Tag: SC upholds courts’ power to modify arbitral awards under limited circumstances

UPSC DAILY CURRENT AFFAIRS (1st May,2025) Disproportionate Burden on Women in Risk Society Syllabus: GS1/ Society Context In a risk society shaped by modern crises, women disproportionately bear the burden due to existing gender inequalities and caregiving roles. What is Risk Society? The term ‘risk society’ describes a shift from an industrial society to one increasingly shaped by uncertainty and hazards created by technological and environmental developments. Industrial societies brought prosperity but also created complex, global risks—like climate change and pandemics—that stem from human progress rather than natural causes. The term risk society was coined by German sociologist Ulrich Beck in his 1986 book Risk Society: Towards a New Modernity. Gendered Impacts in the Risk Society Environmental and Health Risks: Water collection duties of women expose them to contaminated sources, increasing vulnerability to water borne diseases. Use of solid fuels for cooking leads to chronic respiratory diseases due to indoor air pollution. Gender norms such as eating last or less nutritious food during scarcity worsen health outcomes. As per NFHS-5 (2019–21), 57% of Indian women suffer from anaemia, compared to 25% of men. Economic Vulnerability: Women are more likely to work in the informal sector, with limited job security or savings. They also have limited ownership of land and property, reducing post-disaster recovery ability. Lower access to credit and institutional support, making them more dependent and less resilient during crises. Unpaid care work places additional physical and emotional strain. Political and Institutional Exclusion: Women’s perspectives are often underrepresented in decision-making on disaster preparedness, climate policies, and health systems. This results in: Gender-blind policies or insufficiently responsive to women’s needs. Missed opportunities to harness women’s local knowledge and community networks for risk mitigation. Way Ahead Gender Mainstreaming: Risk mitigation strategies, including climate resilience and pandemic responses, must include a gender perspective. Economic Empowerment: Land rights, access to finance, and social protection schemes must prioritise women to strengthen recovery capacity. Investing in Care Infrastructure: Recognising and supporting unpaid care work through services like crèches, health insurance, and community kitchens can reduce women’s disproportionate burden. Participation in Governance: From disaster management authorities to local planning bodies, women’s representation must be institutionalised. 50 Years of End of the Vietnam War Syllabus: GS1/World History Context The Vietnamese celebrated the 50th anniversary of the end of the Vietnam War. Background Vietnam had been a French colony since the mid-19th century, part of French Indochina (along with Laos and Cambodia). During World War II, the Japanese occupied Vietnam but allowed the French to maintain some control. After Japan’s defeat in 1945, Ho Chi Minh, leader of the Viet Minh (League for the Independence of Vietnam), declared Vietnam’s independence in 1945. The French, however, tried to reassert colonial control, leading to the First Indochina War. The Vietnam War The Vietnam War — also known as the Second Indochina War — was a prolonged conflict from 1955 to 1975 between North Vietnam (Communist) and South Vietnam (anti-Communist), with heavy U.S. involvement on the side of the South. North Vietnam: Led by Ho Chi Minh and the Communist Party, supported by the Soviet Union, China, and other communist allies. South Vietnam: Initially led by Ngo Dinh Diem, later by various leaders after multiple coups. Supported by the United States, South Korea, Australia, Thailand, and others. Reasons for the War Division of Vietnam: After the First Indochina War, the 1954 Geneva Accords temporarily divided Vietnam at the 17th parallel into North and South Vietnam. Cold War tensions: The U.S. saw the spread of communism in Asia as a threat (the Domino Theory). Internal conflict: The Communist-aligned Viet Cong insurgency in the South sought to reunify Vietnam under communist rule. Key Phases Advisory Phase (1955–1963): The U.S. provided military advisers and aid to support the South Vietnamese government. Ngo Dinh Diem’s regime became increasingly unpopular and was overthrown in a U.S.-backed coup in 1963. Escalation (1964–1969): Gulf of Tonkin Incident (1964): Alleged attacks on U.S. ships led to congressional approval for expanded U.S. involvement. U.S. troop levels peaked at over 500,000 by 1969. Major battles: Tet Offensive (1968), Battle of Hue, Khe Sanh. Heavy use of napalm, Agent Orange, and carpet bombing sparked international outrage. Withdrawal (1969–1973): Under President Richard Nixon, the U.S. began “Vietnamization” — training South Vietnamese forces to take over the war. U.S. forces gradually withdrew; the Paris Peace Accords were signed in 1973. Final Collapse (1973–1975): Fighting continued after U.S. withdrawal. Fall of Saigon (April 30, 1975): North Vietnamese forces captured the capital of South Vietnam, ending the war. Vietnam was reunified under communist control as the Socialist Republic of Vietnam. Agent Orange– Agent Orange was a powerful herbicide used by the United States military during the Vietnam War as part of Operation Ranch Hand (1961–1971). – It became one of the most controversial aspects of the war due to its devastating health and environmental effects.1. The manufacturing process of 2,4,5-T created a dangerous dioxin contaminant called TCDD, one of the most toxic chemicals.– The U.S. military used Agent Orange to:1. Defoliate forests and jungles to reduce enemy cover (especially for the Viet Cong).2. Destroy crops used to feed North Vietnamese forces.– Over 20 million gallons of herbicides were sprayed across South Vietnam, particularly in dense jungles and rural farmlands.– Aftermath: 1. Agent Orange remains a symbol of the war’s human and moral cost.2. Programs by the Vietnamese Red Cross, USAID, and international NGOs are working to support victims and clean up the environment.3. Many advocate for continued support, justice, and recognition of all those affected. Cabinet Approves Caste Enumeration in Upcoming Census Syllabus: GS2/Governance Context Recently, the Cabinet Committee on Political Affairs (CCPA), chaired by Prime Minister of India, has decided to include caste enumeration in the upcoming Census exercise, marking a significant shift in India’s approach to demographic data collection. Caste Based Enumeration Historical Perspective: The last caste-based enumeration in India was carried out in 1931 under British rule, recording 4,147 distinct castes. Although caste details were gathered in 1941, they were never published due to the outbreak of World War II. Post-Independence, only Scheduled Castes (SCs) and Scheduled Tribes (STs) have been counted in the decennial Census. In 1961 Directive, the Union Government authorized states to conduct their own surveys to identify OBCs (Other Backward Classes). In 2011, Socio-Economic Caste Census was conducted to obtain data about socio-economic status of various communities. Constitutional Basis for the Decision Union Subject: As per Article 246 of the Constitution of India, the Census is a Union subject, listed in the Union List under the Seventh Schedule. It ensures that caste enumeration, conducted as part of the main Census, will have a uniform and transparent framework across the country. The Census Act, 1948 provides the legal framework for conducting population censuses in India. It outlines the procedures, duties, and penalties associated with census operations. Significance of Caste Enumeration Digital Census: The next Census will be conducted in digital mode, with respondents having the option to fill the questionnaire via a mobile application. A new column for caste enumeration will be added, featuring a drop-down code directory for easy selection. Data-Driven Policy Making: Comprehensive caste data will enable evidence-based governance, ensuring fair representation in education, employment, and welfare programs. It will help refine reservation policies. It will aid in the implementation of the 33% reservation for women in Parliament and State Assemblies. Addressing Socio-Economic Disparities: The data will provide insights into economic inequalities among caste groups, aiding in targeted development programs. Judicial Demand: The Supreme Court’s judgment in the Indra Sawhney case established that a state’s conclusion regarding the “backwardness” of a group must be founded on proper assessment and objective evaluation. Concerns Related to Caste Enumeration Potential for Political Exploitation: Critics argue that caste enumeration could be used as a political tool to influence electoral strategies. There are concerns that state-level caste surveys have lacked transparency and were conducted with political motivations. Risk of Deepening Social Divisions: Some fear that caste enumeration may reinforce caste identities, leading to fragmentation rather than inclusivity. The debate over caste-based reservations could intensify, creating social tensions. Challenges in Implementation: Ensuring accurate data collection without manipulation or misrepresentation remains a challenge. The methodology for caste classification must be transparent and scientifically validated. Conclusion The inclusion of caste enumeration in the next Census is a landmark decision that promises to reshape India’s socio-political landscape. By providing detailed data on caste demographics, the government aims to address inequalities and foster inclusive development. As the Census unfolds, its impact on policy-making and societal dynamics will be closely watched. Right To Digital Access Part of Article 21 Syllabus: GS2/ Polity and Governance Context The Supreme court emphasized that digital access is a crucial component of the Right to Life under Article 21. Background The judgment was based on a petition filed by a group of acid attack survivors. They raised concerns about how disabled people, including acid attack victims, find it nearly impossible to successfully complete the digital KYC processes, which include visual tasks. Supreme Court Ruling The court said that the state has an obligation to provide an inclusive digital ecosystem to the marginalised, underprivileged, vulnerable, disabled, and historically-excluded sections of society. Directive to Improve KYC Accessibility: The Court mandated that alternative verification mechanisms must be introduced for those unable to blink or use facial recognition. It also called for full compliance with Section 46 of the Rights of Persons with Disabilities (RPwD) Act, 2016, which mandates accessibility in electronic and print media. Websites, mobile applications, and digital platforms must be made compliant with universal accessibility standards. The state’s obligations under Article 21, with Articles 14, 15 and 38 of the Constitution, must encompass the responsibility to ensure that digital infrastructure, government portals, and financial technologies are universally accessible. Article 21 of the Indian Constitution No person shall be deprived of his life or personal liberty except according to procedure established by law. Article 21 is part of the Fundamental Rights, Part III of the Constitution. It is guaranteed to all persons, citizens and non-citizens alike. It places a restriction on the state from arbitrarily interfering with a person’s life and liberty. Over time, courts have interpreted it to also impose positive obligations on the state to ensure a dignified life. Rights Included Under Article 21 ( Judicial Interpretation) RightLandmark CaseRight to livelihoodOlga Tellis v. Bombay Municipal Corporation (1985)Right to clean environmentSubhash Kumar v. State of Bihar (1991)Right to education (prior to Article 21A)Mohini Jain v. State of Karnataka (1992)Right to privacyJustice K.S. Puttaswamy v. Union of India (2017)Right to die with dignityCommon Cause v. Union of India (2018) SC upholds courts’ power to modify arbitral awards under limited circumstances Syllabus :GS2/Governance In News The Supreme Court of India, in a majority 4:1 judgment, ruled that courts have the limited power to modify arbitral awards under Section 34 of the Arbitration and Conciliation Act, 1996. Background This decision responds to a legal question referred by a three-judge bench in February 2024, seeking clarity on whether courts can modify arbitral awards. Arbitration It is an alternate mode of dispute resolution under the 1996 law and it minimises the role of courts to interfere with the awards by the tribunals. Major Highlights of the Judgement Courts can modify awards to remove invalid portions or correct typographical, computational, or clerical errors. Courts can also adjust the interest post-award if necessary. Judicial intervention under Section 34 of the Arbitration and Conciliation Act, 1996 is confined to limited grounds, such as public policy or fraud. Courts cannot correct factual errors, reconsider costs, or review the merits of the award. Article 142 Powers: The Supreme Court can use its inherent powers under Article 142 to ensure complete justice in cases involving arbitral awards. However, this power must be exercised cautiously and in line with the principles of the 1996 Arbitration Act. Do you know?– Section 34 of the Arbitration and Conciliation Act allows a court to set aside an arbitral award on specific grounds such as violation of public policy, fundamental legal principles, fraud, corruption, or moral injustice. 1. Section 37 deals with the circumstances in which an appeal would lie against the order in an arbitral dispute– However, the Supreme Court, in its majority judgment, noted that it had occasionally modified arbitral awards in the past to avoid prolonged litigation and ensure justice, even though such modification is not explicitly provided under Section 34. Dissent Justice Viswanathan’s Argued that arbitral awards cannot be modified unless specifically permitted by the statute. Section 34 only allows for the setting aside of awards, not modifying them. The dissent mirrored the Centre’s view, which emphasized that the power to modify should be statutorily conferred. Lawyers argued that allowing courts to modify arbitral awards could replace them with court decrees, which could have international implications. Modifying arbitral awards could lead to issues with enforcing them under international conventions. Tension and Clumpiness of Universe Syllabus: GS3/Science and Technology Context The latest research that suggests the key to revealing the fundamental nature of the universe lies in finding out how clumpy it is. Clumpiness of Universe The universe was explosively born in a ‘Big Bang’ in the void some 13.8 billion years ago, it expanded, engendering galaxies, star clusters, solar systems, and planets. When scientists looked at the cosmic microwave background (CMB) — the radiation left over from the Big Bang itself — they saw an absolutely smooth glow across the sky. They concluded that the early universe must have been remarkably uniform with only small variations in density. The S8 Tension The clumpiness of the universe refers to the non-uniform distribution of matter, where matter is concentrated in regions like galaxies and galaxy clusters, while other regions are relatively empty. The “clumpiness” is measured by the “clumpiness factor,” often denoted as S8, which reflects how much matter is clustered together compared to an evenly distributed scenario. A higher value for S8 indicates more clustering with a greater amount of matter clumped together, while a lower value indicates a more uniform distribution of matter. S8 tension: A problem arose when cosmologists used different ways to measure the value of S8 and came up with different estimates. This lack of agreement has come to be called the ‘S8 tension’ in astrophysics. Why Does It Matters? If this tension cannot be explained by observational uncertainties it could mean: The Lambda Cold Dark Matter (ΛCDM) model is incomplete or needs revision. Dark matter or dark energy may behave differently than currently assumed. New physics could be involved (e.g., interacting dark energy, modified gravity, or even time-varying fundamental constants). The Lambda Cold Dark Matter (ΛCDM) Model– Over the years, cosmologists have tried to map the overall spread of matter through the early universe. – In the standard cosmological model, ΛCDM model, dark matter and dark energy — the mysterious force that drives the expansion of the universe — comprise about 95% of the universe. – The interplay between these components influences how the primordial fluctuations evolved into the large-scale structures that we observe today. India Opposes Inclusion of Chlorpyrifos at Stockholm Convention Syllabus :GS 3/Environment In News At meetings of the conferences of the Parties to the Basel, Rotterdam and Stockholm (BRS) conventions in Switzerland, India has opposed the inclusion of the insecticide Chlorpyrifos under the Stockholm Convention on Persistent Organic Pollutants (POPs), citing concerns over food security due to the lack of alternatives. Over 40 countries have banned Chlorpyrifos. Chlorpyrifos – It is an insecticide which is a chemical linked to adverse effects on neurodevelopment, reduced birth size, lung and prostate cancer upon chronic exposure.– The World Health Organization (WHO) has classified chlorpyrifos as a moderately hazardous pesticide. The chemical inhibits an enzyme called acetyl cholinesterase, which results in adverse nervous system effects. Stockholm Convention on Persistent Organic Pollutants (POPs) It was adopted in May 2001 in Stockholm, Sweden, and entered into force on 17 May 2004, following the submission of the fiftieth ratification or accession. It aims to protect human health and the environment from harmful chemicals known as persistent organic pollutants. It also mandates the Conference of the Parties to establish arbitration and conciliation procedures for resolving disputes between member countries. The Stockholm Convention lists chemicals in three annexes. While Annex A lists chemicals to be eliminated, Annex B and C lists chemicals to be restricted, and minimising unintentional production and release of listed chemicals. Steps to Phase out of Chlorpyrifos Chlorpyrifos was nominated for global phase-out in 2021 by the European Union. In 2024, the Persistent Organic Pollutants Review Committee (POPRC) recommended Chlorpyrifos’ inclusion in Annex A of the Convention (elimination), with exemptions for specific uses such as plant protection, cattle tick control, and wood preservation. At the Basel, Rotterdam and Stockholm (BRS) conventions, countries debated exemptions for Chlorpyrifos in agricultural uses and pest control, with India and other nations calling for certain exceptions. India’s Stance Chlorpyrifos has been registered in India since 1977 and was the most used insecticide in the country in 2016-17. India argued that Chlorpyrifos is crucial for agriculture and pest control, particularly for urban pests and vector-borne diseases, and remains a commonly used pesticide in India. It is considered important in India for controlling urban pests like cockroaches and termites and for vector-borne disease control. Chlorpyrifos residues have been found in food products in India, with a 2024 study detecting the chemical in 33% of the samples tested. The Anupam Verma Committee, constituted in 2013 to review 66 pesticides that had been banned, restricted, or withdrawn in other countries, but still in use in India, submitted its report in 2015. It recognised that chlorpyrifos is toxic to fish and bees. Future Plans The Indian government has been promoting a national mission on natural farming (a Centrally Sponsored Scheme under the Ministry of Agriculture & Farmers’ Welfare Other chemicals like Medium-chain chlorinated paraffins and long-chain perfluorocarboxylic acids (LC-PFCAs) are also being discussed at the BRS Convention. News In Facts 1-05-2025 Jagadguru Basaveshwara Syllabus: GS1/ History and Culture Context PM Modi remembered the profound wisdom of Jagadguru Basaveshwara on the occasion of Basava Jayanthi. Jagadguru Basaveshwara Jagadguru Basaveshwara (also known as Basavanna or Basaveśvara) was a 12th-century philosopher, poet, and social reformer, primarily active in the Kalyana region of Karnataka. He served as a minister under King Bijjala II of the Kalachuri dynasty, and played a pivotal role in shaping the Lingayat religious tradition. Lingayats had been classified as a Hindu subcaste called “Veerashaiva Lingayats” and they are considered to be Shaivites. Contributions of Basaveshwara Women Empowerment: He promoted gender equality, encouraging women like Akka Mahadevi and others to become spiritual leaders and poets. Equality: Basavanna rejected the caste system and ritual hierarchy. He established the Anubhava Mantapa, a spiritual parliament where men and women from all castes participated equally in discourse. Literature: Basavanna’s thoughts were expressed through Vachanas, short and profound Kannada verses written in the vernacular, making spiritual knowledge accessible to all. Thrissur Pooram Syllabus: GS1/ History and Culture Context The Thrissur Pooram has officially begun with the ceremonial flag hoisting (Kodiyettam) marking the start of festivities at the participating temples. Thrissur Pooram Location: The Thrissur Pooram is an annual Hindu temple festival held in Thrissur, Kerala. Timing: Celebrated during the months of April-May. It was started by Shakthan Thampuran, Maharaja of Kochi and includes the participation of 10 different temples from Paramekkavu, Thiruvambadi Kanimangalam, Karamucku, Laloor, Choorakottukara, Panamukkampally, Ayyanthole, Chembukkavu and Neythilakavu. Key Highlights of the Festival Poorams: Processions of caparisoned elephants, accompanied by traditional percussion ensembles. Kudamattom Ceremony: A synchronised and competitive display of colourful parasols changing atop elephants, drawing massive crowds. Ilanjithara Melam: A traditional percussion orchestra performance held at Vadakkumnathan Temple, featuring hundreds of artists and drawing euphoric participation from spectators. Zojila Pass Syllabus :GS 1/Geography Context Zojila Pass, reopened early this year, enabling tourist access to the Siachen base camp without prior authorization. Zojila Pass It is one of the most critical and challenging high-altitude passes in the world . It is located at 3,528 metres in Jammu and Kashmir. It is a vital link between the Kashmir Valley and Ladakh. It is known for its strategic importance and stunning Himalayan scenery. Zojila Tunnel Project It is an under-construction tunnel situated at an altitude of 11,578 ft (around 3,500 metres) on the Srinagar-Leh Highway in Jammu and Kashmir. It will be India’s longest road tunnel, and Asia’s longest bi-directional tunnel. Do you know?– During the 1947–48 Indo-Pakistani War, Pakistani forces captured the pass, prompting Operation Bison by the Indian Army.1. In a landmark move, tanks were deployed at high altitude, surprising the enemy and reclaiming the pass. 2. This operation, led by Lt Col Rajinder Singh ‘Sparrow’, was crucial in reopening access to Kargil and Leh, and is remembered as a remarkable feat in military history. International Workers’ Day Syllabus: GS2/Governance/GS3/Economy Context May 1 is observed as the International Workers’ Day, commonly known as Labour Day. About Also referred to as May Day, in some regions it is observed on the first Monday of May. The day serves to acknowledge the social and economic contributions of workers and to draw attention to the continuing fight for workers’ rights and fair labour conditions globally. The origins of International Labour Day date back to the late 19th-century labour movement in the United States. On May 1, 1886, workers across America launched a strike demanding an eight-hour workday, May 1 was chosen to commemorate the strike. In India, the first Labour Day celebration was held in Chennai (then Madras) in 1923 by the Labour Kisan Party of Hindustan. Canada’s first Labour Day celebration took place in 1872, nearly a decade before the United States officially recognised it. International Labour Organisation (ILO) It is an United Nations Agency established in 1919 as part of the Treaty of Versailles that ended World War I, and it became the first specialized agency of the UN in 1946. India became a founding member of the ILO in 1919, even before gaining independence. It has 187 Member states. It sets labour standards, develops policies and devises programmes promoting decent work for all women and men. It is the only tripartite U.N. agency that brings together governments, employers and workers. It is headquartered in Geneva, Switzerland. Labour Laws in India The Indian government has consolidated 29 central labour laws into four labour codes: Code on Wages, 2019: Regulates wages, bonus payments, and equal remuneration. Industrial Relations Code, 2020: Deals with trade unions, employment conditions, layoffs, and dispute resolution. Code on Social Security, 2020: Merges laws on provident funds, pensions, insurance, maternity benefits, and gratuity. Occupational Safety, Health and Working Conditions Code, 2020: Consolidates regulations on safety, working hours, health, and welfare. Labour laws in India apply to both organized and unorganized sectors, although enforcement in the unorganized sector remains a challenge. Enforcement agencies include the Ministry of Labour and Employment, state labour departments, and specific boards (e.g., EPFO, ESIC). Fair and Remunerative Price (FRP) of Sugarcane Syllabus: GS3/Economy Context The Centre has approved an increase in the Fair and Remunerative Price (FRP) of sugarcane to ₹355 per quintal for the 2025-26 sugar season, up from ₹340 per quintal in the previous season. About FRP was introduced by the government in 2009 by an amendment to the Sugarcane (Control) Order, 1966. It replaced the Statutory Minimum Price (SMP) on the Commission for Agricultural Costs and Prices (CACP) consultation. Aim: To ensure remunerative returns to farmers and a stable supply of sugarcane to mills. The FRP system assured timely payment to farmers, irrespective of the profit and loss to sugar mills. It made it mandatory for sugar mills to pay the farmers within 14 days of delivery of sugarcane. The FRP system also introduced grading on the basis of sugar recovery rate from sugarcane wherein a premium was paid to the farmer on higher recovery and a reduction in rates on lower recovery. It is recommended by the Commission for Agricultural Costs and Prices (CACP); fixed by the Cabinet Committee on Economic Affairs (CCEA). Locust Syllabus: GS3/Environment In News A recent study reveals that locusts swarm using cognitive decision-making based on visual cues, not random movements like gas particles. This behavior-based model helps explain how individual locusts align with others, improving the understanding of swarm dynamics. Locust Locusts belong to the Acrididae family within the Orthoptera order Locusts are large grasshoppers that live on almost every continent of the world and are known for their propensity to gather in large, destructive swarms. They grow larger and change colour in response to their environment. In a process called gregarisation, they transition from solitary creatures to a swarm, congregating in large numbers and travelling together over several leagues at time. The 2019–2022 desert locust outbreak, the worst in decades, devastated crops across East Africa and India. Historically, these ‘outbreaks’ have led to widespread famine and economic devastation, earning them the name “locust plagues”. Cholistan Canal Project Syllabus: GS3/ Infrastructure Context The Cholistan Canal Project has been temporarily suspended by the Pakistani government following protests in Sindh. Green Pakistan Initiative It is a $3.3 billion project, launched by Pakistan in 2023. GPI seeks to “modernise” Pakistan’s agriculture sector by introducing new technologies, providing farmers high-quality inputs, and creating irrigation infrastructure. The Cholistan Canal Project The Cholistan Canal is one of the six strategic canals envisioned under the Green Pakistan Initiative (GPI). It is designed to irrigate approximately 5,000 sq km (1.2 million acres) of land in the arid Cholistan region of southern Punjab. The project is expected to cost around $800 million and will primarily use water from the Sutlej River. Shiv Shakti Point Syllabus: GS3/Space Context India’s Chandrayaan-3 mission has uncovered critical evidence of primitive lunar mantle materials at the Moon’s Shiv Shakti Point. About The findings reinforce the Shiv Shakti Point’s value as a site for sampling primitive mantle materials, which could clarify the timing of lava crystallisation and volatile distribution during the Moon’s early evolution. Shiv Shakti Point It is the internationally recognized site of the Chandrayaan 3’s moon lander at the Moon’s South Pole. Planetary nomenclature is like naming places on Earth. It helps to identify and talk about specific features on planets and moons. This list, created by the International Astronomical Union (IAU), includes all the names given to different spots on planets, moons, and even some ring systems since 1919.

Tag: SC upholds courts’ power to modify arbitral awards under limited circumstances

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