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The State of Commercial Laws – FIDIC, 1999 versus Section 28 of the Indian Contract Act
Adopting an international contract into the Indian context without making necessary adaptations carries with it numerous problems. A perfect case study to establish the same is Clause 20.1 contained in Part 1 of the Conditions of Contract for Design-Build and Turnkey (First Ed., 1999) published by FIDIC which reads as follows: