Arbitration in Construction Contracts in India

Construction contracts are unique in nature as theparty fails to appoint an arbitrator within 30 days
construction industry embraces a very widefrom the receipt of a request to do so from the
variety of types of construction ranging fromother party or if the two appointed arbitrators fail
pure building work to pure engineering withto agree on the third arbitrator within 30 days
combinations of building and engineering to varyingfrom the date of their appointment, the
degrees. A construction projects is continuous inappointment shall be made upon request of a
nature usually spread over number of years. Theparty by the Chief Justice or any person or
problems that arise in the working of the projectsinstitution designation by him.
are sometimes not foreseeable or even if theyHowever, in Datar Switchgear vs Tata Finance
are foreseeable, their magnitude may not beLtd. (2000)8 SCC 151: 2000(3) Arb LR 447, it had
foreseeable before or during the execution of thebeen held that if one party demanded
contract. Since the numbers of the parties involveappointment of an arbitrator and the other party
in the construction contract it is oblivious that thedid not make the appointment, the right to
disputes will arise between them if one partyappoint was not automatically forfeited on the
failed to perform their obligation in terms of theexpiry of 30 days, however, the right would be
contract. Disputes can be resolved either throughforfeited if the opposite party fails to make the
litigation or through Alternative disputes resolutionappointment and the claimant approaches the
mechanism, which includes Mediation, ConciliationChief Justice or his designate for the needful.
and Arbitration. In India where the courts areUntil, the recent judgment pronounced by the
already heavy burdened with the backlog ofapex court in M/s. S.B.P. & Co. Versus M/s.
cases, the dispute hangs over for years. LitigationPatel Engineering Ltd. and another 2008) 4 SCC
is expensive as well as time consuming. If litigation190, the appointment of arbitrator by the court
is resorted for every problem, then, suchwas an administrative order, however, The
problems will likely to increase rather than toconstitutional benches verdict in M/s. S.B.P. &
resolve the tension generated by the emergenceCo. Versus M/s. Patel Engineering Ltd. overruling
of such problems.the judgment in Konkan Railway Corpn. Ltd.
In the Construction contract, where the huge& anr. Vs. Rani Construction Pvt. Ltd. [(2000)
money involves, an early and inexpensive dispute8 SCC 159] held that the order passed by the
resolution is required otherwise the project will runChief Justice or his delegate of the High Court,
in time overrun resulting into the huge losses ofappointing the arbitrator is now appealable, thus
money, idling of manpower and machineries.enunciating that the order passed under section 11
Though Mediation and Conciliation is veryis not an administrative order but a judicial order.
inexpensive mode of dispute resolutionUnder Section 16 of Arbitration and Conciliation
mechanism but the decision of the Mediator andAct 1996, a party may take a plea of lack of
Conciliator are not enforceable. Due to this reasonjurisdiction on many grounds including the
the Mediation and conciliation fails in most of thefollowing:i)         Arbitration Agreement
cases. Arbitration is also one of the Alternativedoes not existii)        Contract containing it
Dispute Resolution modes, which is moreis invalidiii)       There has been full &
successful than mediation and conciliation becausefinal settlement and contract is
the Award passed by the Arbitrator is as good asdischargediv)       Disputes do not arise out
the decree passed by the Civil Court.of contractv)        Reference is beyond the
Before 1996, statutory provisions of Arbitrationscope of Arbitration Agreement.
were covered by three different enactments 
namely, the Arbitration Act, 1940, The ArbitrationThe arbitrators are free to
, (Protocol and Convention) Act, 1937 and Thechoose procedure and subject to parties
Foreign Awards (Recognition and Enforcement)agreement, may conduct the proceedings "in the
Act, 1960.  The Arbitration Act, 1940 laid downmanner they consider appropriate. Neither the
the framework within which the domesticCode of Civil Procedure nor the Indian Evidence
arbitration was conducted in India while the otherAct applies to arbitrations. In an international
two enactments dealt with the foreign awards. Incommercial arbitration, parties are free to
1996, Arbitration and Conciliation Act, 1996 wasdesignate the governing law for the substance of
come into force. This Act repealed all the threethe dispute.
previous enactments. Arbitration Act, 1996 is An award can be challenged before Court under
based on UNCITRAL model law.section 34 of the Arbitration Act, 1996 on the
Part I of the Arbitration Act,1996 deals withfollowing grounds.
domestic arbitration, part II deals with1. a party was under some incapacity; or
enforcement of foreign wards, part III deals with2. the arbitration agreement was not valid under
conciliation and part IV deals with thethe governing law; or
supplementary provisions. Moreover Arbitration3. a party was not given proper notice of the
and Conciliation Act, 1996 is applicable only toappointment of the arbitrator or on the arbitral
disputes, which are civil in nature.proceedings; or
A valid Arbitration Agreement is must for invoking4. the award deals with a dispute not
the Arbitration and set into motion the Arbitrationcontemplated by or not falling within the terms of
mechanism. Section 7 of the Arbitration Act, 1996submissions to arbitration or it contains decisions
defines the Arbitration Agreement. An arbitrationbeyond the scope of the submissions; or
agreement may be in the form of an arbitration5. the composition of the arbitral tribunal or the
clause in a contract or in the form of a separatearbitral procedure was not in accordance with the
agreement. An arbitration agreement shall be inagreement of the parties; or
writing.6. the subject matter of the dispute is not
An arbitration agreement is in writing if it iscapable of settlement by arbitration; or The
contained in-arbitral award is in conflict with the public policy of
(a) A document signed by the parties;India.
(b) An exchange of letters, telex, telegrams orA challenge to an award is to be made within
other means of telecommunication which providethree months from the date of receipt of the
a record of the agreement; orsame. The courts may, however, condone a
(c) An exchange of statements of claim anddelay of maximum 30 days on evidence of
defence in which the existence of the agreementsufficient cause. Subject to any challenge to an
is alleged by one party and not denied by theaward, the same is final and binding on the parties
other..and enforceable as a decree of the Court.
Section 8 of the Arbitration Act, 1996 bar theSupreme Court of India decision in Oil and Natural
filing of civil suit in relation to any dispute if arisesGas Corporation vs. Saw Pipe (2003) 5 SCC 705
between the parties where a valid Arbitrationthe Court added an additional ground of "patent
Agreement between the parties exist.illegality", thereby considerably widening the scope
Section 9 of Arbitration Act, 1996, gives powerof judicial review on the merits of the decision.
to Civil Court to grant interim injunction forIn another Judgment Supreme Court in the recent
preservation, interim custody or sale of anycase of Venture Global Engineering v. Satyam
goods, which are the subject matter of theComputer Services Ltd (Venture Global) (2008) 4
arbitration agreement or securing the amount inSCC 190 held that a challenge to a foreign award
dispute in the arbitration or Such other interimin India would have to meet the expanded scope
measure of protection as may appear to theof public policy as laid down in Saw Pipes. The
court to be just and convenient, before, during orVenture Global case creates a new procedure and
after the Arbitral proceedings.a new ground for challenge to a foreign award.
Section 10 of the Act, provides for the numberUnder Section 37 of the Arbitration Act, 1996, an
of arbitrators.  The parties are free to determineappeal shall lie from the following orders (and from
the number of arbitrators provided that suchno others) to the court authorised by law to hear
number is not an even number.  If the partiesappeals from original decrees of the court passing
have failed to provide for the number ofthe order, namely: -
arbitrators, in that case, it is provided that an(a) Granting or refusing to grant any measure
arbitral tribunal shall consist of a sole arbitrator.under section 9;
Section 11 prescribes procedures for appointment(b) Setting aside or refusing to set aside an
of Arbitrator under which a person of anyarbitral award under section 34.
nationality may be an arbitrator unless other wise(2) An appeal shall also lie to a court from an
agreed to by the parties.  The parties are freeorder of the arbitral tribunal--
to agree on a procedure for appointment of an(a) Accepting the plea referred to in sub-section
arbitrator(s).(2) or sub-section (3) of section 16; or
Under Section 11(3) and (4), if the parties fails to(b) Granting or refusing to grant an interim
arrive at an agreement, as mentioned above in anmeasure under section 17.
arbitration with three arbitrator, each party shall 
be entitled to appoint one arbitrator and the twoThe award passed by the Arbitral Tribunal can be
appointed arbitrators shall appoint a third arbitratorexecuted in the same manner as the decree of
who shall act as the presiding arbitrator.  If athe Civil Court is executed.