However, it was to apply only prospectively ie to arbitration agreements entered into after 6 September 2012. The Supreme Court in Harmony Innovation Shipping Ltd v Gupta Coal India Ltd & Anr 2015 (3) SCALE 295 (not reported by LexisNexis®) clarified that pre-Balco arbitration agreements (executed prior to 6 September 2012) must be considered based on the principles laid down in Bhatia International. This effectively led to two parallel streams of law being developed insofar as arbitration was concerned.