Arbitration panel non-disclosure upheld as a procedural safeguard, with court oversight and bias objections preserved.

Rule III(3) of the Indian Chamber of Commerce Arbitration Rules, which allows the Registrar to withhold the names of arbitrators from a non-member party until arbitration commences, was treated as a procedural safeguard rather than an infringement of the Indian Arbitration Act or natural justice. The rule did not oust the court's powers under Sections 5 and 11, and objections based on misconduct, bias, or prejudice could still be raised when the proper stage arose. The arbitration agreement remained valid and effective, and the challenge to the rule failed.

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Issues: Whether Rule III(3) of the Indian Chamber of Commerce Arbitration Rules, which permits non-disclosure of the names of arbitrators to a non-member party until the arbitration commences, is invalid as being inconsistent with the Indian Arbitration Act and the principles of natural justice.

Analysis: The agreement was to submit disputes to arbitration by the Indian Chamber of Commerce, and the parties were bound by the rules governing that arbitral forum. The challenged rule gave the Registrar a discretion to withhold disclosure of the names of the arbitration tribunal, but it did not abrogate the court's powers under Sections 5 and 11 of the Act. The court's authority to revoke an arbitrator's mandate or to deal with misconduct or bias remained available when the stage for such objections arose. The rule was treated as a procedural safeguard against premature influence, not as a restriction on judicial control or on objections grounded in bias or prejudice.

Conclusion: Rule III(3) was not inconsistent with the Indian Arbitration Act, and the arbitration agreement was not void or ineffective on that account. The challenge failed.

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