Delhi High Court

Court grants extension of arbitral mandate under Section 29A upon mutual consent and sufficient cause.

M/S Home And Soul Infratech Private Limited vs M/S Raj Krishna Construction Company

Delhi High CourtJUDGMENT: March 16, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The parties entered into a Work Order on 12.10.2018 for RCC and allied works at the "Page Three Residencies" project

Source reference: p.1-2

Following disputes, a Sole Arbitrator was appointed by the High Court on 01.02.2024

Source reference: p.2

Arbitral proceedings commenced in March 2023, and pleadings were completed on 11.09.2024

Source reference: p.2

Under the statutory timeline, the mandate was initially set to expire on 10.09.2025; however, the parties mutually extended the mandate by six months until 11.03.2026

Source reference: p.2

Due to the filing of additional documents and applications, the proceedings did not conclude, and final arguments remained pending

Source reference: p.2

The parties jointly approached the Court seeking a further one-year extension of the mandate

Source reference: p.1-2
02

Issues

1. Whether sufficient cause exists under Section 29A(5) of the Arbitration and Conciliation Act, 1996, to grant a further extension of the mandate of the Arbitral Tribunal

Source reference: p.4
03

Law Applied

The Court applied Section 29A of the Arbitration and Conciliation Act, 1996, which mandates that an award must be made within 12 months of the completion of pleadings, with an allowable 6-month consensual extension by the parties

Source reference: p.3

Beyond this, Section 29A(4) and (5) empower the Court to extend the mandate upon an application by a party for "sufficient cause" and on such terms as deemed fit

Source reference: p.3

The Court also referenced Rohan Builders (India) Private Limited v. Berger Paints India Limited, wherein the Supreme Court clarified the scope and mandate of Section 29A

Source reference: p.4
04

Reasoning

The Court noted that Section 29A does not allow for the "routine grant" of extensions and requires a judicial assessment of the progress of the arbitration

Source reference: p.4

In this instance, the Court observed that the proceedings had reached the stage of final arguments but were delayed due to the filing of additional documents and various applications by the parties

Source reference: p.2, 4

Given that the proceedings were at an advanced stage and that both parties were ad idem (in agreement) regarding the necessity of more time, the Court found that these circumstances constituted "sufficient cause" to prevent the termination of the arbitrator's mandate

Source reference: p.4
05

Holding

The Court granted the petition and extended the mandate of the Sole Arbitrator for one year from 11.03.2026, setting the new deadline as 10.03.2027

The Court also regularized the period from the expiry of the previous mandate until the date of the order

Source reference: p.5

The petition and all pending applications were disposed of in these terms

Source reference: p.5
Delhi High Court

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M/S Home And Soul Infratech Private LimitedvsM/S Raj Krishna Construction Company

Delhi High Court · March 16, 2026

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