Delhi High Court

Arbitral mandate extended under Section 29A(4) for advanced-stage proceedings upon mutual consent of parties.

M/S Anj Vc Jv vs National Highways Authority Of India

Delhi High CourtJUDGMENT: April 20, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The parties entered into a contract on 08.08.2018

Source reference: p. 1

Following disputes, the Petitioner invoked arbitration on 28.10.2022 and subsequently filed a Section 11 petition

Source reference: p. 1

A Sole Arbitrator was appointed on 03.07.2023

Source reference: p. 2

Pleadings were completed on 16.05.2024, and the proceedings reached the stage of cross-examination of the respondent’s witness

Source reference: p. 2

Earlier, under O.M.P. (Misc.) (Comm.) No. 664/2025, the Court had extended the arbitrator’s mandate until 31.03.2026

Source reference: p. 2

The Petitioner filed the present petition under Section 29A(4) of the Arbitration and Conciliation Act, 1996 ("the Act"), seeking a further extension until 31.03.2027, citing the complexity of the evidence and the advanced stage of the proceedings

Source reference: p. 1-2

The Respondent expressed no objection to the extension

Source reference: p. 2
02

Issues

1. Whether sufficient cause exists under Section 29A(4) and (5) of the Act to extend the mandate of the Sole Arbitrator for the conclusion of arbitral proceedings

Source reference: p. 1 / para. 1, 10
03

Law Applied

The court primarily applied Section 29A of the Arbitration and Conciliation Act, 1996, which stipulates the statutory timelines for making an arbitral award and provides for the extension of the arbitrator's mandate by the court upon the showing of "sufficient cause"

Source reference: para. 11

It further relied on the precedent established in Rohan Builders (India) Private Limited v. Berger Paints India Limited (2024 SCC OnLine SC 2494), which clarified the scope, ambit, and mandatory nature of the timelines and extension provisions under Section 29A

Source reference: para. 12
04

Reasoning

The Court observed that the arbitral proceedings had progressed substantially, having moved past the claimant's evidence to the cross-examination of the respondent's witness

Source reference: para. 3

It noted that the failure to conclude within the previously extended timeline was attributable to the nature of the disputes and the requirement for detailed evidence, rather than lack of diligence

Source reference: para. 6

Applying Section 29A(5), the Court found that the "interest of justice" and the need for "continuity and consistency" in the proceedings constituted sufficient grounds for extension

Source reference: para. 10

Crucially, the Court highlighted that since both parties were ad idem (in agreement) regarding the necessity of the extension, there was no legal impediment to granting the relief

Source reference: para. 10
05

Holding

The Court allowed the petition and extended the mandate of the learned Sole Arbitrator until 31.03.2027

Furthermore, the Court ordered that the period from the expiry of the previous mandate (31.03.2026) until the date of the present order be regularized

Source reference: para. 14

The petition and all pending applications were disposed of accordingly

Source reference: para. 15
Delhi High Court

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M/S Anj Vc JvvsNational Highways Authority Of India

Delhi High Court · April 20, 2026

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