Third-Party Funding in Arbitration: Lessons from the UK’s 2025 Act for India

The graphic summarises the relationship between investors, funders, plaintiffs and the Court.

Introduction

The United Kingdom’s Arbitration Act 2025 – a long-awaited fine-tuning of the 1996 Act – has brought into focus several modern issues, not least third-party funding (TPF) in arbitration. A key question considered in the UK’s reform process was whether to regulate TPF. Ultimately, the Act did not incorporate explicit TPF provisions, reflecting a conscious choice to favor party autonomy and flexibility over prescriptive regulation . This UK approach, combined with recent case law, offers valuable insights for jurisdictions like India, where TPF remains in a legal vacuum. India’s Arbitration and Conciliation Act, 1996 and related rules are silent on third-party funding, creating uncertainty and enforcement risks for funded arbitrations. This commentary, from the perspective of a seasoned Indian arbitration practitioner, critically examines the UK’s TPF stance and distills lessons for India. It argues that while the UK’s measured approach champions clarity through restraint, India must proactively codify a balanced TPF regime to enhance transparency and predictability. The discussion draws on international best practices – notably Singapore and Hong Kong – and concludes with concrete reform recommendations for India, including amendments to the 1996 Act and alignment of institutional rules.

UK Arbitration Act 2025: Forward-Thinking Clarity through Restraint

TPF Under the 2025 Amendments: The UK Arbitration Act 2025 introduced several refinements to maintain London’s edge as a leading arbitral seat, but it pointedly avoided new TPF regulation . The England & Wales Law Commission, in its review, considered proposals such as mandatory disclosure of funding or empowering tribunals to order such disclosure, yet recommended against statutory intervention . The result is that the 2025 Act is silent on third-party funding, neither mandating disclosure of funding arrangements nor restricting them. On its face, this might appear a missed opportunity to codify transparency. However, the Law Commission’s choice reflects a forward-thinking stance: it acknowledged that the arbitral community and institutions are already evolving practices on TPF, and a one-size-fits-all law might “straitjacket” a dynamic area of practice . By deferring to arbitral procedure and party agreement, the Act reinforces party autonomy – a core principle of arbitration – and avoids premature regulation that could stifle funding innovation. Crucially, nothing in UK law now prohibits TPF in arbitration; on the contrary, it is effectively accepted as part of the ecosystem.

Clarity Amidst Common Law Flux: The UK’s hands-off approach comes even as domestic case law threw TPF into a degree of flux. The Supreme Court’s decision in R (PACCAR) v Competition Appeal Tribunal (2023) unsettled the litigation funding market by holding that certain typical funding agreements (where the funder’s remuneration is a percentage of damages) qualified as impermissible damages-based agreements . This ruling, though arising in a litigation context, raised questions about similar funding structures in arbitrations seated in England . Notably, the 2025 Act did not respond directly to PACCAR. Instead, separate legislative efforts are underway to reverse the effect of PACCAR for litigation funders . The omission of TPF provisions in the Arbitration Act 2025 can thus be seen as strategic regulatory restraint – the drafters avoided entangling the arbitral regime in unresolved funding issues best addressed elsewhere. By not codifying requirements that might soon change (depending on PACCAR’s legislative fix), the Act preserved stability. In the interim, England relies on existing norms for TPF transparency, primarily through soft-law and institutional rules. For instance, while English law imposes no statutory disclosure duty on funded parties, many arbitral institutions do. The ICC Rules 2021 require parties to disclose any third-party funder’s identity to avoid arbitrator conflicts . ICSID’s 2022 Rules go further, empowering tribunals to order detailed disclosure of funding arrangements . English arbitrators, applying such rules or their general case management powers, can ensure the transparency needed in each case. In sum, the UK’s treatment of TPF in 2025 exemplifies regulatory clarity through minimalism: it clearly signals that TPF is permitted and leaves room for party-driven solutions and evolving best practices rather than imposing rigid statutory mandates.

Critique of the UK Approach: From a normative standpoint, the UK model demonstrates respect for party autonomy and the flexibility of arbitration. It avoids over-regulation, trusting parties and arbitrators to handle funding issues. This is laudable as a pro-arbitration, market-driven approach – especially in contrast to more heavy-handed regimes. However, one might question whether the UK should have at least codified a basic disclosure obligation. Transparency is essential to ensure no hidden conflicts of interest and to inform decisions on costs (e.g. applications for security for costs). The Act’s silence means transparency relies on voluntary compliance or institutional rules, which might not uniformly apply. Even seasoned English practitioners have noted this as a “missed opportunity,” given that several consultees had advocated addressing TPF . Nevertheless, the English consensus appears to be that arbitral confidentiality and flexibility would be better served by leaving TPF to party agreement and soft law . The UK’s stance ultimately reflects confidence that self-regulation and party agreement can ensure fairness – a stance that underscores London’s continued attractiveness to funded claimants and funders alike. For India, where uncertainty reigns, the UK example is instructive: clear permission of TPF (even if by silence) combined with supportive case law and institutional practices can create a de facto framework. The challenge for India, however, is that it currently has neither an explicit statutory nod nor a robust set of arbitral norms on TPF.

India’s Legal Vacuum on TPF: Uncertainty and Risks

No Codified Regime – Allowed but Unregulated: India’s arbitration statute and regulations do not mention third-party funding, leaving a grey area as to the legality and handling of TPF in arbitral proceedings. Unlike jurisdictions that outlawed maintenance and champerty, Indian law never explicitly forbade third-party financing of claims by non-lawyers. In fact, the Supreme Court in Bar Council of India v. A.K. Balaji (2018) affirmed that third-party funding by persons who are not advocates is lawful in India, since it does not offend public policy . This means that, at least in litigation, a non-lawyer funder can fund a lawsuit and be repaid from the proceeds. By extension, nothing in Indian law prohibits TPF in arbitration – a point the Delhi High Court recently emphasized. In Tomorrow Sales Agency Pvt Ltd v. SBS Holding Inc (2023), a case arising from a funded SIAC arbitration, the court noted that third-party funding is “essential to ensure access to justice” and is not per se impermissible . The court underscored that TPF has become a “key aspect of the legal ecosystem” and recognized that India must welcome it as other leading jurisdictions do . Thus, Indian courts are increasingly receptive to TPF, seeing it as aligned with public policy rather than against it.

Legal Uncertainty and Enforcement Gaps: Despite judicial acknowledgments that TPF is not barred, India’s lack of a codified framework creates practical uncertainty. Parties and funders have little statutory guidance on their rights and obligations. Key questions – disclosure of funding, cost liability of funders, recoverability of funding costs, etc. – are unanswered by legislation, leaving them to ad hoc decisions. The Tomorrow Sales case vividly illustrates an enforcement risk: after a funded claimant lost the arbitration and was ordered to pay costs, the award-creditor had no recourse against the funder for the adverse costs, since the funder was not a party to the arbitration or award . The court held it had no jurisdiction to bind the third-party funder to the award, reflecting the consensual nature of arbitration . For respondents, this is a cautionary tale – if they prevail against a funded claimant who turns out to be insolvent or asset-less, they may face a pyrrhic victory with unrecoverable costs. In the Delhi case, the court suggested that the presence of a funder is a relevant factor when deciding security for costs – indicating tribunals should ensure respondents aren’t left without remedy . But without clear rules, whether a tribunal will order disclosure of the funder or security for costs is unpredictable. This case-by-case approach breeds uncertainty for all stakeholders.

Another area of ambiguity is the enforceability of funding agreements themselves. If a funded claimant wins and then reneges on paying the funder its success fee, can the funder enforce the contract in India? Given the Balaji ruling, a well-drafted funding agreement with a non-lawyer funder should be enforceable as not contrary to public policy . Yet, the lack of precedent means each enforcement could be litigated, potentially inviting challenges that the agreement is champertous or extortionate (especially if the return to the funder is very high). Clear legislative validation of TPF contracts would foreclose such arguments. Likewise, cost recovery for funding expenses is uncertain. In some jurisdictions (e.g. England in Essar v. Norscot), arbitrators have awarded the successful party the cost of obtaining funding as part of recoverable costs. Indian law (Section 31A of the 1996 Act) gives tribunals broad discretion to award costs, but it is unclear if this extends to a funder’s success fee or premium. Without guidance, tribunals may shy away from awarding such costs for fear of challenge on public policy grounds during enforcement.

Finally, regulatory uncertainty extends to foreign funding and exchange control. If an Indian party obtains funding from a foreign investor, the cross-border fund flow triggers the Foreign Exchange Management Act, 1999 (FEMA). FEMA does not expressly classify proceeds of third-party funding as either debt or equity, leaving room for doubt on repatriation of a funder’s return . While Indian courts have enforced awards despite technical FEMA violations (emphasizing that FEMA is regulatory, not prohibitive) , a proactive clarification is needed so that foreign funders can enter the market without trepidation. In sum, India’s non-regulation of TPF amounts to benign neglect – TPF is not banned, but its contours are undefined. This creates unnecessary risk: parties may be hesitant to use funding, funders may price in legal risk or avoid Indian arbitrations, and outcomes involving TPF could spawn satellite litigation. For a country aspiring to be a global arbitration hub, this uncertainty is a handicap.

International Best Practices: Singapore and Hong Kong’s Pro-TPF Frameworks

India’s path forward can be illuminated by comparative perspectives. Leading Asian arbitration hubs like Singapore and Hong Kong have embraced TPF with forward-thinking regulatory frameworks, combining legality, transparency, and ethical safeguards. Their experiences underscore that it is possible to strike a balance – legitimizing TPF to enhance access to justice and competitiveness, while mitigating potential abuses through targeted rules.

Singapore: Faced with the archaic common law doctrines of maintenance and champerty, Singapore undertook sweeping reforms to permit third-party funding in international arbitration. In 2017, it amended its Civil Law Act to abolish maintenance and champerty as crimes/torts and to explicitly allow third-party funding for prescribed dispute resolution proceedings, including international arbitrations seated in Singapore . The law clarified that funding agreements for such arbitrations “are not contrary to public policy or illegal,” removing any doubt about their validity . Singapore’s regime is noteworthy for coupling legalization with stringent disclosure and professional conduct rules. Rather than imposing disclosure obligations directly in the arbitration statute, Singapore amended its legal profession rules to require that lawyers disclose any third-party funding their client is receiving . Rule 49A of the Professional Conduct Rules now obliges counsel to promptly disclose the existence of a funding arrangement to the court or tribunal and other parties. The rationale, as explained by Singapore’s Senior Minister of Law, is to ensure “no conflict of interest” in the proceedings . By making lawyers gatekeepers of disclosure, Singapore ensures transparency (arbitrators can check for conflicts, respondents can seek security for costs if needed) without heavy-handed intervention in the arbitration itself. Additionally, Singapore set criteria for funders – via regulations defining “qualifying third-party funder” – essentially requiring funders to have a certain minimum capital and business of funding, to prevent fly-by-night entities from funding claims . It also clarified that lawyers may assist clients in obtaining funding and even refer funders, as long as they don’t receive any commission (thus avoiding ethical pitfalls) . These measures have been heralded as best practice, marrying party autonomy with safeguards. The impact has been positive: Singapore’s clear stance on TPF has attracted major global funders and given parties confidence that funded arbitrations will not face legal obstacles.

Hong Kong: Similarly, Hong Kong introduced reforms in 2017 via the Arbitration and Mediation (Third Party Funding) (Amendment) Ordinance. This law abolished champerty for arbitrations and put in place a comprehensive but flexible regime. A cornerstone is the requirement that a funded party must disclose the fact of funding and the funder’s identity to all parties and the arbitral tribunal . This disclosure must be made at the commencement of the arbitration or when the funding agreement is made, and it continues as an ongoing obligation if circumstances change . By writing the disclosure duty into law (and supplementing it with detailed guidelines in a Code of Practice), Hong Kong ensured maximum transparency from the outset. Hong Kong’s approach goes beyond disclosure; it instituted a binding Code of Practice for Third Party Funding of Arbitration that funders are expected to follow. The Code, which became effective in 2019, lays down ethical and operational standards for funders – for example, requiring funders to maintain adequate capital and to refrain from undue control over the arbitration (the funding agreement must not give the funder the right to control the conduct of the case or settlement decisions) . Non-compliance with the Code doesn’t itself lead to penalties, but it can be taken into account by courts or tribunals , creating a soft enforcement mechanism. Notably, Hong Kong also amended its arbitration ordinance to assure that sharing information with a potential funder does not breach confidentiality or privilege, facilitating the due diligence phase of funding . The upshot of Hong Kong’s regime is a high degree of regulatory clarity – parties know TPF is permissible, but also what conditions apply. This has dispelled the uncertainty around TPF and made Hong Kong a TPF-friendly seat, in line with its pro-arbitration policy.

Global Trends and Guidelines: Beyond specific jurisdictions, international arbitral practice has converged on certain TPF norms. Leading arbitral institutions have filled the gap by updating their rules and guidance. For instance, the ICC Arbitration Rules (2021) mandate that each party must promptly disclose “the existence and identity of any non-party which has entered into an arrangement to fund its claims or defenses” – effectively a TPF disclosure rule aimed at avoiding conflicts of interest in arbitrator selection . The LCIA Rules (2020) include a similar provision requiring disclosure of any interest a third party (such as a funder) has in the outcome. SIAC, while not embedding TPF rules in its 2016 Rules, issued a Practice Note in 2017 obliging parties to disclose any third-party funding and giving tribunals authority to order such disclosure and consider funding in cost allocation . More recently, ICSID’s revised Arbitration Rules (2022) broke new ground for investor-state disputes by requiring mandatory written notice of any funding arrangement and the funder’s name at the outset of the case, and expressly empowering tribunals to order disclosure of funding terms and to consider TPF when deciding applications for security for costs . These developments all point one way: transparency and oversight of TPF are now standard features of international arbitration. They do so, importantly, without banning or unduly restricting funding, thus preserving the essential benefit of TPF – improved access to justice and efficient risk management for claimants. India’s arbitral community, which regularly interfaces with ICC, SIAC, LCIA, etc., is already aware of these evolving standards. Indeed, an ICCA-Queen Mary Task Force in 2018 (with Indian participation) issued non-binding principles recommending disclosure of the funder’s identity to arbitrators and institutions, and urging tribunals to manage TPF-related conflicts proactively . The direction is clear: embrace TPF but tame its potential downsides through disclosure and limited regulatory controls. This international consensus provides India both motivation and a menu of options for reform.

The Way Forward: Reform Recommendations for India

For India to harness the benefits of third-party funding while minimizing uncertainty, a multi-pronged reform is needed. This entails amendments to legislation, clarification of ethical rules, and alignment of institutional practices. As Indian arbitration practitioners vested in making India a competitive seat, we propose the following specific measures:

• Amend the Arbitration and Conciliation Act, 1996 to Recognize TPF: The Act should be amended to explicitly permit third-party funding in arbitrations seated in India. A new section (or an explanation to Section 2) could clarify that “Funding of arbitration by a person who is not a party (and has no prior interest in the dispute) in return for remuneration or a share in the award is not by itself contrary to public policy or illegal.” This would remove any lingering doubt about the validity of TPF agreements, foreclosing challenges to arbitral awards or enforcement on grounds of champerty. It would put legislative weight behind the Balaji judgment’s principle , ensuring consistency across courts.

• Mandate Disclosure of Funding and Funders: India should statutorily require transparency of TPF arrangements in arbitrations. A provision could be added (perhaps as Section 34A or in a Schedule) that obliges a funded party to disclose the existence of any funding arrangement and the identity of the funder to the other party and the tribunal at the earliest appropriate stage. The rule could mirror the approach of the ICC/HKIAC rules or the draft MCIA Rules. Notably, the Mumbai Centre for International Arbitration’s latest draft rules (3rd Edition) already contain a rule that a party must disclose that it has a funding agreement, the funder’s identity, and whether the funder has agreed to cover adverse costs . This kind of disclosure requirement in the Act would ensure that even in ad hoc arbitrations or those under rules which lack TPF provisions, the parties are on equal footing regarding knowledge of any funding. It addresses the Delhi High Court’s call for “transparency and disclosure in relation to the involvement of external funders” . Importantly, an accompanying amendment should specify that such disclosure does not waive any applicable privilege and does not breach confidentiality, to reassure parties that sharing funding information is legally safe (similar to Hong Kong’s ordinance) .

• Empower Tribunals on Costs and Security for Costs: The Act should equip arbitral tribunals with clear powers to deal with the implications of TPF. One recommendation is to amend Section 17 (interim measures by arbitral tribunal) to explicitly include the power to order security for costs where appropriate – for example, “the tribunal may require a party to provide security for the costs of the arbitration, taking into account any third-party funding arrangement and the funded party’s ability to satisfy adverse cost awards.” This aligns with international practice that a tribunal, upon finding that a claimant is relying on a funder and may not independently have the means to pay costs if it loses, can protect the respondent from the risk of non-recovery . Likewise, Section 31A (which defines the regime for arbitral costs) could be augmented to clarify that the tribunal may take into account the existence of third-party funding when apportioning costs. This does not mean funders become liable for costs directly, but it allows a tribunal to, say, award costs against a funded claimant in a manner that recognizes a funder enabled the claim. Conversely, the law might permit – in exceptional cases of egregious conduct – a costs award directly against a funder who is controlling the claim, though ordinarily funders remain non-parties (following the Tomorrow Sales principle of consent in arbitration) . Additionally, India could consider whether to allow recovery of funding costs as part of “costs of arbitration” – a contentious point. A middle ground is to leave it to tribunal discretion in “exceptional circumstances” (such as where the losing respondent’s conduct forced the claimant to seek funding). Explicitly addressing these cost issues in the statute will give parties and funders a more predictable risk assessment.

• Regulatory Oversight and Funder Conduct: While heavy licensing of funders may not be necessary at this stage, India would benefit from industry-led regulation under a statutory umbrella. One approach is to empower an appropriate body (perhaps the proposed Arbitration Council of India or a recognized industry association) to develop a Code of Conduct for third-party funders. Participation could be voluntary initially, but incentives (like a presumption of validity or easier enforceability for agreements adhering to the Code) can be provided. The code should incorporate internationally recognized standards: requiring funders to maintain adequate capital, uphold confidentiality, avoid conflicts of interest, not take control of the litigation strategy away from the client, and ensure their funding agreements do not undermine the integrity of proceedings . Notably, an Indian Association for Litigation Funding has been reportedly developing guidelines – coordination between such private efforts and the government could yield a robust self-regulatory regime. The Act could include a provision encouraging the use of an approved code of conduct and stipulating that non-compliance with such code may be considered by courts/tribunals in certain decisions (akin to Hong Kong’s model) . This would nudge funders towards best practices without onerous licensing, preserving competition and innovation in the funding market.

• Aligning Bar Council Rules: Since Indian advocates are prohibited from funding cases or charging contingency fees (as reinforced by Bar Council Rules and the Balaji judgment) , the reforms should clarify that lawyers can participate in TPF arrangements in legitimate ways. The Bar Council of India could issue a clarification or amend its rules to state that advising or assisting a client in securing third-party funding does not amount to professional misconduct, as long as the advocate does not have a financial interest in the funder or the outcome beyond normal fees. This would be similar to Singapore’s approach of allowing lawyers to connect clients with funders and even negotiate funding agreements on the client’s behalf (something their rules explicitly permit) . Freeing lawyers from uncertainty here will facilitate smoother handling of TPF in practice – lawyers often act as the conduit between clients and funders, and ethical clarity is necessary so they can perform this role without fear. Additionally, any confidentiality concerns could be addressed by allowing lawyers to share necessary information with prospective funders under confidentiality agreements, deemed not to violate attorney-client privilege.

• Addressing Foreign Funding and Enforcement: To tackle the FEMA ambiguity, the Ministry of Finance (or RBI) should issue guidance classifying inbound third-party funding as an approved financial transaction for arbitration expenses. For example, it could be treated as an external commercial borrowing or as a masala bond equivalent for arbitration finance, or simply as a permitted current account transaction if repaid from damages. Similarly, the tax treatment of funder’s returns should be clarified to avoid surprises (perhaps treating it analogous to capital gains or speculative investment income). On enforcement of awards, an amendment to Section 34/48 could make clear that the mere fact that an award-debtor was funded is not a ground to challenge an award as contrary to public policy – closing the door to any creative but meritless challenges by losing parties upset that the winner had outside financial help.

Harmonizing Institutional Rules and a Pro-Arbitration Stance on TPF

Legislative reform must go hand-in-hand with evolution of institutional arbitration rules in India. Indian arbitral institutions – such as MCIA, Delhi International Arbitration Centre (DIAC), Nani Palkhivala Centre, and others – should either adopt or, where already in progress, finalize rules on third-party funding disclosure and procedure. MCIA’s draft Rule 37 on Third-Party Funding is an excellent model, requiring disclosure of the funding and funder at the outset and updates throughout the case . All major institutions in India should incorporate similar provisions for consistency. A harmonized approach ensures that whether a case is administered by MCIA, DIAC or IIAC, etc., the expectations on TPF are the same – thereby preventing “forum shopping” or confusion. The Arbitration Council of India (ACI), once operational with its mandate to grade institutions, could include the presence of TPF-friendly rules as a factor in evaluating arbitral institutions. This would incentivize institutions to update their rules in line with global standards. It would also project India’s arbitration scene as modern and facilitative, aware that practices like TPF are integral to today’s complex disputes.

In addition to institutional rules, soft law and training will play a role. Indian arbitral institutions and the IBA’s India branch can organize workshops or issue guidance notes on handling TPF – covering points like how arbitrators should deal with disclosure (e.g., updating conflict checks to include known funders, as per the IBA Guidelines on Conflicts which now mention TPF), how to address applications related to TPF (for security for costs, or for adverse costs against funders), and how to draft awards accounting for TPF involvement (ensuring reasoning if funding costs are awarded or declined). Arbitral tribunals seated in India should also be encouraged to exercise their existing case management powers to order disclosure of funding arrangements when justice demands, even before a statutory rule is in place. While parties may be wary to disclose, the tribunals can cite growing international practice and the imperative of equal treatment – if one side is funded, the other side should at least know of it to tailor its strategy . Over time, these practices will normalize TPF in Indian arbitration, just as they have elsewhere.

Finally, a pro-arbitration stance on TPF means publicly embracing the idea that third-party funding enhances access to justice and does not undermine the arbitral process. Indian arbitral institutions and chambers of commerce might formally endorse TPF as a tool that can reduce the financial barriers to arbitration for Indian businesses (especially MSMEs) and for the assertion of claims against well-resourced opponents. Such endorsements, coupled with success stories, can dispel the lingering perception that funding is a form of gambling on litigation. Instead, the narrative should be that India, as a bold reformer in arbitration in recent years, welcomes responsible funding as part of its growth as an arbitration-friendly jurisdiction. This attitudinal shift is already visible in Indian jurisprudence – the Delhi High Court explicitly recognized the “vital role” of TPF in its 2023 judgment . It is time to cement that understanding into our normative framework.

Conclusion

The UK’s Arbitration Act 2025 offers a nuanced lesson for India: sometimes, doing less is doing more – the UK drew a line between essential updates and over-regulation, opting not to rush into TPF rules while still signaling openness to funding. The UK’s emphasis on party autonomy, coupled with reliance on evolving norms for transparency, reflects a confidence in the arbitration process to self-regulate where needed. India, however, is at a different stage in its arbitral evolution. With TPF in India currently an uncharted territory governed only by scattered case law, a hands-off approach risks perpetuating uncertainty and deterring both funders and users of arbitration. Indian arbitration law has seen major pro-enforcement and pro-efficiency amendments in the last decade; the next frontier is third-party funding. By drawing on the best practices from the UK (ensure flexibility), Singapore and Hong Kong (ensure clarity and transparency), India can craft a TPF regime that is both progressive and tailored to our legal context. The reforms recommended above center on legitimizing TPF, mandating disclosure, empowering tribunals, and coordinating institutional rules – all aimed at eliminating ambiguity. The payoff would be significant: increased confidence for international investors and arbitral users, greater access to justice for Indian claimants who might otherwise drop valid claims for lack of resources, and a boost to India’s reputation as a modern arbitration hub. In a global landscape where capital meets dispute resolution, India should not remain on the sidelines. A calibrated, well-considered embrace of third-party funding in arbitration will signal that Indian arbitration is ready for the future – a future where funding is no longer an “outsider” but a welcome facilitator of fair and effective dispute resolution.

Sources:

1. Baker Botts, The Arbitration Act 2025: A Welcome Fine-Tuning of England’s Arbitration Law.

2. LCM Finance, Still Best in Class? – Changes to the English Arbitration Act.

3. Linklaters, Delhi High Court says third party funder not liable for adverse cost award (2023).

4. Kluwer Arbitration Blog, Third Party Funding in Asia: Whose duty to disclose?

5. Kluwer Arbitration Blog, Comparing Hong Kong Code of Practice with England & Wales Code .

6. IBA Article, Third Party Funding in Arbitration in India: Setting the Law Straight.

7. MCIA Rules (3rd Ed. Draft, 2024), Proposed Rule 37 on Third-Party Funding.

8. L. & T. (HK) Ordinance 2017 (HK), Code of Practice provisions.

9. LCM Finance, English Arbitration Act 2025 – Impact on Funders (2025.

10. Linklaters, ArbitrationLinks – TPF in India-related arbitrations.