Religare Finvest Limited vs. Edisons Infrapower And Multiventures Private Limited & Anr.
Background
Religare Finvest Limited had loan-agreement disputes referred to arbitration; the arbitrator's mandate needed extension under Section 29A(4)/(5) of the Arbitration Act. The original arbitrator, Justice (Retd.) Rekha Sharma, had withdrawn; Justice (Retd.) S.J. Mukhopadhaya (a former Supreme Court judge) was appointed as the replacement sole arbitrator in 2024. Disputes over stamping of the loan agreements led to a Common Interim Award (28.02.2026), which was itself challenged under Section 34, with those petitions reserved for orders since August 2026. Since arguments had concluded and neither side attributed the delay to the other, Religare sought a further extension of the arbitrator's mandate.
Decision Breakdown
The Court held that sufficient cause was shown under Section 29A to extend the mandate, noting the proceedings were at an advanced stage, arguments were complete, and the delay wasn't attributable to either party (the respondents had no objection). The Court extended the sole arbitrator's mandate until 02.09.2027 and regularised the period of delay up to the date of the order. The petition was disposed of in these terms.
Lesson Learnt
Courts will readily extend an arbitrator's mandate under Section 29A where the delay is not attributable to either party and the proceedings are nearly complete: parties need not fear a "time-barred" award merely because adjudication takes longer than the statutory period, so long as they promptly seek a court extension.