Thursday, August 8, 2013

What’s in the number of Arbitrators? : An analysis of Section 10 of the Arbitration and Conciliation Act, 1996

In order to ensure that an arbitral proceeding is run smoothly, it is imperative to have the presence of arbitrators. In some situations, arbitral proceedings may require the presence of several arbitrators. However, there is also a possibility that, in some situations, the presence of a single arbitrator may be sufficient for the conduct of arbitral proceedings. Section 10 of the Arbitration and Conciliation Act, 1996 (“Arbitration”) provides that the number of such arbitrators shall not be in even. Section 10(1) of the Arbitration Act reads as:

“…..The parties are free to determine the number of arbitrators, provided that such number shall not be an even number.”

Given this situation, will an arbitration agreement, providing for an even number of arbitrator, become invalid? In this post, while focusing on the decisions of the Supreme Court of India (“Supreme Court”), we will explain this issue pertaining to Section 10 of the Arbitration Act.

Comparison between UNCITRAL Model Law and Arbitration Act, 1996

Section 10 of the Arbitration Act is based on Article 10 of the 1985 UNCITRAL Model Law on International Commercial Arbitration (“Model Law”).[1]Article 10(1) of the Model Law reads as:

“….The parties are free to determine the number of arbitrators”

A difference can be seen between Section 10 of the Arbitration Act and Article 10 of the Model Law. While Model Law does not require the parties to provide for an odd number of arbitrators, such requirement is present in Arbitration Act. If Parliament of India (“Parliament”) has added such words, there must have been a reason behind it. Did Parliament intend to render arbitration agreement, contrary to Section 10 of Arbitration Act, as invalid? Before arriving at any conclusion, it is important to see the take of the Supreme Court on the issue.


Present Legal Position of Section 10 in India

In Narayan Prasad Lohia v. Nikunj Kumar Lohia, it was held that, under Arbitration Act, an objection against the composition of arbitral tribunal is a derogable in nature.[2] Further, it was held that an agreement does not become invalid merely because it provides for the even number of arbitrators. For instance, where the agreement provides for two arbitrators, third arbitrator can be appointed by the two arbitrators under Section 11(3) of the Arbitration Act. It was held by the Court that:

“….However, we see no reason, why the two arbitrators cannot appoint a third arbitrator at a later stage i.e. if and when they differ. This would ensure that on a difference of opinion the arbitration proceedings are not frustrated…………. Thus we do not see how there would be waste of time, money and expense if a party, with open eyes, agrees to go to arbitration of two persons and then participates in the proceedings….”

Even if it is assumed that Section 10 of the Arbitration Act is a derogable provision, it would not be correct to say that there will be no waste of time and money, if the third arbitrator is appointed at a later stage. In such a situation, there is a possibility that the newly appointed third arbitrator may want to go through the evidence, contentions etc., which have already been adduced before the other arbitrators. That being the case, it is hard to believe how both the time and money will not be wasted, if such an appointment of third arbitrator is carried out at a later stage when the two arbitrators differ.

In support of this, Court made an analogy with Section 11 whereby no provision is present for a situation when 5 or 7 or more arbitrators are to be appointment. This, according the Court, would not imply that an agreement, providing for 5 or more odd number of arbitrators, will be invalid. Rather, provisions under Section 11 can be applied mutatis mutandis. Similarly, an arbitration agreement, providing for two arbitrators, will not be invalid since, in such a situation, two arbitrators can appoint the third arbitrator under Section 11(3) of the Arbitration Act.

There is a problem with such reasoning. Section 11(3) provides for a situation when parties fail to agree on the procedure for appointing arbitrators. However, we are concerned with a situation when parties agree to provide for even number of arbitrators, for example, two. How, in such a situation, can Section 11(3) be applied when the procedure has already been agreed upon, i.e., there is no failure to reach an agreement under Section 11(2)? Or, was it the case that the Court intended to mean that the agreement under Section 11(2) should be in conformity with Section 10(1), otherwise in will not be in accordance with the Arbitration Act. And, in such a situation, Section 11(3) will become applicable. Though it may be the case, this is not very clear in the judgment. In any case, even such an interpretion would be very difficult.

The intention behind the requirement of the odd number of arbitrator could have been to avoid any such eventuality. In case only two arbitrators are provided in the agreement, a more viable solution can the appointment of the third arbitrator at the beginning itself. In this sense, it would both be in conformity with the Section 10 and would not create any hardship at a later stage. If the intention of the Parliament was to allow parties to have even number of arbitrators, then there was no need to deviate from the language of Article 10 of Model Law.

At this juncture, let us also look at Section sub-section (6) of Section 11 of Arbitration Act. Clause (b) of sub-section (6) confers power on the Chief Justice to take necessary measures if the two appointed arbitrators, fail to reach an agreement expected of them under that procedure. The reason for providing two arbitrators here should be related to constitution of arbitral tribunal, and should not be related to the different in the opinion of the two arbitrators with regard to the result/award. It is because arriving at different conclusions, with regard to the result/award of arbitration, is always a possibility in arbitration. Indeed, it is an integral part of arbitration that the appointed arbitrators should act to arrive at a proper result/award.

Though Supreme Court, in ¶ 12 of Groupe Chimique Tunisien SA v. Southern Petrochemicals Industries Corpn. Ltd.,[3] considered Section 10 of the Arbitration Act for concluding that arbitral tribunal shall consist of three members, no sound reasoning was provided for resolving the conflict between even and odd number of arbitrators. Further, in Sime Darby Engg. SDN. BHD. v. Engineers India Ltd.,[4] Supreme Court held that:

“Section 10 deviates from Article 10 of the Uncitral Model Law only in the sense that Section 10(1) of the Act provides that despite the freedom given to the parties to determine the number of arbitrators such numbers shall not be even number”(emphasis supplied)
These two cases, though decided after Narayan Lohia (supra), were quite specific to their factual situations. For the time being, the law of the land is that an arbitration agreement, even with two arbitrators, can be made.



[1] Sime Darby Engg. SDN. BHD. v. Engineers India Ltd., (2009) 7 SCC 545, 550
[2] Narayan Prasad Lohia v. Nikunj Kumar Lohia, (2002) 3 SCC 572 at page 582, 583
[3] Groupe Chimique Tunisien SA v. Southern Petrochemicals Industries Corpn. Ltd., (2006) 5 SCC 275, 281
[4] Darby Engg. SDN. BHD. v. Engineers India Ltd., (2009) 7 SCC 545 at page 550

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