Expired arbitral mandate under Section 29A permits substitution of the arbitrator to ensure timely completion of arbitration.

Expiry of the arbitral mandate under Section 29A of the Arbitration and Conciliation Act, 1996 renders the sole arbitrator functus officio unless time is further extended. Section 29A(6) empowers the Court, when extending time, to substitute one or all arbitrators, and that power is not limited by the separate remedies under Sections 14 and 15. Prior rejection of proceedings under Sections 14 and 15 does not bar relief under Section 29A where the mandate had not then terminated. The Court should therefore act under Section 29A(6) rather than continue an expired mandate, in furtherance of the statute's objective of timely completion of arbitration.

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Issues: Whether, on expiry of the arbitral mandate under Section 29A of the Arbitration and Conciliation Act, 1996, the Court was required to substitute the sole arbitrator instead of extending his mandate.

Analysis: Section 29A is a remedial provision designed to secure expeditious conclusion of arbitral proceedings. Once the statutory period for making the award expired, and no further extension had been obtained, the sole arbitrator could not continue and became functus officio. Section 29A(6) expressly empowers the Court, while extending time, to substitute one or all arbitrators, and the exercise of that power is not confined by the separate remedies available under Sections 14 and 15. The prior rejection of proceedings under Sections 14 and 15 did not preclude relief under Section 29A, because the mandate had not then terminated. In the facts, the High Court ought to have acted under Section 29A(6) rather than extend the mandate of an arbitrator whose authority had already ceased.

Conclusion: The request for substitution was warranted, and the High Court's order extending the mandate was unsustainable.

Ratio Decidendi: When the arbitral mandate has expired under Section 29A, the Court may substitute the arbitrator under Section 29A(6) to advance the statute's objective of timely completion of arbitration; continuation of an expired mandate is impermissible.

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