mere conferral of statutory jurisdiction on a specialized forum or civil court does not automatically establish an implicit bar on arbitrability

Conferment of exclusive jurisdiction on a specific court or statutory tribunal is an important factor but is not the sole or decisive test to infer an implicit legislative bar against arbitration. For an implied bar on arbitrability to apply, a special statute must create specific public rights or liabilities and mandate a complete mechanism to adjudicate all questions through designated public forums. Where a dispute involves subordinate rights in personam arising from private agreements rather than actions in rem or sovereign functions of the State, the existence of a statutory civil forum does not automatically render the underlying contractual dispute non-arbitrable. (Motilal Oswal Financial Services Limited v. Santosh Cordeiro and Another | 2026 INSC 5)