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No More Escape Clauses: Finality, Neutrality, And The Transformation Of Indian Arbitration




Radhika Baderia, National Law Institute University, Bhopal

Aviral Singhai, National Law Institute University, Bhopal

Ryan Bang, National Law Institute University, Bhopal


Introduction


The evolution of Indian arbitration has been characterized by a persistent and often contentious struggle between the principles of party autonomy and the necessity of judicial oversight. In the decades following the enactment of the Arbitration and Conciliation Act, 1996, the role of the Indian judiciary has transitioned from that of a “helicopter parent,” prone to frequent and substantive intervention, to that of a “guardian angel,” intended to facilitate and protect the integrity of the process without stifling its inherent efficiency. This transformation has been propelled by significant legislative milestones, most notably the amendments of 2015, 2019, and 2021, which aimed to curtail judicial interference and establish India as a global hub for international commercial dispute resolution. Despite these efforts, the practical application of the law often reveals a stark dichotomy, while arbitration is celebrated in conferences as a paradigm of commercial wisdom, it is frequently treated as a foe in practice, with parties exploiting every procedural avenue to delay proceedings or manipulate outcomes.


The landmark judgment in Hindustan Construction Company Ltd vs Bihar Rajya Pul Nirman Nigam Limited represents a critical juncture in this legal trajectory. The case primarily addresses three interrelated pillars of arbitral jurisprudence, the finality and non-reviewability of appointment orders passed under Section 11, the doctrine of severability as applied to “negative covenants” that seek to foreclose arbitration through procedural failures, and the complex interplay between deemed waivers under Section 4 and the mandatory, non-derogable ineligibility criteria under Section 12(5). At its heart, the ruling reinforces the “self-contained code” nature of the Arbitration Act, ensuring that once the judicial gateway of Section 11 has been traversed, the process is insulated from retrospective sabotage by the same court that initiated it. This analysis explores the historical legal landscape that necessitated this intervention, the specific nuances of the 2025 ruling, and its profound implications for the infrastructure sector and the broader constitutional standard expected of state instrumentalities in India.



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

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All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

 

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The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

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