It was observed that patent illegality, as a ground for setting aside a domestic award was first expounded in the judgment of Oil and Natural Gas Corporation Ltd. v. Saw Pipes Ltd. 3, where the Supreme Court gave a wider interpretation to the public policy of India in terms of Section 34(2)(b)(ii) of the Arbitration Act. It was held that an award would be patently illegal if it is contrary to the substantive provisions of law, or the provisions of the Arbitration Act, or the terms of the contract.