In this episode of The Fountain Court Podcast, we present a live-streamed discussion from June 2025, jointly hosted by Fountain Court and Mumbai Centre for International Arbitration (MCIA). The conversation explores the evolving legal landscapes in two key arbitration jurisdictions—India and the UK—against the backdrop of significant recent reforms.
Chaired by Leigh-Ann Mulcahy KC, a leading silk at Fountain Court, the panel discusses pivotal developments including the UK Arbitration Act 2025, the liberalisation of India’s legal market, amendments to the MCIA Arbitration Rules, and broader efforts in both jurisdictions to enhance the efficiency and global appeal of arbitration.
Joining Leigh-Ann for this insightful session are:
• Alexander Milner KC: A silk at Fountain Court with a broad practice in litigation and international arbitration, particularly in banking, energy, aviation, and civil fraud. Alex has acted in numerous India-related disputes, including a current arbitration concerning the manufacture and distribution of COVID-19 vaccines for the Indian market. He has also sat as arbitrator in London, Singapore, Hong Kong, and Moscow.
• Zal Andhyarujina SA: A door tenant at Fountain Court and a senior advocate in India. Zal practises before the Bombay High Court and the Supreme Court, with a focus on high-value international and domestic arbitrations. His areas of expertise include shareholder and company disputes, banking, financial services, real estate, and intellectual property.
• Neeti Sachdeva: Registrar and Secretary General of MCIA, India’s leading arbitral institution. Neeti is a regular arbitrator, teaches international arbitration at three National Law Universities in India, and serves as Secretary and Board Member of the CIArb India Branch.
• Abhijit Mukhopadhyay: President (Legal) and General Counsel (Europe) at the Hinduja Group. Based in London since 2001, Abhijit is widely recognised as a leading Indian General Counsel. He has held senior roles with global arbitration bodies including the ICC and CPR, and has played a key role in promoting arbitration in India.
• Sudeshna Guha Roy: Partner at Saraf & Partners in Mumbai. Sudeshna specialises in both domestic and international arbitrations, with particular experience in shareholder disputes, investor exits, infrastructure and real estate matters, and enforcement proceedings. She also advises on cross-border insolvency issues.
This episode offers a comparative, practice-oriented look at how legal frameworks in both the UK and India are evolving to meet the demands of modern dispute resolution.
For more information on Fountain Court’s Indian practice, please visit https://www.fountaincourt.co.uk/international/asia-pacific/.
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In this episode of The Fountain Court Podcast, we present a live-streamed discussion from June 2025, jointly hosted by Fountain Court and Mumbai Centre for International Arbitration (MCIA). The conversation explores the evolving legal landscapes in two key arbitration jurisdictions—India and the UK—against the backdrop of significant recent reforms.
Chaired by Leigh-Ann Mulcahy KC, a leading silk at Fountain Court, the panel discusses pivotal developments including the UK Arbitration Act 2025, the liberalisation of India’s legal market, amendments to the MCIA Arbitration Rules, and broader efforts in both jurisdictions to enhance the efficiency and global appeal of arbitration.
Joining Leigh-Ann for this insightful session are:
• Alexander Milner KC: A silk at Fountain Court with a broad practice in litigation and international arbitration, particularly in banking, energy, aviation, and civil fraud. Alex has acted in numerous India-related disputes, including a current arbitration concerning the manufacture and distribution of COVID-19 vaccines for the Indian market. He has also sat as arbitrator in London, Singapore, Hong Kong, and Moscow.
• Zal Andhyarujina SA: A door tenant at Fountain Court and a senior advocate in India. Zal practises before the Bombay High Court and the Supreme Court, with a focus on high-value international and domestic arbitrations. His areas of expertise include shareholder and company disputes, banking, financial services, real estate, and intellectual property.
• Neeti Sachdeva: Registrar and Secretary General of MCIA, India’s leading arbitral institution. Neeti is a regular arbitrator, teaches international arbitration at three National Law Universities in India, and serves as Secretary and Board Member of the CIArb India Branch.
• Abhijit Mukhopadhyay: President (Legal) and General Counsel (Europe) at the Hinduja Group. Based in London since 2001, Abhijit is widely recognised as a leading Indian General Counsel. He has held senior roles with global arbitration bodies including the ICC and CPR, and has played a key role in promoting arbitration in India.
• Sudeshna Guha Roy: Partner at Saraf & Partners in Mumbai. Sudeshna specialises in both domestic and international arbitrations, with particular experience in shareholder disputes, investor exits, infrastructure and real estate matters, and enforcement proceedings. She also advises on cross-border insolvency issues.
This episode offers a comparative, practice-oriented look at how legal frameworks in both the UK and India are evolving to meet the demands of modern dispute resolution.
For more information on Fountain Court’s Indian practice, please visit https://www.fountaincourt.co.uk/international/asia-pacific/.
S4: Episode 2 - Arbitrability: can jurisdictions police the public policy of other jurisdictions?
The Fountain Court Chambers Podcast
1 hour 8 minutes 50 seconds
1 year ago
S4: Episode 2 - Arbitrability: can jurisdictions police the public policy of other jurisdictions?
This is the third episode of the fourth series of The Fountain Court Podcast. The episode is moderated by Darius Chan, a door tenant at Fountain Court and is a recording of a virtual panel discussion hosted in September 2023, marking the annual Christopher Bathurst Prizegiving.
The episode features an internationally focused discussion on the topic of ‘Arbitrability: Can Jurisdictions Police the Public Policy of Other Jurisdictions?’. This was the topic that this year’s applicants for the Christopher Bathurst Prize were asked to write about. The Panel discussed the Court of Appeal case of Anupam Mittal v Westbridge Ventures II Investment Holdings [2023] SGCA 1 and explored to what extent there was or could be a harmonised approach between different jurisdictions on the issue of arbitrability.
Adopting a comparative law approach, our panel included:
Yuet Min Foo: Based in Singapore, Yuet Min is a director at Drew & Napier. She advises clients on civil disputes relating to a wide range of commercial contracts. Many of Yuet Min’s matters involve SIAC and ICC arbitrations as well as arbitration-related Court proceedings.
Gaurav Pachnanda SA: A Senior Advocate in India and a Barrister in England and Wales. Gaurav is an experienced commercial lawyer, whose practice includes a wide range of commercial litigation, arbitration and advisory work, with a significant multi-jurisdictional component. He is based in New Delhi but practices as a Door Tenant at Fountain Court.
Professor Luca G Radicati di Brozolo: A door tenant at Fountain Court and the founding partner of Arblit, an arbitration and litigation boutique in Milan. Luca’s current practice focuses on international arbitration and litigation. He has vast experience in commercial and investor-State arbitrations across many different sectors and seats and under a variety of rules and governing laws.
Nik Yeo: An experienced trial and appellate advocate at Fountain Court. Nik has a diverse practice including fraud, fintech and finance. He is regularly consulted on questions of legal professional privilege, conflict of laws and jurisdiction. Described as a “powerful and persuasive advocate”, Nik was awarded the “Technology, Data & Crypto Junior of the Year” at The Legal 500‘s Bar Awards 2023.
For more information on Fountain Court’s international experience, please see here https://www.fountaincourt.co.uk/international/.
The Fountain Court Chambers Podcast
In this episode of The Fountain Court Podcast, we present a live-streamed discussion from June 2025, jointly hosted by Fountain Court and Mumbai Centre for International Arbitration (MCIA). The conversation explores the evolving legal landscapes in two key arbitration jurisdictions—India and the UK—against the backdrop of significant recent reforms.
Chaired by Leigh-Ann Mulcahy KC, a leading silk at Fountain Court, the panel discusses pivotal developments including the UK Arbitration Act 2025, the liberalisation of India’s legal market, amendments to the MCIA Arbitration Rules, and broader efforts in both jurisdictions to enhance the efficiency and global appeal of arbitration.
Joining Leigh-Ann for this insightful session are:
• Alexander Milner KC: A silk at Fountain Court with a broad practice in litigation and international arbitration, particularly in banking, energy, aviation, and civil fraud. Alex has acted in numerous India-related disputes, including a current arbitration concerning the manufacture and distribution of COVID-19 vaccines for the Indian market. He has also sat as arbitrator in London, Singapore, Hong Kong, and Moscow.
• Zal Andhyarujina SA: A door tenant at Fountain Court and a senior advocate in India. Zal practises before the Bombay High Court and the Supreme Court, with a focus on high-value international and domestic arbitrations. His areas of expertise include shareholder and company disputes, banking, financial services, real estate, and intellectual property.
• Neeti Sachdeva: Registrar and Secretary General of MCIA, India’s leading arbitral institution. Neeti is a regular arbitrator, teaches international arbitration at three National Law Universities in India, and serves as Secretary and Board Member of the CIArb India Branch.
• Abhijit Mukhopadhyay: President (Legal) and General Counsel (Europe) at the Hinduja Group. Based in London since 2001, Abhijit is widely recognised as a leading Indian General Counsel. He has held senior roles with global arbitration bodies including the ICC and CPR, and has played a key role in promoting arbitration in India.
• Sudeshna Guha Roy: Partner at Saraf & Partners in Mumbai. Sudeshna specialises in both domestic and international arbitrations, with particular experience in shareholder disputes, investor exits, infrastructure and real estate matters, and enforcement proceedings. She also advises on cross-border insolvency issues.
This episode offers a comparative, practice-oriented look at how legal frameworks in both the UK and India are evolving to meet the demands of modern dispute resolution.
For more information on Fountain Court’s Indian practice, please visit https://www.fountaincourt.co.uk/international/asia-pacific/.
