In CC/Devas (Mauritius) Ltd v Republic of India 2022 QCCS 4785, the Québec Superior Court rejected India's application to refuse recognition in Québec of two arbitral awards rendered against it in the Netherlands on the basis that it was immune under subsection 3(1) of the State Immunity Act RSC 1985, c S-18 (SIA). The court concluded that the "commercial activity" exception under section 5 of the SIA applied, meaning India was not immune from the jurisdiction of the court. The court further concluded that India had waived immunity under paragraph 4(2)(a) of the SIA.