Delhi High Court

Non-Constitution of Dispute Redressal Committee Within Stipulated Period Warrants Appointment of Independent Sole Arbitrator

Mohd Amjad vs Union Of India Through Executive Engineer Cpwd

Delhi High CourtJUDGMENT: July 13, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner was awarded a tender by the respondent (CPWD) for the repair and maintenance of 176 MPS flats in New Delhi for the year 2024–25

Source reference: p. 1-2

Following the issuance of a Letter of Award dated 27.09.2024, a formal agreement was executed

Source reference: p. 2

Work commenced on 30.09.2024 and was completed on 11.02.2025, slightly beyond the stipulated deadline of 29.01.2025

Source reference: p. 5

The respondent imposed contractual penalties for delay and subsequently debarred the petitioner from future tenders following a show-cause notice

Source reference: p. 5

Disputes arose regarding the non-payment of the final bill dated 25.02.2025

Source reference: p. 5

The petitioner referred the dispute to the Dispute Redressal Committee (DRC) as per Clause 25 of the agreement on 28.01.2026, but the respondent failed to constitute the DRC

Source reference: p. 6

Consequently, the petitioner invoked arbitration on 05.05.2026 and filed the present petition under Section 11 of the Arbitration and Conciliation Act, 1996

Source reference: p. 2, 6
02

Issues

1. Whether an independent Sole Arbitrator should be appointed under Section 11 of the Arbitration and Conciliation Act, 1996, given the failure to constitute the internal Dispute Redressal Committee

Source reference: p. 6, para 13

2. Whether the existence of an arbitration agreement and the impartiality of the arbitrator are established as per prevailing judicial precedents

Source reference: p. 6, para 14-15
03

Law Applied

Section 11 of the Arbitration and Conciliation Act, 1996, which governs the appointment of arbitrators by the Court

Source reference: p. 1

Perkins Eastman Architects DPC v. HSCC (India) Ltd. and TRF Limited v. Energo Engineering Projects Ltd., which establish that a party interested in the outcome of the dispute cannot unilaterally appoint an arbitrator

Source reference: p. 6

Bharat Broadband Network Limited v. United Telecoms Limited, SBI General Insurance Co. Ltd. v. Krish Spinning, and the In re: Interplay between Arbitration Agreements and the Indian Stamp Act decision

Source reference: p. 6
04

Reasoning

The Court observed that the respondent did not dispute the existence of the arbitration agreement contained within Clause 25 of the contract

Source reference: p. 6

It noted that the petitioner had followed the requisite pre-arbitral steps, including referring the matter to the DRC and issuing a notice of invocation, to which the respondent failed to respond

Source reference: p. 6

Applying the principles from Perkins Eastman, the Court determined that since the administrative mechanism for dispute resolution had failed and the independence of the tribunal is a statutory necessity, the judicial appointment of a neutral arbitrator was warranted

Source reference: p. 6

The respondent’s counsel acceded to the appointment of an independent arbitrator, thereby removing any contest regarding the necessity of the tribunal

Source reference: p. 6
05

Holding

The Court allowed the petition and appointed Mr. Divyansh Nigam, Advocate, as the Sole Arbitrator to adjudicate the disputes

The arbitration is to be conducted under the aegis of the Delhi International Arbitration Centre (DIAC)

Source reference: p. 7

The respondent was granted liberty to raise preliminary objections regarding arbitrability and jurisdiction before the arbitrator

Source reference: p. 6-7

The Court clarified that all rights and contentions of the parties remain open and that the appointment does not constitute an expression of opinion on the merits of the claims

Source reference: p. 7
Delhi High Court

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Mohd AmjadvsUnion Of India Through Executive Engineer Cpwd

Delhi High Court · July 13, 2026

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