The Supreme Court in Gemini Bay Transcription Pvt. Ltd. v. Integrated Sales Service Ltd. held that a foreign award can be binding on non-signatories to the arbitration agreement and thus can be enforced against them. The enforcement of a foreign arbitral award cannot be resisted on the ground that it has been passed against a non-signatory under Section 48(1) of the Arbitration Act. Section 46 of the Arbitration Act refers to “persons as between whom it was made” which is a wider term than “parties” and therefore, can include non-signatories to the agreement.
 2021 SCC OnLine SC 572.