Arbitration And The Courts - Judicial Views On Article 29A

Author: LawSphereX

Category: Arbitration & ADR

Published: 2026-08-23T18:07:29.876602+00:00

Updated: 2026-08-26T17:12:07.723+00:00

ARBITRATION AND THE COURTS: JUDICIAL VIEWS ON

ARTICLE 29A

Devansh Saxena, University of Allahabad

ABSTRACT

A study of the functioning and issues connected with Section 29A of the

Arbitration and Conciliation Act, 1996. Section 29A was inserted in 2015 in order to streamline and hasten arbitration in India, by introducing a strict time-limit on submission of an arbitral award. 1 At first glance, the rule appears to be quite uncomplicated; once the pleadings are complete, the tribunal shall submit their arbitral award within a legally prescribed period of 12 months. There is provision for an additional period of 6 months, to which the parties consent. After the lapse of that time, the arbitrator's powers shall have ceased, absent the intervention of the "Court. "2 In practice, the process has proven to be less than simple. Different High Courts read the section differently; some read the commitment timelines as mandatory and others somewhat more permissive.

The meaning of "Court" also became an issue until the Supreme Court stated that it referred the principal civil court having original jurisdiction. 3 The different interpretations produced confusion for arbitrators and parties and led to concerns regarding efficiency, justice and party autonomy. This study adopts a doctrinal approach, with reference to the legislative framework, the detailed leading cases and with attention to academic commentary. 4 This study argues that, while Section 29A is a step in the right direction, the rigidity contained in the section may act to frustrate the purpose of arbitration altogether.

INTRODUCTION

Delay is often referred to as the Achilles’ heel of arbitration in India. Whereas arbitration is meant to be a quicker and more flexible option to litigation, the arbitral process would often stretch over years at a time, which compromised parties’ faith in the arbitration process itself. To combat this situation, the 2015 amendment to the Arbitration and Conciliation Act, 1996, introduced Section 29A for the first time, whereby any arbitral award needed to be made within 12 months from when the pleadings were deemed to be closed. The parties are also entitled to consent to an additional six-month extension. Despite what may seem to be a straightforward provision, this part of Section 29A led to extensive litigation regarding issues of potential interpretation and statutory ambiguity.

Courts were tasked with deciding whether the time-lines set out in Section 29A were mandatory or directory; what party had the ability to extend time, the appointing authority under Section 11, or the principal civil court; and if an extension of the timeline could extend beyond the expiration of the tribunal's mandate or extension of time, or after the issuing of an award. Moreover, there has been uncertainty among litigants due to differences in reasoning by the High Courts in India. The contradictory reasoning by different benches of High Courts, where sometimes narrow readings were favored, while other times wider readings were adopted, all added to the uncertainty.

On a recent occasion, the Supreme Court clarified that the term "Court" in Section 29A refers to the principal civil Court of original jurisdiction, which includes High Courts which are exercising their ordinary civil jurisdiction in this context. The Supreme Court ruling has provided certainty, but the journey through the courts in this context has highlighted the tension between the goals of efficiency in arbitral proceedings and fairness in arbitral proceedings. 5

LITERATURE REVIEW

Statutory background: Section 29A was introduced by the Arbitration and Conciliation (Amendment) Act, 2015. It gave that for domestic arbitrations, a tribunal would need to render an award within 12 months from the date of completion of pleadings. Parties could agree to extend that deadline for an additional 6 months; however, after the six months the tribunal's mandate would lapse. 6 The 2019 amendment clarified that international arbitrations should likewise be completed "as expeditiously as possible" (attempting to stay within the 12 month framework) and confirmed that if a party is kept waiting by a pending application to extend, the tribunal stayed in existence until the matter was resolved. Comparative / policy observations: Scholars observe that while many jurisdictions encourage a timely award (e. g. UNCITRAL Model Law art.

17 encourages parties to aspire to have an award within one year) few jurisdictions impose automatic cuts short. 7 Early critiques warned that having a strict kill-switch could create incompatibilities with party autonomy, and efficiency. The Supreme Court observed that Section 29A is not punishment; judges do not get to read into Section 29A some hidden limitation period (which would create "penal and fatal" consequences. ). Rather, courts must take a flexible approach to applying the "sufficient cause" element in Section 29A - and take benefit of the safeguards in Section 29A to provide substitution of arbitrators, and deterrent costs for delay. Judicial conflict ("Court" definition): Pre-2024 decisions show a split.

Some of the High Court’s interpreted Section 29A by analogy to their appointing powers under Chapter III, and provided that if a tribunal was appointed under Section 11, only the appointing court (HC/SC) can extend its term. Others insisted that “Court” must be interpreted per Section 2(1)(e) (the principal civil court of original jurisdiction), regardless of who appointed the arbitrator. Analysts have criticized the former as overreach: as the Supreme Court has held, even if a High Court appoints an arbitrator, it does not become the “Court” for judicial remedies. 8

Case law summaries: Legal alerts and articles document these tensions. For instance, Khaitan & Co. note that divergent HC judgments (e.g. Delhi, Calcutta, Gujarat vs. Bombay, Kerala) “spawned confusion” over venue. Leading briefs argue that an extension power in Section 29A (4) is a remedial, Section 14like tool, and thus should vest in the principal civil courts, not be limited to appointing authorities. These commentaries anticipate the Supreme Court’s eventual resolution.9

METHODOLOGY

This paper is based on doctrinal research, relying primarily on legal texts and judicial decisions rather than empirical data. • Primary sources: The foundation of the study is the Arbitration and Conciliation Act, 1996 (as amended) along with judicial pronouncements. Particular attention is given to key Supreme Court and High Court judgments that interpret and apply Section 29A. • Secondary sources: Law firm commentaries, academic writings, and journal articles are consulted to frame debates, identify divergent perspectives, and provide critical insights. These sources help in contextualising the judicial trends but do not form the basis of substantive conclusions. • Comparative material: References are made to international frameworks such as UNCITRAL and select foreign arbitration practices.

These are used sparingly and only to provide perspective, with the central focus remaining on Indian jurisprudence. The research is interpretive in nature, tracing how courts have applied or departed from the legislative intent underlying Section 29A, and assessing whether judicial interpretation furthers the objective of promoting efficiency in arbitration.

BACKGROUND & GOALS of SECTION 29A The 1996 Arbitration and Conciliation Act was modeled loosely off the UNCITRAL Model Law but made no reference to any time limits that would need to be adhered to during arbitration. 10 The thinking was to provide the parties freedom and flexibility; however it appeared that this freedom was allowing delays. As a result, arbitration in India began to become notorious for its long delays, with some arbitrations taking months if not years, which completely undermined the very objective of overcoming lengthy court dispute resolution. Many began perceiving arbitration in India as being just as slow as the courts, and justified serious concern for both domestic and international users of arbitration. Many highlighted that these perceptions were a serious roadblock for India in its aspirations to become a global arbitration hub.

The Law Commission of India in its 246th Report in 2014 detailed the issues associated with these delays as placing the confidence of users in arbitration at risk11. It recommended changing the law to provide timely resolution of disputes. As part of these recommendations the Commission suggested that law should provide a default timeline of issuance of arbitral awards with some degree of judicial oversight. This formed the basis for the 2015 Amendment Act (and its Section 29A). As enacted, Section 29A (1) imposed a strict requirement that arbitral awards in domestic arbitrations be made within twelve months of the completion of pleadings. Parties were permitted to extend this period by six months through mutual consent, but any further extension required an application to “the Court.

” Sub-section (4) reinforced this framework by providing that, absent such extension, the mandate of the arbitral tribunal would automatically terminate. If a party seeks an extension beyond these stipulated periods, the request must demonstrate sufficient cause and is at the court’s discretion; the court may also penalize arbitrators for undue delay by reducing their fees or substituting them, aiming to deter procedural procrastination. This legislative scheme sets clear limits for arbitration duration while balancing flexibility through judicial oversight, thereby strengthening accountability and efficiency in dispute resolution. 12

A subsequent amendment clarified that where an extension application is pending before the

court; the tribunal may continue to function until the application is decided—thus preventing a procedural vacuum. Therefore, Section 29A has two objectives: • Expediency and efficiency – Parliament was concerned that if it did not impose a clear temporal discipline on arbitrators and parties, arbitration would slip into a parallel form of litigation. • Balance and fairness – In recognizing the potential for courts to extend the time of arbitral proceedings on the showing of sufficient cause, the law ensures that the aims of expediency do not undermine the interests of justice in complex, or special, cases. In this regard, Section 29A is indicative of an attempt to balance two competing interests: the global interest in timely dispute resolution, and the domestic interest in appropriate procedural protections.

This is an important legislative attempt to make arbitration in India a more credible and timely form of dispute resolution that is consistent with international norms at the national level.

STATUTORY FRAMEWORK AND LEGISLATIVE INTENT

Section 29A has been added to the Arbitration and Conciliation Act by the 2015 Amendment to control the time lines for arbitration processes and to foreshadow delays to guarantee the arbitration process is carried out expeditiously. It prescribes a strict timeline: awards in domestic arbitrations will be made within 12 months from the date the arbitral tribunal commences reference, which is after the pleadings have been made. (For international commercial arbitrations, the Act requires that awards are to be made as expeditiously as may be, considering the time-frame of no more than 12 months as an aspirational period.

) Section 29A is significant in that it provides two levels of extension: (i) the tribunal may extend the 12-month period for a period of up to 6 months if all the parties consent; and (ii) if an award has not been made after the first 18 months, the tribunal's mandate is automatically terminated unless a court grants a further extension for "sufficient cause". 13

In other words, absent extension, the arbitrators lose authority to award after this cut-off. • Time-lines: Domestic awards – 12 months from completion of pleadings; thereafter parties can consent to a 6-month extension. International awards – “as expeditiously as possible,” with 12 months as target. • Automatic termination: If the tribunal misses the deadline (18 months in total), its mandate ends, subject to court extension. • Court extension (29A (4)–(6)): The statute empowers the designated “court” to extend time and even substitute arbitrators if delay is attributable to them. By design, substitution is consequential on extension: only the same court that can extend may replace arbitrators. •

2019 Amendment safeguards: The 2019 Amendment clarified that if an extension

application is pending, the tribunal’s mandate continues until the court decides.14 This prevents a deadlock where arbitrators would otherwise lapse before a court can act. In sum, Section 29A reflects a legislative intent to expedite arbitration by enshrining hard deadlines, while allowing a narrowly circumscribed “safety valve” – court-ordered extensions for “sufficient cause” – to avoid injustice in exceptional cases.

JUDICIAL CONTROVERSY: IDENTITY OF THE “COURT” UNDER SECTION

29A

One of the earliest and most persistent controversies surrounding Section 29A concerns the identity of the “Court” competent to extend the mandate of the arbitral tribunal. The definitional clause in Section 2(1) (e) provides that, in the case of domestic arbitration, the “Court” means the principal civil court of original jurisdiction in a district (ordinarily the District Court) and includes a High Court in exercise of its ordinary original civil jurisdiction. By contrast, Section 29A (4) simply states that “the Court” may extend the deadline, without any express cross-reference to Section 11 (appointment of arbitrators) or other provisions. This lacuna produced two competing judicial approaches.

Narrow view: “Court” means the appointing authority under Section 11: Several High Courts have taken the view that Section 29A must be read in conjunction with Section 11, with the reasoning being that allowing the District Court to change or extend the mandate of an arbitrator appointed by the High Court or Supreme Court would be institutionally “incongruent. ” This approach emphasizes the preservation of judicial hierarchy and the authority of the court that made the original appointment. Proponents argue that the appointing court, whether the High Court or Supreme Court, holds a unique position to oversee further proceedings, as it already has full knowledge of the case context, parties, and complexities.

Moreover, restricting Section 29A applications to the appointing authority eliminates the risk of conflicting orders and ensures procedural clarity, which is crucial for fostering confidence in the arbitration process and reducing administrative delays. • In Delhi Development Authority v. Tara Chand Sumit Construction Co. (Delhi High Court, 2020), the Court held it was clear that the only authority that could deal with the Section 29A application was the one who appointed the arbitrator. In this case, the arbitrator was appointed under Section 11(6) by the High Court, and so a District Court cannot interfere with that mandate. 15 • The Calcutta High Court followed suit in Amit Kumar Gupta v. Dipak Prasad (2021) by ruling that where the appointment has been made under Section 11, any subsequent extension or substitution has also ultimately to be sought from the same court.

16 • The Gujarat High Court, in Nilesh Ramanbhai Patel v. Bhanubhai Ramanbhai Patel (2019), decided that “Court” under Section 29A could not be separated from the Section 11 appointing venue. 17 Collectively, this “narrow” interpretation anchored the Section 29A jurisdiction to the appointing authority under Section 11, notwithstanding the somewhat general definitional bracket provided in Section 2(1) (e).

Broad view: “Court” means the principal civil court under Section 2 (1) (e): Other benches rejected this reasoning, adhering instead to the plain statutory text. They stressed that Parliament had consciously used the defined term “Court” in Section 29A (4), without importing the Section 11 framework. • In A’Xykno Capital Services Ltd. v. State of U. P. 18 (Allahabad High Court, 2018), the Court concluded that an extension petition lies with the “Court” defined in Section 2(1)(e), i. e. the principal civil court of original jurisdiction, irrespective of who appointed the arbitrator. • The Bombay High Court produced conflicting strands: in Cabra Instalaciones y Servicios v. Maharashtra State Electricity Distribution Co. Ltd.

19 (2019), one bench suggested that, in an international arbitration, only the Supreme Court could grant an extension as appointing authority; • The Kerala High Court in Lots Shipping Co. 20 was also cited by later benches for the opposite proposition—that the plain meaning of Section 2(1) (e) should govern. This “broad” interpretation thus treated Section 29A as a self-contained provision, with jurisdiction determined only by the definitional clause and not by the identity of the appointing authority.

KEY CLARIFICATIONS & JUDICIAL TRENDS

Defining the “Court” under Section 29A: The Supreme Court has now settled that the power to extend an arbitral tribunal’s mandate under Section 29A (4) “vests... in the Court as defined in Section 2(1)(e) of the Act,” i.e. the principal civil court of original jurisdiction (typically the District Court).

A High Court is included only if it exercises ordinary original civil jurisdiction. In Chief

Engineer (NH) PWD v. BSC & C&C JV 21 (May 2024), the Court explicitly rejected the view that “Court” means only the appointing authority.

It held that the substitution power under Section 29A (6) (to remove or replace arbitrators) is merely “a consequential power” exercisable by the same Court that may extend time. Practically, this means district courts (within their pecuniary limits) can now hear Section 29A petitions — including substitution applications — even if the arbitrator was appointed by a High Court. This ruling brings finality to earlier disputes: parties now know that all Section 29A extensions (and related substitution requests) go to the principal civil court of first instance (or to a High Court only when it has ordinary original jurisdiction). • Timing of Extension Applications: Prior to the Supreme Court’s recent ruling, High Courts were split on whether Section 29A petitions must be filed before the 12‐month (plus consent extension) deadline, or can be filed after expiry.

Several High Courts (Delhi, Bombay, Kerala, Madras, etc. ) had held that an extension application may in fact be filed after the period lapses, because Section 29A expressly allows “either prior to or after” expiry. For example, the Delhi High Court in Wadia Techno-Engineering v. DGMAP 22 and a coordinate Delhi Bench in Reliance Infrastructure v. MVVNL23 permitted post-expiry applications, noting the tribunal’s mandate continues until the extension is decided. Similarly, the Bombay High Court in Nikhil H. Malkan v. Standard Chartered 24 ruled that confining applications to pre-expiry period would “undermine provision’s purpose”, the Kerala High Court in Hiran Valiiyakkil Lal v Vineeth 25 allowed extensions filed after the 18‐month limit (subject to cause). In contrast, the Calcutta and Patna Benches took a strict view. In Rohan Builders v.

Berger Paints 26, the Calcutta High Court held that once the tribunal’s mandate has “terminated by efflux of time,” it cannot be revived – i. e. no extension after expiry. The Patna High Court similarly insisted that Section 29A only extends an existing mandate, not a dead one.

The Supreme Court unanimously agreed with the former line of cases. In Rohan Builders (India) Pvt. Ltd. v. Berger Paints India Ltd. 27 (Sept. 2024), it held that courts have the power to extend the award period “at any time before or after the expiry” of the mandated period. The Court found the phrase “either prior to or after” in Section 29A (4) to be “clear and unambiguous,” so that extension applications can be filed even after the 12‐month (or 18‐month) limit. It refused to read any separate limitation period into the statute (noting that doing so would have “penal and fatal consequences” for unwary parties). The Court also underscored that an extension is not automatic merely on filing; judges must assess whether the delay was for “sufficient cause” and may impose reasonable conditions.

In particular, Section 29A itself includes deterrents – a court can substitute delinquent arbitrators and impose costs if a party has caused undue delay. Notably, the Supreme Court confirmed that arbitral proceedings may continue during the pendency of a Section 29A application, but no final award should be passed until the extension petition is decided. In other words, proceedings remain alive, subject to the condition that a tribunal cannot render a final award while an extension request is sub-judice. In conclusion, the SC Chapter in Rohan Builders also creates uniformity in the law dealing with timing: Every court agrees that extension petitions can be made after the expiry time where the applicant is able to provide sufficient cause.

This restores the flexibility of the 2015/2019 amendments, while still allowing courts to get rid of meritless requests and frivolous extensions and reasonably delayed requests. 28 • Post-Award Extensions – Conflicting High Court Views: A related question (yet unresolved by the Supreme Court) is whether Section 29A can

retrospectively validate an award already delivered. A few High Courts have allowed ex post extensions in narrow circumstances. For instance, the Kerala High Court in RKEC Projects Ltd. v. Cochin Port Trust held that an application filed after the award was permissible: the court extended the tribunal’s mandate retroactively up to the award date, since the delay was excusable.29

Likewise, single-judge benches of the Delhi High Court in IRCON International v. NHAI and Harkirat Singh Sodhi v. Oram Foods granted extensions after award delivery, the latter taking into account extraordinary pandemic-related disruptions. These courts reasoned that Section 29A’s termination rule should not be absolute if injustice would otherwise result. 30 By contrast, other benches have flatly rejected post-award relief. In Powergrid Corp. v. SPML Infra, a Delhi bench held that once the award is rendered, Section 29A is no longer operative – an extension petition filed thereafter is not maintainable. 31 Similarly, another Delhi bench in National Skill Development Corpn. v. Best First Step Education insisted that applications must be made before the award, disallowing any “ex post facto” revival of the mandate.

The Madras Court emphasized that allowing extension after award “would be impermissible” under the text of Section 29A. 32 In Skylark Cagers India v. Institute of Liver & Biliary Sciences, a Delhi court similarly refused an extension application filed 17 months after expiry, describing such delay as “inordinate”. 33 In short, the law on post-award extensions remains unsettled and split. The Supreme Court has not directly ruled on this point, so lower courts continue to reach opposite conclusions. Many commentators note that post-award extensions risk undermining finality (since Section 29A (6) on substitution makes little sense once an award is out). Practically, it is now best practice for a party to file any extension petition before an award is pronounced, because relief after the fact is far from guaranteed.

Some courts, like the Kerala High Court, have taken a more flexible approach allowing post-award extensions in exceptional cases where sufficient cause is shown. Others, including benches in Delhi and Madras, hold a stricter view that once an award is delivered, Section 29A’s timelines become final and no extensions apply. This divergence creates uncertainty for parties and practitioners, underscoring the need for clarity from the Supreme Court in future rulings. Meanwhile, filing extension applications prior to award delivery remains the safest and most prudent course of action to preserve rights and avoid procedural complications.

Critical Trends and Analysis: Taken together, these developments show a pragmatic balancing act by Indian courts. The prevailing trend is to read Section 29A purposively – enforcing its timelines to ensure arbitration is “thoroughly and swiftly” concluded, but not construing deadlines so rigidly that they defeat justice. The Supreme Court’s recent decisions give parties clear rules (the forum is now the Section 2(1) (e) court, and applications can be late but only for “sufficient cause”). 34 At the same time, courts are rigorously policing the exceptions: an extension request must explain the delay, and judges will impose costs or substitute arbitrators if a party or tribunal is to blame. As the SC noted, Section 29A itself contains “built-in mechanisms to deter parties from causing undue delays,” such as substitution under (6) and exemplary costs under (8).

35 This “directory-but-directive” approach mirrors global arbitration trends: strict default timelines (like UNCITRAL’s 6‐month rule) but with judicial discretion for exceptional cases. Indian courts have emphasized that permitting a short extension on valid grounds actually advances the Act’s object – to promote efficient, cost-effective dispute resolution – whereas a hyper‐strict view would “set the clock back for a genuine claimant”. 36 Thus, while speed remains paramount, procedural technicalities will not be allowed to work injustice. For example, courts have repeatedly warned that yet another extension will not be granted routinely, and any belated petition must face “notably high” scrutiny. Looking ahead, parties and practitioners should heed these lessons.

Always calculate deadlines carefully, but remember that relief is available if a well-founded extension application is filed — even belatedly. Equally, one should be prepared for conditions: be ready to explain delays and accept substitutions or costs. The Supreme Court has aligned Section 29A with both the letter and spirit of the law – defining “Court” as per Section 2(e), and upholding the statute’s flexibility on extensions. This ensures that arbitration in India can be both expeditious and fair, with local courts effectively sharing jurisdiction. 37

CONCLUSIONS

Section 29A was enacted as a legislative antidote to endemic delay in Indian arbitration. Its strict timelines, coupled with judicial oversight, reflect Parliament’s attempt to align arbitration with global best practices. Yet, its bare text gave rise to several doctrinal controversies—most prominently, the identity of the “Court,” the permissibility of postexpiry applications, and the treatment of awards delivered after the statutory deadline. The Supreme Court has now clarified two critical questions. First, in Chief Engineer (NH) PWD v. BSC & C&C JV (2024), it affirmed that “Court” under Section 29A means the forum defined in Section 2(1)(e)—the principal civil court of original jurisdiction (including High Courts with ordinary original civil jurisdiction)—not merely the appointing authority.

This harmonizes procedure, democratizes access to justice by empowering district courts, and prevents concentration of jurisdiction in a handful of superior courts. Second, in Rohan Builders v. Berger Paints (2024), the Court resolved conflicting High Court rulings by holding that extension petitions may be filed “either prior to or after” expiry of the stipulated period. This purposive interpretation preserves the legislative intent of efficiency without sacrificing substantive justice. At the same time, the Court underscored that extensions are discretionary and conditioned on “sufficient cause. ” What remains unsettled is the contentious issue of post-award extensions. While some High Courts have retrospectively validated awards by granting extensions after their delivery, others have rejected this approach, emphasizing finality.

The Supreme Court has yet to resolve this doctrinal tension, leaving practitioners in a zone of uncertainty. Overall, Indian jurisprudence on Section 29A reflects a “flexible strictness”: courts insist on compliance with timelines, but interpret them in a manner that prevents procedural rigidity from undermining justice. The legislative framework, as judicially refined, now ensures predictability in forum, flexibility in timing, and deterrence against abuse. Going forward, the unresolved question of post-award relief will likely define the next phase of evolution. Section 29A thus stands as both a disciplining mechanism and a safety valve—a provision that advances India’s arbitral reform agenda by mandating speed while accommodating fairness.

BIBLIOGRAPHY

Statutes • Arbitration and Conciliation Act, 1996, § 29A (as amended by Act 3 of 2016 and Act

33 of 2019).

International Instruments • UNCITRAL Model Law on International Commercial Arbitration, art. 17 (1985, amended 2006). Reports • Law Commission of India, 246th Report on Amendments to the Arbitration and Conciliation Act, 1996 (Aug. 2014). Case Law (alphabetical order) • A’Xykno Capital Servs. Ltd. v. State of U.P., 2023 SCC OnLine All 37194 (All HC). • Amit Kumar Gupta v. Dipak Prasad, 2021 SCC OnLine Cal 2634 (Cal HC). • Cabra Instalaciones y Servicios S.A. v. Maharashtra State Electricity Distribution Co. Ltd., 2019 SCC OnLine Bom 1312 (Bom HC). • Chief Engineer (NH) PWD (Roads) v. BSC & C&C JV, SLP (C) No. 10544/2024 (SC, May 13, 2024). • Delhi Dev. Auth. v. Tara Chand Sumit Constr. Co., 2020 SCC OnLine Del 2501 (Del HC).

Harkirat Singh Sodhi v. Oram Foods Pvt. Ltd., 2021 SCC OnLine Del 4422 (Del

HC).

Hiran Valiiyakkil Lal v. Vineeth M.V., 2023 SCC OnLine Ker 4287 (Ker HC). • IRCON Int’l Ltd. v. Nat’l Highways Auth. of India, 2021 SCC OnLine Del 3123 (Del

HC).

Lots Shipping Co. Ltd. v. Cochin Port Trust Bd. of Trustees, 2020 SCC OnLine Ker

2826 (Ker HC).

Nat’l Skill Dev. Corp. v. Best First Step Educ. Pvt. Ltd., 2019 SCC OnLine Del 8506 (Del HC). • Nikhil H. Malkan v. Standard Chartered Inv. & Loans (India) Ltd., 2023 SCC OnLine Bom 2035 (Bom HC). • Nilesh Ramanbhai Patel v. Bhanubhai Ramanbhai Patel, 2019 SCC OnLine Guj 910 (Guj HC).

Power Grid Corp. of India Ltd. v. SPML Infra Ltd., 2020 SCC OnLine Del 1650 (Del

HC).

RKEC Projects Ltd. v. Cochin Port Trust, 2020 SCC OnLine Ker 1132 (Ker HC). • Reliance Infrastructure Ltd. v. Madhyanchal Vidyut Vitran Nigam Ltd., 2023 SCC OnLine Del 4894 • Rohan Builders (India) Pvt. Ltd. v. Berger Paints India Ltd., 2024 SCC OnLine SC

2494 (SC Sept. 12, 2024).

Skylark Cagers India Pvt. Ltd. v. Inst. of Liver & Biliary Sciences, 2021 SCC OnLine Del 3125 • Survadev Alloys v. Govindaraja Textiles Pvt. Ltd., 2019 SCC OnLine Mad 3770 (Mad

HC).

Wadia Techno-Eng’g Servs. Ltd. v. Dir. Gen. of Married Accommodation Project,

2023 SCC OnLine Del 11553 (Del HC).

Secondary Sources • Khaitan & Co., Judicial Trends on Section 29A of the Arbitration Act (2020). • Vidhi Centre for Legal Policy, Reforming Arbitration Timelines in India (Policy Brief, 2021).