“Recently, in NTPC Ltd. v. SPML Infra, the Supreme Court, overturned the judgment of the Delhi High Court on the point of the scope of pre-referral jurisdiction under Section 11 of the Arbitration and Conciliation Act, 1996. In its judgement, the Supreme Court has discussed the jurisprudence on the scope of pre-referral jurisdiction prior to the Arbitration and Conciliation (Amendment) Act, 2015 as well as post the Amendment, and proposed an expansive scope of examination in the form of the ‘eye of the needle approach.”