Arbitration limitation begins on receipt of the signed award, not on circulation of a draft or majority decision.

Under Section 34(3) of the Arbitration and Conciliation Act, 1996, limitation to challenge an arbitral award begins only on receipt of the signed copy of the award under Section 31(5), because the award attains legal effect and finality only when signed and delivered. In a tribunal with multiple arbitrators, a majority decision is the award, while any dissent remains only an opinion and does not alter the operative date. Circulation of a draft or majority decision does not start time for a setting-aside petition. On the stated facts, the signed award was received on 19.05.2018, so the objections filed thereafter were within time and the finding of delay was unsustainable.

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Issues: Whether the limitation period for filing objections under Section 34 of the Arbitration and Conciliation Act, 1996 commenced on circulation of the draft or majority award, or only on receipt of the signed copy of the arbitral award.

Analysis: An arbitral award attains legal effect and finality only when it is signed and delivered in accordance with Section 31. In a tribunal with more than one arbitrator, a majority decision constitutes the award under Section 29, while a dissenting opinion remains only an opinion and does not form part of the enforceable award. Reading Sections 31(5) and 34(3) harmoniously, the period for filing a setting-aside petition begins from the date on which the party receives the signed copy of the award. The delivery of a signed award is a substantive step, because it triggers the time for correction or interpretation proceedings, the termination of arbitral proceedings, and the limitation period for challenge. The facts showed that the signed copy of the award was made available to the parties only on 19.05.2018.

Conclusion: The limitation period under Section 34(3) commenced from 19.05.2018, and the objections filed thereafter were within time. The finding of delay was unsustainable.

Ratio Decidendi: For purposes of Section 34(3) of the Arbitration and Conciliation Act, 1996, limitation to challenge an arbitral award begins only upon receipt of the signed copy of the award under Section 31(5), not on the date of circulation or oral pronouncement of a draft or majority decision.

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