Introduction On 17 April 2026 an award debtor applied under Section 36(3) of the Arbitration and Conciliation Act, 1996 for a stay and for continuation of a bank guarantee. Seven days later the Supreme Court decided Home Care Retail Marts v Haresh N Sanghavi, holding that an unsuccessful party may invoke Section 9 after an award. Four days after that the debtor abandoned its Section 36(3) prayer, moved under Section 9, and obtained the relief. Counsel argued in both forums th