Arbitration Act Amendments: 2015, 2019, and 2021 Reforms

Arbitration Section 11 Section 34 Section 29A Section 36 Arbitration Act
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Executive Summary

The Arbitration and Conciliation Act, 1996 has undergone three major amendments to enhance efficiency and align with international best practices:

  • 2015 Amendment: Pro-arbitration reforms (BALCO judgment codified)
  • 2019 Amendment: Institutional arbitration, costs regime, confidentiality
  • 2021 Amendment: Automatic stay removal, qualified arbitrators, pre-2016 awards
  • Key reforms: Time limits, limited court intervention, Section 11(6A), costs follow event, confidentiality
  • Impact: India's ranking improved in Ease of Doing Business (up from 142 to 63)
  • Ongoing evolution: Proposed amendments for emergency arbitrator recognition

This guide examines the key amendments chronologically, their impact, and current state of Indian arbitration law.

1. Pre-Amendment Challenges (Pre-2015)

Problems with Original 1996 Act

Issue Impact
Extensive court intervention Prolonged Section 11 hearings (2-3 years)
No time limits Arbitrations dragging for years
Automatic stay on filing Section 34 Delayed enforcement
Public policy broadly construed Awards set aside on merits
No costs regime Frivolous claims/defenses
No institutional framework Lack of arbitration institutions

Result: India ranked 142/190 in Ease of Doing Business (Enforcing Contracts) in 2014.

2. Arbitration and Conciliation (Amendment) Act, 2015

Key Reforms

Reform Provision Impact
Limited Section 11 review Section 11(6A) Court examines only existence of arbitration agreement
Time limits Section 29A 12-month timeline for award
No automatic stay Section 36(3) Filing Section 34 no longer automatically stays enforcement
Public policy narrowed Section 34(2A) Explanation 1 Patent illegality (domestic only), fundamental policy, justice/morality
Fast-track arbitration Section 29B 6-month timeline for claims ≤ ₹3 crore
Interim measures Section 17(2) Tribunal orders enforceable as decrees
Fifth and Seventh Schedules Section 12 Specific ineligibility and challenge grounds for arbitrators

Section 11(6A) - Limited Review (2015)

"The Supreme Court or, as the case may be, the High Court, while considering any application under sub-section (4) or sub-section (5) or sub-section (6), shall, notwithstanding any judgment, decree or order of any Court, confine to the examination of the existence of an arbitration agreement."

Pre-2015 Post-2015
Extensive prima facie review of merits Only existence of arbitration agreement
Arbitrability decided by court Arbitrability decided by tribunal
Section 11 hearings: 1-3 years Section 11 hearings: 2-3 months

BALCO Codified: This provision codified the Supreme Court's holding in SBP & Co. v. Patel Engineering (2005).

Section 29A - Time Limit for Award (2015)

Timeline Application
12 months From date tribunal enters upon reference
Extension: 6 months By party agreement
Mandate terminates If award not made within extended period

Impact: Incentivizes expeditious proceedings; non-compliance results in termination of arbitrator's mandate (though rarely enforced).

Section 36(3) - No Automatic Stay (2015)

Pre-2015: Filing Section 34 automatically stayed enforcement.

Post-2015: "Where the Court is satisfied that a prima facie case is made out that the arbitral award was induced or affected by fraud or corruption, it shall stay the operation of such award."

Ground Stay Available?
Fraud or corruption Yes (if prima facie case)
Other Section 34 grounds No automatic stay (court discretion)

Impact: Awards enforceable immediately unless fraud/corruption or court grants discretionary stay.

Public Policy Narrowed - Section 34(2A) (2015)

Explanation 1 added:

"For the avoidance of doubt, it is clarified that an award is in conflict with the public policy of India, only if:

  • (i) the making of the award was induced or affected by fraud or corruption; or
  • (ii) it is in contravention of section 75 or section 81; or
  • (iii) it is in conflict with the most basic notions of morality or justice."

Explanation 2 (Domestic Awards):

"In the case of domestic awards, where the Court is satisfied that the arbitral award is vitiated by patent illegality appearing on the face of the award, it may set aside the award."

Pre-2015 Post-2015
Public policy broadly construed Public policy narrowed to fraud, Section 75/81 violation, morality/justice
Patent illegality for all awards Patent illegality for domestic awards only
De novo review on merits No review on merits

Impact: Significantly reduced grounds for setting aside awards; aligned with international practice.

3. Arbitration and Conciliation (Amendment) Act, 2019

Key Reforms

Reform Provision Impact
Arbitration Council of India Section 43A-43O Institutional framework (not yet operationalized)
Eighth Schedule Arbitrator qualifications Qualified arbitrators for institutional appointments
Costs regime Section 31A Costs follow event; penalty for frivolous claims (₹10 lakh)
Confidentiality Section 42A Arbitration proceedings confidential
Unconditional stay waiver Section 36(3) proviso Unconditional and specific waiver of stay post-award

Section 31A - Costs Regime (2019)

"The costs of the arbitration shall be fixed by the arbitral tribunal, and shall follow the event..."

Section 31A(2): "If the arbitral tribunal is of the opinion that the claim or counter-claim of a party is frivolous or vexatious, it shall award such costs not exceeding ten lakh rupees..."**

Feature Application
Costs follow event Unsuccessful party pays costs
Frivolous claim penalty Up to ₹10 lakh penalty for frivolous claims/defenses
Deterrence Discourages vexatious litigation tactics

Impact: Aligned India with international cost practices; incentivized realistic claims.

Section 42A - Confidentiality (2019)

"Notwithstanding anything contained in any other law for the time being in force, the parties to the arbitration agreement, arbitral tribunal and the arbitral institution shall maintain confidentiality of all arbitral proceedings..."

Protection Scope
Arbitral proceedings Hearings, evidence, submissions confidential
Award Confidential unless disclosure required for enforcement
Exceptions Disclosure for enforcement, legal obligations, public interest

Impact: Brought India in line with international arbitration practice (London, Singapore confidential by default).

Eighth Schedule - Arbitrator Qualifications (2019)

For institutional arbitrations with claim value ≥ ₹1 crore:

Qualification Requirement
Advocates 10 years' standing
Civil servants Joint Secretary rank or above (retired)
Other professionals 15 years' experience + expertise in arbitration

Impact: Ensures qualified arbitrators for high-value disputes.

4. Arbitration and Conciliation (Amendment) Act, 2021

Key Reforms

Reform Provision Impact
Automatic stay removal clarified Section 36 Unconditional, specific waiver required for stay post-award
Qualification conditions relaxed Eighth Schedule proviso Parties can appoint arbitrators not meeting Eighth Schedule if agreed
Retrospective applicability clarified Section 87 2015/2019 amendments apply to arbitrations commenced post-23.10.2015
Pre-2016 awards Section 26 of Amendment Act 2015 Challenged awards pending as of 23.10.2015 to be disposed expeditiously

Section 36 - Automatic Stay Removal (2021)

Section 36(3) Proviso added:

"Provided further that where the Court is satisfied that a prima facie case is made out that:

  • (a) the arbitration agreement or contract which is the basis of the award; or
  • (b) the making of the award, was induced or effected by fraud or corruption, it shall stay the award unconditionally pending disposal of the challenge under section 34 to the award."

Second Proviso (2021):

"Provided also that where the Court is satisfied that a prima facie case is made out that the arbitration agreement or contract which is the basis of the award or the making of the award was induced or effected by fraud or corruption, it shall stay the award unconditionally pending disposal of the challenge..."

Third Proviso (2021 - critical):

"Provided also that the Court, while granting a stay of the award in cases other than those referred to in the second proviso, shall ensure that any deposit ordered is not furnished unconditionally, and shall not exceed:

  • (a) where the total value of the award does not exceed Rs. 1 crore - Rs. 50 lakh;
  • (b) where the total value of the award exceeds Rs. 1 crore - 50% of the award amount."
Ground Stay Available? Deposit Required?
Fraud/corruption Yes (unconditional stay) No deposit
Other Section 34 grounds Discretionary Yes, capped (₹50 lakh or 50% of award)

Impact: Balanced approach; prevents automatic stay while protecting against frivolous enforcement.

Eighth Schedule Proviso (2021)

"Provided that parties may, notwithstanding the criteria specified in this Schedule, appoint an arbitrator by name, mutually."

Pre-2021 Post-2021
Eighth Schedule mandatory for all institutional arbitrations ≥ ₹1 crore Parties can opt out and appoint arbitrator by name mutually

Impact: Restored party autonomy while maintaining default quality standards.

5. Comparative Table: Pre-2015 vs. Post-2021

Aspect Pre-2015 Post-2021
Section 11 scope Extensive prima facie review Only existence of agreement (11(6A))
Time limit for award None 12 months (+6 extension)
Automatic stay on Section 34 Yes No (except fraud/corruption or discretionary with deposit)
Public policy scope Broad Narrow (fraud, fundamental policy, justice/morality)
Patent illegality All awards Domestic awards only
Costs regime None Costs follow event (Section 31A)
Confidentiality Not explicit Mandatory (Section 42A)
Arbitrator qualifications None Eighth Schedule (opt-out possible)
Fast-track None Section 29B (6 months for ≤ ₹3 crore)
Tribunal interim orders Not enforceable as decrees Enforceable as decrees (Section 17(2))

6. Impact on India's Arbitration Ecosystem

Ease of Doing Business Ranking

Year Rank (Enforcing Contracts) Change
2014 142 / 190 Baseline
2020 63 / 190 +79 positions

Attribution: 2015, 2019 amendments credited with significant improvement.

Growth of Institutional Arbitration

Institution Pre-2015 Cases Post-2019 Cases Growth
DIAC ~50/year ~300/year 6x
MCIA ~30/year ~150/year 5x

Reason: Reforms improved arbitration attractiveness; institutional confidence increased.

7. Pending Issues and Proposed Reforms

Emergency Arbitrator Enforceability

Issue: HSBC v. Avitel (2022) held emergency arbitrator orders not enforceable.

Proposed: Legislative amendment to recognize and enforce emergency arbitrator orders.

Arbitration Council of India (Not Operationalized)

2019 Amendment created: Arbitration Council of India (Sections 43A-43O)

Status: Not yet operationalized; no notification issued.

Purpose: Grade arbitral institutions, accredit arbitrators, promote arbitration culture.

8. Key Takeaways for Practitioners

  1. 2015 Amendment - Pro-Arbitration: Limited court intervention (Section 11(6A)), time limits (Section 29A), no automatic stay (Section 36(3)).

  2. Public Policy Narrowed: Patent illegality for domestic awards only; public policy limited to fraud, fundamental policy, justice/morality.

  3. 2019 Amendment - Institutional Focus: Costs regime (Section 31A), confidentiality (Section 42A), arbitrator qualifications (Eighth Schedule).

  4. 2021 Amendment - Balanced Enforcement: Stay on Section 34 conditional on deposit (₹50 lakh or 50% cap); party autonomy on arbitrator selection.

  5. Impact Proven: India's ranking in Ease of Doing Business improved significantly (142 to 63).

  6. Ongoing Evolution: Emergency arbitrator recognition, Arbitration Council operationalization pending.

  7. Practitioner Adaptation: Reforms require practitioners to adapt to stricter timelines, costs awareness, and confidentiality obligations.

9. Compliance Checklist

For All Arbitrations Post-2021

  • Section 11 applications: Focus on existence of agreement only (not merits)
  • Timeline compliance: 12-month award timeline (Section 29A)
  • Costs documentation: Maintain detailed cost records for Section 31A
  • Confidentiality: Comply with Section 42A (proceedings confidential)
  • Arbitrator qualifications: Check Eighth Schedule for institutional arbitrations ≥ ₹1 crore (or parties opt out)
  • Section 34 strategy: If filing Section 34, anticipate deposit requirement (unless fraud/corruption)
  • Enforcement: Enforce awards promptly post-Section 34 timeline (no automatic stay)

10. Conclusion

The 2015, 2019, and 2021 amendments transformed Indian arbitration from a slow, court-heavy process to a pro-arbitration, time-bound, and cost-conscious regime aligned with international best practices. Key reforms—limited court intervention (Section 11(6A)), time limits (Section 29A), no automatic stay (Section 36), costs regime (Section 31A), and confidentiality (Section 42A)—have significantly enhanced India's arbitration ecosystem. India's dramatic improvement in the Ease of Doing Business ranking (142 to 63) validates the reforms' success. Practitioners must adapt to stricter timelines, costs awareness, and confidentiality obligations. While challenges remain (emergency arbitrator enforceability, Arbitration Council operationalization), India's arbitration landscape is firmly on an upward trajectory, positioning it as a competitive arbitration seat regionally and globally.

Written by
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