Before

Before, the word 'before' means, inter alia, 'ahead of'; in presence or sight of; under the consideration or cognisance of. The two events sought to be interconnected by use of the term 'before' must have proximity of relationship by reference to occurrence; the later event proximately following the preceding event as a foreseeable or 'within-sight' certainty, Firm Ashok Traders v. Gurumukh Das Saluja, (2004) 3 SCC 155 (168): AIR 2004 SC 1433. (Arbitration and Conciliation Act, 1996, s. 9)