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Nimet Resources Inc. and another vs. Essar Steels Ltd.

( Whether Chief Justice or his designate can decide a challenge to the “existence” of the arbitration clause under Section 11 or it is to be decided under Section 16 by the Arbitral Tribunal itself)
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Case Reference :
Arbitration Petitions No.19 of 2000 with Nos.20 and 21 of 2000, decided on September 27, 2000

Judges :
Justice S.Rajendra Babu

Parties :
Nimet Resources Inc. and another (Petitioners) Vs. Essar Steels Ltd. (Respondent).

Question of Law :

When the existence of an agreement between the parties to submit to arbitration any disputes between them is itself challenged, whether such a question is to be decided by the Chief Justice or his nominee under Section 11 of the Act of 1996 or should it be decided by the Arbitral Tribunal in terms of Section 16 of the Act of 1996?
 

Gist of the Case:

Nimet Resources Inc. is a company incorporated in Canada and is engaged in trading of metals conducting its business though its agent, the second Petitioner. They claim that they entered into certain transactions with the Respondent for sale and supply of about 100 metric tons of ferro-vanadium through its agent, the second Petitioner. The Respondent purchased 20 tons of ferro-vanadium by opening a letter of credit but failed to open further letters of credit for the balance quantity of 80 tons of ferro-vanadium. The Petitioner contended that the fact that the Respondent opened a letter of credit for 20 tons of ferro-vanadium itself would indicate that the Respondent had acted upon the terms of the sales contract and the correspondence between them also would reveal the Respondent’s acceptance of the sales contract. Thus the Petitioner contended that a dispute exists between them and clause 10 of the sales contract between the parties indicates an agreement providing for resolution of disputes between the parties by arbitration. The Petitioner sent a notice to the Respondent to choose a venue for the arbitration failing which the Petitioner was free to choose the same. The Respondent denied the existence of the sales contract stating that it was not signed by them nor was the same confirmed in any other manner.
The Supreme Court observed that there was some correspondence between the Petitioner and Respondent with regard to sale and supply of different quantities of ferro-vanadium on different dates. But whether these transactions fructified into a contract with an arbitration clause is not clear. When there is a doubt as to the existence or otherwise of the arbitration agreement and when the correspondence or exchange of letters or documents between the parties is not clear as to the existence or non-existence of the arbitration agreement in terms of Section 7 of the Act of 1996, the appropriate course would be that the arbitrator should decide such a question under Section 16 of the Act of 1996 rather than the Chief Justice of India or his nominee under Section 11 of the Act of 1996. The learned Judge said that he took this view because the power exercised by the Chief Justice of India or his nominee under Section 11 of the Act of 1996 is in the nature of an administrative order. In such a case, unless the Chief Justice of India or his nominee can be absolutely sure that there exists no arbitration agreement between the parties, it would be difficult to state that there should be no reference to arbitration. Further, such a view may not be conclusive in view of the nature of the powers that are exercised under Section 11(6) of the Act of 1996. It would therefore be appropriate to refer the matter to arbitration and the arbitrator will decide the question as to existence or otherwise of the arbitration agreement.

Citation :
(2000) 7 SCC 497

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LIST OF SUPREME COURT CASES RELATING TO ARBITRATION AND CONCILIATION ACT, 1996 ----- Click Here