Delhi High Court

Court May Extend Arbitral Mandate Under Section 29A Even After Expiry of the Prescribed Period.

Delhi Development Authority vs Dharamvir And Co

Delhi High CourtJUDGMENT: May 21, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner (DDA) and the Respondent entered into an agreement on 15.03.2011.

Source reference: no citation

Following disputes, a Sole Arbitrator was appointed by the Delhi High Court on 09.10.2023.

Source reference: p. 2

The Arbitrator entered reference on 03.11.2023, and pleadings were completed on 23.04.2024.

Source reference: p. 3

The statutory 12-month mandate expired on 22.04.2025, but was extended by mutual consent for six months until 06.10.2025.

Source reference: p. 3

The Petitioner initially filed this petition for extension on 26.11.2025 but withdrew it on 12.12.2025.

Source reference: p. 2-3

Subsequently, the Petitioner filed I.A. 14263/2026 seeking restoration of the petition, which the Respondent did not oppose.

Source reference: p. 2
02

Issues

1. Whether the petition for extension of the arbitral mandate, previously withdrawn, should be restored to its original position.

Source reference: p. 2, para 5

2. Whether the mandate of the Arbitral Tribunal should be extended under Section 29A of the Arbitration and Conciliation Act, 1996, despite the expiry of the previous mandate.

Source reference: p. 3, para 7; p. 4, para 13
03

Law Applied

The court applied Section 151 of the Code of Civil Procedure, 1908, regarding the inherent powers of the court to restore a withdrawn petition.

Source reference: p. 1

Section 29A of the Arbitration and Conciliation Act, 1996, which mandates a 12-month timeline for awards (sub-section 1), allows for a 6-month mutual extension (sub-section 3), and empowers the Court to grant further extensions for sufficient cause (sub-sections 4 and 5).

Source reference: p. 4-5

The court also referenced the Supreme Court’s interpretation of Section 29A in Rohan Builders (India) Private Limited v. Berger Paints India Limited [2024 SCC OnLine SC 2494].

Source reference: p. 5, para 16
04

Reasoning

The court first addressed the procedural hurdle by allowing the restoration application (I.A. 14263/2026), noting that the Respondent had no objection to the revival of the petition.

Source reference: p. 2

Regarding the extension of the mandate, the court reviewed the timeline of proceedings: the pleadings were completed on 23.04.2024, and the mutually extended mandate had expired on 06.10.2025.

Source reference: p. 3

Under Section 29A(4) and (5), the Court determined that sufficient cause existed to prevent the termination of the arbitrator's mandate.

Source reference: no citation

The court observed that the Petitioner sought the extension specifically for the rendering of the award.

Source reference: p. 3-4

Given the "no objection" from the Respondent and the need to ensure the proceedings conclude in accordance with law, the court found it appropriate to exercise its discretion to extend the mandate and regularize the intervening period.

Source reference: p. 5
05

Holding

The Court allowed the restoration of the petition.

It further granted a three-month extension of the Arbitrator’s mandate from the date of the order to conclude the proceedings and render the award.

Source reference: p. 5, para 17

The court ordered that the period from the expiry of the previous mandate (07.10.2025) to the date of the judgement (21.05.2026) be regularized for the purposes of Section 29A of the Act.

Source reference: p. 5, para 18
Delhi High Court

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Delhi Development AuthorityvsDharamvir And Co

Delhi High Court · May 21, 2026

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