Post-award interest under arbitration law stops when the full award amount is deposited in court as payment.

Under Section 31(7)(b) of the Arbitration and Conciliation Act, 1996, where an arbitral award does not itself provide for post-award interest, the statutory rate applies until payment. The Supreme Court treated deposit of the entire award amount in court as payment because it amounted to satisfaction of the award and extinguishment of liability. On that basis, post-award interest ceased from the date of the deposit, and no further interest accrued thereafter.

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Issues: Whether deposit of the entire award amount in court amounts to payment for the purpose of post-award interest, thereby stopping liability for interest under Section 31(7)(b) of the Arbitration and Conciliation Act, 1996.

Analysis: The award did not exercise discretion on post-award interest, so the statutory rate of 18% per annum applied from the date of the award until payment. The question was whether deposit of the award amount in the High Court satisfied the award and extinguished the obligation to continue paying interest. Payment, in this context, was understood as satisfaction of the award and extinguishment of liability. Once the entire award amount was deposited in court on 24 May 2001, the amount stood credited to the decree-holder and the liability for further post-award interest ceased from that date.

Conclusion: The deposit in court constituted payment, and the appellants were liable to pay post-award interest only up to 24 May 2001, not thereafter.

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