Can a broadly worded arbitration clause empower an arbitral tribunal to decide all contract disputes even without a Section 21 notice?

 

Summary

Category Data
Court Supreme Court of India
Case Number C.A. No.-000039-000039 – 2026
Diary Number 11333/2025
Judge Name HON’BLE MR. JUSTICE K.V. VISWANATHAN
Bench

HON’BLE MR. JUSTICE J.B. PARDIWALA

HON’BLE MR. JUSTICE K.V. VISWANATHAN

Precedent Value Binding authority
Overrules / Affirms Sets aside High Court’s limitation of arbitration to a single dispute; reaffirms established jurisprudence on Section 21 and broad arbitration clauses
Type of Law Arbitration and Conciliation Act, 1996; Contract law
Questions of Law
  • Whether an arbitrator’s jurisdiction can be limited to specified disputes when the arbitration clause covers “any matter arising out of or connected with” the contract?
  • Whether failure to issue a notice under Section 21 of the A&C Act is fatal to pursuing arbitrable claims?
Ratio Decidendi
  1. A broadly worded arbitration clause covering “any matter arising out of or connected with” the agreement empowers the tribunal to decide all disputes, irrespective of which issues prompted its appointment.
  2. Section 21 notice serves only to fix the commencement date for limitation; it is procedural, not jurisdictional, and its non-issuance does not invalidate an award.
  3. The employer’s conduct—failing to treat the adjudicator’s decision as final and then invoking arbitration—precludes it from objecting to tribunal jurisdiction (estoppel/waiver).
  4. Followed precedents: M.K. Shah Engineers v. State of M.P., State of Goa v. Praveen Enterprises, ASF Buildtech v. Shapoorji Pallonji, Adavya Projects v. Vishal Structurals, Indian Oil Corp. v. Amritsar Gas.
Judgments Relied Upon
  • M.K. Shah Engineers & Contractors v. State of M.P. (1999)
  • State of Goa v. Praveen Enterprises (2012)
  • ASF Buildtech Pvt. Ltd. v. Shapoorji Pallonji & Co. (2025)
  • Adavya Projects Pvt. Ltd. v. Vishal Structurals Pvt. Ltd. (2025)
  • Indian Oil Corporation Ltd. v. Amritsar Gas Service (1991)
Logic / Jurisprudence / Authorities Relied Upon by the Court
  • Doctrine of estoppel/waiver: a party cannot take advantage of its own wrong.
  • Statutory interpretation distinguishing Section 21 (procedural commencement/limitation) from Section 23 (substantive claim framing).
  • Ultra-vires concerns absent when contract clause is exhaustive.
  • Precedents affirming amendment and supplementation of claims and counterclaims before the tribunal despite notice scope.
Facts as Summarised by the Court Four World-Bank-funded road maintenance contracts were awarded through competitive bidding. Disputes on price adjustment, escalation, bitumen pricing and interest were referred first to an Adjudicator, who decided four issues. The State rejected the award on one issue and appointed an arbitrator; the contractor then sought to include all four disputes. The Arbitral Tribunal awarded ₹1.99 crore plus interest on all four issues. The District Judge set aside the award and restored the Adjudicator’s decision; the High Court upheld that only dispute No.1 could be arbitrated. The Supreme Court allowed the appeal.

Practical Impact

Category Impact
Binding On All subordinate courts and High Courts on arbitration jurisdiction and Section 21 interpretation
Persuasive For Arbitral tribunals and contracting parties in infrastructure and construction sector
Overrules Division Bench of the Kerala High Court in Arbitration Appeal No. 56/2012
Distinguishes Iron & Steel Co. Ltd. v. Tiwari Road Lines (2007); MSK Projects India (JV) Ltd. v. State of Rajasthan (2011)
Follows M.K. Shah Engineers v. State of M.P. (1999); State of Goa v. Praveen Enterprises (2012); ASF Buildtech v. Shapoorji Pallonji (2025); Adavya Projects v. Vishal Structurals (2025); Indian Oil Corp. v. Amritsar Gas Service (1991)

What’s New / What Lawyers Should Note

  • Section 21 notice fixes limitation only; non-issuance does not strip arbitrator of jurisdiction.
  • A comprehensive arbitration clause (“any matter arising out of or connected with this agreement”) empowers adjudication of all disputes, regardless of which issues prompted appointment.
  • Party conduct (failing to treat adjudicator’s decision as final and then invoking arbitration) precludes objection to jurisdiction (estoppel).
  • Disputes and counterclaims not mentioned in the notice can still be raised and amended before the tribunal under Section 23.

Summary of Legal Reasoning

  1. Conduct and Estoppel
    The respondent’s actions (delayed reference, rejecting finality of adjudicator, then invoking arbitration) precluded reliance on contract timelines or limited reference (M.K. Shah).
  2. Section 21 vs. Section 23
    Section 21 notice determines commencement date for limitation; it is procedural. Section 23 governs framing of claims, defences and counterclaims; amendments allowed unless contract restricts them.
  3. Broad Arbitration Clause
    Clause 25.3 covers “any dispute or difference arising out of or connected with” the contract. Tribunal jurisdiction derives from arbitration agreement, not the scope of the notice under Section 21 (Praveen Enterprises).
  4. Precedents and Statutory Interpretation
    Followed ASF Buildtech on non-jurisdictional nature of Section 21. Relied on Adavya Projects on claimant/respondent filing patterns. Indian Oil on counterclaims and post-reference pleadings.

Arguments by the Parties

Petitioner (Contractor)

  • The arbitration clause is exhaustive and covers all disputes, not limited to adjudicator’s issues.
  • No contractual or statutory requirement to issue a Section 21 notice to invoke arbitration.
  • The High Court based its decision on a ground not pleaded before the tribunal.
  • The contractor’s letter dated 29.11.2004 constituted adequate invocation and waived any technical objections.
  • Allowing only the referring party’s disputes would cause multiplicity of arbitrations and conflicting awards.

Respondent (State)

  • The escalation mechanism prescribes strict timelines: decision by engineer, then adjudicator within 14 days, then arbitrator within 28 days.
  • Arbitration can only revisit the adjudicator’s decision, not the original disputes under the contract.
  • A Section 21 notice is mandatory to constitute the claim and appoint tribunal; non-issuance vitiates jurisdiction.
  • Only the referring party is “claimant”; the contractor never invoked arbitration under Section 21.
  • Reliance on para 41(c) of State of Goa v. Praveen Enterprises to limit tribunal to specifically referred disputes.

Factual Background

Four road-maintenance contracts under the Kerala State Transport Project were awarded to the contractor. Disputes concerning price adjustment for bitumen/POL, escalation during extensions, bitumen pricing and interest on delayed payments were referred in April 2004 to an Adjudicator, who decided all four disputes. The State rejected the award on dispute No. 1 and, after delay, appointed an arbitrator; the contractor sought arbitration on all four disputes. The Arbitral Tribunal awarded ₹1.99 crore plus 18% interest on all claims. The District Judge set aside the arbitrator’s award and reinstated the Adjudicator’s decision; the High Court confined arbitration to dispute No. 1. The Supreme Court allowed the appeal.

Statutory Analysis

  • Section 21, A&C Act: Notice fixes commencement date for limitation; procedural, not a condition of tribunal jurisdiction.
  • Section 23, A&C Act: Mandates statement of claim, defence, counterclaim and allows amendments “unless otherwise agreed”.
  • Section 16, A&C Act: Governs tribunal’s jurisdictional objections; tribunal held its jurisdiction was comprehensive.
  • GCC Clauses 24.1 & 25.2: Engineer/Adjudicator timelines, held to be contractual but waivable by conduct.
  • Special Conditions 25.3: Arbitration clause covering all disputes under the agreement.

Alert Indicators

  • ✔ Precedent Followed – Reaffirms established doctrine on Section 21 and broad arbitration clauses
  • 🔄 Conflicting Decisions – Conflicts with the Kerala High Court’s limitation to a single dispute under the contract

Leave a Reply

Your email address will not be published. Required fields are marked *

Recent Comments

No comments to show.