M/s STL Networks Limited v. Caspian India Engicon Pvt. Ltd.
Background
The parties had two separate contracts for optical fibre cable services: the "Mahanet Agreement" and the "T-Fiber Agreement." A dispute under the Mahanet Agreement led to arbitration before the Delhi High Court, with one arbitrator appointed. A separate dispute arose under the T-Fiber Agreement, and the Delhi High Court appointed a different, second arbitrator for it under Section 11 of the Arbitration Act, an order the appellant challenged. The appellant argued it had a substantial cross-project set-off claim under the T-Fiber Agreement (more than double the Mahanet claim) that needed to be considered together.
Decision Breakdown
Without going into the merits of the underlying claims, the Supreme Court held that, in the interest of consistency, the same arbitrator who was first appointed (for the Mahanet dispute) should also handle the T-Fiber dispute, since both arise from related contracts and involve overlapping financial claims. The Court modified the High Court's order accordingly, allowed the appeal, and clarified it was not expressing any view on the merits of the cross-project set-off claim or the quantum involved. Those issues remain fully open before the arbitrator.
Lesson Learnt
Where related contracts between the same parties generate overlapping disputes, courts favour consolidating arbitration before a single arbitrator to avoid fragmented and potentially inconsistent outcomes, even while leaving all substantive contentions for the arbitrator to decide.