Saturday, 23 July 2022

Would a party forfeit its right to apply U/S 8(1) of the arbitration Act if it fails to apply U/S 8(1) within the time available for filing the written statement?

  The change in the language of Section 8(1) of the A&C Act ismaterial. Whereas prior to the 2015 Amendment, Sub-section (1) of Section 8 of the A&C Act used the expression “not later than when submitting his first statement on the substance of the dispute”. Subsection (1) of Section 8, as substituted, uses the expression “not later than the date of submitting his first statement on the substance of the dispute”. The legislative intent to introduce the words “not later than the date of” clearly stipulates a framework of time within which an application under Section 8(1) of the A&C Act can be made. {Para 22}

25. As stated above, a written statement would also fall within the sweep of expression “statement on the substance of the dispute” as used in Section 8(1) of the A&C Act. The introduction of the expression “the date of” in the context of the suit would necessarily have to be co-related with the time available or granted for filing of a written statement. The legislative intent of introducing the expression “the date of”, when read with the contemporaneous amendments to Order VIII Rule 1 of the CPC by virtue of the Commercial Courts Act, 2015, is quite clear; it is to introduce the precise time frame within which an application under Section 8(1) of the A&C Act could be filed.

26. Resultantly, if a party fails to file an application under Section 8(1) of the A&C Act for referring the parties to arbitration within the time available or granted for filing the first statement on the substance of the dispute (which would include a written statement in the context of a suit), the party would forfeit its right to apply under Section 8(1) of the A&C Act.

IN THE HIGH COURT OF DELHI AT NEW DELHI

FAO(COMM) 81/2022 and CM No. 24865/2022

M/S SPML INFRA LTD. Vs M/S. TRISQUARE SWITCHGEARS

PVT. LTD. 

CORAM:

HON'BLE MR. JUSTICE VIBHU BAKHRU

HON'BLE MR. JUSTICE AMIT MAHAJAN

Author: VIBHU BAKHRU, J.

Judgment delivered on: 6th July 2022

1. The appellant has filed the present appeal impugning an order

dated 28.03.2022 (hereinafter ‘the impugned order’) passed by the

learned Commercial Court rejecting the appellant’s application filed

under Section 8 of the Arbitration and Conciliation Act, 1996

(hereinafter ‘the A&C Act’). The learned Commercial Court had

declined to refer the parties to arbitration on the ground that the

appellant had filed the said application after the statutory period to file

the written statement had expired and the appellant’s right to do so

was closed. In addition, the learned Commercial Court also observed

that the proceedings indicated the appellant’s intention to participate

in the same.

2. It is the appellant’s case that it had no intention to participate in

the proceedings before the learned Commercial Court or to waive its

right to refer the subject disputes to arbitration.

3. The principal question that is required to be addressed is

whether a party forfeits its right to file an application under Section 8

of the A&C Act on expiry of time to file the written statement of its

defence.

4. Briefly stated, the relevant facts necessary to address the

controversy in the present appeal are as under: -

4.1 The respondent (plaintiff) has filed the suit for recovery and

claiming a decree against the appellant (defendant) for a sum of

₹15,60,000/- along with pendente lite and future interest at the rate of

18% per annum as well as costs. The plaintiff claims that it had

supplied goods and raised invoices for a value of ₹1,06,32,953/-.

Against the aforesaid amount, it had received an aggregate amount of

₹97,17,481/- till 31.03.2015. It had received a further payment of

₹1,146/- on 18.04.2015. Thus, a balance amount of ₹10,20,477/-

remains outstanding and payable.


4.2 In its plaint, the plaintiff claims that it is entitled to the said

amount along with interest at the rate of 18% per annum from

18.04.2015 till filing of the plaint on 26.03.2018 computed at

₹5,39,700/-. Thus, in aggregate, the plaintiff claims that it was entitled

to a sum of ₹15,60,177/- inclusive of interest till the date of filing of

the suit, which is rounded off to ₹15,60,000/-.

4.3 The said suit was listed before the learned Commercial Court on

11.04.2018 and a copy of the plaint and other documents were

provided to the learned counsel for the defendant (the appellant

herein). The learned Commercial Court granted one month’s time to

file the Written Statement and listed the suit for further proceedings on

29.07.2018. The appellant failed to file the Written Statement within

the specified period and the matter was adjourned. It was again listed

on 03.11.2018. On that date, the learned Commercial Court noted that

the appellant had not filed the Written Statement and the time for

doing so had expired. Accordingly, the learned Commercial Court

closed the right of the appellant to file the Written Statement and relisted

the matter for the plaintiff’s evidence on 29.01.2019.

4.4 The plaintiff (the respondent) filed an affidavit of its witness

and a copy of the same was also provided to the appellant. However,

since the representative of the plaintiff (the respondent) had not

brought the original documents to court on 29.01.2019, the learned

Commercial Court adjourned the matter to 18.04.2019.


4.5 At this stage, the appellant has filed an application under

Section 8 of the A&C Act. The appellant relied upon the dispute

resolution clause as included in the Purchase Order dated 01.04.2018

and sought reference of the subject disputes to arbitration.

5. Mr Khurana, learned counsel appearing for the appellant,

submitted that the learned Commercial Court had relied upon the

decision of a Single Bench of this Court in Anil Mahindra & Anr. v.

Surender Kumar Makkar & Anr.1 and on the strength of the said

decision, rejected the appellant’s application under Section 8 of the

A&C Act. He submitted that the said decision was rendered in a

petition filed under Article 227 of the Constitution of India and the

Court had declined to interfere with the orders passed by the learned

Trial Court without examining the language of Section 8 of the A&C

Act. He further referred to another decision of the Single Bench of this

Court in Hughes Communication India Ltd. & Ors. v. Union of

India2 and drew the attention of this Court to paragraph 27 of the said

judgment, wherein the Court had noted that the decision in Anil

Mahindra’s3 case was rendered without noting that Section 8 of the

A&C Act did not permit any such interpretation and therefore, the

same was not a binding precedent. He submitted that the learned

Commercial Court had erred in following the said decision.

6. In fairness, the learned counsel also referred to the decisions of

a Single Bench of this Court in SSIPL Lifestyle Private Limited v.

12017 SCC OnLine Del 11532

22018 SCC OnLine Del 10879

3Supra Note 1


Vama Apparels (India) Private Limited & Anr.4 and the decision in

the case of Krishan Radhu v. The Emmar MGF Construction Pvt.

Ltd.5, wherein the Court had taken different view in the context of

Section 8 of the A&C Act as amended by virtue of the Arbitration and

Conciliation (Amendment) Act, 2015. Further, he also referred to the

decision of a Single Judge of this Court in Shri Chand Construction

and Apartments Private Limited &Anr. v. Tata Capital Housing

Finance Ltd.6.

7. Prior to enactment of the A&C Act (Arbitration and

Conciliation Act, 1996), the law relating to arbitration was embodied

in the Arbitration Act, 1940. Section 34 of the said Act empowered the

court “to stay legal proceedings where there is an arbitration

agreement”. Section 34 of the said Act is relevant and reproduced

below:

“34. Power to stay legal proceedings where there is an

arbitration agreement.— Where any party to an

arbitration agreement or any person claiming under him

commences any legal proceedings against any other

party to the agreement or any person claiming under him

in respect of any matter agreed to be referred, any party

to such legal proceedings may, at any time before filing

a written statement or taking any other steps in the

proceedings, apply to the judicial authority before which

the proceedings are pending to stay the proceedings; and

if satisfied that there is no sufficient reason why the

matter should not be referred in accordance with the

arbitration agreement and that the applicant was, at the

42020 SCC OnLine Del 1667

52016 SCC OnLine Del 6499

62020 SCC OnLine Del 472

time when the proceedings were commenced, and still

remains, ready and willing to do all things necessary to

the proper conduct of the arbitration, such authority may

make an order staying the proceedings.”

8. In terms of Section 34 of the Arbitration Act, 1940, a party was

entitled to apply to the court/judicial authority before which the legal

proceedings were pending to stay the proceedings “at any time before

filing a written statement or taking any other steps in proceedings”.

The courts had interpreted the expression “other steps in the

proceedings” to mean “such steps as would manifestly display an

unequivocal intention to proceed with the suit and to give up the right

to have the matter disposed of by arbitration”7.

9. The Supreme Court had also explained the expression “taking

any ‘other steps in the proceedings’ does not mean that every step in

the proceedings would come in the way of enforcement of the

arbitration agreement. The step must be such as would clearly and

unambiguously manifest the intention to waive the benefit of

arbitration agreement”8.

10. The A&C Act replaced the Arbitration Act, 1940. The A&C

Act is based on the UNCITRAL Model Law. Article 8 of the

UNCITRAL Model Law reads as under: -

“Article 8. Arbitration agreement and substantive claim

before court (1) A court before which an action is

brought in a matter which is the subject of an

arbitration agreement shall, if a party so requests not

7Food Corpn. of India v. Yadav Engineer & Contractor: (1982) 2 SCC 499

8RachappaGurudappaBijapur v. GurudiddappaNurandappa: (1989) 3 SCC 245

later than when submitting his first statement on the

substance of the dispute, refer the parties to arbitration

unless it finds that the agreement is null and void,

inoperative or incapable of being performed.

(2) Where an action referred to in paragraph (1) of this

article has been brought, arbitral proceedings may

nevertheless be commenced or continued, and an award

may be made, while the issue is pending before the

court.”

11. Section 8 of the A&C Act, as enacted, was somewhat similar to

Article 8 of the UNCITRAL Model Law and reads as under:

“8. Power to refer parties to arbitration where there is

an arbitration agreement.–

(1) A judicial authority before which an action is

brought in a matter which is the subject of an

arbitration agreement shall, if a party so applies not

later than when submitting his first statement on the

substance of the dispute, refer the parties to arbitration.

(2) The application referred to in sub-section (1) shall

not be entertained unless it is accompanied by the

original arbitration agreement or a duly certified copy

thereof.

(3) Notwithstanding that an application has been made

under sub-section (1) and that the issue is pending

before the judicial authority, an arbitration may be

commenced or continued and an arbitral award made.”

12. It is clear from the above that Section 8 of the A&C Act did not

prescribe any specific time for filing an application under Section 8 of

the A&C Act for referring the parties to arbitration. It merely provided


that such application ought to be moved not later than submission of

the first statement on the substance of the dispute.

13. In Booz Allen and Hamilton Inc. v. SBI Home Finance Ltd. &

Ors.9, one of the questions that fell for consideration before the

Supreme Court was whether an application under Section 8 of the

A&C Act was liable to be rejected on the ground that it was filed

almost twenty months after the defendant had entered appearance in

the suit. The Court answered the question as under: -

“19. Though Section 8 does not prescribe any time

limit for filing an application under that section, and

only states that the application under Section 8 of the

Act should be filed before submission of the first

statement on the substance of the dispute, the scheme

of the Act and the provisions of the section clearly

indicate that the application thereunder should be made

at the earliest. Obviously, a party who willingly

participates in the proceedings in the suit and subjects

himself to the jurisdiction of the court cannot

subsequently turn round and say that the parties should

be referred to arbitration in view of the existence of an

arbitration agreement. Whether a party has waived his

right to seek arbitration and subjected himself to the

jurisdiction of the court, depends upon the conduct of

such party in the suit.

When plaintiffs file applications for interim relief like

appointment of a receiver or grant of a temporary

injunction, the defendants have to contest the

application. Such contest may even lead to appeals and

revisions where there may be even stay of further

proceedings in the suit. If supplemental proceedings

like applications for temporary injunction on

9(2011) 5 SCC 532


appointment of Receiver, have been pending for a

considerable time and a defendant has been contesting

such supplemental proceedings, it cannot be said that

the defendant has lost the right to seek reference to

arbitration. At the relevant time, the unamended Rule 1

of Order VIII of the Code was governing the filing of

written statements and the said rule did not prescribe

any time limit for filing written statement. In such a

situation, mere passage of time between the date of

entering appearance and date of filing the application

under Section 8 of the Act, can not lead to an inference

that a Defendant subjected himself to the jurisdiction of

the court for adjudication of the main dispute. The facts

in this case show that the plaintiff in the suit had filed

an application for temporary injunction and

appointment of Receiver and that was pending for some

time. Thereafter, talks were in progress for arriving at a

settlement out of court. When such talks failed, the

appellant filed an application under Section 8 of the

Act before filing the written statement or filing any

other statement which could be considered to be a

submission of a statement on the substance of the

dispute. The High Court was not therefore justified in

rejecting the application on the ground of delay.”

14. The expression “first statement on the substance of the dispute”

is of wide import. It would take within its sweep any statement filed to

join or raise issues regarding the substratum of the matter in dispute.

In the context of the civil suit, it would include the written statement

as required to be presented under Order VIII Rule 1 of the Code of

Civil Procedure, 1908 (CPC).


15. In Rashtriya Ispat Nigam Ltd. v. Verma Transport Co.10, the

Supreme Court had interpreted the expression “first statement on the

substance of the dispute” and observed as under: -

“36. The expression ‘first statement on the substance of

the dispute’ contained in Section 8(1) of the 1996 Act

must be contradistinguished with the expression

“written statement”. It employs submission of the party

to the jurisdiction of the judicial authority. What is,

therefore, needed is a finding on the part of the judicial

authority that the party has waived its right to invoke

the arbitration clause. If an application is filed before

actually filing the first statement on the substance of

the dispute, in our opinion, the party cannot be said to

have waived its right or acquiesced itself to the

jurisdiction of the court. What is, therefore, material is

as to whether the petitioner has filed his first statement

on the substance of the dispute or not, if not, his

application under Section 8 of the 1996 Act, may not

be held wholly unmaintainable.”

16. The expression “not later than” as used in Section 8(1) of the

A&C Act also makes it amply clear that a party would not be

precluded from applying under Section 8 of the A&C Act

simultaneously along with filing of a written statement or include such

relief in the written statement. However, the party would forfeit its

right to apply under Section 8 of the A&C Act once it has filed the

written statement. The expression “first statement on the substance of

the dispute” would also take within its sweep any other filing,

whereby a party evinces his intention to contest the proceedings and

subject himself to the jurisdiction of court/judicial authority. Filing of

10(2006) 7 SCC 275

any such statement, would indicate the party’s intention to abandon

the arbitration agreement. It would preclude the said party to thereafter

seek that the parties be referred to arbitration under Section 8 of the

A&C Act.

17. Although Section 8 of the A&C Act (as in force prior to

23.10.2015) did not prescribe any time period within which a party

must apply under Section 8 of the A&C Act as explained in Booz

Allen and Hamilton Inc. v. SBI Home Finance Ltd. & Ors.11, the

scheme of the A&C Act and the provisions of Section 8 of the A&C

Act clearly indicate that the application under that section “should be

made at the earliest”.

18. It is clear from the scheme of the Act that once the proceedings

before the court or judicial authority progress beyond the initial stage,

it would no longer be permissible for a party to then turn around and

seek recourse to arbitration. A mere delay in making an application

under Section 8 of the A&C Act may not be fatal to a party’s right; but

once the proceedings have progressed beyond the stage of completion

of pleadings, such an application would not lie. This is because at that

stage, the parties are sufficiently invested in the said proceedings, and

it would not be permissible for any party to turn around and apply

under Section 8 of the A&C Act.

19. If a party’s right to file a statement of defence is closed, the

same would also result in its rights accruing in favour of the other

11Supra Note 9

party. Clearly, at this stage, it would not be permissible for a party to

apply under Section 8 of the A&C Act even though he has not

expressly evinced any intention to contest the proceedings. It is

implicit in the expression “not later than submitting the first statement

of substance of the dispute” that the application under Section 8 of the

A&C Act can be made at the stage when it is open for a party to

submit such a statement. It, obviously, follows that once such a stage

is crossed, the right of the party to apply under Section 8(1) of the

A&C Act would also stand closed. The scheme of Section 8 of the

A&C Act does not contemplate unraveling concluded proceedings.

Once the right of a party to file the written statement of defence is

closed, the proceedings in a suit progress beyond the stage of

completion of pleadings. It is not open for the defendant to now seek a

reference to arbitration. Although Section 8 of the A&C Act (as in

force prior to 23.10.2015) did not specify any time limit, it did

indicate the stage of the proceedings at which a party could apply, that

is, before filing of the first statement on the substance of the dispute.

This clearly implies a stage at which such a statement could be filed

and not thereafter.

20. If the contention advanced by the appellant is accepted, it would

imply an application under Section 8 of the A&C Act can be allowed

to be filed at any stage of the proceedings; even after the evidence is

tendered and witnesses have been cross-examined or for that matter

just before the matter is fixed for pronouncement of the decision.

Clearly, this is not in conformity with the scheme of Section 8 of the

A&C Act.

21. The Arbitration and Conciliation (Amendment) Act, 2015 [Act

3 of 2016] amended the A&C Act significantly. By virtue of the said

Act, Sub-section (1) of Section 8 of the A&C Act was substituted and

a proviso was introduced to Sub-section (2) of Section 8 with

retrospective effect from 23.10.2015. Section 8 of the A&C Act, as in

force with effect from 23.10.2015, reads as under:

“8. Power to refer parties to arbitration where there

is an arbitration agreement-[(1) A judicial authority,

before which an action is brought in a matter which is

the subject of an arbitration agreement shall, if a party

to the arbitration agreement or any person claiming

through or under him, so applies not later than the date

of submitting his first statement on the substance of the

dispute, then notwithstanding any judgment, decree or

order of the Supreme Court or any Court, refer the

parties to arbitration unless it finds that prima facie no

valid arbitration agreement exists]

(2) The application referred to in sub section (1) shall

not be entertained unless it is accompanied by the

original arbitration agreement or a duly certified copy

thereof:

[Provided that where the original arbitration agreement

or a certified copy thereof is not available with the

party applying for reference to arbitration under subsection

(1), and the said agreement or certified copy is

retained by the other party to that agreement, then, the

party so applying shall file such application along with

a copy of the arbitration agreement and a petition

praying the Court to call upon the other party to

produce the original arbitration agreement or its duly

certified copy before that Court.] ...”

22. The change in the language of Section 8(1) of the A&C Act is

material. Whereas prior to the 2015 Amendment, Sub-section (1) of

Section 8 of the A&C Act used the expression “not later than when

submitting his first statement on the substance of the dispute”. Subsection (1) of Section 8, as substituted, uses the expression “not later than the date of submitting his first statement on the substance of the dispute”. The legislative intent to introduce the words “not later than the date of” clearly stipulates a framework of time within which an application under Section 8(1) of the A&C Act can be made.

23. This amendment to Section 8 of the A&C Act, cannot be

considered in isolation. It is material to note that the Parliament had

also enacted the Commercial Courts Act, 2015 (Act 4 of 2016), which came into force on the same date as the Arbitration and Conciliation (Amendment) Act, 2015, that is, with effect from 23.10.2015. By virtue of Section 16 of the said Act, certain provisions of the CPC were amended in their application to any suit in respect of a commercial dispute of the specified value. The said provisions, inter alia, also included amendment to Order VIII Rule 1 and Order VIII Rule 10 of the CPC. The proviso to Order VIII Rule 1 of the CPC was substituted, which expressly provided that if the defendant failed to file a written statement within the prescribed period of thirty days, the court could, for reasons to be recorded in writing, extend further time to file the written statement. However, such extended time could not be later than 120 days from the date of service of summons. Further, the proviso to Order VIII Rule 10 of the CPC was introduced, which expressly provided that no court would make an order to extend the time provided under Order VIII Rule 1 of the CPC for filing of the written statement. Thus, the Parliament has curtailed the outer time limit of filing of a written statement in a commercial suit to 120 days after receipt of summons. The said amendment is obviously to ensure expeditious adjudication of commercial disputes.

24. Arbitration is an alternate dispute resolution mechanism to

provide for an expeditious adjudication of disputes. By virtue of the

Arbitration and Conciliation (Amendment) Act, 2015, certain other

provisions were also introduced in the A&C Act to provide for time

limits for making the arbitral award. Section 29A of the A&C Act was

introduced, which specifically provide that an arbitral award would be

made within a period of twelve months from the date the arbitral

tribunal enters upon reference. One of the objects of the A&C Act is to

provide for an expeditious resolution of disputes in a time bound

manner. In Bharat Sanchar Nigam Limited and Anr. v. M/s Nortel

Networks India Private Limited (2021) 5 SCC 738, the Supreme Court had observed

that the A&C Act “has been amended twice over in 2015 and 2019, to

provide for further time limits to ensure that the arbitration

proceedings are conducted and concluded expeditiously”.

25. As stated above, a written statement would also fall within the

sweep of expression “statement on the substance of the dispute” as

used in Section 8(1) of the A&C Act. The introduction of the

expression “the date of” in the context of the suit would necessarily

have to be co-related with the time available or granted for filing of a

written statement. The legislative intent of introducing the expression

“the date of”, when read with the contemporaneous amendments to

Order VIII Rule 1 of the CPC by virtue of the Commercial Courts Act, 2015, is quite clear; it is to introduce the precise time frame within which an application under Section 8(1) of the A&C Act could be filed.

26. Resultantly, if a party fails to file an application under Section

8(1) of the A&C Act for referring the parties to arbitration within the

time available or granted for filing the first statement on the substance

of the dispute (which would include a written statement in the context

of a suit), the party would forfeit its right to apply under Section 8(1)

of the A&C Act.

27. This Court is unable to accept that there is any infirmity in the

decision of the learned Commercial Court. This Court is unable to

concur with the decision of the Single Judge of this Court in Hughes

Communications India Ltd. and Ors. v. Union of India13 that Section

8 of the A&C Act cannot be read to mean that an application under

Section 8(1) of the A&C Act would not lie after the right to file the

written statement has been closed. We, accordingly, over-rule the said

decision.

13Supra Note 2


28. The decision of the learned Commercial Court to follow the

decision of Single Bench of this Court in Anil Mahindra’s14 case

(supra) cannot be faulted. We concur with the decision of the learned

Commercial Court that the right of the appellant to file an application

under Section 8(1) of the A&C Act stood closed. We find no infirmity with the impugned decision to reject the appellant’s application under Section 8(1) of the A&C Act.

29. The appeal is, accordingly, dismissed. The pending application

is disposed of.

VIBHU BAKHRU, J

AMIT MAHAJAN, J

JULY 6, 2022


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