A.es. Engineering Pvt. Ltd. V. Urgo Capital Ltd.

A non-signatory can be subjected to arbitration without its prior consent, only in exceptional cases where there is, inter alia, direct commonality of the subject matter, and the agreement between the parties is a composite transaction for achieving the common object.
In this case the two impugned agreements are thus not adequately inter-connected to warrant a composite reference to arbitration.