Nalin Vallabhbhai Patel vs Atharva Realtors on 1 April, 2026

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    Bombay High Court

    Nalin Vallabhbhai Patel vs Atharva Realtors on 1 April, 2026

    2026:BHC-OS:7780
                 Neeta Sawant                                                                 CARAPL NO. 430 of 2025
    
    
    
                                IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                                    ORDINARY ORIGINAL CIVIL JURISDICTION
                       COMMERCIAL ARBITRATION APPLICATION NO. 430 OF 2025
    
    
                 Nalin Vallabhbhai Patel and Another                                        .....APPLICANTS
    
    
                           : VERSUS :
    
    
                 Atharva Realtors and Others                                             ....RESPONDENTS
    
    
    
                 Mr. Rohaan Cama with Mr. Manish Gala, Mr. Aayush Yadav, Mr. Minil
                 Shah and Ms. Alpa Gala i/b Mr. Nilesh N. Gala for the Applicants.
    
                 Mr. V.M. Chavda with Ms. M.V. Chavan and Ms. Reva Kulkarni                                      for
                 Respondent Nos. 1 and 2.
    
                 Mr. Kapil Shah with Mr. Vatsal Parmar i/b M.K. Juris Associates for
                 Respondents Nos. 3 and 4.
    
    
                                                        CORAM :              SANDEEP V. MARNE, J.
                                                        JUDG. RESD. ON : 11 MARCH 2026.
                                                         JUDG. PRON. ON : 1 APRIL 2026.
                 JUDGMENT:

    1) This Application, filed under Section 11 of the Arbitration
    and Conciliation Act, 1996 (Arbitration Act) for appointment of an
    arbitrator, raises an interesting issue as to whether an arbitrator can be
    appointed when the Court has expressly refused to extend the mandate of

    ______________________________________________________________________________________________

    SPONSORED

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    the earlier arbitrator by rejecting the Petition filed under Section 29A of
    the Arbitration Act. The Court is thus tasked upon to decide the issue as
    to whether refusal by the Court to extend the mandate under Section 29A
    of Arbitration Act would bring to an end the very arbitral proceedings
    making it impermissible to appoint another arbitrator to decide the same
    dispute.

    2) Disputes and differences between the parties have arisen out
    of performance of Deed of Assignment of Development Rights dated 6
    December 2010. Petitioners had filed Commercial Arbitration Petition No.
    1310 of 2019 under Section 9 of the Arbitration Act in this Court seeking
    interim measures. In that Petition, this Court referred the parties to
    arbitration in view of arbitration agreement contained in clause 17 in the
    Deed of Assignment of Development Rights. By order dated 14 November
    2019, this Court appointed a sole Arbitrator for adjudication of disputes
    and differences between the parties by converting Section 9 Petition into
    application under Section 17 of the Arbitration Act. The Arbitrator so
    appointed by order dated 14 November 2019 expressed inability to take
    up the reference and accordingly by order dated 13 January 2020, this
    Court substituted the Arbitrator. The learned sole Arbitrator passed order
    under Section 17 of the Arbitration Act on 31 August 2020. Nothing
    happened thereafter for a considerable period of time. Applicants
    thereafter filed Commercial Arbitration Petition No.221 of 2024 under
    Section 29A of the Arbitration Act seeking extension of mandate of the
    arbitrator. By order dated 18 October 2024, this Court refused to extend
    the mandate of the Arbitrator observing that the Applicants had
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    abandoned the arbitration proceedings. Special Leave to Appeal (C) No.
    29786 of 2024 preferred by the Applicants came to be dismissed by the
    Apex Court by order dated 14 February 2025.

    3) Applicants have thereafter issued notice dated 10 July 2025
    contending inter alia that the cause of action for arbitration continues and
    accordingly made demand for appointment of arbitrator for adjudication
    of the disputes. Respondent was called upon to either consent for the
    suggested Arbitrator or to suggest name of other nominee arbitrator.
    Since the Respondent did not consent for appointment of the arbitrator,
    the present Application is filed under Section 11(6) of the Arbitration Act
    for appointment of arbitrator.

    4) Respondent has appeared in the Application and has opposed
    the same inter alia submitting that appointment of arbitrator is now
    impermissible in the light of termination of arbitration proceedings by
    this Court vide order dated 18 October 2024, which is upheld by the Apex
    Court.

    5) Mr. Cama, the learned counsel appearing for the Petitioner
    has submitted that order dated 18 October 2024 passed by this Court
    merely refuses to extend the mandate of the arbitrator on account of lack
    of sufficient cause for explaining the delay in filing application under
    Section 29A of the Arbitration Act. He submits that the said order does
    not come in the way of this Court appointing an arbitrator. That unlike
    Order IX Rule 9 of the Code of Civil Procedure, 1908 (the Code) which
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    provides for specific bar for new suit in the event of earlier suit being
    dismissed for non-prosecution, there is no such similar provision in
    Section 29A or anywhere in the Arbitration Act. That Section 29A only
    tests the aspect of sufficient cause for delay in conduct of arbitration and
    prosecution thereof. Therefore, order dated 18 October 2024 can be only
    read to mean that the Court concluded that there was no sufficient cause
    for extending the mandate of the Arbitral Tribunal. That the same would
    not tantamount to abandonment of arbitration clause or of arbitral
    proceedings. He relies on judgment of this Court in Tata Motors
    Passengers Vehicles Ltd. & Anr. Vs. Ghosh Brothers Automobiles &
    Ors.1
    in support of his contention that there is a vast difference between
    the concepts of termination of mandate of the arbitrator and termination
    of the arbitral proceedings themselves. He relies on judgment of this
    Court in Khorshed E. Nagarwalla vs. Daryus Soley Panthakey 2 in support
    of his contention that only mandate of the arbitrator gets terminated
    under Section 14 and not the arbitral proceedings. That when provisions
    of Section 29A are read together with Section 32, the present case
    contemplates termination of mandate of arbitrator and not of arbitral
    proceedings.

    6) Mr. Cama further submits that even if it is assumed arguendo
    that there was any embargo against appointment of arbitrator qua the
    same issue and same reliefs, there is a continuing entitlement of the
    Applicant in the facts and circumstances of the present case. That there is

    1 Commercial Arbitration Petition (L) No. 26333 of 2025 decided on 12 February 2026
    2 2010 (4) Mh.L.J. 936
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    a continuous obligation on the part of the contesting Respondents to
    deliver the flats including the 8 flats on 16 and 17 floor. He invites my
    attention to Affidavit in Reply in which Respondents have admitted the
    obligation to provide the flats to the Applicant. That since cause of action
    is continuous, the arbitration agreement also continues and that
    therefore, there is no embargo on this Court to appoint the arbitrator for
    adjudication of such continuous disputes.

    7) Mr. Cama further submits that the defence of Respondents
    about abandonment of earlier arbitral proceedings is misplaced as the
    said defence does not mean that there is abandonment or non-existence
    of the arbitration clause. That existence of arbitration clause is not in
    dispute and there is no question of same being abandoned. That there is
    no valid termination of mandate of arbitral proceedings under Section 32
    of the Arbitration Act. Without prejudice, he submits that the issue of
    abandonment, waiver, res judicata, etc cannot be decided by Reference
    Court under Section 11 of the Arbitration Act. He relies on judgment of
    Apex Court in SBI general Insurance Company Limited vs. Krish
    Spinning3
    , Motilal Oswal Financial Services Limited vs. Santosh
    Cordeiro and Anr.4 and Cox and Kings Limited vs. SAP India Private
    Limited and Anr.5
    and of this Court Rajuram Sawaji Purohit vs. The
    Shandar Interior Private Limited6
    .

    3 (2024) 12 SCC 1
    4 2026 SCC OnLine SC 6
    5 (2025) 1 SCC 611
    6 Commercial Arbitration Application (L) No. 25035 of 2024 decided on 10 October 2025
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    8) Mr. Cama further submits that the order passed by this Court
    in Fedbank Financial Service Ltd. vs. Narendra H Shelar 7 has no
    application to the present case as the same does not lay down any ratio
    and turns squarely on facts of that case. Reference was sought in that case
    in respect of the very same arbitration and the case did not involve issue
    of continuous cause of action.
    He also submits that this Court in Fedbank
    Financial
    (supra) did not consider the issue of interplay between Sections
    29A
    and 32 of Arbitration Act. That the law is subsequently developed
    which does not permit the Reference Court to decide the issue of
    abandonment, waiver, res judicata, etc. He also relies on judgment of
    Constitution Bench of Apex Court in Re : Interplay between arbitration
    agreements under Arbitration and Conciliation Act, 1996 and Stamp
    Act, 18998. On above broad submissions, Mr. Cama would pray for making
    reference of disputes to arbitrator.

    9) The Petition is opposed by Mr. Chavda, the learned counsel
    appearing for Respondent Nos. 1 and 2. He submits that since this Court
    has refused to extend mandate of arbitration, Applicant is precluded from
    seeking reference in respect of the same arbitration. That legislative
    intent behind insertion of Section 29A is speedy resolution of arbitral
    proceedings as held in Mohan Lal Fatehpuria vs. M/s. Bharat textiles
    and Ors.9 and Rohan Builders (India) Private Limited vs. Berger Paints
    India Limited10
    .

    7 2020 SCC OnLine Bom 5252

    8 (2024) 6 SCC 1
    9 SLP (C) No. 13759 of 2025 decided on 10 December 2025
    10 (2025) 10 SCC 802
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    10) Mr. Chavda further submits that termination of mandate of
    Arbitral Tribunal under Section 29A implies termination of arbitral
    proceedings so far as the party at fault is concerned. That the expression
    ‘termination’ used in Section 29A of the Arbitration Act has been
    interpreted by the Apex Court in Rohan Builders (supra) holding that
    arbitral proceedings will get terminated in absence of extension of time
    limit under Section 29A. That the effect of the judgment is that once the
    Court, in its wisdom, does not extend the time limit for arbitral
    proceedings, the same stands terminated at least so far as the party at
    fault is concerned. That only a faultless party is entitled to initiate fresh
    arbitral proceedings.

    11) Mr. Chavda further submits that permitting a defaulting
    party to maintain fresh arbitration would tantamount to review of the
    order rejecting extension of time under Section 29A of the Arbitration
    Act. That upon conjoint reading of provisions of the Arbitration Act, the
    only plausible view that emerges is that while considering the Section 11
    Application filed after rejection of Section 29A Application, the Court
    needs to examine whether Section 29A Application was dismissed due to
    the Applicant’s fault or for any other reason such as default on the part of
    the Tribunal. That in the present case, the Section 29A application is
    dismissed by holding the Applicant responsible and that therefore, there
    is no question of making fresh reference by undertaking the exercise of
    reversal of Section 29A order, which is already confirmed by the Apex
    Court. That provisions of Order IX Rule 9 of the Code would also apply

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    even if not expressly provided for in view of stringent timelines under
    Section 29A of the Arbitration Act.

    12) Mr. Chavda further submits that Section 29A is a self-
    contained code and that provisions contained in Sections 14, 15 or 32 of
    the Arbitration Act cannot be imported to interpret the same. That this
    Court needs to decide the issue of permissibility to make reference and
    the same cannot be left out to be decided by the Arbitral Tribunal. Lastly,
    he submits that the present Application is otherwise barred by limitation.
    He denies that there is any continuous cause of action. He would
    accordingly pray for dismissal of the Application.

    13) Mr. Shah, the learned counsel appearing for Respondent
    Nos.3 and 4 also opposes the Application submitting that there is gross
    abuse of process of law highlighting the negligent manner in which
    previous arbitral proceedings were prosecuted by the Applicant. That
    Respondent Nos.3 and 4 were never involved in the negotiation process.
    He would therefore pray for dismissal of the Application.

    14) Rival contentions urged on behalf of the parties now fall for
    my consideration.

    15) Applicant is desirous of having the disputes and differences
    with the Respondents arising out of the Deed of Assignment of
    Development Rights dated 6 December 2010 adjudicated through
    Arbitration. There is no dispute to the position that clause 17 of the Deed

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    of Assignment and Development Rights dated 6 December 2010 contains
    arbitration agreement. The Arbitral Tribunal for adjudication of the
    disputes was earlier constituted by this Court vide order dated 14
    November 2019 passed in Commercial Arbitration Petition No.1310 of
    2019. The learned sole Arbitrator so appointed was substituted by this
    Court by order dated 13 January 2020. The order further directed that the
    time to complete the arbitration would commence from the date when the
    substituted Arbitrator entered upon the reference to his arbitration.

    16) It appears that the time limit for making Award under
    Section 29A of the Arbitration Act commenced on 10 August 2020. The
    Arbitral Tribunal passed order dated 31 August 2020 deciding the
    application filed by the Applicant under Section 17 of the Arbitration Act.
    It appears that after disposal of Section 17 Application, no further
    proceedings in the arbitration took place for a considerable period of
    time. The Applicant approached this Court seeking extension of mandate
    of the Arbitral Tribunal under Section 29A of the Arbitration Act by filing
    Commercial Arbitration Petition No.221 of 2024 on 26 April 2024. This
    Court has however dismissed the Petition by refusing to extend the
    mandate of the Arbitrator by recording following findings:

    10. After having heard Learned Counsel and perusing the judgments
    upon which reliance was placed, I have no hesitation in holding that the
    Petitioner has not made out any sufficient cause as to why the mandate
    of the Tribunal should be extended under Section 29A(5) of the
    Arbitration Act. I say so because, viz.

    A. Even accepting the Petitioners’ case that there were
    settlement talks between the Parties, the record clearly bears out

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    that these settlement talks did not fructify into a settlement as is
    clear from the Petitioners’ own email dated 20th April 2022. The
    Petitioners did absolutely nothing post this to seek an extension
    of time until the filing of the present Petition which is over 2
    years. There is also no explanation as to why the Petitioner had
    waited for over two years from this date to file the present
    Petition.

    B. Additionally, to accept the Petitioners’ contention that there
    is no time prescribed for filing a Petition under Section 29A,
    would in my view be to turn Section 29A on its head. The very
    provisions of Section 29A of the Arbitration Act lay down the
    stringent timelines in which Arbitration proceedings have to be
    conducted. Section 29A(5) itself makes it clear that the extension
    of period referred to in sub-section(4) is to be granted only if the
    Court is satisfied that sufficient cause is shown for extending the
    mandate. This would therefore in my view include the conduct of
    the Parties so as to demonstrate that the Parties were diligently
    pursuing the arbitration proceedings. The judgment of the
    Hon’ble Supreme Court in the case of Rohan Builders (supra)
    itself makes it expressly clear that extension under Section
    29A(5) was not to be granted mechanically on filing of the
    application. In my view, the Petitioners’ conduct alone would
    disentitle the Petitioner to seek an extension of time.
    Even
    accepting the Petitioners’ case that the mandate expired on 1st
    March 2022 the present Petition has been filed on 26th April
    2024, which delay in my view is adequate to show that the
    Petitioner was not serious in pursuing the arbitration.

    C. Equally, the judgments of the Hon’ble Supreme Court in the
    case of Collector Land Acquisition, Anantnag & Anr. (supra) and
    Hari Shankar Singhania & Ors. (supra) would not apply since the
    said judgments were delivered considering the power of
    condonation of delay under general of law of limitation and not
    in the context of Section 29A. Additionally, it is crucial to note
    that the judgment of the Hon’ble Supreme Court in the case of
    Hari Shankar Singhania & Ors. was in the context of section 20 of
    The Arbitration Act, 1940 and not Section 29A.

    D. In my view, it is plainly clear that after the passing of the
    Interim Order dated 31st August, 2018, the Petitioners have
    abandoned the arbitration proceedings. Nothing prevented
    the Petitioners from approaching this Court earlier and equally,
    nothing prevented the Petitioners from keeping the Learned
    Arbitrator, who is a Former Judge of this Court informed of the

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    settlement talks etc. That is the least that was expected from the
    Petitioner, infact from both Parties. Once Parties had committed
    themselves to the stringent timelines under the Arbitration Act,
    the Parties were then bound to ensure that the settlement talks
    etc. were also conducted and concluded within these timelines or
    then applied for an extension of time at that stage itself and not
    belatedly as has been done in the present case.

    (emphasis and underlining supplied)

    17) Thus, this Court refused to extend the mandate of Arbitral
    Tribunal holding that the settlement talks had failed by 20 April 2022 and
    nothing was done thereafter for over two years. This Court took into
    consideration Applicant’s conduct for denying the extension of mandate.
    Most importantly this Court recorded a finding that after passing of
    interim order dated 31 August 2018 (sic 2020) the Applicant had
    ‘abandoned the arbitration proceedings’. This Court held that nothing
    prevented the Applicant from approaching the Court or at least from
    informing the learned Arbitrator about settlement talks. This Court
    further held
    that it was the duty of the parties to ensure that the
    settlement talks were conducted and concluded within reasonable time.

    18) The order passed by this Court on 18 October 2024 refusing
    to extend mandate of Arbitral Tribunal was challenged by Applicant by
    filing Special Leave to Appeal (C) No.29786 of 2024 before the Hon’ble
    Supreme Court, which has been dismissed by order dated 14 February
    2025.

    19) After being unsuccessful in getting the mandate of the
    Arbitral Tribunal extended under Section 29A of the Arbitration Act, the
    Applicant issued notice dated 10 July 2025 nominating an Arbitrator for
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    resolution of disputes between the parties by referring to clause 17 of the
    Deed of Assignment of Development Rights dated 6 December 2010. The
    notice dated 10 July 2025 repeatedly asserts that there are continuous
    obligations on the Respondents and that their acts constituted continuing
    defaults. Another notice dated 18 July 2025 was addressed by the
    Applicant once again nominating Arbitrator for resolution of the disputes.
    This is how the present Application is filed seeking appointment of the
    Arbitrator.

    20) The issue that arises for consideration is whether an
    Arbitrator can be appointed by this Court under Section 11(6) of the
    Arbitration Act when this Court has already refused to extend mandate of
    the earlier Arbitral Tribunal.

    21) Section 29A of the Arbitration Act has been added to the
    Arbitration Act by the 2015 Amendment for ensuring completion of
    arbitral proceedings in a timely manner without undue delays. Section
    29A
    of the Arbitration Act provides thus:

    29A. Time limit for arbitral award.–

    (1)The award in matters other than international commercial
    arbitration shall be made by the arbitral tribunal within a period of
    twelve months from the date of completion of pleadings under sub-

    section (4) of section 23:

    Provided that the award in the matter of international
    commercial arbitration may be made as expeditiously as possible and
    endeavor may be made to dispose of the matter within a period of twelve
    months from the date of completion of pleadings under sub-section (4)
    of section 23.

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    (2) If the award is made within a period of six months from the date the
    arbitral tribunal enters upon the reference, the arbitral tribunal shall be
    entitled to receive such amount of additional fees as the parties may
    agree.

    (3) The parties may, by consent, extend the period specified in sub-
    section (1) for making award for a further period not exceeding six
    months.

    (4) If the award is not made within the period specified in sub-
    section (1) or the extended period specified under sub-section (3),
    the mandate of the arbitrator(s) shall terminate unless the Court
    has, either prior to or after the expiry of the period so specified,
    extended the period:

    Provided that while extending the period under this sub-section,
    if the Court finds that the proceedings have been delayed for the reasons
    attributable to the arbitral tribunal, then, it may order reduction of fees
    of arbitrator(s) by not exceeding five per cent. for each month of such
    delay.

    Provided further that where an application under sub-section (5)
    is pending, the mandate of the arbitrator shall continue till the
    disposal of the said application:

    Provided also that the arbitrator shall be given an opportunity of
    being heard before the fees is reduced.

    (5) The extension of period referred to in sub-section (4) may be on the
    application of any of the parties and may be granted only for sufficient
    cause and on such terms and conditions as may be imposed by the Court.

    (6) While extending the period referred to in sub-section (4), it shall be
    open to the Court to substitute one or all of the arbitrators and if one or
    all of the arbitrators are substituted, the arbitral proceedings shall
    continue from the stage already reached and on the basis of the evidence
    and material already on record, and the arbitrator(s) appointed under
    this section shall be deemed to have received the said evidence and
    material.

    (7) In the event of arbitrator(s) being appointed under this section, the
    arbitral tribunal thus reconstituted shall be deemed to be in
    continuation of the previously appointed arbitral tribunal.

    (8) It shall be open to the Court to impose actual or exemplary costs
    upon any of the parties under this section.

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    (9) An application filed under sub-section (5) shall be disposed of by the
    Court as expeditiously as possible and endeavour shall be made to
    dispose of the matter within a period of sixty days from the date of
    service of notice on the opposite party.

    (emphasis and underlining supplied)

    22) Thus, the Award in the domestic arbitration is required to be
    made by the Arbitral Tribunal within a period of 12 months from the date
    of completion of pleadings, which period can be extended by six months
    with the consent of the parties. Under sub-section (4) of Section 29A of
    the Act, if the Award is not made within the time specified in sub-section
    (1) or within the extended period agreed between the parties, the
    mandate of arbitrator(s) terminates unless the Court extends the time.
    Thus, what terminates under Section 29A (4) of the Arbitration Act is the
    ‘mandate of the arbitrator’. Second proviso to sub-section (4) provides
    that when Application under sub-section (5) is pending, the mandate of
    the Arbitrator shall continue till disposal of the Application. Thus, what is
    contemplated under Section 29A(4) of the Arbitration Act is essentially
    extension of and termination of ‘mandate of the arbitrator’ and not the
    ‘mandate of arbitration proceedings’. In similar manner, Sections 14 and
    15 of the Arbitration Act also deal with termination of mandate of
    arbitrator. Sections 14 and 15 of the Arbitration Act provide thus:

    14. Failure or impossibility to act.–

    (1) The mandate of an arbitrator shall terminate and he shall be
    substituted by another arbitrator, if–

    (a) he becomes de jure or de facto unable to perform his
    functions or for other reasons fails to act without undue delay;

    and

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    (b) he withdraws from his office or the parties agree to the
    termination of his mandate.

    (2) If a controversy remains concerning any of the grounds referred to in
    clause (a) of sub-section (1), a party may, unless otherwise agreed by the
    parties, apply to the Court to decide on the termination of the mandate.
    (3) If, under this section or sub-section (3) of section 13, an arbitrator
    withdraws from his office or a party agrees to the termination of the
    mandate of an arbitrator, it shall not imply acceptance of the validity of
    any ground referred to in this section or sub-section (3) of section 12.

    15. Termination of mandate and substitution of arbitrator.–
    (1) In addition to the circumstances referred to in section 13 or section
    14
    ,the mandate of an arbitrator shall terminate–

    (a) where he withdraws from office for any reason; or

    (b) by or pursuant to agreement of the parties.

    (2) Where the mandate of an arbitrator terminates, a substitute
    arbitrator shall be appointed according to the rules that were applicable
    to the appointment of the arbitrator being replaced.
    (3) Unless otherwise agreed by the parties, where an arbitrator is
    replaced under sub-section (2), any hearings previously held maybe
    repeated at the discretion of the arbitral tribunal.
    (4) Unless otherwise agreed by the parties, an order or ruling of the
    arbitral tribunal made prior to the replacement of an arbitrator under
    this section shall not be invalid solely because there has been a change
    in the composition of the arbitral tribunal.

    23) As contradistinct from termination of mandate of arbitrator
    under Sections 14, 15 and 29A of the Arbitration Act, Section 32 provides
    for termination of arbitral proceedings. Section 32 of the Arbitration Act
    provides thus:

    32. Termination of proceedings.–

    (1) The arbitral proceedings shall be terminated by the final arbitral
    award or by an order of the arbitral tribunal under sub-section (2).
    (2) The arbitral tribunal shall issue an order for the termination of the
    arbitral proceedings where–

    (a) the claimant withdraws his claim, unless the respondent
    objects to the order and the arbitral tribunal recognises a
    legitimate interest on his part in obtaining a final settlement of
    the dispute,

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    (b) the parties agree on the termination of the proceedings, or

    (c) the arbitral tribunal finds that the continuation of the
    proceedings has for any other reason become unnecessary or
    impossible.

    (3) Subject to section 33 and sub-section (4) of section 34, the mandate
    of the arbitral tribunal shall terminate with the termination of the
    arbitral proceedings.

    24) Thus, arbitral proceedings get terminated by final Award or
    by withdrawal of claim by the Claimant or by termination of proceedings
    with agreement of parties or when the Tribunal finds that continuation of
    proceedings has become unnecessary or impossible. Under sub-section (3)
    of Section 32 of the Arbitration Act, the mandate of the Arbitral Tribunal
    terminates with termination of arbitral proceedings. Thus, Sub-section (3)
    of Section 32 of the Arbitration Act once again makes a distinction
    between concepts of ‘termination of mandate of arbitrator’ and
    ‘termination of arbitral proceedings’. This Court had an occasion to
    consider distinction between the concepts of termination of mandate of
    arbitrator and termination of mandate of arbitral proceedings in Tata
    Motors Passenger Vehicles Ltd.
    (supra) and has held that mere
    termination of mandate of the Arbitral Tribunal does not result in
    automatic termination of arbitral proceedings. This Court held in
    paragraphs 21, 22, 23 and 24 as under:

    21) However, there is difference between the concepts of
    termination of mandate of arbitrator and termination of arbitral
    proceedings. Mere termination of mandate of arbitrator does not
    automatically result in termination of arbitral proceedings, and in
    such an event the reference continues and merely a vacancy occurs in
    the chair of the arbitrator, which can be filled up under Section 15(2) of
    the Arbitration Act. However, the distinct concept of termination of

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    arbitral proceedings is dealt with under Section 32 of the Arbitration Act
    which provides thus:

    xxx

    22) The position that mere termination of mandate of the arbitrator
    does not result in automatic termination of arbitral proceedings is well
    settled and reference in this regard can be made to the judgment of the
    Apex Court in Dani Wooltex Corporation (supra) in which the Apex
    Court has held in Paras-12 to 14 as under:

    12. The Arbitration Act has two provisions for
    terminating an arbitrator’s mandate. Sections 14 and
    15 are the relevant sections. The arbitrator is
    empowered to withdraw from his office, which
    terminates his mandate. However, the arbitral
    proceedings continue by the arbitrator’s substitution.

    13. The order of termination passed by the learned
    arbitrator, in this case, gives an impression that he was of
    the view that unless parties move the Arbitral Tribunal
    with a request to fix a meeting or a date for the hearing,
    the Tribunal was under no obligation to fix a meeting or a
    date for hearing. The appointment of the Arbitral
    Tribunal is made with the object of adjudicating upon the
    dispute covered by the arbitration clause in the
    agreement between the parties. By agreement, the parties
    can appoint an arbitrator or Arbitral Tribunal. Otherwise,
    the Court can do so under Section 11 of the Arbitration
    Act. An arbitrator does not do pro bono work. For him, it
    is a professional assignment. A duty is vested in the
    learned arbitrator or the Arbitral Tribunal to adjudicate
    upon the dispute and to make an award. The object of the
    Arbitration Act is to provide for an efficient dispute
    resolution process. An arbitrator who has accepted his
    appointment cannot say that he will not fix a meeting to
    conduct arbitral proceedings or a hearing date unless the
    parties request him to do so. It is the duty of the Arbitral
    Tribunal to do so. If the claimant fails to file his
    statement of claim in accordance with Section 23, in view
    of clause (a) of Section 25, the learned arbitrator is bound
    to terminate the proceedings. If the respondent to the
    proceedings fails to file a statement of defence in
    accordance with Section 23, in the light of clause (b) of
    Section 25, the learned arbitrator is bound to proceed
    further with the arbitral proceedings. Even if the
    claimant, after filing a statement of claim, fails to appear

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    at an oral hearing or fails to produce documentary
    evidence, the learned arbitrator is expected to continue
    the proceedings as provided in clause (c) of Section 25.

    Thus, he can proceed to make an award in such a case.

    14. On a conjoint reading of Sections 14 and 15, it is
    apparent that an arbitrator always has the option to
    withdraw for any reason. Therefore, he can withdraw
    because of the parties’ non-cooperation in the
    proceedings. But in such a case, his mandate will be
    terminated, not the arbitral proceedings.

    23) Similarly, this Court in Kifayatullah Haji Gulam Rasool (supra)
    has held in paras-11, 12, 16 and 17 as under:

    11. Section 14 specifies the grounds for terminating the mandate
    of an arbitrator and method of doing so. The grounds for
    terminating the mandate are : (i) the arbitrator becomes de
    jure or de facto unable to perform his function or (ii) for some
    other reasons fails to act without undue delay or (iii) the
    arbitrator withdraws from his office or (iv) the parties agree to
    the termination of his authority as an arbitrator; whereas three
    methods can be employed for terminating the mandate of the
    arbitrator. They are (a) by withdrawal of the arbitrator from his
    office (b) by agreement of parties and (c) by decision by the
    Court.

    12. Section 15 provides for additional grounds for termination of
    the mandate and for appointment of substitute arbitrator. The
    additional grounds provided are (a) where he withdraws from
    office for any reason or (b) by or pursuant to the agreement of the
    parties. Though sub-section (1) purports to state additional
    grounds for termination of authority of an arbitrator but one of
    the grounds mentioned therein is covered by the grounds set out
    in clause (b) of sub-section (1) of section 14. On the authority of
    the arbitrator being terminated, a substitute arbitrator in place of
    arbitrator whose authority is terminated has to be appointed and
    such appointment, as per sub-section (2) is required to be made
    by following the same procedure as followed while appointing
    the arbitrator who is being substituted.

    16. On the above backdrop let us consider the legal provisions
    providing for commencement and termination of the arbitration
    proceedings.

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    (a) Section 21 of the Act provides for commencement of
    the arbitral proceedings. This section provides that in the
    absence of an agreement between the parties to the reference,
    the arbitral dispute in respect of a particular dispute shall
    commence on the date on which a request for that dispute to be
    referred to the Arbitration is received by other party. If in the
    arbitral agreement parties provide any other mode for
    commencement of the arbitral proceedings, the arbitral
    proceedings will commence in accordance therewith.

    (b) Section 25 incorporates the course of action arbitral
    Tribunal may adopt in the event of party committing any of the
    three defaults mentioned in this section. The provision of section
    25
    is intended to enable the arbitral tribunal not to allow any
    proceedings to drag on at the instance of one or the other party.
    What is contemplated in this section is an order passed by
    arbitral Tribunal terminating arbitral proceedings. No such order
    has been passed by the arbitral tribunal in this case as such even
    provision of section 25 is not available to the petitioners. The
    said provision cannot be invoked before this Court. However, the
    petitioners are at liberty to obtain appropriate orders in this
    behalf from the arbitral Tribunal but not from this Court.

    (c) Section 32 of the Act makes provision for termination
    of the arbitral proceedings. Under this section it is provided, that
    the arbitral proceedings shall automatically stand terminated
    when final award is made. Hence, for automatic termination of
    the arbitral proceedings, arbitral award has to be final. Reading of
    section 32 unequivocally provides that only ‘final award’ shall
    terminate the arbitral proceedings. The final award is one which
    decides or completes decision of claims presented.

    The arbitral proceedings can also be terminated by an
    order of the arbitral Tribunal which order can only be passed
    when claimant withdraws the claim or when the parties to the
    reference agree on the termination of the proceeding, or the
    arbitral Tribunal finds that continuation of the arbitral
    proceeding has become unnecessary or impossible. As per clause

    (b) of sub-section (2) of section 32 the parties to the agreement
    have also been given liberty to terminate arbitral proceedings but
    such a request must be made to the arbitral tribunal by the
    parties to the proceedings and it must be accepted by the arbitral
    Tribunal by an order passed in that behalf. As per sub-section (3)
    the mandate of the arbitral tribunal, can also be brought to an
    end with termination of arbitral proceedings subject to section 33
    and sub-section (4) of section 34 of the Act.

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    17. In the above premises, the Act makes specific provision for
    commencement and termination of the arbitral proceedings. In
    the instant case, none of the events as contemplated under
    section 32 of the Act have taken place. No final award has been
    passed. No joint request depicting agreement of parties have
    been made to the arbitral tribunal to terminate proceedings. No
    orders have been passed by the Arbitral Tribunal as contemplated
    under sub-section (2) of section 32 of the Act. Therefore, it
    cannot be said that the arbitral proceeding have come to an
    end. I, therefore, hold that the arbitral proceedings have not
    come to an end even though the mandate of the arbitrators
    have come to an end.

    24) Therefore, mere withdrawal by the learned Arbitrator from the
    arbitral proceedings vide letter dated 18 March 2021 has not resulted in
    termination of arbitral proceedings under Section 32 of the Arbitration
    Act. The reference continued notwithstanding the withdrawal by the
    learned Arbitrator.

    (emphasis supplied)

    25) The distinction between the concepts of termination of
    mandate of arbitrator and termination of arbitral proceedings is also
    highlighted in Division Bench judgment of this Court in Khorshed E.
    Nagarwalla
    (supra) in which it is held in the context of provisions of
    Section 14 and 15 of the Arbitration Act as under:

    4. Both the provisions if read would show what is terminated is the
    mandate of the arbitrator and not the provision for arbitration.

    Section 11(2) thereafter provides that in the event of vacancy in the
    arbitral tribunal and the parties not agreeing to appoint an arbitrator,
    any aggrieved party can move under section 11(5) of the said Act
    requesting the Chief Justice or his designate to fill in the vacancy. Thus,
    the Act itself contains provisions for reconstitution of the Tribunal even
    in the case where the named arbitrator expires.

    (emphasis supplied)

    26) Thus, when the time limit specified in Section 29A of the
    Arbitration Act expires and the Court refuses to extend the same, the

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    mandate of the arbitrator terminates. Does this mean that the arbitral
    proceedings still continue and can Court appoint a substitute arbitrator in
    such circumstances? There appears to be no direct judgment on the issue
    with elaborate discussion on distinction in the concepts of termination of
    mandate of arbitrator under Section 29A of the Arbitration Act and
    termination of arbitral proceedings under Section 32. However, in
    Fedbank Financial Services Limited (supra), learned Single Judge of this
    Court had an occasion to deal with similar situation. In case before this
    Court, the sole Arbitrator had entered upon the reference and after filing
    of statement of claim and statement of defence, nothing had happened at
    all. The Respondent therein therefore filed an application for closure of
    the proceedings on the ground that the same were not concluded within
    one year. The Applicant therein filed an Application under Section 29A of
    the Arbitration Act, which was dismissed by this Court. Thereafter, the
    Applicant therein filed Application under Section 11 of the Arbitration
    Act for start of the process all over again by appointing the arbitrator. In
    the light of the above factual position, this Court passed following order
    in Fedbank Financial Services Ltd. (supra).

    5. The Respondent then filed an application for closure of the
    proceedings saying that they had not been concluded within one year.
    On this the learned sole arbitrator made an application that since time
    had not been extended, there being no application by the Petitioner
    under Section 29-A of the Arbitration and Concilliation Act, the
    arbitration proceeding was closed with the mandate terminated. Parties
    were set at liberty to take appropriate steps in accordance with law. This
    order passed by the learned sole arbitrator was on 18 th July 2019.

    6. Ms. Bhogale cannot dispute the fact that the Petitioner was late in
    filing a Section 29-A Petition. It did file that Petition, Arbitration
    Petition No. 1271 of 2019. I dismissed it on 9 th January 2020.

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    7. The situation therefore is that an arbitration previously invoked with
    a nomination agreed by the Respondent has now come to an end. The
    Arbitral tribunal mandate has been terminated. There is no extension of
    time.

    8. What the Petitioner now seeks is to start the process all over again by
    presenting this application under Section 11. This is a second go-around
    for the same arbitration.

    9. The opposition from the Respondents is that there must be some
    limit. The emphasis in arbitration law is on a speedy and time-bound
    disposal. If a Petitioner invoking arbitration is itself remiss in diligently
    prosecuting the arbitration, the submission is that it surely cannot be
    open to the Petitioner to come back to Court and constantly seek to
    reopen the arbitration like this. If such constant circular actions are
    permitted, then conceivably there would be no end to arbitration at all
    and no finality to the disputes. The arbitration law cannot possibly aid, it
    is submitted, a party who is not vigilant in prosecuting its rights and
    remedies.

    10. I agree. There is no explanation for the delay.

    The order of the arbitral tribunal, though short, does not in any way
    assist the Petitioner.

    11. I do not see how an arbitration clause can be constantly revived and
    brought back to life again and again like this. If the Petitioner has any
    rights under the contract in question it is at liberty to pursue those but
    its arbitral remedy must surely be considered to be closed.

    12. The application is dismissed.

    27) Thus, in Fedbank Financial Services Ltd. (supra) this Court
    refused to make reference by appointing arbitrator holding that the
    arbitration clause could not be constantly revived and brought back into
    life again and again. This Court agreed with submission of the
    Respondent therein that arbitration law cannot aid a party who is not
    vigilant in prosecuting its rights and remedies. However, this Court left

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    open the remedy other than arbitration for the Applicant in respect of
    rights under the contract.

    28) Perusal of the judgment in Fedbank Financial Services Ltd.
    (supra) would indicate that the argument of difference between
    termination of mandate of Arbitrator under Section 29A of the Arbitration
    Act and termination of the arbitration proceedings under Section 32 of
    the Arbitration Act was not raised before this Court. It therefore becomes
    difficult to accept that Fedbank Financial Services Limited (supra) lays
    down an abstract proposition of law that in no case, application for
    appointment of Arbitrator can ever be made after refusal by the Court to
    extend the mandate of the Arbitrator under Section 29A of the Arbitration
    Act.

    29) There can be myriad reasons why the Award is not made
    within the time limit specified in Section 29A of the Arbitration Act.
    Sometimes parties may be responsible for the delay and sometimes even
    the Arbitral Tribunal may be responsible for delay. In a case where
    Arbitral Tribunal is responsible for the delay in concluding the arbitral
    proceedings and in making the Award and if the Court refuses to extend
    mandate of the Arbitrator under Section 29A (4) of the Arbitration Act,
    can it be contended that the arbitral proceedings would also end? The
    answer, to my mind, appears to be in the negative. No doubt under sub-
    section (6) of Section 29A of the Arbitration Act, the Court has power to
    substitute the Arbitrator and this power of substitution is to be
    necessarily exercised keeping in mind the conduct of the Arbitrator. In a

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    given case where the appointed Arbitrator does not make progress in the
    proceedings and parties are not at fault, the Court can substitute the
    Arbitrator while extending the mandate under Section 29A. But there may
    be a case that the Court does not substitute the Arbitrator but also does
    not grant extension of mandate of the Arbitrator under Section 29A(4) of
    the Arbitration Act. Whether parties can be made to suffer for the acts of
    the Arbitrator in such a situation? The answer can obviously not be in the
    affirmative. This is also because mere termination of mandate of
    Arbitrator under Section 29A (4) of the Arbitration Act does not
    automatically result in termination of arbitration proceedings under
    Section 32 of the Arbitration Act.

    30) A converse however is true. With termination of mandate of
    arbitration proceedings, the mandate of Arbitrator also comes to an end
    under sub-section (3) of Section 32 of the Arbitration Act. The Arbitration
    Act
    otherwise does not recognize the concept that termination of
    mandate of Arbitrator under Sections 14, 15 or 29A of the Arbitration Act
    brings to an end the very arbitration proceedings. In my view therefore, it
    is difficult to accept an abstract principle that in every case where the
    Court refuses to extend the mandate of Arbitrator, the arbitral
    proceedings themselves would automatically come to an end and that the
    Court would be precluded from making appointment of another Arbitrator
    under Section 11(6) of the Arbitration Act.

    31) Therefore, in my view, appointment of arbitrator after refusal
    by Court to extend mandate of previous arbitrator under Section 29A

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    would depend on facts of each case and the question as to ‘who is at fault’
    would provide the key for solving the problem. If parties are responsible
    for delay and Court has refused to extend the mandate on account of
    conduct of parties, the arbitral proceedings will have to be treated as
    having been terminated. This is necessary because if the arbitral
    proceedings are not treated to have been terminated, parties at fault
    would get another bite at the cherry by seeking appointment of another
    arbitrator. Finding recorded by Section 29A Court against them would
    become redundant and they would be free to get another Arbitrator
    appointed even though the Court has consciously refused to extend
    mandate of the previous Arbitrator. If fresh arbitrator is appointed by
    exercise of powers under Section 11(6) of the Arbitration Act after Section
    29A Court refuses to extend the mandate of arbitrator by recording a
    finding that the Claimant had abandoned the arbitration, exercise of
    power under Section 11(6) of the Arbitration Act would tantamount to
    review of the order passed under Section 29A.

    32) In the present case however, the Applicant is found to be
    extremely negligent in prosecuting arbitral proceedings before the
    previous Arbitrator. This Court has recorded a specific finding that the
    Applicant had abandoned ‘the arbitration proceedings’. The issue for
    consideration is whether in such circumstances, the principle of expiry of
    mandate of arbitrator not resulting in automatic expiry of mandate of
    Arbitral Tribunal can be applied in the present case? The answer to this
    question also appears, to my mind, to be in the negative. When this Court
    did not extend the mandate of the previous arbitrator on account of
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    conduct of the Applicants and has held that the Applicants had
    abandoned the arbitration proceedings, appointing another arbitrator at
    the behest of the Applicants would be like rewarding them for their faults.

    33) Considering the facts of the present case, if this Court, in
    exercise of referral jurisdiction under Section 11(6) of the Arbitration Act
    proceeds to appoint an arbitrator, it would virtually sit in appeal, if not
    review, over the findings recorded while deciding the Petition under
    Section 29A of the Arbitration Act. When the Court exercising powers
    under Section 29A of the Arbitration Act has recorded an emphatic
    finding that ‘the Petitioners have abandoned the arbitration proceeding’, this
    Court cannot reward them by providing an opportunity to arbitrate the
    disputes. The doors of arbitration are closed for them by Section 29A
    Court. What Applicant is seeking to do in the present case is an attempt
    to overreach the findings recorded by Court while refusing to extend the
    mandate under Section 29A of the Arbitration Act. Such an attempt
    cannot be countenanced in law. As observed above, there may be cases
    where the Court can refuse to extend mandate of Arbitrator for reasons
    not attributable to the parties and in such circumstances, it is possible
    that referral Court can exercise powers under Section 11(6) of the
    Arbitration Act to appoint a substitute arbitrator by concluding that the
    arbitration proceedings still continues. But that principle cannot be
    applied in the present case.

    34) Thus, on conjoint reading of provisions of Sections 11, 29A
    and 32 of the Arbitration Act, the position that emerges is that
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    application for appointment of Arbitrator is not maintainable in a case
    where the Court has refused to extend mandate of the arbitrator under
    Section 29A of the Arbitration Act due to fault of the Applicant. It is only
    in cases where refusal to extend mandate of the Arbitrator under Section
    29A
    of the Arbitration Act is due to reasons other than fault of the
    Applicant, the referral Court would be justified in entertaining and
    deciding the application for appointment of arbitrator under section 11
    (6)
    of the Arbitration Act. I am fortified in my view, by judgment of the
    Apex Court in Rohan Builders (supra). The issue before the Apex Court in
    Rohan Builders (supra) was slightly different i.e. whether an application
    for extension of time under Section 29A of the Arbitration Act can be filed
    after expiry of the period for making the arbitral Award. The Apex Court
    has held that such an application for extension of time under Section 29A
    (4) and (5) of the Arbitration Act is maintainable even after expiry of
    12/18 months. However while answering the issue, the Apex Court has
    drawn distinction between a ‘faultless party’ and the ‘party at fault’. In
    paragraph 17 of the judgment, the Apex Court has refused to give
    restrictive or normal interpretation to the language used under Section
    29A (4)
    of the Arbitration Act and has held that narrow interpretation
    would present an additional challenge by relegating a ‘faultless party’ to a
    fresh reference or appointment of an arbitrator under the Arbitration Act,
    thereby impeding the arbitration rather than facilitating it. It is held by
    the Apex Court in paragraphs 12, 13, 14, 15, 16 and 17 of the judgment as
    under:

    12. The word “terminate” in Section 29-A(4) has to be read in the context
    of the said provision. 19 It should not be read as an isolated word with a
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    strict dictionary meaning, but rather in conjunction with the
    surrounding words and expressions which warrant recognition and
    consideration. This evinces the legislative intent. Secondly, the
    legislative preference for the term “terminate” over “suspend” is
    apparent, since the word “suspend” could cause incongruity and a legal
    conundrum if no party files an application for an extension of time. In
    such a scenario, the arbitral proceedings would stand suspended ad
    infinitum. Therefore, the legislature by using the word “terminate”

    intends to affirm the principle of party autonomy. Resultantly, if neither
    party moves an application for an extension of time for making the
    award, the arbitration proceedings are terminated. Consequences follow.
    Clearly, the use of the word “suspension” would have led to infeasible
    ramifications.

    13. The word “terminate” in Section 29-A(4) makes the Arbitral Tribunal
    functus officio, but not in absolute terms. The true purport of the word
    “terminate” must be understood in light of the syntax of the provision.
    The absence of a full stop after the word “terminate” is noteworthy. The
    word “terminate” is followed by the connecting word “unless”, which
    qualifies the first part with the subsequent limb of the section i.e.
    “unless the court has, either prior to or after the expiry of the period so
    specified, extended the period”. The expression “prior to or after the
    expiry of the period so specified” has to be understood with reference to
    the power of the court to grant an extension of time.

    14. Accordingly, the termination of the arbitral mandate is conditional
    upon the non-filing of an extension application and cannot be treated as
    termination stricto sensu. The word “terminate” in the contextual form
    does not reflect termination as if the proceedings have come to a legal
    and final end, and cannot continue even on filing of an application for
    extension of time. Therefore, termination under Section 29-A(4) is not
    set in stone or absolutistic in character.

    15. An interpretive process must recognise the goal or purpose of the
    legal text. Section 29-A intends to ensure the timely completion of
    arbitral proceedings while allowing courts the flexibility to grant
    extensions when warranted. Prescribing a limitation period, unless
    clearly stated in words or necessary, should not be accepted. Bar by
    limitation has penal and fatal consequences. This Court in North Eastern
    Chemicals Industries (P) Ltd. v. Ashok Paper Mill (Assam) Ltd.
    21
    observed: (SCC p. 812, para 37)

    “37. … When no limitation stands prescribed it would be
    inappropriate for a Court to supplant the legislature’s wisdom by

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    its own and provide a limitation, more so in accordance with
    what it believes to be the appropriate period.”

    16. Courts should be wary of prescribing a specific period of limitation in
    cases where the legislature has refrained from doing so. If we give a
    narrow and restrictive meaning to Section 29-A(4), we would be
    indulging in judicial legislation by incorporating a negative stipulation
    of a bar of limitation, which has a severe annulling effect. Such an
    interpretation will add words to widen the scope of legislation and
    amount to modification or rewriting of the statute. If the legislature
    intended such an outcome, it could have stated in the statute that “the
    Court may extend the period only if the application is filed before the
    expiry of the mandate of the arbitrator, not after”. Indeed, there would
    have been no need to use the phrase “after the expiry of the period” in
    the statute. In other words, a rigid interpretation would amount to
    legislating and prescribing a limitation period for filing an application
    under Section 29-A, when the section does not conspicuously so state.
    Rather, the expression and intent of the provision are to the contrary.

    17. In our opinion, a restrictive interpretation would lead to rigour,
    impediments and complexities. A party would have to rush to the court
    even when the period of arbitral mandate of twelve months has not
    expired, notwithstanding the possibility of a consent-based extension of
    six months under Section 29-A(3). Narrow interpretation presents an
    additional challenge by relegating a faultless party to a fresh reference
    or appointment of an arbitrator under the A&C Act 23, thereby
    impeding arbitration rather than facilitating it.

    (emphasis and underlining supplied)

    35) Thus, in paragraph 17 of the judgment in Rohan Builders
    (supra) it is held that narrow interpretation presents an additional
    challenge by relegating a ‘faultless party’ to a fresh reference or
    appointment of an arbitrator under the Arbitration Act. These findings
    clearly suggest that if mandate of the arbitrator is not extended under
    Section 29A of the Arbitration Act, the faultless party can seek a fresh
    reference for appointment of an Arbitrator.

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    36) Thus, the key is to determine whether the party is at fault or
    is faultless. If the party is found to be at fault, on account of whose
    conduct, the Court has refused to extend mandate of an arbitrator under
    Section 29A (4) of the Arbitration Act, the application for making fresh
    reference or appointment of arbitrator must necessarily be rejected. On
    the other hand, if the party applying under Section 11(6) is faultless, its
    application for appointment of an arbitrator would not only be
    maintainable but it would be the duty of the Court to appoint the
    arbitrator for ensuring adjudication of disputes between the parties on
    merits.

    37) Mr. Cama has strenuously urged before me that this Court
    needs to conduct limited enquiry into the aspect of existence of
    arbitration agreement and leave the rest of the issues for being decided by
    the Arbitral Tribunal. It is contended that the objection raised by the
    Respondents essentially relating to waiver, acquiescence, res judicata etc.
    can be considered and decided by the Arbitrator. Reliance is placed on
    judgments of the Apex Court in State Bank of India General Insurance
    Company Limited vs. Krish Spinning (supra), Motilal Oswal Financial
    Services Limited (supra), Cox and Kings Ltd. (supra) and Re: Interplay
    between arbitration agreements under Arbitration and Conciliation Act,
    1996
    and Stamp Act, 1899 (supra). I am unable to agree. The enquiry
    before me is not whether the claims sought to be adjudicated by the
    Applicant are barred by principles of waiver, acquiescence or res judicata.
    The issue is about exercise of jurisdiction by the referral Court under
    Section 11(6) of the Arbitration Act. Though there may exist arbitration
    ______________________________________________________________________________________________

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    agreement between the parties, if the mandate of the arbitral proceedings
    has been terminated, this Court cannot exercise referral jurisdiction
    under Section 11(6) of the Arbitration Act and appoint an arbitrator where
    the reference itself is not in existence. The present application is
    premised on an assumption as if only the seat of the arbitrator is vacant
    but the reference and the mandate of the arbitral proceedings continue.
    This assumption itself is faulty. Neither the chair of the arbitrator is
    vacant nor the reference is alive. The arbitration proceedings have come
    to an end and therefore, no arbitrator can be appointed by this Court in
    exercise of referral jurisdiction under Section 11(6) of the Arbitration Act.
    Therefore, reliance by Mr. Cama on judgments of the Apex Court in SBI
    General Insurance Company, Motilal Oswal, Cox and King and Re :

    Interplay (supra) is inapposite. Similar is the position in respect of
    judgment of this Court in Rajuram Sawaji Purohit (supra) in which the
    Award was set aside under the Section 34 of the Arbitration Act and
    thereafter application under Section 11 of the Arbitration Act was filed for
    appointment of an arbitrator on lines of Section 43(4) of the Arbitration
    Act. It was sought to be urged by the Respondent therein that the claim
    was time barred as Section 34 order was pending challenge before Section
    37
    Court. It is in the light of those facts that this Court proceeded to
    exercise referral jurisdiction by appointing the Arbitrator leaving open the
    issue of limitation.
    The issue before this Court in Rajuram Sawaji
    Purohit
    (supra) was altogether different and the said judgment has no
    application to the facts of the present case.

    ______________________________________________________________________________________________

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    38) In my view therefore, this Court needs to adjudicate the issue
    as to whether arbitrator can be appointed or not, and the issue cannot be
    left open to be decided by the arbitrator as once the Arbitral Tribunal is
    constituted, it cannot decide whether reference made by the Court is valid
    or not.

    39) Mr. Cama has also sought to suggest that the Applicant has
    invoked the arbitration afresh in respect of a continuous cause of action.
    He has taken me through contents of notices dated 10 July 2025 and 18
    July 2025 in support of his contention that there is a continuous cause of
    action and that a fresh reference can be made by ignoring the previous
    round of arbitration in respect of continuous defaults on the part of the
    Respondent. I am afraid, this argument cannot be accepted. Both the
    notices refer to previous invocation notice dated 21 December 2018 and
    state that the same are issued ‘in view of the continuing breach’. Both the
    notices thereafter refer to the interim order dated 31 August 2020,
    handing over of possession of five flats in pursuance of the interim Award
    and failure to comply with further directions in the impugned Award by
    handing over possession of balance flats and depositing amounts received
    against sale of two flats in escrow account. Thus, both the notices dated
    10 July 2025 and 18 July 2025 specifically refer to the previous round of
    arbitration. It is therefore, difficult to accept the case of the Applicants
    that the reference is sought in respect of a fresh cause of action. There is
    nothing pleaded in the application to the effect that the Applicants are
    not seeking adjudication of disputes which formed part of previous round
    of arbitration or that they are seeking adjudication of only those disputes
    ______________________________________________________________________________________________

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    in respect of which any fresh cause of action has arisen. In fact the
    contention of ‘continuous cause of action’ is premised on an assumption
    that the Applicants also want to arbitrate the disputes covered by
    previous arbitration, in respect of which the cause continues. It is not the
    case of the Applicants that arbitration is sought in respect of a ‘fresh
    cause of action’ which has arisen after termination of previous arbitral
    proceedings. The argument of alleged continuous cause of action is thus
    raised only to seek an escape out of consequence of order passed by this
    Court on 18 October 2024 and by the Apex Court on 14 February 2025.

    40) In view of the discussion above, this Court is unable to make
    a reference nor can appoint the Arbitrator since the arbitration
    proceedings have come to an end in the present case.

    41) Consequently, the Commercial Arbitration Application is
    dismissed. There shall be no order as to costs.

      NEETA                                                       [SANDEEP V. MARNE, J.]
      SHAILESH
      SAWANT
       Digitally signed by
       NEETA SHAILESH
       SAWANT
       Date: 2026.04.01
       20:17:38 +0530
    
    
    
    
    

    ______________________________________________________________________________________________

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