Delhi High Court

Scope of Section 11 Scrutiny Limited to Prima Facie Existence of Arbitration Agreement

M/S Moneywise Financial Services Pvt. Ltd. vs Smt. Sonia Nagpal Proprietor Of Bobby Impex And Anr.

Delhi High CourtJUDGMENT: May 04, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner filed a petition under Section 11 of the Arbitration and Conciliation Act, 1996, seeking the appointment of a sole arbitrator

Source reference: p.1

The dispute arose from a Master Loan Agreement dated 24.02.2024, which contained an arbitration clause (Clause 8.2) designating Delhi as the seat

Source reference: p.1-2

The Petitioner issued a Section 21 notice on 15.10.2025

Source reference: p.2

Although the Respondents were served and the Joint Registrar closed their right to file a reply on 20.04.2026, the Respondents failed to appear or contest the proceedings

Source reference: p.2
02

Issues

1. Whether a Sole Arbitrator should be appointed under Section 11 of the Act given the non-responsiveness of the Respondents and the existence of a prima facie arbitration agreement

Source reference: p.6, para. 8
03

Law Applied

Section 11(6) of the Arbitration and Conciliation Act, 1996, regarding the appointment of arbitrators

Source reference: p.1

Judicial scrutiny under Section 11 is confined strictly to a prima facie examination of the existence of the arbitration agreement as established in SBI General Insurance Co. Ltd. v. Krish Spinning (2024) and In re: Interplay Between Arbitration Agreements under Arbitration Act, 1996 & Stamp Act, 1899 (2024)

Source reference: p.2-3

Legislative amendments to Section 11(6-A) overruled earlier broader standards, ensuring minimal judicial interference and protecting the "competence-competence" doctrine of the Arbitral Tribunal

Source reference: p.3-5
04

Reasoning

The Court observed that the Petitioner successfully established the existence of an arbitration agreement through Clause 8.2 of the Loan Agreement

Source reference: p.2

Applying the "facilitative and procedural" standard from Krish Spinning, the Court noted that it must not engage in a "laborious enquiry" into the merits or contested facts, such as "accord and satisfaction," which are reserved for the tribunal under Section 16

Source reference: p.4-6

Since the Respondents were served but chose not to participate, and the Section 21 notice requirements were met, the Court found no impediment to referring the matter to arbitration

Source reference: p.6

The Court also determined that referring the dispute to the Delhi International Arbitration Centre (DIAC) was appropriate given the dispute's valuation of approximately Rs. 30 Lakhs

Source reference: p.6-7
05

Holding

The Court allowed the petition and appointed Mr. Dheeraj Gupta, Advocate, as the Sole Arbitrator to adjudicate the disputes under the aegis of the DIAC

The Court directed the arbitrator to provide a disclosure under Section 12(2) and ordered that the arbitration abide by DIAC rules and fee schedules; all rights and contentions on merits were left open for the tribunal’s decision

Source reference: p.7
Delhi High Court

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M/S Moneywise Financial Services Pvt. Ltd.vsSmt. Sonia Nagpal Proprietor Of Bobby Impex And Anr.

Delhi High Court · May 04, 2026

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