Section 29A extension in arbitration remains maintainable after tribunal expiry, but relief depends on case-specific justification.

An application for extension of time under Section 29A of the Arbitration and Conciliation Act, 1996 remains maintainable even after the Arbitral Tribunal's tenure has expired. The Court applied that settled position to each matter individually, extending time where the delay in making and publishing the award was satisfactorily explained and the circumstances justified continuation. Where no sufficient justification existed, extension was refused and the matter was remitted for appointment of a new arbitrator. The connected appeals were disposed of on a mixed basis, with some orders set aside or modified and consequential directions given, including exclusion of time covered by stay or interim orders.

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Issues: (i) Whether an application for extension of time under Section 29A of the Arbitration and Conciliation Act, 1996 can be entertained even after expiry of the tenure of the Arbitral Tribunal; (ii) whether extension of time ought to be granted on the facts of the individual appeals, or the matter should be remitted for appointment of a new arbitrator.

Issue (i): Whether an application for extension of time under Section 29A of the Arbitration and Conciliation Act, 1996 can be entertained even after expiry of the tenure of the Arbitral Tribunal.

Analysis: The earlier judgment dated 12.09.2024 had already settled that an application for extension under Section 29A is not barred merely because the tribunal tenure has expired. That legal position governed the connected matters, and the Court proceeded on that basis while considering the consequences in each appeal.

Conclusion: Yes. Such applications can be filed and considered even after expiry of the Arbitral Tribunal's tenure.

Issue (ii): Whether extension of time ought to be granted on the facts of the individual appeals, or the matter should be remitted for appointment of a new arbitrator.

Analysis: The Court applied the settled Section 29A framework to the facts of each matter. Where the delay in making and publishing the award was explained by the record and the circumstances justified continuation, the time for making the award was extended. Where the Court found no sufficient and good justification for further extension, it declined to extend time and remitted the matter for appointment of a new arbitrator. In some matters, the impugned orders were set aside and the appeals were allowed, while in others the appeals were dismissed or partly allowed with consequential directions, including exclusion of the period during which the stay or interim order operated.

Conclusion: Extension was granted in appropriate matters, refused in others, and the connected orders were modified, set aside, dismissed, or remitted accordingly.

Final Conclusion: The connected appeals were disposed of by applying the earlier Section 29A ruling to the individual factual settings, resulting in a mixed outcome with extensions granted in some matters and refusal of extension with remand in others.

Ratio Decidendi: An application for extension of time in arbitral proceedings under Section 29A is maintainable even after expiry of the tribunal's tenure, but the grant of extension depends on a case-specific assessment of justification, delay, and the circumstances of the proceedings.

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