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

Konkan Railway Corpn. Ltd. vs. Rani Construction Pvt.Ltd

( Whether the order of Chief Justice or his designate in appointing an arbitrator under Section 11(6) is administrative or judicial in nature )
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Case Reference :
Civil Appeals No.5880-89 of 1997 with Nos.713-16, 2037-44, 4311-12, 4324, 4356, 7304 and 7306-09 of 1999, decided on October 19, 2000.

Judges :
Shri Justice M.Jagannadha Rao and Shri Justice K.G.Balakrishnan

Parties :
Konkan Railway Corpn.Ltd and others (Appellants) Vs. Rani Construction Pvt.Ltd.(Respondent).

Question of Law :

Whether the order of Chief Justice or his nominee appointing an Arbitrator u/s.11 of the Arbitration and Conciliation Act, 1996 is an administrative or judicial order?
 

Gist of the Case:

The learned Solicitor General of India appearing for the appellants submitted that the order of the learned Chief Justice of Mumbai High Court, u/s.11 of Arbitration & Conciliation Act, 1996 (for short “the Act”), on the preliminary issues is a judicial order, on facts, is liable to be set aside under Article 136 of the Constitution of India. It was contended that even if the order is treated as administrative in nature, it is amenable to Article 136.
The three-Judge Bench of the Supreme Court of India in Konkan Railway Corpn.Ltd. vs.Mehul Construction Co. held that the order of the Chief Justice or his nominee in appointment of an Arbitrator under Section 11 of the Act is administrative in nature and no appeal is maintainable under Article 136 of the Constitution against such an order, even if they contain reasons and decisions on certain preliminary issues raised by the parties at the stage of appointment of an Arbitrator.
The learned Solicitor General contended that it is now well settled in several countries, where the UNCITRAL Model has been adopted and where the Arbitrator also is permitted to decide questions as to the existence of the arbitration clause or validity of the agreement, that the court can decide certain preliminary disputes which are raised before it or before the appointment of Arbitrators - such as disputes relating to existence of arbitration agreement or a question as to the very existence of a “dispute” or as to whether the items of disputes fall within “excepted” matters or whether an arbitrator could be appointed where the invocation of the clause by one party was beyond the prescribed period in which one has to ask the other side to appoint an Arbitrator etc. The Solicitor General contended that in a situation where the matter has straight away gone before an Arbitrator by act of parties without intervention of court, the Arbitrator is empowered to decide these basic questions under Section 16 of the Act. However, when a case comes before judicial authority and the defendant pleads that there is an arbitration clause or where, on account of non-appointment of an Arbitrator, the court is approached for appointment of an Arbitrator, the court can decide these preliminary issues judicially and need not mechanically appoint an Arbitrator under Section 11 in such cases.
A reference was drawn to the post-UNCITRAL case-law in France, Austria, Sweden, Belgium, Netherlands, USA, etc., where if the court is first seized of the preliminary issues before appointment of an Arbitrator, even in cases where the Arbitrator, under the statute, is empowered to decide these questions - the court can and will decide these issues first rather than permit the Arbitrator to decide them.
The Solicitor General contended that merely because the words “Chief Justice (or his nominee)” are now used in the 1996 Act, the order of the Chief Justice (or his nominee) does not become an administrative order. The order does not relate to administrative functions of the Chief Justice of India or Chief Justice of the High Court –
such as those concerning the internal administration of the Supreme Court, or the High Court or of the subordinate judiciary, as the case may be. On the other hand, if preliminary issues raised by two contracting litigating parties are decided by the Chief Justice (or his nominee), such an order cannot be administrative in nature.
It was pointed out that if an order of the Chief Justice (or his nominee) was to be treated as an administrative order, it could be challenged before a Single Judge of the High Court and then before a Division Bench and then in the Supreme Court under Article 136 and such a procedure would only delay the arbitration proceedings more than if the order was accepted as a judicial order and was permitted to be challenged directly under Article 136. If the order of the Chief Justice (or his nominee) were to be treated to be administrative in nature, in practice, the defaulting party could drag on the matter for years at the two stages of Article 226 proceedings even on the preliminary issues.
The learned Judges were of the view in the light of the above contentions and a number of cases arising out of the question discussed above (i.e. whether administrative order or not) it was desirable to re-examine the matter and directed the papers to be placed before the Hon’ble Chief Justice of India for passing appropriate orders.

Citation :
( 2000) 8 SCC 159

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