On 17 December 2025, a learned Single Judge of the Bombay High Court, Justice Somasekhar Sundaresan, delivered a crisp but far-reaching ruling in Reliance Naval & Engineering Ltd. v. Afcons Infrastructure Ltd., Interim Application (L) No. 9646 of 2024 in Arbitration Petition No. 1755 of 2015. The judgment unpacks the intersection of two statutory streams the Arbitration & Conciliation Act, 1996 and the Insolvency & Bankruptcy Code, 2016 when an award-creditor has already pocketed a court-deposit, only to discover later that the approved resolution plan of the corporate debtor has surgically reduced the multi-crore claim to a symbolic rupee. The Court held that money which was merely in custodia legis must retrace its steps; retention…

