Execution Courts, Arbitral Interest and Partial Deposits:
A Commentary on Power Grid Corporation of India Ltd. v. M/s Mega Electricals (Meghalaya High Court, 14 November 2025)

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1. Introduction

This judgment of the Meghalaya High Court in Power Grid Corporation of India Ltd. v. M/s Mega Electricals (CRP No. 7 of 2025, decided on 14.11.2025, per B. Bhattacharjee, J.) addresses a recurring and often misunderstood issue in arbitration law:

• How should interest under an arbitral award be computed at the execution stage, particularly where the award grants a composite stream of simple interest “till payment”?
• Can an Executing Court reinterpret the award so as to effectively grant compound interest or interest on interest?
• What is the impact of a partial deposit of the awarded sum made to obtain a stay of the award — does interest continue to run even on the deposited portion?

The judgment clarifies the interaction between:

• Section 31(7)(a) and (b) of the Arbitration and Conciliation Act, 1996,
• the Supreme Court’s line of authorities culminating in Hyder Consulting (UK) Ltd. v. State of Orissa, UHL Power Co. Ltd. v. State of Himachal Pradesh and Morgan Securities and Credits Pvt. Ltd. v. Videocon Industries Ltd., and
• Supreme Court rulings on interest after partial deposits, especially Nepa Ltd. v. Manoj Kumar Agarwal and other interest-related precedents.

The case arises in the context of a construction contract between Power Grid Corporation of India Ltd. (“petitioner/award debtor”) and M/s Mega Electricals (“respondent/award holder”), where an arbitral tribunal had, in 2016, rendered an award in favour of the contractor. After an unsuccessful Section 34 challenge and no appeal under Section 37, the award proceeded to execution. The dispute before the High Court concerned the correct method of calculating interest under that arbitral award.

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2. Summary of the Judgment

2.1 Procedural posture

• Contract for construction of pile foundation awarded on 01.03.2012.
• Disputes referred to arbitration; arbitral award dated 30.12.2016 (one place also mentions 30.10.2016).
• Section 34 challenge by Power Grid dismissed on 22.12.2023; no Section 37 appeal; award thus attained finality.
• Execution filed by Mega Electricals (Commercial Arbitration Execution No. 2/2024) claiming:
  • Rs. 3,87,46,270.18 as on 29.02.2024 + daily interest of Rs. 9171.68 till payment.
• Power Grid deposited Rs. 2,98,94,010 on 16.07.2024 and claimed that the award stood fully satisfied.
• Both sides submitted competing calculation sheets on interest; the Commercial Court (Executing Court) accepted the respondent’s calculation and rejected Power Grid’s objections by order dated 05.02.2025.
• Power Grid filed the present Civil Revision Petition challenging that execution order.

2.2 Core holdings

The High Court holds, in essence:

1. The Executing Court exceeded its jurisdiction by effectively modifying the arbitral award and converting a composite simple interest award into one yielding compound interest/interest on interest.
   The arbitral tribunal had not directed that post-award interest would be payable on the aggregate of principal plus pre-award interest; therefore, the Executing Court could not reconfigure the award using the logic of Hyder Consulting.
2. The Hyder Consulting rule (that “sum” under Section 31(7)(b) includes principal plus pre-award interest) applies only where the arbitral tribunal is silent or leaves the matter unqualified. Where the tribunal has actively exercised its discretion under Section 31(7)(a) and structured the interest “till payment”, the Executing Court cannot superimpose a different interest construct by resorting to Hyder.
3. The arbitral award granted a single, continuous stream of simple interest at 12% p.a. from specified dates (05.01.2013 and 21.03.2015) “till the date of payment”, with an escalation to a maximum of 18% in case of delay beyond 90 days after receipt of the award. This is a case of composite simple interest, not of separately demarcated pre-award and post-award interest on different “sums”.
4. On the issue of partial deposit of 25% of the awarded amount in 2019 (Rs. 32,96,972), which was withdrawn by the award holder:
   • Applying the principle from Nepa Ltd. v. Manoj Kumar Agarwal (and similar Supreme Court authority), no further interest can be charged on the portion that has already been paid/withdrawn from the date of deposit/withdrawal.
   • However, interest was still payable on the entire principal amount up to the date of that deposit (27.08.2019). Power Grid’s calculation wrongly denied interest even for that prior period on the 25% sum.
5. As both the respondent’s and the petitioner’s calculation sheets were inconsistent with the award and the applicable law on interest, the High Court:
   • Set aside the Executing Court’s order dated 05.02.2025, and
   • Remitted the matter back to the Executing Court for fresh calculation, directing both parties to file new calculation sheets strictly in line with the Court’s observations.

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3. Detailed Analysis

3.1 The arbitral award on interest: composite simple interest “till payment”

The heart of the controversy lay in the proper reading of the operative part of the arbitral award. The tribunal held:

“... hereby unanimously award a sum of Rs. 1,31,87,889.00 ... in favour of the Claimants ... We also award and direct that the Respondents shall pay simple interest @12% per annum on the awarded amount of Rs. 1,26,55,793.00 ... against Claim No. 1,2,3,4,5 & 6 and on the awarded amount of Rs. 5,32,096.00 against the Claim No. 7 from 05-01-2013 and from 21-03-2015 respectively ... till the date of payment of the awarded amount by the Respondent to the Claimants within 90 (ninety) days of the receipt of this award. This rate of simple interest @ 12% p.a., would however increase @2% p.a. (subject to a maximum of overall simple interest of 18% p.a.) for every quarter of delay, if any, made by the Respondent in releasing payment of the awarded amount beyond this stipulated period of 90 days mentioned above.”

From this, the High Court draws several crucial inferences:

• The tribunal intended a single, continuous stream of simple interest at 12% p.a. starting from 05.01.2013 (for Claims 1–6) and 21.03.2015 (for Claim 7) up to the actual date of payment.
• Interest is not separately labeled as “pre-award” and “post-award”; instead, there is a composite award of interest “till payment”, with an escalation clause after 90 days.
• There is no direction that post-award interest should be calculated on an amount comprising principal plus pre-award interest. There is no express or necessarily implied provision for interest upon interest or compound interest.

The Court therefore concludes:

“A careful perusal of the operative part of the award makes it clear that the Arbitral Tribunal had not granted compound interest rather awarded composite interest i.e. simple interest per annum effective from the dates mentioned in the award till the date of payment… There is no indication of grant of any interest upon interest or compound interest on the principal amount awarded by the Arbitral Tribunal.” (para 11)

This finding is foundational: once it is accepted that the award only grants composite simple interest, any computation method resulting in effective compound interest or interest on interest must be rejected as contrary to the award.

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3.2 Precedents cited and their role in the Court’s reasoning

3.2.1 Hyder Consulting (UK) Ltd. v. State of Orissa, (2015) 2 SCC 189

Hyder Consulting interpreted Section 31(7)(a)–(b) of the Arbitration Act and overruled the earlier view in State of Haryana v. S.L. Arora & Co. The majority held that:

• Under Section 31(7)(a), the arbitral tribunal may award pre-award interest which then becomes part of the “sum for which the award is made”.
• Under Section 31(7)(b), if the award is silent on post-award interest, such interest (at 18% p.a. or such rate as specified) is payable on that “sum”, i.e., principal plus pre-award interest.

The Meghalaya High Court quotes Hyder Consulting as follows (para 6):

“... Parliament intended that an award for payment of money may be inclusive of interest, and the ‘sum’ of the principal amount plus interest may be directed to be paid by the Arbitral Tribunal for the pre-award period. Thereupon, the Arbitral Tribunal may direct interest to be paid on such ‘sum’ for the post-award period ... at which stage the amount would be the sum arrived at after the merging of interest with the principal...”

However, the Court carefully limits the application of this principle. It notes (para 9) that:

• Section 31(7) confers discretion on the arbitrator to define how interest is to run.
• Once the tribunal has exercised its discretion and provided a clear structure of interest “till the date of payment”, the default rule in Section 31(7)(b) (as construed in Hyder) does not step in to add another layer of interest.
• Thus, Hyder Consulting applies where the arbitral tribunal “leaves a matter unqualified or silent”. It does not license the Executing Court to reconstruct an award that already clearly deals with interest.

This is a significant nuance: the Court effectively says that Hyder is a rule of default construction, not a trump card that can override a tribunal’s explicit interest directions.

3.2.2 UHL Power Co. Ltd. v. State of Himachal Pradesh, (2022) 4 SCC 116

The High Court notes that UHL Power reaffirmed Hyder Consulting’s view that:

• Pre-award interest, once awarded, merges with the principal and forms part of the “sum” for purposes of post-award interest under Section 31(7)(b), in appropriate situations.

But again, the Meghalaya High Court stresses that this merger will only control where the award is silent or leaves the matter to Section 31(7)(b). Where the tribunal’s own directions show it has chosen a particular regime, those directions must prevail.

3.2.3 Morgan Securities and Credits Pvt. Ltd. v. Videocon Industries Ltd., (2023) 1 SCC 602

Morgan Securities is extensively relied upon in the judgment. The Supreme Court there clarified three critical propositions about Section 31(7):

1. Under Section 31(7)(a), the arbitrator has a wide discretion regarding:
   • whether to grant pre-award interest,
   • on what portion of the principal (“whole or any part”),
   • at what rate, and
   • for which period (whole or part of the period up to the award).
2. Section 31(7)(b) operates only when the award is silent on post-award interest, in which case 18% p.a. is statutorily supplied. It does not curtail the arbitrator’s discretion to specify post-award interest in a manner different from that default.
3. Importantly, the arbitrator has the discretion to grant post-award interest on “a part of the sum”, not necessarily on the entire “sum” awarded.

The Meghalaya High Court quotes para 25, 26 and 28.5 of Morgan Securities and sums up the position (para 9–10):

• The arbitral tribunal can choose to award interest on the whole or on any part of the monetary sum.
• Therefore, the notion in Hyder that “sum” includes interest does not override the tribunal’s choice to design interest on only the principal, or only on a part of the total amount.
• Once the arbitrator has exercised that discretion (e.g., by granting one composite rate from specific dates “till payment”), no further interest can be grafted by invoking Section 31(7)(b).

In other words, Morgan Securities is used by the High Court to protect the primacy of the arbitrator’s expressed choice about:

• what forms the base for interest, and
• how the interest is to run over time.

3.2.4 D. Khosla and Company v. Union of India, (2024) 9 SCC 476

Counsel for Power Grid cited D. Khosla to argue that where an award grants interest on the “principal amount” only, an Executing Court cannot reinterpret “amount awarded” to include pre-award interest for the purpose of awarding post-award interest.

Although the Meghalaya High Court does not discuss D. Khosla at length, its reasoning is in harmony with that decision: it refuses to convert a clearly worded award of simple interest on principal amounts into a de facto award of interest on an aggregate of principal and pre-award interest.

3.2.5 Nepa Ltd. v. Manoj Kumar Agarwal, (2023) 17 SCC 659

This case is cited by Power Grid to support the proposition that simple interest runs only on the unpaid portion of the principal. Once a part of the principal is paid, interest cannot continue on that portion.

Although the High Court ultimately leans more heavily on the broader principle summarized in Manoj Kumar Agarwal (discussed below), its application is consistent with Nepa:

• Interest is payable only on what remains unpaid.
• Once a portion of the decreed/awarded sum is deposited and withdrawn, there can be “no liability to pay interest on the amount that stands paid/withdrawn.”

3.2.6 Nepa Ltd. / Manoj Kumar Agarwal line of authority on partial deposits

The judgment refers to the Supreme Court decision in Manoj Kumar Agarwal (cited through the title Nepa Ltd. v. Manoj Kumar Agarwal) while addressing whether interest can continue on a portion of the decretal/awarded amount that has already been deposited and withdrawn.

The High Court summarises the Supreme Court’s holding as follows (para 12):

“[T]here can be no liability to pay interest on the amount that stands paid/withdrawn. It was further held that interest is payable only on amount that is not paid and it will be incongruous to hold that person would be liable to pay interest even in respect of amount which has been paid and handed over to decree holder.”

This directly informs the Court’s conclusion that:

• After Power Grid deposited 25% of the award (Rs. 32,96,972) on 27.08.2019 and Mega Electricals withdrew it, no further interest could accrue on that portion from that date onwards.
• However, interest was payable on the entire principal amount up to 27.08.2019, which Power Grid’s calculation sheet had failed to recognise (see para 13).

3.2.7 Sarup Singh v. Union of India, (2011) 11 SCC 198, and Meenakshi Saxena v. ECGC Ltd., (2018) 7 SCC 479

These decisions were cited by Power Grid for the proposition that an Executing Court:

• is bound by the terms of the decree/award, and
• cannot go behind, modify, or re-write the award at the stage of execution.

The judgment is consistent with this principle: it holds that the Executing Court, by interpreting the award so as to grant post-award interest on an amount different from that envisaged by the arbitral tribunal, effectively modified the award and thereby acted without jurisdiction.

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3.3 The Court’s legal reasoning

3.3.1 Section 31(7) and the arbitrator’s discretion

The High Court’s reasoning turns on a precise reading of Section 31(7) of the Arbitration and Conciliation Act, 1996:

• Section 31(7)(a) – deals with pre-award interest:
  • Arbitrator may include interest in the “sum” for which the award is made.
  • Discretionary as to the rate, the base amount, and the period.
• Section 31(7)(b) – deals with post-award interest:
  • If the award is silent, post-award interest at 18% p.a. is payable on the “sum directed to be paid by the award”.
  • This is a default rule; it does not override explicit directions given by the tribunal.

The Court synthesizes Hyder Consulting and Morgan Securities to hold:

1. The arbitrator’s power to regulate pre-award and post-award interest is wide and primary.
2. Only where the arbitrator is silent on post-award interest, Section 31(7)(b)’s default of 18% p.a. and the “sum = principal + pre-award interest” logic come into play.
3. Where the arbitrator has already:
   • specified the base amounts (here, Rs. 1,26,55,793 and Rs. 5,32,096), and
   • directed simple interest at a particular rate from specific past dates “till the date of payment”, with a defined escalation mechanism,
   there is no room for an Executing Court to apply Section 31(7)(b) as if the tribunal had been silent.

As the Court puts it (para 9):

“Once such discretion is exercised by the Arbitral Tribunal in granting interest, question of additional or compound interest under clause (b) of sub-section (7) of Section 31 would not arise. The principle of Hyder Consulting would apply when the Arbitral Tribunal leaves a matter unqualified or silent.”

Thus, the Executing Court’s move to treat pre-award interest as having merged into principal (for imposing further post-award interest) is rejected as an unwarranted second layer of interest not contemplated by the award.

3.3.2 Why the Executing Court’s approach was impermissible

The Executing Court had accepted the respondent’s calculation sheet which treated the “amount awarded” for purposes of post-award interest as an aggregate sum that effectively included pre-award interest, thereby generating a higher interest liability, akin to compound interest.

The High Court finds this to be legally untenable for two interrelated reasons:

1. Jurisdictional limitation of Executing Courts:
   • The Executing Court is bound by the award and cannot “modify or interpret it” in a way that adds a new substantive benefit not granted by the tribunal.
   • By recasting the base amount for interest and allowing interest on an expanded “sum”, the Executing Court effectively rewrote the award.
2. Substantive inconsistency with the award’s terms:
   • The award clearly gave simple interest at 12% p.a. “till the date of payment”, escalating by 2% per quarter of delay up to a cap of 18% p.a.
   • There is no provision for “interest on accumulated interest” or for modifying the principal after the award date to include pre-award interest for the purpose of further interest.
   • Therefore, accepting the respondent’s computation “was not prepared strictly in accordance with the terms set out in the arbitral award” (para 11).

On this basis, the High Court holds that the Executing Court “was not correct in passing the impugned order by accepting the calculation” (para 11).

3.3.3 Effect of the 25% deposit and withdrawal: no further interest on that portion post-deposit

A second major issue was whether the respondent could charge interest on the entire principal amount even after 25% of the awarded sum had been deposited by Power Grid and withdrawn by Mega Electricals.

The facts:

• Pursuant to an interim order dated 20.05.2019 in the Section 34 proceedings, Power Grid deposited Rs. 32,96,972 (25% of the awarded amount) on 27.08.2019.
• This amount was allowed to be withdrawn by the respondent, subject to the final outcome of the case.

The High Court, relying on Manoj Kumar Agarwal (Nepa line of cases), holds (para 12):

• There can be no continuing interest liability on an amount once it has been deposited and withdrawn by the award holder.
• Interest is payable only on the unpaid balance.
• Thus, “the claim of the respondent with regard to interest on the entire principal amount after 27-08-2019 is not valid in the eye of law. Such interest ought to accrue exclusively on the unpaid portion of the principal amount.”

At the same time, the Court finds error in Power Grid’s counter-calculation:

• Power Grid excluded interest on the 25% amount (Rs. 32,96,972) even for the period prior to 27.08.2019, although under the award the respondent was clearly entitled to interest on the entire principal amount up to the date of its deposit.
• The Court corrects this by holding (para 13) that:

  “The petitioner is under obligation to pay interest on the entire principal amount till 27-08-2019 ... and can claim no interest liability only on the satisfied portion of the principal amount with effect from 27-08-2019.”

Thus, both parties’ calculations were flawed: the respondent by over-claiming interest post-deposit, and the petitioner by under-paying interest pre-deposit.

3.3.4 Remand and directions to the Executing Court

Given these miscalculations, the High Court:

• Sets aside the impugned order dated 05.02.2025 (rejecting Power Grid’s objections), and
• Remits the matter to the Executing Court “for reconsideration of the issue of interest under the arbitral award dated 30-10-2016” (para 14).

The parties are directed to:

• file fresh calculation sheets before the Executing Court,
• in the light of the High Court’s findings on:
  • composite simple interest under the award,
  • non-application of Hyder’s “sum” logic to create compound interest, and
  • the stopping of interest on the deposited 25% from 27.08.2019.

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3.4 Impact and doctrinal significance

3.4.1 Clarifying the scope of Hyder Consulting in execution of arbitral awards

One important contribution of this judgment is its explicit limitation of Hyder Consulting to scenarios where the arbitral tribunal has not already exercised its discretion in structuring interest. The Court states that Hyder’s principle:

• is a default interpretive rule under Section 31(7)(b),
• does not authorize an Executing Court to reframe the award where the tribunal has already granted composite simple interest “till payment”, and
• cannot be used to create compound interest or interest on interest when the award does not so provide.

This has practical ramifications:

• Execution Courts must first closely read the award to see whether the arbitrator has fully specified the interest regime, rather than reflexively applying Hyder’s “sum = principal + pre-award interest” logic.
• Where the award is complete and unambiguous on interest, execution must be strictly in accordance with it.

3.4.2 Strengthening the finality of arbitral awards at the execution stage

By holding that the Executing Court cannot:

• change the base on which interest runs, or
• add interest components not granted by the arbitral tribunal,

the judgment reinforces the principle that:

• An arbitral award, once it survives Section 34/37 scrutiny, is akin to a decree and must be executed, not re-adjudicated.
• The award holder cannot back-door additional benefits through execution by invoking general principles (like Hyder) inconsistent with the actual terms of the award.

3.4.3 Clear guidance on partial deposits and continuing interest

The judgment explicitly applies the Supreme Court’s reasoning on partial deposits to the arbitral context:

• Even if the deposit is made pursuant to an interim order and withdrawn subject to the final outcome, once the money is in the hands of the award holder, interest stops on that portion.
• This avoids unjust enrichment: it would be “incongruous” to allow interest to run on sums already received by the creditor.

For future cases, this means:

• Judgment debtors (or award debtors) can make part deposits in execution or appellate proceedings with the knowledge that:
  • those deposits will reduce their interest burden from the date of deposit/withdrawal, even if the case is still pending; but
  • they remain fully liable for interest up to the date of deposit.
• Decree/award holders cannot claim continuing interest on sums already encashed, simply because the deposit was “conditional”.

3.4.4 Operational guidance for drafting arbitral awards

The judgment indirectly underscores the importance of precise drafting by arbitral tribunals:

• If a tribunal intends to:
  • grant compound interest, or
  • grant post-award interest on an aggregate of principal and pre-award interest,
  it must say so clearly.
• If the tribunal wishes to grant a single stream of simple interest “till payment”, as here, it should do so in unambiguous language to avoid disputes at the execution stage.

The case thus serves as a cautionary note: ambiguities in interest clauses are fertile ground for execution-stage litigation.

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4. Complex Concepts Simplified

4.1 Pre-award interest vs. post-award interest

• Pre-award interest: Interest for the period before the arbitral award – typically from:
  • the date the cause of action arose, or
  • the date of claim, or
  • some contractually specified date,
  up to the date of the award.
• Post-award interest: Interest from the date of the award until the date of actual payment.

Section 31(7) of the Arbitration Act:

• Gives the arbitrator discretion on pre-award interest, and
• Supplies a default rule (18% p.a.) for post-award interest only if the award is silent.

In this case, the tribunal effectively joined both periods into one continuous interest stream at 12% p.a. (with escalation) “till the date of payment”.

4.2 “Composite simple interest” vs. compound interest

• Simple interest:
  • Interest calculated only on the original principal amount.
  • Interest already accrued does not itself earn further interest.
• Compound interest / interest on interest:
  • Interest is periodically added to the principal.
  • Future interest is then calculated on this expanded base (principal + earlier interest).
• Composite simple interest “till payment” (as in this award):
  • The tribunal specifies one rate (here, 12% p.a., with escalation) applied continuously from a backdate to the actual date of payment.
  • No stage at which interest already accrued becomes part of the principal for the purpose of generating further interest.

The key point in this case is that the award’s language supports only composite simple interest, not compound interest.

4.3 The meaning of “sum” in Section 31(7) and its limits

• In Hyder Consulting, the Supreme Court held that “sum” in Section 31(7)(b) can mean:
  • principal amount plus pre-award interest,
  • so that post-award interest can be levied on this entire amount.
• However, Morgan Securities clarified that:
  • This does not reduce the arbitrator’s discretion to grant post-award interest only on a part of the sum.
• The Meghalaya High Court further adds that:
  • This “sum includes interest” concept is a default rule when the award is silent.
  • It cannot be used to override clear language in the award that provides for only simple interest on the principal amounts “till payment”.

4.4 Effect of partial deposits on running interest

A common issue in execution:

• The judgment/award debtor deposits a portion of the decretal amount in court, often to obtain a stay of execution during appeal or Section 34 proceedings.
• The decree/award holder is allowed to withdraw this amount, sometimes on conditions (e.g., furnishing security or subject to final outcome).

The principle, as reaffirmed here:

• From the date the amount is deposited and withdrawn by the creditor, interest on that portion stops — the debtor has fulfilled his obligation as to that part.
• However, interest up to that date still remains payable on the entire sum, because until then it was unpaid.
• Interest continues only on the remaining unpaid balance post that date.

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5. Conclusion and Key Takeaways

5.1 Key legal conclusions

1. Executing Courts cannot convert simple interest awards into compound interest awards.
   Where an arbitral award grants composite simple interest “till payment” on specified principal sums, with a detailed rate structure, an Executing Court:
   • must adhere strictly to that structure, and
   • cannot apply Hyder Consulting to treat pre-award interest as merged principal for the purpose of further post-award interest.
2. Hyder Consulting is a default rule, not a universal principle overriding clear awards.
   Its interpretation of “sum” in Section 31(7)(b) is relevant only when the award is silent on post-award interest. Where the arbitrator has already exercised discretion under Section 31(7)(a), that choice is binding.
3. Interest on satisfied portions of the award stops from the date of deposit/withdrawal.
   Once a part of the award is deposited in court and withdrawn by the award holder:
   • no further interest can be claimed on that portion from that date onwards,
   • though interest up to that date remains due on the entire principal amount.
4. Both over-claiming and under-claiming interest are reversible at the execution stage, but only to bring execution in line with the award.
   The High Court rejects both parties’ calculations and remits the matter, insisting on strict conformity to:
   • the award’s text, and
   • Supreme Court guidance on partial deposits.

5.2 Significance in the broader legal context

This judgment is important for at least three reasons:

• It provides a measured reconciliation of Hyder Consulting and Morgan Securities in the specific context of executing arbitral awards, emphasizing the primacy of the arbitrator’s expressed intention over default statutory rules.
• It extends and concretely applies the Supreme Court’s jurisprudence on interest after partial deposits to arbitral awards, giving litigants practical guidance on how such deposits affect future interest liability.
• It underscores the limited and mechanical nature of execution jurisdiction — Executing Courts are not to “improve” awards, even in the name of applying general principles, but to implement them as written.

For arbitrators, lawyers, and commercial parties, the case serves as a reminder that:

• interest clauses in arbitral awards must be drafted with precision,
• execution strategies must be grounded firmly in the text of the award, and
• partial payments or deposits can be a powerful tool to manage and reduce interest exposure, but must be accurately factored into calculations.

In sum, Power Grid Corporation of India Ltd. v. M/s Mega Electricals strengthens the fidelity of execution proceedings to the arbitral award, clarifies the limits of Hyder-based “interest on interest” interpretations, and aligns the law on partial deposits and interest in the arbitration context with the Supreme Court’s broader civil jurisprudence.