The principle that an award can be set aside on the ground of PATENT ILLEGALITY apparent on the face of the award, an additional public-policy-based ground under the Arbitration Act, was laid down in:

Explanation: ONGC v. Saw Pipes Ltd. (2003) held that an arbitral award could be set aside as being opposed to the public policy of India where it is patently illegal, meaning the illegality is apparent on the face of the award - e.g. it contravenes a statute, disregards a binding precedent, or violates the fundamental policy of Indian law. The decision expanded the Section 34 'public policy' ground. BALCO deals with the seat doctrine, not patent illegality. The scope of 'patent illegality' was later refined in Ssangyong (2019), but Saw Pipes remains the foundational authority.