Summary: The Bombay High Court, in Osterreichischer Lloyd v. Victore Ships, has held that a party seeking to enforce a foreign arbitral award in India does not lose its right to seek interim protective relief under Section 9 of the Arbitration and Conciliation Act, 1996, merely by filing a petition for recognition and enforcement under Part II. Such relief remains available at least until the award is recognised as an enforceable decree under Section 49. This ruling strengthens the hand of award-creditors seeking to prevent dissipation of assets while enforcement is pending. It also reaffirms India’s pro-enforcement stance towards foreign awards. However, the judgement leaves open the more difficult question of whether Section 9 relief continues to be available even after the award is recognised as a decree, during the execution stage. High Courts remain divided on it and may require clarification from the Supreme Court.