Bombay HC rules in favour of IMAX, clears way to enforce arbitral awards against E-City

Mumbai : The Bombay High Court has ruled in favour of IMAX Corporation in its long-running arbitration dispute with Subhash Chandra’s E-City Entertainment, clearing the way for enforcement of foreign arbitral awards against the company.

A division bench of justices Advait M Sethna and M S Sonak partly allowed IMAX’s appeal and set aside a single judge order dated October 24, 2024, which had refused to recognise and enforce three foreign arbitral awards passed between 2006 and 2008 by an ICC Arbitral Tribunal.

In an order dated December 30, 2025, the bench held that the foreign awards in favour of IMAX are enforceable in India and will be deemed as decrees of the court. It rejected all objections raised by E-City Entertainment to their enforcement.

The dispute dates back to September 28, 2000, when IMAX entered into a master agreement with E-City Entertainment for the lease of six IMAX systems for 20 years, extendable by 10 years more. Disputes arose during 2003-2004, following which IMAX initiated arbitration before the ICC in London, claiming $18.3 million plus interest.

The ICC tribunal ruled in favour of IMAX and directed E-City Entertainment to pay $11.3 million along with interest of $2,512.60 per se from October 1, 2007. As of March 31, 2018, the total amount payable had risen to $20.86 million.

The high court remanded the matter to the single judge bench of Justice Bharati Dangre to proceed with execution of the awards against E-City Entertainment and against its properties and assets that were diverted to group entities under schemes of arrangement in 2007.

However, the bench clarified that no independent execution can be levied against E-City Entertainment (India) Pvt Ltd, ECity Projects Construction Pvt Ltd or ECity Investments and Holdings Company, as they are not personally liable for the awards. The second and third entities can be proceeded against only to the extent of assets transferred to them by E-City.

Until further orders, E-City Entertainment has been restrained from dealing with its properties and assets, including bank accounts. Similar restrictions apply to the assets transferred to the second and third respondents.

The court noted that E-City Entertainment delayed enforcement of the awards for nearly two decades and for diverting assets worth ₹210 crore during the pendency of arbitration proceedings. Quoting the Supreme Court’s observations in the Vijay Karia case, the bench said the company was indulging in speculative litigation to frustrate enforcement.

The court imposed costs of ₹5 lakh on ECity Entertainment, payable to IMAX within four weeks.

All parties have been directed to appear before the executing court on January 19, 2026. The bench declined to stay the operation of its order, noting that the respondents have sufficient time to challenge the judgment. While E-City Entertainment India and E-City Projects Constructions objected to the maintainability of Imax's appeal, the bench noted that the coordinate bench of the court, which then comprised justices A S Chandurkar and M M Sathaye, rejected the objections regarding maintainability and admitted this appeal.