In CC/Devas v. India, a tribunal constituted under the Mauritius-India BIT and the 1976 UNCITRAL Rules addressed claims brought by three Mauritian investors arising from India’s annulment of a satellite spectrum leasing agreement. The dispute centered on the 2005 “Devas Agreement” between Antrix Corporation, an Indian state-owned entity, and Devas Multimedia, an Indian company in which the Claimants had invested. In 2011, India’s Cabinet Committee on Security (CCS) annulled the agreement, prompting arbitration. On the merits, India’s principal defense relied on the BIT’s essential security interests exception. The Tribunal determined this provision was not self-judging and, by majority, found the CCS’s decision was driven by a mix of motives. It attributed 60% of the decision to legitimate, non-compensable security interests and 40% to other public purposes that did not fall under the security exception. Based on this, the Tribunal held by majority that India had expropriated the Claimants’ investment to the extent of the 40% of the measure not covered by the security exception. The Tribunal also unanimously found that India had breached the Fair and Equitable Treatment (FET) standard by acting in bad faith, thereby frustrating the Claimants' legitimate expectations. The Claimants' appointee, David Haigh, dissented on the merits award. In the subsequent quantum phase, the Tribunal issued its final award on October 13, 2020. It rejected India’s argument that a Discounted Cash Flow (DCF) analysis was too speculative, finding the detailed business plans developed by Devas and its strategic partner, Deutsche Telekom, to be a reliable basis. The Tribunal valued the investment based on the “Original Spectrum Scenario”—determining the full value of Devas as a going concern—before applying the 40% compensable portion. While largely accepting the Claimants’ experts’ DCF framework, the Tribunal made its own adjustments to key inputs, including the terminal growth rate, the probability of failure, and the discount rate. Based on these modifications, the Tribunal determined the total enterprise value of Devas as of the date of expropriation to be USD 740 million. Consequently, the Tribunal awarded the Claimants 40% of their pro-rata share of this value, totaling approximately USD 111.3 million in principal compensation. The Tribunal also awarded pre- and post-award interest at a rate of LIBOR plus 2%, and ordered India to pay USD 10 million towards the Claimants’ costs. India’s appointee, Anil Dev Singh, issued a dissenting opinion on the quantum award. India subsequently sought to set aside the awards before the Dutch courts. On February 3, 2023, the Supreme Court of the Netherlands dismissed India's appeal, thereby rendering the Merits Award final in the Netherlands; the challenge to the Quantum Award remains pending. Following the award, the Claimants commenced a multi-jurisdictional enforcement campaign. In the United Kingdom, on April 17, 2025, the High Court of Justice issued a judgment on a preliminary issue, finding that India had not waived its state immunity from jurisdiction simply by ratifying the New York Convention. In the United States, the District Court for the District of Columbia granted India's motion to stay its enforcement proceedings pending the final outcome of the set-aside litigation in the Netherlands. In a parallel action, the Claimants sought to enforce the award against Air India, Ltd. in the Southern District of New York, arguing the airline was an alter ego of the state; in February 2022, that court also stayed its proceedings. In France, the Paris Court of Appeal on September 10, 2024, ruled that the US-based entities to which the original Claimants had assigned their rights under the awards were inadmissible to intervene in India's appeal against the French exequatur order. In Canada, the Superior Court of Quebec dismissed India's attempt to quash the enforcement proceedings on state immunity grounds in December 2022, a decision India was granted leave to appeal in March 2023. After the same court dismissed an enforcement action against The Airports Authority of India (AAI) in August 2024, the Quebec Court of Appeal, in a separate but related proceeding on December 4, 2024, reversed a lower court decision and reinstated a seizure of AAI's assets. In another branch of the Canadian litigation, on May 11, 2023, the Supreme Court of Canada dismissed an application for leave to appeal a September 20, 2022, decision of the Quebec Court of Appeal. India also sought and obtained an ex parte interim anti-arbitration injunction from the Supreme Court of Mauritius in January 2023.