Arbitration time extension under Section 29A can be sought after mandate expiry when sufficient cause is shown.

Section 29A(4) of the Arbitration and Conciliation Act, 1996 permits an application for extension of time even after expiry of the arbitral tribunal's mandate, so expiry does not by itself bar relief. The Court also held that sufficient cause existed for extension, considering the pandemic-related exclusion period, the stage of the proceedings, completion of hearings, and the parties' agreement to seek extension. It found the High Court had overstated the delay and granted extension of time for making the award, setting aside the refusal of extension.

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Issues: (i) Whether an application for extension of time under Section 29A(4) of the Arbitration and Conciliation Act, 1996 can be entertained after the expiry of the arbitral tribunal's mandate; (ii) Whether the facts and circumstances of the case disclosed sufficient cause for extension of time.

Issue (i): Whether an application for extension of time under Section 29A(4) of the Arbitration and Conciliation Act, 1996 can be entertained after the expiry of the arbitral tribunal's mandate.

Analysis: Section 29A(4) expressly empowers the Court to extend the period for making the award either prior to or after expiry of the statutory period. The provision, read with the earlier decision explaining its scope, makes it clear that termination of the tribunal's mandate on expiry of time is not absolute and an application for extension is maintainable even after expiry. The filing of the application after expiry therefore does not, by itself, defeat the request for extension.

Conclusion: The issue is answered in favour of the appellant.

Issue (ii): Whether the facts and circumstances of the case disclosed sufficient cause for extension of time.

Analysis: The Court took into account the pandemic-related exclusion period, the progress of the arbitral proceedings, the completion of hearings, and the parties' agreement to seek extension. It held that the delay after the relevant adjusted date was limited and that the High Court had erred in treating the matter as involving a much longer delay. On the overall circumstances, the Court found sufficient cause to extend the time for making the award.

Conclusion: The issue is answered in favour of the appellant.

Final Conclusion: The arbitral tribunal's time for making the award was extended, and the High Court's order refusing extension was set aside.

Ratio Decidendi: Under Section 29A of the Arbitration and Conciliation Act, 1996, an application for extension of time may be entertained even after expiry of the tribunal's mandate, and extension may be granted where sufficient cause is shown in furtherance of effective dispute resolution.

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