Relan Infracon Pvt. Ltd. Vs Jasvinder Kaur — Arbitration | Delhi HC (2026)

Relan Infracon Pvt. Ltd. Vs Jasvinder Kaur — Arbitration | Delhi HC (2026)

What the court decided

AI extract

Outcome

Extension of the mandate of the arbitral tribunal by twelve months from 13.04.2026.

Issue for consideration

Whether the mandate of the arbitral tribunal under Section 29A(4) and 29A(5) of the Arbitration & Conciliation Act, 1996 can be extended on an application filed after the expiry of the twelve-month mandate. +1 more

Court's answer

An application for extension of the mandate of the arbitral tribunal under Section 29A(4) and 29A(5) is maintainable even after expiry of the twelve-month period; accordingly, the respondent's contention (supported by the Patna High Court decision in the South Bihar Power case) that such an extension cannot be granted post-expiry is illfounded.

Ratio / Principle

Having accepted the elucidated reasons for the proceedings remaining pending as constituting sufficient cause, this Court extends the mandate of the arbitral tribunal by twelve months.

Detailed headnote1 paragraphs

Arbitration — Extension of mandate under Sections 29A(4) and 29A(5), Arbitration & Conciliation Act, 1996 — Application filed after expiry of twelve-month mandate — Maintainability. Petition by Relan Infracon Pvt. Ltd. arising from a collaboration agreement dated 18.11.2018 (Clause 35 arbitration clause); arbitrator appointed by the Delhi High Court on 14.12.2022; proceedings adjourned sine die on 03.10.2023 pending payment of stamp duty; duty accepted on 02.01.2026 after an order in W.P.(C) 5856/2025; revival application filed 08.01.2026; arbitrator intimated expiry of mandate on 20.01.2026. Respondent's counsel relied on a Patna High Court decision (South Bihar Power Distribution Co. Ltd. v. Bhagalpur Electricity Distribution Co. (P) Ltd., CWJC 20350/2021, decided 26.04.2023) to contend that the mandate under Section 29A(4) & (5) cannot be extended on an application filed after expiry of twelve months. Following the quoted para 23 of Rohan Builders (India) Private Limited v. Berger Paints India Limited, (2025) 10 SCC 802 — holding such applications maintainable post-expiry and adjudicable on the principle of sufficient cause — the Court found the respondent's contention illfounded, accepted the reasons for pendency elucidated in the application, and extended the arbitral tribunal's mandate by twelve months from 13.04.2026. Bench: Justice Avneesh Jhingan (sole author).

$~67

IN THE HIGH COURT OF DELHI AT NEW DELHI

- O.M.P.(MISC.)(COMM.) 134/2026 & I.A. 3023/2026

RELAN INFRACON PVT. LTD. .....Petitioner

Through: Mr. Rajiv Bajaj, Mr. Vishant Prakash & Mr. Naman Arora, Advs.

versus

JASVINDER KAUR .....Respondent Through: Mr. Shahrukh Inam & Ms. Usha Singh, Advs. (through VC).

CORAM: HON'BLE MR. JUSTICE AVNEESH JHINGAN

O R D E R % 13.04.2026

This petition is filed under Section 29A(4) and 29A(5) of the Arbitration & Conciliation Act, 1996 for extension of mandate of the arbitral tribunal.

The brief facts are that the dispute between the parties to the lis arises from a collaboration agreement (for short „CA‟) dated 18.11.2018 in respect of scheduled property. Clause 35 of CA talks about dispute resolution through arbitration. On 14.12.2022 the arbitrator was appointed by this court. The matter was adjourned sine die on 03.10.2023 with the direction to the claimant/applicant to pay the stamp duty. After an order passed by this court in W.P.(C) 5856/2025 filed by petitioner, the stamp duty was accepted on 02.01.2026. On 08.01.2026 the application for revival of proceedings was filed. On 20.01.2026, the arbitrator informed that the mandate has expired

This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 20/04/2026 at 11:53:17

hence this petition.

Learned counsel for the respondent relies upon the decision of the Patna High Court in South Bihar Power Distribution Co. Ltd. v. Bhagalpur Electricity Distribution Co. (P) Ltd. Civil Writ Jurisdiction Case No. 20350/2021 decided on 26.04.2023 to buttress the contention that the mandate under Section 29A (4) & (5) cannot be extended on an application filed after expiry of twelve months.

The contention raised by learned counsel for the respondent is illfounded. The Supreme Court in Rohan Builders (India) Private Limited v. Berger Paints India Limited (2025) 10 SCC 802 held as under :

“23. In view of the above discussion, we hold that an application for extension of the time period for passing an arbitral award under Section 29-A(4) read with Section 29A(5) is maintainable even after the expiry of the twelvemonth or the extended six-month period, as the case may be. The court while adjudicating such extension applications will be guided by the principle of sufficient cause and our observations in para 19 of the judgement.”

The reasons for the arbitral proceedings remaining pending are duly elucidated in the application and are accepted. The mandate is extended by twelve months from today.

AVNEESH JHINGAN, J

APRIL 13, 2026 ‘JK’

This is a digitally signed order.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 20/04/2026 at 11:53:17