special development made recently in Cox and Kings Ltd.<\/span> v. SAP India (P) Ltd.<\/span>2<\/sup><\/a> (Cox and Kings)<\/span> referring the subject to a larger Bench.<\/p>\n

The roots of the group companies doctrine in India<\/h4>\n

In India, the foundations of the doctrine in the domestic context can be seen in Sukanya Holdings (P) Ltd.<\/span> v. Jayesh H. Pandya<\/span>3<\/sup><\/a> (Sukanya Holdings<\/span>). In this case, some of the parties were not part of the original arbitration agreement which formed part of a partnership agreement. The appellant was claiming relief against such other parties. The Supreme Court of India observed that under Section 8<\/a> of the A&C Act<\/a>4<\/sup><\/a> any matter which is the subject-matter of an arbitration agreement was required by court to be referred to arbitration. Neither the A&C Act nor the Code of Civil Procedure, 1908<\/a>5<\/sup><\/a> allows the bifurcation of the subject-matter of the suit\/arbitration and therefore the entire matter ought to be referred to arbitration notwithstanding the fact that some parties were not party to the arbitration agreement. Although this initial case did not deal directly with companies, it is one of the oldest cases laying down the foundations for the doctrine in India. The applicability of Sukanya Holdings<\/span>6<\/sup><\/a> has been widely accepted to be only vis-\u00e0-vis Part I of the A&C Act, which deals with domestic arbitration.<\/p>\n

The first time the doctrine was expounded by the Supreme Court of India was in Chloro Controls India (P) Ltd.<\/span> v. Severn Trent Water Purification Inc.<\/span>7<\/sup><\/a> (Chloro Controls<\/span>). This was a case under Part II of the A&C Act dealing with international commercial arbitration for the invocation of Section 45<\/a> of the A&C Act<\/a>. This section grants the judicial authority, the power to refer parties to arbitration when one of the parties to the arbitration agreement or any person claiming through or under him requests for the same8<\/sup><\/a>. In this case, the Court observed the difference between Sections 8 (under Part I) of the A&C Act and Section 45 (Part II) of the A&C Act, which both deal with the power of the judicial authority to refer a matter to arbitration. The Supreme Court noted that when contrasted, Section 45 uses the expression \u201cparties or any person claiming through or under him\u201d as compared to only \u201cparties\u201d under Section 8. This enlarges the scope of who could be referred to arbitration under Part II. The Court noted, that therefore, any enquiry of whether a third party could be joined to arbitration under Section 45 should include a sine qua non that such a person\/applicant should claim through or under the signatory party. The doctrine in India could have only been under Part II for international commercial arbitrations because at that point in time, the language of the two sections (that is Sections 8 and 45) differed significantly.<\/p>\n

In Chloro Controls<\/span>9<\/sup><\/a> although the Supreme Court observed that intention of the parties is significant to establish the introduction of non-signatory parties, it developed a four-pronged test to extend arbitration agreements to non-signatories without prior consent and in exceptional circumstances. This test included the following elements:<\/p>\n

(a<\/span>) direct relationship to the party signatory to the arbitration agreement;<\/p>\n

(b<\/span>) direct commonality of subject-matter;<\/p>\n

(c<\/span>) the composite nature of the transaction, that is the agreement between the parties being of a composite nature where performance of \u201cmother agreement\u201d may not be feasible without aid, execution, and performance of the supplementary or ancillary agreements for achieving the common object and collectively having bearing on the dispute;<\/p>\n

(d<\/span>) if the composite reference of such parties would serve the ends of justice.<\/p>\n

The Court pointed to the fact that all the above ingredients should have been fulfilled in order for the case to fall under exceptional circumstances, when even non-signatories can be referred to the same arbitration proceedings. Not much emphasis was laid on looking at mutual or implied consent or the intention of the third parties to be bound by the arbitration agreement.<\/p>\n

In Chloro Controls<\/span>10<\/sup><\/a> although the Court accepted that there must be some legal relationship between the non-signatory parties and the parties to the arbitration agreement, it accepted the doctrine as a sufficient basis to establish this legal relationship, notwithstanding the absence of implied\/express consent.<\/p>\n

Post Chloro Controls developments, expansions, and interpretations<\/h4>\n

Following Chloro Controls<\/span>11<\/sup><\/a>, the position of the doctrine was considered in the 246th Law Commission Report. The Report recommended an amendment to Sections 2(1)(h<\/span>)12<\/sup><\/a> and 813<\/sup><\/a> of the A&C Act to modify the definition of \u201cparty\u201d under Part I of the A&C Act, to resemble the language of Section 45 of Part II. The words \u201ca party to an arbitration agreement or any person claiming through or under such party\u201d were recommended to be introduced to do away with the anomaly between the two parts.<\/p>\n

Following this recommendation of the Law Commission, the Arbitration and Conciliation (Amendment) Act, 201514<\/sup><\/a> (the 2015 Amendment) was passed which widened the scope of \u201cparty\u201d under Section 8 to include \u201cor any person claiming through or under him\u201d. However, the recommended amendment under Section 2(1) was not introduced. Section 2(1)(h<\/span>) still reads, \u201c \u2018party\u2019 means a party to an arbitration agreement\u201d and does not include any reference to any person claiming through or under such party.<\/p>\n

This amended Section 8 was then applied in Ameet Lalchand Shah<\/span> v. Rishabh Enterprises<\/span>15<\/sup><\/a> (Ameet Lalchand<\/span>), where the Court observed that this was a case of a composite transaction, where several parties were involved in a single commercial project executed through several agreements\/contracts where all parties could be covered by the arbitration clause in the main agreement. Both, the Division Bench and the Single Judge of the Delhi High Court had rejected the application under Section 8 of the Act and held that since the agreement in question was unrelated to the principal agreement, the parties could not be referred to arbitration following the Sukanya Holding case<\/span>16<\/sup><\/a>. The Supreme Court in Ameet Lalchand<\/span>17<\/sup><\/a> rejected this conclusion, holding that the arbitrator assigned can properly investigate the claims of fraud. The Supreme Court also determined that all agreements are interconnected, and hence the disagreement must be resolved by an arbitrator.<\/p>\n

In Cheran Properties Ltd.<\/span> v. Kasturi & Sons Ltd.<\/span>18<\/sup><\/a> ( Cheran Properties<\/span>), the Court expanded Chloro Controls<\/span>19<\/sup><\/a> by interpreting Section 35 of the A&C Act20<\/sup><\/a> to enforce an arbitral award against a non-signatory even though it had not participated in the arbitration proceedings.21<\/sup><\/a> In Reckitt Benckiser (India) (P) Ltd.<\/span> v. Reynders Label Printing (India) (P) Ltd.<\/span>22<\/sup><\/a> (Reckitt Benckiser<\/span>), the Supreme Court interpreted Chloro Controls<\/span>23<\/sup><\/a> narrowly and refused to apply the doctrine as the applicant had failed to prove the commonality of the intention of the non-signatories to be bound by the arbitration agreement.<\/p>\n

In MTNL<\/span> v. Canara Bank<\/span>24<\/sup><\/a> (MTNL) the Court observed that the doctrine could also be invoked where there is a tight group structure with strong organisational and financial links, so as to constitute a single economic unit, or single economic reality. The Supreme Court opined that this would apply particularly when funds of one company are used to financially support or restructure other members of the group.<\/p>\n

The anomalies and the current scenario<\/h4>\n

The current scenario of the doctrine has created confusion in arbitration jurisprudence in India. As such there are only a handful of countries where the doctrine permits joinder of non-signatories to arbitration, namely, France and India. This is mainly because the group company doctrine as currently applicable has given rise to several anomalies:<\/p>\n

Lack of intention \u2014 Expansion and contraction<\/i><\/h4>\n

The inception of the doctrine has been through Chloro Controls<\/span>25<\/sup><\/a>. However, there seems to be an inherent contradiction in the manner in which the case deals and develops the doctrine.<\/p>\n

This is evident from the fact that although the Supreme Court emphasised that the intention of the parties is a very significant feature which must be established before the arbitration can be said to include a non-signatory, it in fact, went on to introduce a test to extend the applicability of arbitration agreements to non-signatories even without their prior consent, albeit in exceptional circumstances. So, the said test extends an arbitration agreement to non-signatories notwithstanding the absence of intention of parties to be bound by it.<\/p>\n

Ultimately such a contradiction creates a conclusion where mutual consent and intention should be disregarded if equity so requires.<\/p>\n

This is also evident from the varied ways in which the Supreme Court itself has applied the doctrine. While in some cases the scope has been expanded in others it has been narrowed down.<\/p>\n

For instance, relying on Chloro Controls<\/span>26<\/sup><\/a> in Ameet Lalchand<\/span>27<\/sup><\/a> the Court by a mere finding of a composite transaction existing with a mother agreement and ancillary agreements in a single commercial project, thus presuming the intention from the companies being part of the Group. Similarly, Cheran Properties<\/span>28<\/sup><\/a> expanded the scope of Chloro Controls<\/span>29<\/sup><\/a> for enforcement of an arbitral award against a non-signatory. MTNL<\/span>30<\/sup><\/a> also expanded the scope of Chloro Controls<\/span>31<\/sup><\/a> by invoking an analysis of tight group structure or single economic reality.<\/p>\n

To the contrary, Reckitt Benckiser<\/span>32<\/sup><\/a> has narrowed down the scope by noting a failure to prove commonality of intention. This element was missing from the aforementioned judgments which expanded the scope of the group company doctrine and was a contradiction in the original Chloro Controls<\/span> judgment33<\/sup><\/a>.<\/p>\n

More recently, the Supreme Court in ONGC Ltd.<\/span> v. Discovery Enterprises (P) Ltd<\/span>.34<\/sup><\/a> (ONGC) observed that \u201ca non-signatory may be held to be bound on a consensual theory founded on agency and assignment or a non-consensual basis such as estoppel or alter ego\u201d. This judgment also added an additional element to the factors laid down in Chloro Controls<\/span>35<\/sup><\/a> to bind non-signatories that is \u201cmutual intent of the parties\u201d. However, this does not take away from the fact that this judgment in no way has overruled Chloro Controls<\/span>36<\/sup><\/a>.<\/p>\n

In view of the above discussion a major anomaly created by Chloro Controls<\/span>37<\/sup><\/a> is that even where non-signatories have not been shown to have a mutual intention to be bound by the arbitration agreement, they can still be held to be bound if the tests laid down in Chloro Controls<\/span>38<\/sup><\/a> are fulfilled. This anomaly has already created a variety of offshoots in the form of expansion and contraction cases as discussed above, and there might be more to come.<\/p>\n

Responsibilities but no rights<\/i><\/h4>\n

As highlighted above, the 246th Law Commission Report had recommended adding the words \u201cany person claiming or through or under such party\u201d39<\/sup><\/a> in both the definition Section 2(1)(h<\/span>) as well as Section 8<\/a> of the A&C Act<\/a>. However, when the 2015 Amendment was brought about, only Section 8 was amended, and Section 2 remains unamended.<\/p>\n

The direct result of this is that while a non-signatory could be referred to arbitration (due to the presence of these words in Section 8) at the same time, they cannot invoke other sections such as Section 940<\/sup><\/a> or Section 1741<\/sup><\/a> to seek interim relief. Similarly, a non-signatory cannot challenge an award under Section 34 of the A&C Act42<\/sup><\/a>. This is because these sections refer only to \u201cparties\u201d and do not include \u201cpersons claiming to or under\u201d the parties.<\/p>\n

The anomaly created therefore, is that although non-signatories can be bound to the arbitration, or the award, they do not have the benefit of availing remedies available to \u201cparties\u201d or signatories to the arbitration agreement.<\/p>\n

Lack of party autonomy<\/i><\/h4>\n

Party autonomy is a major cornerstone of arbitration in India as well as internationally. However, after Chloro Controls<\/span>43<\/sup><\/a>, the expansion cases by the Supreme Court of India as well as several judgments by the High Courts in India are premised more on convenience and efficiency in resolution of disputes rather than a consistent and clear legal doctrine which respects party autonomy and mutual intentions.<\/p>\n

Failure to recognise separate legal identity of companies<\/i><\/h4>\n

Various contradictory judgments as already highlighted have mushroomed in the Indian scenario. In MTNL<\/span>44<\/sup><\/a> the concept of \u201csingle economic reality\u201d was highlighted as a means of expanding the doctrine. This is a marked departure from the separate legal corporate personality of companies even within the same group.45<\/sup><\/a><\/p>\n

The concept of single economic reality is also a significant departure from the alter-ego concept or the concept of piercing the corporate veil. These two concepts are more for the purpose of identifying fraudulent or duplicitous acts by a third party which would then inevitably lead to the application of group companies doctrines to bind them to such duplicitous acts.<\/p>\n

Despite this stark difference, High Courts across the country have applied the principles of alter ego and piercing corporate veil thereby completely bypassing the principle of separate legal identity of companies even within the same group.<\/p>\n

In order to bind a third party to an arbitration, it ideally should be necessary to inquire into implied consent by such a party, by looking at the explicit facts and circumstance of each case.<\/p>\n

The road ahead: Season 2<\/h4>\n

Several of the anomalies highlighted above have been recently observed by the Supreme Court of India in Cox and Kings<\/span>46<\/sup><\/a>.<\/p>\n

Cox and Kings was a petition under Section 11<\/a> of the A&C Act<\/a>47<\/sup><\/a> for appointment of an arbitrator in an Indian-seated international commercial arbitration. Here the applicant and first respondent entered into a software licensing agreement. This agreement was later divided into three separate agreements the first one being signed by the applicant and Respondent 1, the second and third one being signed by all parties. The arbitration was being invoked under the third agreement.<\/p>\n

When there were issues in appointment of the arbitrator between the parties, the group companies doctrine was invoked which the Supreme Court then went into depth, and thought it fit to refer the issue to a larger Bench of clarity.<\/p>\n

The majority decision, refers the following questions to the larger Bench in the context of the group companies doctrine:<\/p>\n

(a<\/span>) Whether the phrase \u201cclaiming through or under\u201d in Sections 8 and 11 could be interpreted to include the \u201cgroup of companies doctrine\u201d?<\/p>\n

(b<\/span>) Whether the \u201cgroup of companies\u201d doctrine as expounded in Chloro Controls<\/span>48<\/sup><\/a> and subsequent judgments is valid in law?<\/p>\n

In addition to these questions, the minority judgment has referred the following questions to the larger Bench:<\/p>\n

(a<\/span>) Whether the group of companies doctrine should be read into Section 8<\/a> of the A&C Act<\/a> or whether it can exist in Indian jurisprudence independent of any statutory provision?<\/p>\n

(b<\/span>) Whether the group of companies doctrine should continue to be invoked on the basis of the principle of \u201csingle economic reality\u201d?<\/p>\n

(c<\/span>) Whether the group of companies doctrine should be construed as a means of interpreting the implied consent or intent to arbitrate between the parties?<\/p>\n

(d<\/span>) Whether the principles of alter ego and\/or piercing the corporate veil can alone justify pressing the group of companies doctrine into operation even in the absence of implied consent?<\/p>\n

Another interesting observation made by the Supreme Court was how the doctrine is very relevant in the Indian context. The minority judgment observes:<\/p>\n

97<\/span>. \u2026 a large chunk of Indian business houses are composed of family run entities or groups. The individuals running these entities often occupy multiples roles in different companies within the group. Thus, the commonality in terms of key managerial personnel and the preponderance of family members occupying these positions moulds the way these companies conduct business\u2026.<\/p>\n

98<\/span>. \u2026 in this scenario it becomes even more relevant to have a doctrine such as the group companies doctrine in Indian arbitral law.49<\/sup><\/a><\/p>\n

Denouement and future outlook<\/h4>\n

Currently in the Indian scenario, the group company doctrine has created several anomalous results in the arbitration jurisprudence of India. There seem to be inherent contradictions in not only the development of the doctrine but from its very inception. At the same time, it is a doctrine that appears to be intrinsic to the Indian arbitration regime.<\/p>\n

It is still to be seen what kind of clarity the larger Bench of the Supreme Court provides on whether the current interpretation of the group company doctrine is sufficient to imply consent, or whether consent is even to be looked into by the courts while invoking the doctrine.<\/p>\n

However, while the matter remains sub judice several arbitrations and court proceedings are underway where anomalous interpretations continue to be made.<\/p>\n

The appropriate response to this uncertainty would be a quick and much appreciated authoritative determination of the different facets of the group company doctrine. All eyes are on the Supreme Court as of now to see whether the group company doctrine is retained due to its importance to the Indian scenario or whether it is done away with altogether.<\/p>\n<\/div>\n

\n

*Dual Qualified Lawyer (India \u2014 Advocate, England & Wales \u2014 Solicitor). Partner, Adwitya Legal LLP (Arbitration & Dispute Resolution). The author can be reached at gunjan@adwlegal.co.in<\/a>. The author is grateful to Ms Avishikta Chattopadhyay for her able assistance.<\/span><\/strong><\/p>\n

1.<\/a> Arbitration and Conciliation Act, 1996<\/a>.<\/p>\n

2.<\/a> (2022) 8 SCC 1<\/a>.<\/p>\n

3.<\/a> (2003) 5 SCC 531<\/a>.<\/p>\n

4.<\/a> Arbitration and Conciliation Act, 1996, S. 8<\/a>.<\/p>\n

5.<\/a> Civil Procedure Code, 1908<\/a>.<\/p>\n

6.<\/a> (2003) 5 SCC 531<\/a>.<\/p>\n

7.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

8.<\/a> Arbitration and Conciliation Act, 1996, S. 45<\/a>.<\/p>\n

9.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

10.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

11.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

12.<\/a> Arbitration and Conciliation Act, 1996, S. 2(1)(h<\/span>)<\/a>.<\/p>\n

13.<\/a> Arbitration and Conciliation Act, 1996, S. 8.<\/a><\/p>\n

14.<\/a> Arbitration and Conciliation (Amendment) Act, 2015<\/a>.<\/p>\n

15.<\/a> Ameet Lalchand Shah<\/span> v. Rishabh Enterprises<\/span>, (2018) 15 SCC 678<\/a>.<\/p>\n

16.<\/a> (2003) 5 SCC 531<\/a>.<\/p>\n

17.<\/a> (2018) 15 SCC 678<\/a>.<\/p>\n

18.<\/a> (2018) 16 SCC 413.<\/a><\/p>\n

19.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

20.<\/a> Arbitration and Conciliation Act, 1996, S. 35<\/a>.<\/p>\n

21.<\/a> Gemini Bay Transcription (P) Ltd.<\/span> v. Integrated Sales Service Ltd.<\/span>, (2022) 1 SCC 753<\/a>.<\/p>\n

22.<\/a> (2019) 7 SCC 62<\/a>.<\/p>\n

23.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

24.<\/a> (2020) 12 SCC 767<\/a>.<\/p>\n

25.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

26.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

27.<\/a> (2018) 15 SCC 678<\/a>.<\/p>\n

28.<\/a> (2018) 16 SCC 413.<\/a><\/p>\n

29.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

30.<\/a> (2020) 12 SCC 767<\/a>.<\/p>\n

31.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

32.<\/a> (2019) 7 SCC 62<\/a>.<\/p>\n

33.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

34.<\/a> (2022) 8 SCC 42<\/a>.<\/p>\n

35.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

36.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

37.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

38.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

39.<\/a> Law Commission of India, Report No. 246, Amendments to the Arbitration and Conciliation Act, 1996 (August 2014).<\/a><\/p>\n

40.<\/a> Arbitration and Conciliation Act, 1996, S. 9<\/a>.<\/p>\n

41.<\/a> Arbitration and Conciliation Act, 1996, S. 17.<\/a><\/p>\n

42.<\/a> Arbitration and Conciliation Act, 1996, S. 34<\/a>.<\/p>\n

43.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

44.<\/a> (2020) 12 SCC 767<\/a>.<\/p>\n

45.<\/a> Shapoorji Pallonji & Co. (P) Ltd.<\/span> v. Rattan India Power Ltd.<\/span>, 2021 SCC OnLine Del 3688.<\/a><\/p>\n

46.<\/a> (2022) 8 SCC 1<\/a>.<\/p>\n

47.<\/a> Arbitration and Conciliation Act, 1996, S. 11<\/a>.<\/p>\n

48.<\/a> (2013) 1 SCC 641<\/a>.<\/p>\n

49.<\/a> Cox and Kings Ltd.<\/span> v. SAP India (P) Ltd.<\/span>, (2022) 8 SCC 1<\/a>.<\/p>\n","protected":false},"excerpt":{"rendered":"

by Gunjan Chhabra*<\/p>\n","protected":false},"author":8808,"featured_media":308855,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[42503,1191],"tags":[10131,63346,42856,41994,63347,63345,34169],"class_list":["post-308761","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-legal-analysis","category-op-ed","tag-arbitration-and-conciliation-act","tag-global-commerce","tag-indian-arbitration","tag-law-commission-report","tag-mother-agreement","tag-recap-of-group-companies","tag-supreme-court-of-india"],"yoast_head":"\nRecap of Group Companies Doctrine in Indian Arbitration: Must Read Before Season 2 | SCC Times<\/title>\n<meta name=\"description\" content=\"Arbitration is an alternate dispute resolution mechanism, whereby the mode, manner, and choice of going through the route of arbitration\" \/>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Recap of Group Companies Doctrine in Indian Arbitration: Must Read Before Season 2\" \/>\n<meta property=\"og:description\" content=\"Arbitration is an alternate dispute resolution mechanism, whereby the mode, manner, and choice of going through the route of arbitration\" \/>\n<meta property=\"og:url\" content=\"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/\" \/>\n<meta property=\"og:site_name\" content=\"SCC Times\" \/>\n<meta property=\"article:publisher\" content=\"https:\/\/www.facebook.com\/scc.online\/\" \/>\n<meta property=\"article:published_time\" content=\"2023-12-09T03:30:30+00:00\" \/>\n<meta property=\"article:modified_time\" content=\"2023-12-10T03:58:39+00:00\" \/>\n<meta property=\"og:image\" content=\"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/12\/MicrosoftTeams-image-178.jpg\" \/>\n\t<meta property=\"og:image:width\" content=\"886\" \/>\n\t<meta property=\"og:image:height\" content=\"590\" \/>\n\t<meta property=\"og:image:type\" content=\"image\/jpeg\" \/>\n<meta name=\"author\" content=\"Bhumika Indulia\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:title\" content=\"Recap of Group Companies Doctrine in Indian Arbitration: Must Read Before Season 2\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"Bhumika Indulia\" \/>\n\t<meta name=\"twitter:label2\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"16 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\/\/schema.org\",\"@graph\":[{\"@type\":\"WebPage\",\"@id\":\"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/\",\"url\":\"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/\",\"name\":\"Recap of Group Companies Doctrine in Indian Arbitration: Must Read Before Season 2 | SCC Times\",\"isPartOf\":{\"@id\":\"https:\/\/www.scconline.com\/blog\/#website\"},\"primaryImageOfPage\":{\"@id\":\"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/#primaryimage\"},\"image\":{\"@id\":\"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/#primaryimage\"},\"thumbnailUrl\":\"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/12\/Recap-of-Group-Companies.webp\",\"datePublished\":\"2023-12-09T03:30:30+00:00\",\"dateModified\":\"2023-12-10T03:58:39+00:00\",\"author\":{\"@id\":\"https:\/\/www.scconline.com\/blog\/#\/schema\/person\/919ec47cc1b871b362af05740398033a\"},\"description\":\"Arbitration is an alternate dispute resolution mechanism, whereby the mode, manner, and choice of going through the route of arbitration\",\"breadcrumb\":{\"@id\":\"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/#breadcrumb\"},\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/\"]}]},{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/#primaryimage\",\"url\":\"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/12\/Recap-of-Group-Companies.webp\",\"contentUrl\":\"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/12\/Recap-of-Group-Companies.webp\",\"width\":886,\"height\":590,\"caption\":\"Recap of Group Companies\"},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\/\/www.scconline.com\/blog\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"Recap of Group Companies Doctrine in Indian Arbitration: Must Read Before Season 2\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\/\/www.scconline.com\/blog\/#website\",\"url\":\"https:\/\/www.scconline.com\/blog\/\",\"name\":\"SCC Times\",\"description\":\"Bringing you the Best Analytical Legal News\",\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\/\/www.scconline.com\/blog\/?s={search_term_string}\"},\"query-input\":{\"@type\":\"PropertyValueSpecification\",\"valueRequired\":true,\"valueName\":\"search_term_string\"}}],\"inLanguage\":\"en-US\"},{\"@type\":\"Person\",\"@id\":\"https:\/\/www.scconline.com\/blog\/#\/schema\/person\/919ec47cc1b871b362af05740398033a\",\"name\":\"Bhumika Indulia\",\"image\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\/\/www.scconline.com\/blog\/#\/schema\/person\/image\/\",\"url\":\"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2021\/04\/Me-150x150.jpg\",\"contentUrl\":\"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2021\/04\/Me-150x150.jpg\",\"caption\":\"Bhumika Indulia\"},\"url\":\"https:\/\/www.scconline.com\/blog\/post\/author\/editor_1\/\"}]}<\/script>\n<!-- \/ Yoast SEO Premium plugin. -->","yoast_head_json":{"title":"Recap of Group Companies Doctrine in Indian Arbitration: Must Read Before Season 2 | SCC Times","description":"Arbitration is an alternate dispute resolution mechanism, whereby the mode, manner, and choice of going through the route of arbitration","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/","og_locale":"en_US","og_type":"article","og_title":"Recap of Group Companies Doctrine in Indian Arbitration: Must Read Before Season 2","og_description":"Arbitration is an alternate dispute resolution mechanism, whereby the mode, manner, and choice of going through the route of arbitration","og_url":"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/","og_site_name":"SCC Times","article_publisher":"https:\/\/www.facebook.com\/scc.online\/","article_published_time":"2023-12-09T03:30:30+00:00","article_modified_time":"2023-12-10T03:58:39+00:00","og_image":[{"width":886,"height":590,"url":"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/12\/MicrosoftTeams-image-178.jpg","type":"image\/jpeg"}],"author":"Bhumika Indulia","twitter_card":"summary_large_image","twitter_title":"Recap of Group Companies Doctrine in Indian Arbitration: Must Read Before Season 2","twitter_misc":{"Written by":"Bhumika Indulia","Est. reading time":"16 minutes"},"schema":{"@context":"https:\/\/schema.org","@graph":[{"@type":"WebPage","@id":"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/","url":"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/","name":"Recap of Group Companies Doctrine in Indian Arbitration: Must Read Before Season 2 | SCC Times","isPartOf":{"@id":"https:\/\/www.scconline.com\/blog\/#website"},"primaryImageOfPage":{"@id":"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/#primaryimage"},"image":{"@id":"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/#primaryimage"},"thumbnailUrl":"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/12\/Recap-of-Group-Companies.webp","datePublished":"2023-12-09T03:30:30+00:00","dateModified":"2023-12-10T03:58:39+00:00","author":{"@id":"https:\/\/www.scconline.com\/blog\/#\/schema\/person\/919ec47cc1b871b362af05740398033a"},"description":"Arbitration is an alternate dispute resolution mechanism, whereby the mode, manner, and choice of going through the route of arbitration","breadcrumb":{"@id":"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/#breadcrumb"},"inLanguage":"en-US","potentialAction":[{"@type":"ReadAction","target":["https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/"]}]},{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/#primaryimage","url":"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/12\/Recap-of-Group-Companies.webp","contentUrl":"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/12\/Recap-of-Group-Companies.webp","width":886,"height":590,"caption":"Recap of Group Companies"},{"@type":"BreadcrumbList","@id":"https:\/\/www.scconline.com\/blog\/post\/2023\/12\/09\/recap-of-group-companies-doctrine-in-indian-arbitration-must-read-before-season-2\/#breadcrumb","itemListElement":[{"@type":"ListItem","position":1,"name":"Home","item":"https:\/\/www.scconline.com\/blog\/"},{"@type":"ListItem","position":2,"name":"Recap of Group Companies Doctrine in Indian Arbitration: Must Read Before Season 2"}]},{"@type":"WebSite","@id":"https:\/\/www.scconline.com\/blog\/#website","url":"https:\/\/www.scconline.com\/blog\/","name":"SCC Times","description":"Bringing you the Best Analytical Legal News","potentialAction":[{"@type":"SearchAction","target":{"@type":"EntryPoint","urlTemplate":"https:\/\/www.scconline.com\/blog\/?s={search_term_string}"},"query-input":{"@type":"PropertyValueSpecification","valueRequired":true,"valueName":"search_term_string"}}],"inLanguage":"en-US"},{"@type":"Person","@id":"https:\/\/www.scconline.com\/blog\/#\/schema\/person\/919ec47cc1b871b362af05740398033a","name":"Bhumika Indulia","image":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/www.scconline.com\/blog\/#\/schema\/person\/image\/","url":"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2021\/04\/Me-150x150.jpg","contentUrl":"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2021\/04\/Me-150x150.jpg","caption":"Bhumika Indulia"},"url":"https:\/\/www.scconline.com\/blog\/post\/author\/editor_1\/"}]}},"jetpack_featured_media_url":"https:\/\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/12\/Recap-of-Group-Companies.webp","jetpack_sharing_enabled":true,"jetpack-related-posts":[{"id":275917,"url":"https:\/\/www.scconline.com\/blog\/post\/2022\/10\/19\/the-group-of-companies-doctrine-defending-an-endangered-species-of-the-indian-arbitration-law\/","url_meta":{"origin":308761,"position":0},"title":"The Group of Companies Doctrine: Defending an Endangered Species of the Indian Arbitration Law","author":"Bhumika Indulia","date":"October 19, 2022","format":false,"excerpt":"by Dhruv S. Patel\u2020","rel":"","context":"In "Op Eds"","block_context":{"text":"Op Eds","link":"https:\/\/www.scconline.com\/blog\/post\/category\/op-ed\/legal-analysis\/"},"img":{"alt_text":"","src":"https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2022\/10\/MicrosoftTeams-image-150-1.jpg?resize=350%2C200&ssl=1","width":350,"height":200,"srcset":"https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2022\/10\/MicrosoftTeams-image-150-1.jpg?resize=350%2C200&ssl=1 1x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2022\/10\/MicrosoftTeams-image-150-1.jpg?resize=525%2C300&ssl=1 1.5x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2022\/10\/MicrosoftTeams-image-150-1.jpg?resize=700%2C400&ssl=1 2x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2022\/10\/MicrosoftTeams-image-150-1.jpg?resize=1050%2C600&ssl=1 3x"},"classes":[]},{"id":249713,"url":"https:\/\/www.scconline.com\/blog\/post\/2021\/06\/14\/arbitration-agreement\/","url_meta":{"origin":308761,"position":1},"title":"Can a non-signatory or confirming party be made party to the arbitration? The position of non-signatory in an arbitration agreement","author":"Editor","date":"June 14, 2021","format":false,"excerpt":"by Arush Agarwal\u2020 and Bhavya Gupta\u2020\u2020","rel":"","context":"In "Op Eds"","block_context":{"text":"Op Eds","link":"https:\/\/www.scconline.com\/blog\/post\/category\/op-ed\/legal-analysis\/"},"img":{"alt_text":"","src":"https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2021\/06\/MicrosoftTeams-image-6.png?resize=350%2C200&ssl=1","width":350,"height":200,"srcset":"https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2021\/06\/MicrosoftTeams-image-6.png?resize=350%2C200&ssl=1 1x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2021\/06\/MicrosoftTeams-image-6.png?resize=525%2C300&ssl=1 1.5x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2021\/06\/MicrosoftTeams-image-6.png?resize=700%2C400&ssl=1 2x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2021\/06\/MicrosoftTeams-image-6.png?resize=1050%2C600&ssl=1 3x"},"classes":[]},{"id":287548,"url":"https:\/\/www.scconline.com\/blog\/post\/2023\/03\/23\/the-group-of-companies-doctrine-in-india-antithetical-to-free-consent\/","url_meta":{"origin":308761,"position":2},"title":"The Group of Companies Doctrine in India \u2013 Antithetical to Free Consent?","author":"Bhumika Indulia","date":"March 23, 2023","format":false,"excerpt":"by Kingshuk Banerjee\u2020 and Nidhi Kulkarni\u2020\u2020 Cite as: 2023 SCC OnLine Blog Exp 32","rel":"","context":"In "Experts Corner"","block_context":{"text":"Experts Corner","link":"https:\/\/www.scconline.com\/blog\/post\/category\/experts_corner\/"},"img":{"alt_text":"Group of Companies Doctrine","src":"https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/03\/MicrosoftTeams-image-842.png?resize=350%2C200&ssl=1","width":350,"height":200,"srcset":"https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/03\/MicrosoftTeams-image-842.png?resize=350%2C200&ssl=1 1x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/03\/MicrosoftTeams-image-842.png?resize=525%2C300&ssl=1 1.5x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/03\/MicrosoftTeams-image-842.png?resize=700%2C400&ssl=1 2x"},"classes":[]},{"id":272575,"url":"https:\/\/www.scconline.com\/blog\/post\/2022\/09\/01\/cox-and-kings-and-the-group-of-companies-conundrum\/","url_meta":{"origin":308761,"position":3},"title":"Cox and Kings and the “Group of Companies” Conundrum","author":"Bhumika Indulia","date":"September 1, 2022","format":false,"excerpt":"by Priyanshu Shrivastava\u2020 and Fatema Kinkhabwala\u2020\u2020","rel":"","context":"In "Op Eds"","block_context":{"text":"Op Eds","link":"https:\/\/www.scconline.com\/blog\/post\/category\/op-ed\/legal-analysis\/"},"img":{"alt_text":"","src":"https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2022\/08\/MicrosoftTeams-image-26-1.jpg?resize=350%2C200&ssl=1","width":350,"height":200,"srcset":"https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2022\/08\/MicrosoftTeams-image-26-1.jpg?resize=350%2C200&ssl=1 1x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2022\/08\/MicrosoftTeams-image-26-1.jpg?resize=525%2C300&ssl=1 1.5x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2022\/08\/MicrosoftTeams-image-26-1.jpg?resize=700%2C400&ssl=1 2x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2022\/08\/MicrosoftTeams-image-26-1.jpg?resize=1050%2C600&ssl=1 3x"},"classes":[]},{"id":293508,"url":"https:\/\/www.scconline.com\/blog\/post\/2023\/05\/31\/tangling-the-non-signatories-without-consent-rethinking-the-group-of-companies-doctrine\/","url_meta":{"origin":308761,"position":4},"title":"Tangling the Non-Signatories without \u201cConsent\u201d: Rethinking the \u201cGroup of Companies\u201d Doctrine","author":"Editor","date":"May 31, 2023","format":false,"excerpt":"by Mohammad Atik Saiyed\u2020 and Shukla Pooja Sunilkumar\u2020\u2020","rel":"","context":"In "Op Eds"","block_context":{"text":"Op Eds","link":"https:\/\/www.scconline.com\/blog\/post\/category\/op-ed\/legal-analysis\/"},"img":{"alt_text":"group of companies","src":"https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/05\/group-of-companies.webp?resize=350%2C200&ssl=1","width":350,"height":200,"srcset":"https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/05\/group-of-companies.webp?resize=350%2C200&ssl=1 1x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/05\/group-of-companies.webp?resize=525%2C300&ssl=1 1.5x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/05\/group-of-companies.webp?resize=700%2C400&ssl=1 2x"},"classes":[]},{"id":286477,"url":"https:\/\/www.scconline.com\/blog\/post\/2023\/03\/06\/non-signatory-parties-can-be-subjected-to-arbitration-in-accordance-with-doctrine-of-group-of-companies-delhi-high-court-legal-news-legal-research-updates\/","url_meta":{"origin":308761,"position":5},"title":"Non-signatory parties can be subjected to arbitration in accordance with Doctrine of Group of Companies: Delhi High Court","author":"Editor","date":"March 6, 2023","format":false,"excerpt":"Delhi High Court held that non-signatory or third party could be subjected to arbitration proceedings without their prior consent. It was necessary to examine the touchstone of direct relationship of signatory parties to the arbitration agreement, forming part of a composite transaction.","rel":"","context":"In "Case Briefs"","block_context":{"text":"Case Briefs","link":"https:\/\/www.scconline.com\/blog\/post\/category\/casebriefs\/"},"img":{"alt_text":"Delhi High Court","src":"https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/02\/MicrosoftTeams-image-472.png?resize=350%2C200&ssl=1","width":350,"height":200,"srcset":"https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/02\/MicrosoftTeams-image-472.png?resize=350%2C200&ssl=1 1x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/02\/MicrosoftTeams-image-472.png?resize=525%2C300&ssl=1 1.5x, https:\/\/i0.wp.com\/www.scconline.com\/blog\/wp-content\/uploads\/2023\/02\/MicrosoftTeams-image-472.png?resize=700%2C400&ssl=1 2x"},"classes":[]}],"amp_enabled":true,"_links":{"self":[{"href":"https:\/\/www.scconline.com\/blog\/wp-json\/wp\/v2\/posts\/308761","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.scconline.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.scconline.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.scconline.com\/blog\/wp-json\/wp\/v2\/users\/8808"}],"replies":[{"embeddable":true,"href":"https:\/\/www.scconline.com\/blog\/wp-json\/wp\/v2\/comments?post=308761"}],"version-history":[{"count":0,"href":"https:\/\/www.scconline.com\/blog\/wp-json\/wp\/v2\/posts\/308761\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.scconline.com\/blog\/wp-json\/wp\/v2\/media\/308855"}],"wp:attachment":[{"href":"https:\/\/www.scconline.com\/blog\/wp-json\/wp\/v2\/media?parent=308761"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.scconline.com\/blog\/wp-json\/wp\/v2\/categories?post=308761"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.scconline.com\/blog\/wp-json\/wp\/v2\/tags?post=308761"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}