Post-expiry extension applications under Section 29A are maintainable when sufficient cause is shown for arbitral delay.

Section 29A of the Arbitration and Conciliation Act permits an application to extend time for making an arbitral award even after expiry of the twelve-month period or the extended six-month period. The Court held that the phrase allowing extension either before or after expiry must be read in context and as a whole, so no implied bar can be imposed on post-expiry applications. A restrictive reading would add words to the statute and frustrate the object of efficient arbitration. The application is therefore maintainable after expiry, and the court may determine it on sufficient cause.

---

---

Issues: Whether an application for extension of time for making an arbitral award under Section 29A of the Arbitration and Conciliation Act, 1996 is maintainable even after expiry of the twelve-month period or the extended six-month period.

Analysis: Section 29A(4) expressly provides that the court may extend time either prior to or after expiry of the prescribed period, and Section 29A(5) permits a party to seek such extension on showing sufficient cause. The provision must be read as a whole and in context, so the expression "terminate" cannot be isolated to create a rigid bar against post-expiry applications. The surrounding scheme, including the continuance of mandate during pendency of an application, the power to substitute arbitrators, and the power to impose costs, shows that the provision is designed to secure expedition without defeating arbitration by technicality. A restrictive construction would amount to adding words to the statute and would frustrate the legislative purpose of efficient arbitral resolution.

Conclusion: The application for extension of time is maintainable even after expiry of the prescribed period, and the court may decide it on the basis of sufficient cause.

Ratio Decidendi: Where a statute expressly empowers the court to extend time either before or after expiry of the prescribed period, no implied limitation can be read into the provision to bar post-expiry applications, and the provision must be construed to further the statutory purpose rather than to defeat it by a rigid literalism.

---