The Delhi High Court, in an appeal by SARR Freights Corporation, reversed a Single Judge's refusal of interim relief and granted an anti-arbitration injunction. The Division Bench held that a final signed Booking Note, executed after a preliminary Fixture Recap, constitutes the binding contract between parties. Because the Booking Note designated Indian courts as the dispute-resolution forum, a London arbitration clause in the earlier Fixture Recap was overridden, making the foreign arbitration proceeding legally unsustainable.

This judgment turns on a foundational contract law principle: when two successive documents govern the same transaction, the later, fully executed instrument supersedes the earlier, preliminary one. A Fixture Recap in shipping is analogous to an 'agreement to agree' or a term sheet — it records negotiated terms but is not always the final bargain. The signed Booking Note, executed afterwards, is the formal, concluded contract.

The doctrine at work is the integration or merger rule: a final written contract is presumed to contain the entire agreement, and earlier negotiations or preliminary documents are absorbed into it. Under Indian contract law (Sections 91–92 of the Indian Evidence Act, 1872), oral or prior documentary evidence cannot be used to contradict a concluded written contract.

The anti-arbitration injunction angle adds a procedural dimension. Indian courts can injunct foreign arbitration proceedings when: (a) there is no valid arbitration agreement, or (b) the arbitration is oppressive or vexatious. Here, since the operative contract (Booking Note) contained an Indian jurisdiction clause, not a London arbitration clause, the court found the foreign arbitration lacked a valid agreement to support it.

For CLAT PG, the examiner will likely test: (1) which document prevails when two instruments conflict, (2) the conditions under which Indian courts can issue anti-arbitration injunctions, and (3) the mirror-image and integration rules in contract formation — the sequence of offer, counter-offer, and final acceptance crystallising the contract.