Ce Testing Company Private Limited vs Madhucon Projects Limited And Anr on 30 July, 2026

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    Calcutta High Court

    Ce Testing Company Private Limited vs Madhucon Projects Limited And Anr on 30 July, 2026

                         IN THE HIGH COURT AT CALCUTTA
                              COMMERCIAL DIVISION                           2026:CHC-OS:336
    
                                  ORIGINAL SIDE
    
                             RESERVED ON: 09.07.2026
                             DELIVERED ON: 30.07.2026
                                      PRESENT:
                    THE HON'BLE MR. JUSTICE GAURANG KANTH
                                 EC-COM 72 OF 2025
                              IA No. GA-COM 1 OF 2025
                     CE TESTING COMPANY PRIVATE LIMITED
                                    VS
                     MADHUCON PROJECTS LIMITED AND ANR.
    
    Appearance: -
    
    Mr. Shiv Shankar Banerjee, Adv.
    Ms. Arijita Ghosh, Adv.
    Mr. Siddhartha Chamria, Adv.
    Mr. Adhip Narayan Banerjee, Adv.
                                                .............. for the award holder
    
    
    Mr. Anubhav Sinha, Adv.
    Mr. Shirsho Banerjee, Adv.                ................. for the award-debtor
    
    
                                      JUDGMENT
    

    Gaurang Kanth, J. :-

    1. The Award Holder has filed the present execution petition seeking

    enforcement of the Arbitral Award dated 10.11.2020 passed by the West

    Bengal Micro and Small Scale Enterprises Facilitation Council (Herein

    after referred as “WBMSE Facilitation Council”).

    2. The Award Holder is a company engaged in the business of supplying shell

    and auger equipment and rendering allied services, including geological

    mapping, seismic refraction survey and drilling of boreholes. The

    Judgment Debtor No.1, awarded five separate contracts to the Award

    Holder between the years 2011 and 2012 by issuing Letters of

    Acceptance/work orders. Two of the said contracts pertained to road
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    projects and the remaining three related to tunnel works in connection

    with various railway and highway projects, including the Jiribam-Tipul

    (Imphal) New Railway Line Project of the N.F. Railway, the four-laning of

    NH-34 between Barasat and Krishnagar and the four-laning of NH-31

    between Rajauli and Bakhtiyarpur in the State of Bihar.

    3. It is the case of the Award Holder that the works entrusted under the

    aforesaid contracts were duly executed and completed to the satisfaction of

    the Judgment Debtor. Running account bills were raised from time to time

    in respect of the works executed. According to the Award Holder, although

    the Judgment Debtor released certain part payments, substantial amounts

    remained unpaid under the respective contracts, leaving an aggregate

    outstanding principal sum of Rs.1,11,39,966/-.

    4. In view of the failure of the Judgment Debtor to liquidate the outstanding

    dues, the Award Holder invoked the provisions of the Micro, Small and

    Medium Enterprises Development Act, 2006 by approaching the WBMSE

    Facilitation Council. The dispute was first taken up for conciliation and,

    upon failure thereof, proceeded to arbitration. According to the Award

    Holder, the Judgment Debtor appeared at the initial sitting before the

    Council but failed to participate in the subsequent proceedings despite due

    notice. Consequently, the Council passed an Award dated 10.11.2020 in

    favour of the Award Holder.

    5. It is the further case of the Award Holder that no application for setting

    aside the Award was filed within the period prescribed under law and, as

    such, the Award has attained finality and has become enforceable as a

    decree of the Court.

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    2026:CHC-OS:336

    6. The Award Holder states that on 16.12.2021 it forwarded to the Judgment

    Debtor a certificate issued by its Chartered Accountant indicating that the

    total amount payable under the arbitral Award dated 10.11.2020, as on

    that date, was Rs.4,63,61,459/-, comprising the principal amount of

    Rs.1,11,39,966/- together with interest amounting to Rs.3,52,21,493/- in

    terms of the Award. According to the Award Holder, despite receipt of the

    said communication, the Judgment Debtor neither satisfied the Award nor

    took any steps towards payment of the decretal dues.

    7. In view thereof, the Award Holder preferred the present execution Petition

    seeking enforcement of the Arbitral Award dated 10.11.2020.

    8. Service of the execution petition having been completed, the Award Debtor

    entered appearance and filed an application being GA No. 1 of 2025

    seeking dismissal of the execution petition.

    9. The Award Debtor principally contended that the execution petition was

    not maintainable on the grounds that: (i) this Court lacked territorial

    jurisdiction, as the Award Debtor had no registered office, assets or

    business within the territorial jurisdiction of this Court and the works in

    question were executed outside its jurisdiction; (ii) the purported arbitral

    award dated 10.11.2020 was not a valid or enforceable award since only

    an unsigned copy had been communicated to it and no signed copy, as

    contemplated under Sections 31(1) and 31(5) of the Arbitration and

    Conciliation Act, 1996, had ever been delivered; (iii) in the absence of

    delivery of a signed copy of the award, the period of limitation for filing an

    application under Section 34 of the Act had not commenced and,

    consequently, the present execution petition under Section 36 of the Act
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    2026:CHC-OS:336
    was premature. On the aforesaid grounds, the Award Debtor prayed for

    dismissal of the execution petition.

    Submissions on behalf of the Award Holder

    10. Mr. Shiv Shankar Banerjee, learned Counsel for the Award Holder submits

    that the Award dated 10.11.2020 was passed by the Arbitral Tribunal

    constituted by the WBMSE Facilitation Council under the provisions of the

    Micro, Small and Medium Enterprises Development Act, 2006, and that

    the general practice followed by the said Council is to retain the original

    signed award with itself and to furnish only a duly certified copy thereof to

    the parties. It is submitted that in the instant case as well, the copy of the

    award supplied to the parties under cover of letter dated 26.11.2021 is a

    certified copy, each page whereof has been authenticated by Mr. A.K.

    Ghosh, Deputy Director (SSE), MSME Directorate, Government of West

    Bengal, and that page 10 of the said award itself reflects that the original

    award was signed by all the members of the Council. Learned Counsel

    further submits that mere absence of original signatures on the copy

    served upon the parties does not render the award invalid or non-est, and

    that in case of any doubt in this regard, this Court may call for a report

    from the MSME Facilitation Council to verify the factum of signing of the

    original award.

    11. In support of the above submission, learned Counsel for the Award Holder

    places reliance upon the judgment of a coordinate Bench of this Court in

    JD Electrical Products Pvt Ltd Vs. Purbachal Udyog, reported as AIR

    Online 2025 Cal 936, as also the Division Bench judgment of this Court

    in National Agricultural Cooperative Marketing Federation of India

    Ltd. Vs. M/s. R. Piyarelall Import & Export Ltd., reported as AIR 2016
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    2026:CHC-OS:336
    Calcutta 160, wherein it has been authoritatively held that a certified

    photocopy of the original award, bearing the photocopied signatures of the

    arbitrators and duly authenticated by the institution administering the

    arbitration, satisfies the requirement of a “signed copy” of the award as

    contemplated under Section 31(5) of the Arbitration and Conciliation Act,

    1996, and that the law does not mandate that every copy furnished to the

    parties in an institutional arbitration must bear the original signatures of

    the arbitrators. It is accordingly submitted that the certified copy of the

    award served upon the Judgment Debtor herein is a valid and binding

    award, duly delivered in compliance with Section 31(5) of the said Act, and

    is capable of being executed as a decree of the Court.

    12. On the question of territorial jurisdiction, learned Counsel for the Award

    Holder submits that the place of arbitration was Calcutta, the proceedings

    having been conducted by the WBMSE Facilitation Council from its office

    at New Secretariat Building, Kolkata, and that consequently this Hon’ble

    Court, being the Court within whose jurisdiction the seat/place of

    arbitration is situated, has jurisdiction to entertain the instant execution

    application. Reliance in this regard is placed upon the judgment of the

    Hon’ble Supreme Court in Sundaram Finance Ltd. Vs. Abdul Samad,

    reported as AIR 2018 SC 965, as also upon the celebrated judgment of

    the Constitution Bench in Bharat Aluminium Co. Vs. Kaiser Aluminium

    Technical Services Inc., reported as AIR 2012 SC (Supp) 444, wherein

    it has been held that the courts having supervisory jurisdiction over the

    arbitration, being the courts of the seat/place of arbitration, are the

    appropriate forum for all proceedings arising out of the arbitration

    agreement, including proceedings for enforcement of the award.
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    2026:CHC-OS:336

    13. In view of the aforesaid, learned Counsel for the Award Holder submits

    that the objections raised by the Judgment Debtor as to the validity of the

    award and the jurisdiction of this Court are devoid of merit, that the award

    dated 10.11.2020 is a valid, binding and executable award, and that this

    Court has the necessary territorial jurisdiction to entertain and adjudicate

    the instant execution proceedings.

    Submission on behalf of the Award Debtor

    14. Learned Counsel, Mr. Anubhav Sinha, appearing for the Judgment Debtor

    submits that the document supplied to the parties as the purported award

    dated 10.11.2020 is admittedly an unsigned copy, forwarded under cover

    of letter dated 26.11.2021. It is submitted that under Section 31(1)(a) read

    with Section 31(5) of the Arbitration and Conciliation Act, 1996, an arbitral

    award is required to be made in writing, signed by the arbitrators or the

    majority thereof, and that a signed copy thereof must be delivered to each

    party. It is contended that mere certification by an officer of the MSME

    Directorate cannot be treated as a substitute for the signatures of the

    Learned Arbitrators themselves. It is submitted that the certification

    appended by the Directorate, at best, authenticates that a copy

    corresponds to some original document, but does not and cannot cure the

    fundamental defect arising from the absence of the arbitrators’ signatures

    on the copy actually served upon the parties. According to the judgment

    debtor such a certified but unsigned copy does not satisfy the mandatory

    requirement of Section 31(5) of the said Act. In support of this submission,

    Learned Counsel for the Judgment Debtor relies upon the judgment of the

    Himachal Pradesh High Court in M/s Sterkam Pharma Pvt. Ltd. Vs.

    Symbiosis Pharmaceuticals Pvt. Ltd. (CMP No. 274 of 2023), as also
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    2026:CHC-OS:336
    upon the judgment of a coordinate Bench of this Court in Odisha Power

    Generation Corporation Ltd. Vs. Techniche Consulting Service & Ors.,

    reported as 2024 SCC OnLine Cal 10386.

    15. Learned Counsel for the Judgment Debtor further seeks to distinguish the

    judgments relied upon by Learned Counsel for the Award Holder in JD Vs.

    Purbachal Udyog (supra) and National Agricultural Cooperative

    Marketing Federation of India Ltd. Vs. R. Piyarelall Import & Export

    Ltd. (supra), submitting that in both the said cases, the copies of the

    awards furnished to the parties were certified photocopies bearing the

    photocopied signatures of the arbitrators, duly certified by the

    administering institution. It is submitted that it was in that specific factual

    context that the Courts held such certified photocopies to be “signed

    copies” within the meaning of Section 31(5) of the Arbitration and

    Conciliation Act, 1996. According to the learned counsel, in the present

    case, the copy of the award served upon the Judgment Debtor does not

    bear even the photocopied signatures of the Arbitrators, and consequently

    the ratio of the said judgments, being premised on the existence of

    photocopied signatures on the certified copy, has no application to the

    facts of the instant case. Learned Counsel accordingly submits that the

    said judgments are clearly distinguishable and cannot be pressed into

    service by the Award Holder to contend that a copy wholly bereft of the

    arbitrators’ signatures, whether original or photocopied, satisfies the

    mandate of Section 31(5) of the said Act.

    16. On the question of territorial jurisdiction, Learned Counsel for the

    Judgment Debtor submits that the cause of action in the present matter

    did not arise in Calcutta, that no seat or venue of arbitration was ever
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    2026:CHC-OS:336
    fixed by agreement between the parties, and that the mere fact that the

    WBMSE Facilitation Council happened to hold its sittings in Calcutta is

    purely fortuitous and cannot, by itself, confer jurisdiction upon this Court.

    It is further submitted that no assets, movable or immovable, of the

    Judgment Debtor are situated within the territorial jurisdiction of this

    Court, and that in the absence of any agreed seat of arbitration or any part

    of the cause of action having arisen within this jurisdiction, this Court has

    no territorial jurisdiction to entertain the present execution petition.

    According to the Award Debtor, this Court is not the ‘Court’ within the

    meaning of Section 2 (1)(e) of the Arbitration & Conciliation Act, 1996. In

    support of this contention, reliance is placed upon the judgment of the

    Hon’ble Supreme Court in Dakshin Haryana Bijli Vitran Nigam Ltd. Vs.

    Navigant Technologies Pvt. Ltd., reported as 2021 (7) SCC 657, as also

    upon the judgment of the coordinate Bench of this Court in Odisha Power

    Generation Corporation Ltd. (supra), wherein it has been held that the

    mere location where the WBMSE Facilitation Council conducts its

    proceedings does not, by itself, confer jurisdiction upon the Court at that

    place, particularly where the arbitration agreement between the parties

    contemplates a different seat or venue, and that the statutory arbitration

    under the MSMED Act does not override or obliterate the independent

    arbitration agreement between the parties.

    17. Learned Counsel for the Judgment Debtor further places reliance upon the

    WBMSE Facilitation Council Rules, 2016, and in particular Rules 7, 8, 9

    and 16 thereof, to contend that the arbitral proceedings before the Council

    cannot be said to have culminated in a final and binding award unless and

    until a duly signed copy of the award is served upon the parties in terms of
    9

    the said Rules. It is submitted that in the present case, since no 2026:CHC-OS:336
    such

    signed copy has ever been served upon the Judgment Debtor, the arbitral

    proceedings must be treated as not having terminated within the meaning

    of Section 32 of the Arbitration and Conciliation Act, 1996.

    18. In view of the aforesaid, it is submitted on behalf of the Judgment Debtor

    that since no valid signed copy of the award has been served upon the

    parties, the period of limitation for filing an application under Section 34 of

    the Arbitration and Conciliation Act, 1996 has neither commenced nor

    expired, and consequently the present execution petition, filed under

    Section 36 of the said Act, is wholly premature and not maintainable.

    Learned Counsel accordingly submits that the instant execution petition,

    being premature both on the ground of want of a valid and duly signed

    award and on the ground of lack of territorial jurisdiction of this Court, is

    liable to be dismissed.

    Legal Analysis

    19. This Court has heard the arguments advanced by the Learned Counsel for

    both the parties and has examined the materials and documents placed on

    record.

    20. The moot question arising from the present matter is whether an award

    issued from the office of the WBMSE Facilitation Council, which does not

    bear the signatures of the Arbitrators constituting the said Council, is

    enforceable at this stage.

    21. Section 31(1) of the Arbitration and Conciliation Act, 1996 mandates that

    an arbitral award shall be made in writing and shall be signed by the

    members of the arbitral tribunal. Sub-section (2) thereof permits, in

    proceedings with more than one arbitrator, the signatures of the majority
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    2026:CHC-OS:336
    of the members to suffice, provided the reason for any omitted signature is

    stated. Sub-section (5) further mandates that after the arbitral award is

    made, a signed copy thereof shall be delivered to each party. The Hon’ble

    Supreme Court, in Union of India Vs. Tecco Trichy Engineers &

    Contractors, reported as (2005) 4 SCC 239, has held that the delivery of

    an award under Section 31(5) is not a mere formality but a matter of

    substance, since it is only upon such delivery that the stage of termination

    of arbitral proceedings under Section 32 of the said Act arises, and several

    periods of limitation, including that for challenging the award under

    Section 34(3), are set in motion by such delivery. This position was

    reiterated by the Hon’ble Supreme Court in State of Maharashtra Vs.

    ARK Builders, reported as (2011) 4 SCC 616, and again in Dakshin

    Haryana Bijli Vitran Nigam Ltd (Supra), wherein it was held that the

    period of limitation for challenging an Award under Section 34 can only

    commence from the date of receipt of a signed copy of the Award, and not

    from the receipt of an unsigned or draft award.

    22. It is true that in National Agricultural Cooperative Marketing

    Federation of India Ltd. (Supra), a Division Bench of this Court held that

    a certified photocopy of the original award, bearing the photocopied

    signatures of the Arbitrators and duly authenticated by the administering

    institution, would satisfy the requirement of a “signed copy” under Section

    31(5) of the said Act. The rationale of that judgment, however, rests

    entirely on the fact that the signatures of the arbitrators, though

    photocopied, were physically reproduced and visible on the face of the copy

    served upon the parties. Upon perusal of the award dated 10.11.2020

    annexed to the instant execution petition, this Court finds that the last
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    page thereof merely records the names of the Chairman and four Members

    of the WBMSE Facilitation Council against the notation “Sd/-” which is

    only a typed representation denoting that a signature exists on the original,

    but does not reproduce the actual signatures of the Arbitrators. What has

    been certified by Mr. A.K. Ghosh, Deputy Director (SSE), MSME

    Directorate, Government of West Bengal, is therefore not a photocopy

    carrying the signatures themselves, but a typed/printed document bearing

    only the certifying officer’s own attestation that the original was signed.

    This distinguishes the present case squarely from National Agricultural

    Cooperative Marketing Federation of India Ltd. (Supra), where the

    photocopied signatures of the arbitrators were themselves visible and

    certified as a true reproduction thereof. A certificate by a third party,

    however authorised, that an unseen original was signed cannot be equated

    with a copy that itself bears the signatures, since the very object of Section

    31(5), as explained in Tecco Trichy Engineers (supra), is to permit each

    party to satisfy itself, from the document delivered to it, that the award

    emanates validly from the Tribunal.

    23. WBMSE Facilitation Council Rules, 2016, particularly Rules 7, 8, 9 and 16,

    which govern the conduct of conciliation and arbitration proceedings

    before the Council, do not dispense with the requirement of Section 31 of

    the Arbitration and Conciliation Act, 1996. On the contrary, arbitration

    under Section 18(3) of the MSMED Act, 2006 is expressly required to be

    conducted as if it were an arbitration in pursuance of an arbitration

    agreement under Section 7(1) of the said 1996 Act, and the provisions of

    the 1996 Act apply thereto as they would to any other arbitration. There is

    nothing in the said Rules of 2016 which permits substitution of the
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    mandatory signatures of the Arbitrators by administrative certification

    alone.

    24. Section 32(1) of the Arbitration and Conciliation Act, 1996 provides that

    arbitral proceedings stand terminated by the final arbitral award. Where

    the mandatory requirement of Section 31(5) has not been complied with by

    delivery of a signed copy of the award. Consequently, it cannot be said that

    the arbitral proceedings have terminated in the eye of law. Section 36(1) of

    the Arbitration and Conciliation Act, 1996 permits enforcement of an

    award only after the time for making an application to set aside the award

    under Section 34 has expired. Since that time has, on the facts before this

    Court, not even commenced to run, the award dated 10.11.2020 is not, at

    this stage, in a form capable of being enforced as a decree of the Court,

    and the instant execution petition is premature.

    25. Since the execution petition itself is found to be premature for want of a

    validly delivered signed copy of the award, this Court does not consider it

    necessary or appropriate, at the present stage, to examine or adjudicate

    upon the question of territorial jurisdiction of this Court raised by the

    Judgment Debtor. That question would arise for consideration only if and

    when the award, upon due compliance with Section 31(5) of the

    Arbitration and Conciliation Act, 1996, attains the character of a valid and

    enforceable award, and the same shall be kept open to be agitated by the

    parties at the appropriate stage.

    26. In view of the foregoing, this Court is not inclined, at this stage, to treat

    the award dated 10.11.2020 as a validly delivered award within the

    meaning of Section 31(5) of the Arbitration and Conciliation Act, 1996, and

    consequently the instant execution petition, being premature, cannot
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    proceed further in its present form. Liberty is granted to both the parties to

    approach the WBMSE Facilitation Council for obtaining a duly signed copy

    of the award dated 10.11.2020, or a copy bearing reproduction of the

    signatures of the Arbitrators duly certified as such, in compliance with

    Section 31(5) of the Arbitration and Conciliation Act, 1996.

    27. Upon such signed copy being obtained and served in accordance with law,

    it shall be open to both parties to avail themselves of their respective legal

    remedies in accordance with law.

    28. The question of territorial jurisdiction of this Court, raised by the

    Judgment Debtor, is kept open and shall be considered, if necessary, only

    at the stage when the award attains the character of a valid and

    enforceable award.

    29. Accordingly, the present petition is dismissed as premature at this stage,

    with the aforesaid liberty.

    30. Pending applications, if any, stand dismissed.

    (GAURANG KANTH, J.)

    SAKIL AMED (P.A)



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