Delhi High Court

Extension of arbitral mandate under Section 29A requires judicial assessment of proceeding progress and sufficient cause.

Randhawa Construction Private Limited vs Ms Hcbs Promoters And Developers Pvt Ltd

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

Facts

The parties entered into a Collaboration Agreement on 11.06.2013

Source reference: para. 2

Following disputes, a Sole Arbitrator was appointed by the Court on 25.03.2021

Source reference: para. 3

The mandate of the Arbitrator was previously extended twice, with the last extension of nine months expiring on 05.02.2026

Source reference: para. 4

The Petitioner filed the present petition under Section 29-A of the Arbitration and Conciliation Act, 1996, seeking a third extension of six months to complete pending cross-examinations and final arguments

Source reference: para. 1, 5

The Respondent expressed no objection to the requested extension

Source reference: para. 7
02

Issues

Whether there exists sufficient cause to grant a third extension of the mandate of the Arbitral Tribunal under Section 29-A of the Arbitration and Conciliation Act, 1996

Source reference: para. 1, 11
03

Law Applied

The Court applied Section 29-A of the Arbitration and Conciliation Act, 1996, which stipulates the time limits for arbitral awards and empowers the Court to extend the mandate of an arbitrator upon the expiry of the statutory period for "sufficient cause" and on such terms as it deems fit

Source reference: para. 9

Section 29-A does not permit routine grants of extension but requires a careful assessment of the progress of the proceedings in light of the specific facts of each case

Source reference: para. 10-11
04

Reasoning

The Court observed that while Section 29-A is intended to ensure timely disposal, extensions are not a matter of routine and must be based on a factual assessment of the arbitration's progress

Source reference: para. 11

In this instance, the Court noted that the proceedings had reached a critical stage involving the completion of cross-examination and hearing of final arguments

Source reference: para. 5, 12

The Court placed significant weight on the fact that both parties were ad idem (in agreement) regarding the necessity of the extension

Source reference: para. 12

Applying the "sufficient cause" standard under Section 29-A(5), the Court determined that the current stage of the proceedings and the mutual consent of the parties justified a further six-month extension to ensure the conclusion of the arbitral process

Source reference: para. 12-13
05

Holding

The Court answered the issue in the affirmative, holding that an extension was apposite given the stage of the proceedings

The Court ordered the extension of the Sole Arbitrator's mandate by a period of six months, effective until 05.08.2026

Source reference: para. 13

The Court regularized the period between the expiry of the previous mandate (05.02.2026) and the date of the order (16.03.2026)

Source reference: para. 13

The petition was disposed of accordingly

Source reference: para. 14
Delhi High Court

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Randhawa Construction Private LimitedvsMs Hcbs Promoters And Developers Pvt Ltd

Delhi High Court · March 16, 2026

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