Arbitral award interest continues until actual payment, and a collateral undertaking does not extinguish accrued liability.

An arbitral award providing future interest at 12% per annum until actual payment continues to govern the parties' liability until realization. A separate undertaking given in collateral proceedings, and payment made pursuant to it, did not cut off the accrued interest for the intervening period because the award was not expressly satisfied in full. The decree holder was therefore entitled to the balance interest from 27.05.2019 to 19.02.2020, with further interest at 12% per annum until realization.

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Issues: Whether, after the judgment debtor paid the amount directed pursuant to proceedings before the Supreme Court, the decree holder was still entitled to claim the balance interest accrued on the arbitral award till the actual date of payment.

Analysis: The award expressly provided for payment of the awarded sum together with future interest at 12% per annum from the date of the award till the date of payment. The payment made on 19.02.2020 did not include interest for the period after 27.05.2019, and the Court held that the undertaking given before the Supreme Court was only to secure payment of the amount then claimed, not to curtail the contractual and adjudicatory obligation under the award to pay interest till actual realization. The earlier direction and the subsequent compliance did not extinguish the accrued liability for the intervening period.

Conclusion: The decree holder remained entitled to the balance interest from 27.05.2019 till 19.02.2020, and the judgment debtor was directed to pay the same with further interest at 12% per annum till realization.

Ratio Decidendi: Where an arbitral award grants future interest till the date of actual payment, liability for interest continues until realization and is not cut down by a separate undertaking or payment made pursuant to collateral proceedings unless the award is expressly satisfied in full.

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