Delhi High Court

Court Extends Mandate of Arbitral Tribunal Under Section 29A For Continuity and Substantial Justice

National Highways Authority Of India vs Roadway Solution India Pvt. Ltd.

Delhi High CourtJUDGMENT: May 29, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner (NHAI) and Respondent entered into two contracts in 2013 for the maintenance of sections of NH-4

Source reference: p. 2, para. 2

Following disputes, the Respondent moved the Court under Section 11 of the Arbitration and Conciliation Act, 1996, resulting in the appointment of Mr. Jagmohan Lal as the Sole Arbitrator on September 20, 2017

Source reference: p. 2, paras. 3-4

The Arbitrator entered reference on September 25, 2017. Over the years, multiple extensions were granted, with the last extension expiring on December 31, 2025

Source reference: p. 2, para. 5

The Petitioner sought a further extension of the mandate under Section 29-A(5) of the Act

Source reference: p. 1, para. 1
02

Issues

Whether the mandate of the learned Sole Arbitrator should be extended under Section 29-A(5) of the Arbitration and Conciliation Act, 1996

Source reference: p. 1, para. 1

Whether there is sufficient cause and mutual consent to justify such an extension to ensure the completion of proceedings

Source reference: p. 2, para. 6; p. 3, para. 8
03

Law Applied

The court applied Section 29-A of the Arbitration and Conciliation Act, 1996, which mandates a 12-month timeline for issuing an award (extendable by 6 months by party consent) and empowers the Court to extend the mandate thereafter upon an application for sufficient cause

Source reference: p. 3, para. 9

The Court further relied on the precedent set by the Hon’ble Supreme Court in Rohan Builders (India) Private Limited v. Berger Paints India Limited (2024 SCC OnLine SC 2494), which clarified the scope, ambit, and procedural mandates for extending an arbitrator’s mandate under Section 29-A

Source reference: p. 4, para. 10
04

Reasoning

The Court noted that the initial mandate and subsequent extensions had lapsed as of December 31, 2025

Source reference: p. 2, para. 5

However, the Court observed that both parties were ad idem (in agreement) regarding the necessity of the extension

Source reference: p. 3, para. 8

Applying Section 29-A(5), the Court reasoned that granting the extension was in the "interest of justice" to ensure "continuity and consistency" in the adjudication of the long-standing disputes arising from the 2013 contracts

Source reference: p. 3, para. 8

The Court found no legal impediment to the relief, especially given the Respondent's "no objection" statement and the guidelines established by the Supreme Court regarding the liberal interpretation of timelines to facilitate the completion of arbitral proceedings

Source reference: p. 2, para. 6; p. 4, para. 11
05

Holding

The Court allowed the petitions and extended the mandate of the learned Sole Arbitrator until October 31, 2026

The Court regularized the period between the expiry of the previous mandate (December 31, 2025) and the date of the current order (May 29, 2026)

Source reference: p. 4, para. 12

The petitions and all pending applications were disposed of accordingly

Source reference: p. 4, para. 13
Delhi High Court

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National Highways Authority Of IndiavsRoadway Solution India Pvt. Ltd.

Delhi High Court · May 29, 2026

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