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[Cites 25, Cited by 3]

Delhi High Court

Mahindra Susten Private Limited vs Nhpc Limited on 17 February, 2021

Equivalent citations: AIRONLINE 2021 DEL 217

Author: C. Hari Shankar

Bench: C. Hari Shankar

                            $~
                            *     IN THE HIGH COURT OF DELHI AT NEW DELHI
                                                                  Reserved on: 3rd February, 2021
                                                              Pronounced on: 17th February, 2021

                            +     ARB.P. 217/2020 and I.A.6503/2020
                                  MAHINDRA SUSTEN PRIVATE LIMITED        ..... Petitioner
                                              Through: Mr. K.V. Viswanathan, Mr.
                                              Sanjeev Kapoor, Mr. Prateek Kumar, Ms.
                                              Sneha Janakiraman, Mr. Apoorv Singhal,
                                              Ms. Smriti Nair, Advs.

                                                     versus

                                  NHPC LIMITED                                ..... Respondent
                                                     Through: Mr. Tejas Karia, Mr.Gauhar
                                                     Mirza, Mr. Prakhar Deep and Mr.Nishant
                                                     Doshi, Advs.

                            +     O.M.P.(I) (COMM.) 162/2020 and I.A.6502/2020
                                  MAHINDRA SUSTEN PRIVATE LIMITED        ..... Petitioner
                                              Through: Mr. K.V. Viswanathan, Mr.
                                              Sanjeev Kapoor, Mr. Prateek Kumar, Ms.
                                              Sneha Janakiraman, Mr. Apoorv Singhal,
                                              Ms. Smriti Nair, Advs.

                                                     versus

                                  NHPC LIMITED                                ..... Respondent
                                                     Through: Mr. Tejas Karia, Mr. Gauhar
                                                     Mirza, Mr. Prakhar Deep and Mr. Nishant
                                                     Doshi, Advs.

                                  CORAM:
                                  HON'BLE MR. JUSTICE C. HARI SHANKAR

Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020             Page 1 of 76
Signing Date:19.02.2021
09:08:48
                             %                   JUDGMENT

                            1.    This judgment disposes of Arb. P. 217/2020 and OMP (I)
                            (Comm) 162/2020.


                            2.    Arb. P. 217/2020 seeks reference of the disputes, between the
                            petitioner and respondent, to arbitration, under Section 11(6) of the
                            Arbitration and Conciliation Act, 1996 (hereinafter referred to as "the
                            1996 Act"). OMP (I) (Comm) 162/2020 seeks certain pre-arbitral
                            interim reliefs.   Mr. Viswanathan, learned Senior Counsel for the
                            petitioner submitted, at the outset, that, if Arb. P. 217/2020 were to be
                            allowed, and the disputes between the petitioner and the respondent
                            referred to arbitration as prayed therein, he would have no objection to
                            OMP (I) (Comm) 162/2020 being also referred for adjudication to the
                            arbitrator, treating it as an application under Section 17 of the 1996
                            Act. As such, the necessity of adjudicating, on merits, OMP (I)
                            (Comm) 162/2020 would arise only if Arb. P. 217/2020 were not to be
                            allowed.


                            3.    Mr. Tejas Karia, learned counsel for the respondent, vehemently
                            opposed Arb. P. 217/2020. The ground for opposition would become
                            clearer from the recital that follows. Suffice it to state, at this stage,
                            that I am of the opinion that the opposition of Mr. Tejas Karia is
                            without substance and that, therefore, the dispute between the
                            petitioner and the respondent ought to be referred to arbitration. As
                            such, in view of the submission made by Mr. Viswanathan, noted
                            supra, OMP (I) (Comm) 162/2020 would also be decided by the
Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                 Page 2 of 76
Signing Date:19.02.2021
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                             Arbitral Tribunal under Section 17 of the 1996 Act. The necessity of
                            this Court adjudicating on the said petition, thereby, stands obviated.


                            Facts


                            4.      A notice, dated 5th July, 2018, was issued by the respondent-
                            NHPC, inviting tenders for "Engineering Procurement Construction
                            (EPC) Contract for 10 MW capacity Floating Solar Power Project at
                            West Kallada in the State of Kerala with its Comprehensive Operation
                            and Maintenance for 10 years". For the sake of convenience, the
                            notice would be referred to, hereinafter, as "the NIT".


                            5.      The following Clauses of the NIT are relevant:
                                    "3.2.A.1.2

                                    The bidder should have experience of having successfully
                                    completed a project of any nature involving floating
                                    structures/platform/ deck/ underwater cable works, in last five
                                    (5) years on Engineering, Procurement and Construction
                                    (EPC) basis.

                                    Note:-

                                    Floatation Device Technology Provider: The bidder should
                                    propose name of the float technology provider with whom
                                    they expect to tie-up for supply of the floats. Bidder may
                                    propose any number of vendors (including bidders own
                                    design) along with their credentials as part of their technical
                                    bid. However, prior to signing of the contract agreement, the
                                    successful bidder shall communicate their finalised float
                                    vendor."

                                                                *****

                                    "3.2.A.4 Bidders with Sub-contractors:
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SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                    Page 3 of 76
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                                   In case the Sole Bidder does not have all the required
                                  experience and also does not wish to enter into a joint-venture
                                  or wants to restrict the joint-venture partnership, he can
                                  associate Sub-contractor for specified activities (in case of
                                  Floatation Device Technology Provider or experience of
                                  installation of floating structures) in which he does not have
                                  the relevant experience. The criteria to be met by such Bidder
                                  shall be as follows:

                                        (i)    The Bidder himself to fully meet the following:

                                               •      Technical criteria specified in para
                                               3.2.A.1.1 and 3.2.A.1.3

                                               •      All criteria mentioned under financial
                                               capacity.

                                        (ii)   The number of sub-contractors not to exceed
                                        one for meeting the technical experience Criteria as
                                        specified in para 3.2.A.1.2

                                        (iii) The proposed sub-contractor to meet the
                                        specified criteria for the component work listed
                                        Technical experience Criteria as specified in para
                                        3.2.A.1.2

                                        (iv) The Bidder and his sub-contractor should
                                        submit separate undertakings that the Bidder/sub-
                                        contractor shall be responsible for execution of that
                                        item of work for which they claim to have specific
                                        construction experience.

                                        (v)    The Applicant and his proposed sub-contractor
                                        should collectively satisfy as a whole all the specified
                                        experience requirements.

                                        (vi) Sub-contractor shall submit Performance Bank
                                        Guarantee equivalent to 5% of value of Work sublet in
                                        addition to the Performance Bank Guarantee for whole
                                        contract submitted by the Bidder on award of Work."

                                                              *****
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Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                  Page 4 of 76
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                                   "4.      TIME FOR COMPLETION

                                  The successful bidder shall complete the entire work within
                                  the time specified under S.No.-1 above, to be reckoned from
                                  the date of issue of Letter of Acceptance"

                            6.    Annexed to the NIT were the "Bid Documents", in six volumes,
                            numbered Volume 0 to Volume 5.


                            7.    Volume 0 constituted the "Instructions to Bidders" (hereinafter
                            referred to as "ITB"). Though many of the clauses of the ITB were
                            reproductions of the clauses of the NIT, in the interests of completion,
                            the relevant clauses of the ITB may be reproduced thus:
                                  "3.2.A.1.2 The bidder should have experience of having
                                  successfully completed a project of any nature involving
                                  floating structures/platform/ deck/ underwater cable works, in
                                  last five (5) years on Engineering, Procurement and
                                  Construction (EPC) basis.

                                  Note:-

                                  Floatation Device Technology Provider: The bidder should
                                  propose name of the float technology provider with whom
                                  they expect to tie-up for supply of the floats. Bidder may
                                  propose any number of vendors (including bidders own
                                  design) along with their credentials as part of their technical
                                  bid. However, prior to signing of the contract agreement, the
                                  successful bidder shall communicate their finalised float
                                  vendor.

                                  3.7    To improve transparency and fairness in tendering
                                  process the Employer is implementing Integrity Pact as per
                                  Clause 33 of this ITB. The bidder must submit the Integrity
                                  Pact as per Annexure- 3 duly signed as per clause 33 of ITB.

                                  Pre- contract Integrity Pact is to be executed on plain paper at
                                  the time of submission of Bid. The successful bidder
                                  (contractor) shall submit duly executed Integrity Pact on non-
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SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                   Page 5 of 76
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                                   judicial stamp paper of appropriate value prior to signing of
                                  Notification of Award.

                                                              *****

                                  27.   AWARD CRITERIA

                                  27.1) a) Subject to Clause 28, the Employer will award the
                                  contract to the successful bidder whose bid has been
                                  determined to be substantially responsive as per the
                                  "Conditions for conducting e- RA after e-tendering" which is
                                  enclosed as per Part-IV to the ITB. The Employer may
                                  request the substantially responsive lowest evaluated bidder to
                                  attend the pre-award discussions / Post Tender Negotiations
                                  (PTN), if required.

                                  b) The mode of contracting with the successful bidder will be
                                  as per stipulation outlined in relevant GCC/SCC
                                  Clauses..........


                                                              *****

                                  29.   NOTIFICATION OF AWARD

                                  29.1 Prior to the expiration of the period of bid validity, the
                                  Employer will notify the successful Bidder in writing by
                                  registered letter/ speed post / fax,, that its bid has been
                                  accepted. The notification of award will constitute the
                                  formation of the contract and will be considered for all
                                  purposes of execution of contract provisions till such time the
                                  signing of the Contract Agreement.

                                  29.2 Upon the successful Bidder's furnishing of the
                                  performance security pursuant to ITB Clause 31, the
                                  Employer will promptly return/discharge the Bid Security to
                                  each unsuccessful Bidder, pursuant to ITB Sub-Clause 14.4.

                                  29.3 The unsuccessful Bidders shall also be informed
                                  simultaneously about their status of Bids.

                                  30.   SIGNING OF CONTRACT AGREEMENT

Signature Not Verified
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SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                  Page 6 of 76
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                                   After notifying the successful bidder that its bid has been
                                  accepted, the Employer will prepare the Contract Agreement
                                  as per Format provided in Volume 5: Forms &Procedures,
                                  incorporating all the correspondence exchanged between the
                                  parties, which have a bearing on the Contract.

                                  Within 14 days of receipt of notice of readiness of the
                                  Contract Agreement by the Employer, the Employer and the
                                  successful bidder shall sign the Contract Agreement.


                                  31. PERFORMANCE SECURITY

                                  31.1 Within twenty-eight (28) days after receipt of the
                                  notification of award, the successful Bidder shall furnish the
                                  performance security as per GCC clause 13.3 and in the form
                                  provided in the section "Forms and Procedures" of the
                                  Bidding Documents or in any other form acceptable to the
                                  Employer.

                                  31.2 Failure of the successful Bidder to comply with the
                                  requirements of ITB Clause 30 or Clause 31.1 shall constitute
                                  sufficient grounds for the annulment of the award and
                                  forfeiture of the bid security.

                                  32. CORRUPT OR FRAUDULENT OR COLLUSIVE OR
                                  COERCIVE PRACTICES

                                  32.1 It is expected from the Bidders / suppliers / contractors
                                  that they will observe the highest standard of ethics during the
                                  procurement and execution of such contracts. In pursuance of
                                  this policy:

                                         (a)    for the purposes of this provision, the terms set
                                         forth below shall mean as under:

                                                i)     "Corrupt practice" means the offering,
                                                giving, receiving or soliciting directly or
                                                indirectly of anything of value to influence the
                                                action of a public official in the procurement
                                                process or in contract execution; and

                                                ii)   "Fraudulent     practice"    means      a
                                                misrepresentation/omission of facts in order to
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SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                   Page 7 of 76
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                                                influence a procurement process or the
                                               execution of a contract to the detriment of the
                                               Employer, and includes collusive practice
                                               among Bidders (prior to or after bid submission)
                                               designed to establish bid prices at artificial non-
                                               competitive levels and to deprive the Borrower
                                               of the benefits of free and open competition;

                                               iii)   "Collusive Practice" means a scheme or
                                               arrangement between two or more bidders, with
                                               or without the knowledge of Employer,
                                               designed to establish bid prices at artificial, non-
                                               competitive levels.

                                               iv)    "Coercive Practice" means harming or
                                               threatening to harm, directly or indirectly,
                                               person or their property to influence their
                                               participation in a procurement process or affect
                                               the execution of Contract.

                                        (b)    An agreement called Integrity Pact between the
                                        prospective bidders and the Employer shall be signed
                                        committing the persons /officials of both the parties,
                                        not to exercise any corrupt influence on any aspect of
                                        the Tender / Contract. The Independent External
                                        Monitor(s) (IEM) appointed by Employer shall oversee
                                        the compliance of obligation under the Integrity Pact.

                                        (c)     A Bid may be rejected by the Employer if it is
                                        determined at any stage that the respective Bidder has
                                        engaged in corrupt or fraudulent or collusive or
                                        coercive or undesirable or restrictive practices or
                                        default commitment under Integrity Pact in competing
                                        for the contract in question.

                                        (d)     The Employer may declare a firm ineligible,
                                        either indefinitely or for a stated period of time, if it at
                                        any time determines that the firm has engaged in
                                        corrupt or fraudulent or collusive or coercive practices
                                        in competing for or default commitment under
                                        Integrity Pact or in executing the contract.

                                        (e)    Banning of Business Dealings: It is not in the
                                        interest of NHPC to deal with Agencies who commit
Signature Not Verified
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SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                    Page 8 of 76
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                                         deception, fraud or other misconduct in the tendering
                                        process. The grounds on which Banning of Business
                                        Dealings can be initiated are as follows:

                                                i)    If the security consideration, including
                                                questions of loyalty of the Agency to NHPC so
                                                warrants;

                                                ii)    If the director/owner of the Agency,
                                                proprietor or partner of the firm, is convicted
                                                by a court of law for offences involving moral
                                                turpitude in relation to its business dealings
                                                with the Government or any other public sector
                                                enterprises, during last five years;

                                                iii) If the Agency has resorted to Corrupt,
                                                Fraudulent, Collusive, Coercive practices
                                                including misrepresentation of facts and
                                                violation of the any provisions of the Integrity
                                                Pact provided in the Contract.

                                                iv) If the Agency uses intimidation /
                                                threatening or brings undue outside pressure on
                                                NHPC or its official for acceptance /
                                                performances of the job under the contract:

                                                v)     If the Agency misuses the premises or
                                                facilities of the NHPC, forcefully occupies or
                                                damages the NHPC's properties including land,
                                                water resources, forests / trees or tampers with
                                                documents/records etc.

                                                vi) If the Agency does not fulfill the
                                                obligations as required under the Contract and
                                                Violates terms & conditions of the contract
                                                which has serious affect for continuation of the
                                                Contract.

                                                vii) If the work awarded to the agency has
                                                been terminated by NHPC due to poor
                                                performance of the contract in the preceding 5
                                                years.


Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                 Page 9 of 76
Signing Date:19.02.2021
09:08:48
                                                 viii) If the Central Vigilance Commission,
                                                Central Bureau of Investigation or any other
                                                Central Government investigation Agency
                                                recommends such a course in respect of a case
                                                under investigation or improper conduct on
                                                agency's part in matters relating to the
                                                Company (NHPC) or even otherwise;

                                                ix) On any other ground upon which
                                                business dealings with the Agency is not in the
                                                public interest.

                                                x)    If business dealings with the Agency
                                                have been banned by the Ministry of Power,
                                                Government of India OR any PSU/ any other
                                                authority under the MOP if intimated to NHPC
                                                or available on MOP Website, the business
                                                dealing with such agencies shall be banned
                                                with immediate effect for future business
                                                dealing except banning under Integrity Pact
                                                without any further investigation.

                                        (Note: The examples given above are only illustrative
                                        and not exhaustive. The Competent Authority may
                                        decide to ban business dealing for any good and
                                        sufficient reason).

                                        The procedure for banning of Business Dealings shall
                                        be governed as per NHPC's "Policy and Procedure for
                                        Banning Business Dealings". This policy is published
                                        in NHPC website under Integrity corner.

                                  32.2 Furthermore, Bidders shall be aware of the provision
                                  stated in Sub-Clause 42.2 of the General Conditions of
                                  Contract and return their bid security as per Clause 13.4 of
                                  ITB.

                                  33.   INTEGRITY PACT

                                  To improve transparency and fairness in the tendering process
                                  the Employer is implementing Integrity Pact.

                                  The Integrity Pact, signed by all the prospective Bidders and
                                  the Employer, shall commit the persons/officials of both the
Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                Page 10 of 76
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                                   parties,     not       to       exercise       any       corrupt/
                                  fraudulent/collusive/coercive practices in the Tendering
                                  process and also during implementation of the Contract. All
                                  Applicants shall enter into an Integrity Pact (to be executed on
                                  plain paper) with the Employer at the time of submission of
                                  their Bids. Only those Bidders who have entered into Integrity
                                  Pact with the Employer shall be eligible to participate in the
                                  bidding process. Entering into Integrity Pact as per Performa
                                  provided in the Section Forms & Procedure is a basic
                                  qualifying requirement.

                                  The Integrity Pact digitally signed on behalf of the Employer
                                  is provided as Annexure-3 in ITB. The Integrity Pact shall be
                                  downloaded, printed and signed by the Applicant and the hard
                                  copy shall be submitted.

                                  Successful bidder shall submit duly executed Integrity pact on
                                  Non-Judicial Stamp paper of appropriate value prior to
                                  signing of Contract Agreement.

                                  To oversee the compliance of obligation under the Integrity
                                  Pact, Sh. Rajan Nair and Sh. Sudhir Krishna has been
                                  appointed as Independent External Monitor (IEM) by the
                                  Employer. The Contact address of IEM is as under:

                                         Sh. Rajan Nair and
                                         Sh. Sudhir Krishna,
                                         Independent External Monitor for NHPC Ltd.,
                                         NHPC Ltd.
                                         NHPC Office Complex,
                                         Sector -33 Faridabad - 121003"


                            8.    Annexure 2 to the ITB constituted the pre-contract Integrity
                            Pact (hereinafter referred to as the "Integrity Pact"), to be executed in
                            accordance with the covenants of the NIT and ITB already reproduced
                            hereinabove. The relevant clauses thereof may be set out thus:


                                  i)     Clause 1.0 set out the commitments of the employer and
                                  the various other sub-clauses of Clause 3.0 set out the
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SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                    Page 11 of 76
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                                   commitments of the bidders/contractors under the Integrity Pact
                                  and they read thus:

                                        "1.0   Commitments of the Employer

                                        1.1    The Employer undertakes that no official of the
                                        Employer, connected directly or indirectly with the
                                        contract, will demand, take a promise for or accept,
                                        directly or through intermediaries, any bribe,
                                        consideration, gift, reward, favour or any material or
                                        immaterial benefit or any other advantage from the
                                        Bidder/Contractor, either for themselves or for any
                                        person, organization or third party related to the
                                        contract in exchange for an advantage in the bidding
                                        process, bid evaluation, contracting or implementation
                                        process related to the contact.

                                        1.2. The Employer will, during the pre-contract stage,
                                        treat all the Bidders/Contractors alike, and will provide
                                        to all the Bidders/Contractors the same information
                                        and will not provide any such information to any
                                        particular Bidder/Contractor which could afford an
                                        advantage to that particular Bidder/Contractor in
                                        comparison to other Bidders/Contractors.

                                        1.3. All the officials of the Employer will report to the
                                        appropriate Authority any attempted or completed
                                        breaches of the above commitments as well as any
                                        substantial suspicion of such a breach.

                                                               *****

                                        3.0 Commitments of the Bidder(s)/Contractor(s)

                                        The Bidder(s)/Contractor(s) commits itself to take all
                                        measures necessary to prevent corrupt practices, unfair
                                        means and illegal activities during any stage of its bid
                                        or during any pre-contract or post-contract stage in
                                        order to secure the contract or in furtherance to secure
                                        it and in particular commit itself to the following:-

                                        3.1. The Bidder(s)/Contractor(s) will not offer, directly
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SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                  Page 12 of 76
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                                         or through intermediaries, any bribe, gift,
                                        consideration, reward, favour, any material or
                                        immaterial benefit or other advantage, commission,
                                        fees, brokerage or inducement to any official of the
                                        Employer, connected directly or indirectly with the
                                        bidding process, or to any person, organization or third
                                        party related to the contract in exchange for any
                                        advantage in the bidding, evaluation, contracting and
                                        implementation of the contract.

                                        3.2 The Bidder/Contractor further undertakes that it
                                        has not given, offered or promised to give, directly or
                                        indirectly any bribe, gift consideration, reward, favour,
                                        any material or immaterial benefit or other advantage,
                                        commission, fees, brokerage or inducement to any
                                        official of the Employer or otherwise in procuring the
                                        Contract or forbearing to do or having done any act in
                                        relation to the obtaining or execution of the contract or
                                        any other contract with Employer for showing or
                                        forbearing to show favour or disfavour to any person
                                        in relation to the contract or any other contract with
                                        Employer.

                                        3.3 The Bidder(s)/Contractor(s) shall disclose the
                                        name and address of agents and representatives and
                                        Indian Bidder(s)/Contractor(s) shall disclose their
                                        foreign principals or associates.

                                        3.4 The Bidder(s)/Contractor(s)shall disclose the
                                        payments to be made by them to agents/brokers or any
                                        other intermediary, in connection with this
                                        bid/contract.

                                        3.5 Deleted.

                                        3.6 The Bidder, either while presenting the bid or
                                        during pre-contract negotiations or before signing the
                                        contract, shall disclose any payments he has made, is
                                        committed to or intends to make to officials of the
                                        Employer or their family members, agents, brokers or
                                        any other intermediaries in connection with the
                                        contract and the details of services agreed upon for
                                        such payments.
Signature Not Verified
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SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                  Page 13 of 76
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                                         3.7 The Bidder/Contractor will not collude with other
                                        parties interested in the contract to impair the
                                        transparency, fairness and progress of the bidding
                                        process,    bid     evaluation,   contracting    and
                                        implementation of the contract.

                                        3.8 The Bidder/Contractor will not accept any
                                        advantage in exchange for any corrupt practice, unfair
                                        means and illegal activities.

                                        3.9 The Bidder/Contractor shall not use improperly,
                                        for purposes of competition or personal gain, or pass
                                        on to others, any information provided by the
                                        Employer as part of the business relationship,
                                        regarding plans, technical proposals and business
                                        details, including information contained in electronic
                                        data carrier. The Bidder/Contractor also undertakes to
                                        exercise due and adequate care lest any such
                                        information is divulged.

                                        3.10 The Bidder(s)/Contractor(s) commits to refrain
                                        from giving any complaint directly or through any
                                        other manner without supporting it with full and
                                        verifiable facts.

                                        3.11 The Bidder(s)/Contractor(s) shall not instigate or
                                        cause to instigate any third person to commit any of
                                        the actions mentioned above.

                                        3.12 If the Bidder/Contractor or any employee of the
                                        Bidder/Contractor or any person acting on behalf of
                                        the Bidder/Contractor, either directly or indirectly, is a
                                        relative of any of the officers of the Employer, or
                                        alternatively, if any relative of an officer of the
                                        Employer has financial interest/stake in the
                                        Bidder(s)/Contractor(s) firm(excluding Public Ltd.
                                        Company listed on Stock Exchange), the same shall be
                                        disclosed by the Bidder/Contractor at the time of
                                        filling of tender.

                                        The term 'relative' for this purpose would be as defined
                                        in Section 2(77) of the Companies Act 2013.

                                        3.13 The Bidder(s)/Contractor(s) shall not lend to or
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SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                   Page 14 of 76
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                                         borrow any money from or enter into any monetary
                                        dealings or transactions, directly or indirectly, with any
                                        employee of the Employer.

                                        3.14 The representative of the Bidder(s)/ Contractor(s)
                                        signing Integrity Pact shall not approach the Courts
                                        while representing the matters to IEMs and he/she will
                                        wait their decision in the matter.

                                        3.15 In case of sub-contracting, the bidder/principal
                                        contractor shall take the responsibility of the adoption
                                        of IP by the sub-contractor."


                                  ii)   Clause 6.0 set out the sanctions for violations committed
                                  by the bidder/contractor, as per the Integrity Pact, and sub-
                                  clause 6.1 thereunder read thus:

                                        "6.1 Any breach of the aforesaid provisions by the
                                        Bidder/Contractor or anyone employed by it or acting
                                        on its behalf shall entitle the Employer to take action
                                        as per the procedure mentioned in the "Guidelines on
                                        Banning of Business Dealings" attached as Annex-3A
                                        and initiate all or anyone of the following actions,
                                        wherever required:-

                                               (i)    To immediately call off the pre contract
                                               negotiations without assigning any reason or
                                               giving     any     compensation      to     the
                                               Bidder/Contractor. However, the proceedings
                                               with the other Bidder(s)/Contractor(s) would
                                               continue.

                                               (ii)    The Earnest Money Deposit (in pre-
                                               contract       stage)      and/or     Security
                                               Deposit/Performance Bond (after the contract is
                                               Signed) shall stand forfeited either fully or
                                               partially, as decided by the Employer and the
                                               Employer shall not be required to assign any
                                               reason thereof.

                                               (iii)   To immediately cancel the contract, if
Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                   Page 15 of 76
Signing Date:19.02.2021
09:08:48
                                                 already     signed,     without   giving   any
                                                compensation to the Contractor. The
                                                Bidder/Contractor shall be liable to pay
                                                compensation for any loss or damage to the
                                                Employer         resulting      from      such
                                                cancellation/rescission and the Employer shall
                                                be entitled to deduct the amount so payable
                                                from the money(s) due to the Bidder/Contractor.

                                                (iv)   Deleted.

                                                (v)    To encash the Bank guarantee, in order to
                                                recover the dues if any by the Employer, along
                                                with interest as per the provision of contract.

                                                (vi)   Deleted

                                                (vii) To debar the Bidder/Contractor from
                                                participating in future bidding processes of
                                                NHPC Ltd., as per provisions of "Guidelines on
                                                Banning of Business Dealings" of NHPC
                                                Ltd.(Annex-3A), which may be further extended
                                                at the discretion of the Employer.

                                                (viii) To recover all sums paid in violation of
                                                this Pact by Bidder(s)/Contractor(s) to any
                                                middleman or agent or broker with a view to
                                                securing the contract.

                                                (ix) In cases where irrevocable Letters of
                                                Credit have been received in respect of any
                                                contract signed by the Employer with the
                                                Bidder/ Contractor, the same shall not be
                                                opened/operated.

                                                (x)    Forfeiture of Performance Security in
                                                case of a decision by the Employer to forfeit the
                                                same without assigning any reason for imposing
                                                sanction for violation of this Pact."


                                  (iii)   Clause 10.0 stipulated, regarding the "law and place of
                                  jurisdiction", as under:
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SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                  Page 16 of 76
Signing Date:19.02.2021
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                                          "10.0 Law and Place of Jurisdiction

                                         This Pact is subject to Indian Law. The place of
                                         performance and jurisdiction is the Registered Office
                                         of the Employer, i.e. Faridabad (Haryana). The
                                         arbitration    clause provided in the tender
                                         document/contract shall not be applicable for any
                                         issue/dispute arising under Integrity Pact."


                            9.    Annexure 2A to the ITB contained the "Guidelines on Banning
                            of Business Dealings", to which Clause 6.1 of the Integrity Pact
                            referred. In as much as the merits of the disputes between the parties
                            are not being examined by me in the present judgment, it is not
                            necessary to refer to the specific clauses of the said guidelines.


                            10.   In accordance with the covenants of the NIT and the ITB, the
                            petitioner submitted the Integrity Pact on 3rd September, 2018, its
                            online bid on 4th September, 2018 and its offline bid on 6th September,
                                                   ₹ 9 7 lakhs was also submitted , by the
                            2018. Security deposit of
                            petitioner, with a bank guarantee dated 31st August, 2018, which was
                            extended from time to time.


                            11.   As required by Clause 3.2.A.1.2, read with Clause 3.2.A.4 of
                            the NIT and the ITB, the petitioner, vide communication dated 31st
                            October, 2018, recommended the names of four suppliers as potential
                            Float Device Technology Providers. The respondent responded thus,
                            on 30th November, 2018:
                                                                             "Date: 30.11.2018

                                  Email:[email protected]/shubham.pratyush
                                  @mahindra.com

Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                 Page 17 of 76
Signing Date:19.02.2021
09:08:48
                                   M/s Mahindra Susten Pvt. Ltd.,
                                  6th floor, AFL House,
                                  Lok Bharati Complex,
                                  Marol Maroshi Road,
                                  Mumbai, Maharashtra-400059

                                        Kind Attention: Mr. Ankit Jain, General Manager

                                  Subject: Engineering Procurement and Construction (EPC)
                                  contract for development of 10MW Floating Solar Power
                                  Project including evacuation arrangements at West Kallada
                                  Site, Dist.- Kollam in the state of Kerala, along with its
                                  comprehensive operation and maintenance for 10 (ten) years.

                                  Ref: (i) E-TENDER NO. 2018_NHPC_355399_1

                                  Dear Sir,

                                  This is with reference to your Bid submitted against aforesaid
                                  Tender.

                                  In this regard, it is informed that your bid has been found
                                  Techno-commercially responsive on the basis of following
                                  proposed sub-contractor as per Clause- 3.2.A.l.2 of ITB/NIT:

                                  1. M/s Yellow 2 Gen Energy Pvt. Limited. Gurugram

                                  Thanking you,

                                                                               Yours faithfully,

                                                                                          Sd/-
                                                          General Manager (Civil Contracts-III)
                                                           Telephone No. : +91 (129) 2270974"


                            12.   In the e-reverse auction which took place consequent to the
                            aforesaid NIT, the petitioner emerged as the successful bidder. Clause
                            13.1 of the ITB stipulated that bids would remain valid for 120 days
                            from the last date of submission of online bids, and required the
                            respondent to issue letters of award within the said period, subject to
                            the right to seek extension from the petitioner for exceptional
Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                 Page 18 of 76
Signing Date:19.02.2021
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                             circumstances, vide Clause 13.2. The normal period, as per Clause
                            13.1, therefore, expired on 2nd January, 2019. The respondent,
                            however, requested for extension of time for notification of the award
                            of the tender to the petitioner vide letters dated 26th December, 2018,
                            23rd January, 2019, 25th March, 2019, 15th April, 2019, 19th June,
                            2019, 15th July, 2019, 26th July, 2019 and 19th August, 2019, to all of
                            which the petitioner consented. Ultimately, the tender was awarded to
                            the petitioner vide three Letters of Award (hereinafter referred to as
                            "LOAs"), issued on 20th September, 2019, by the respondent. These
                            three LOAs were for
                                  (i)     supply of plant and equipment and materials,
                                  (ii)    providing services such as       port handling, insurance,
                                  inland transportation, site handling, installation, testing,
                                  commissioning etc., and
                                  (iii)   operation and maintenance for a period of ten years,
                                  including 24 months' defect liability period, from the date of
                                  commissioning of the project.

                            13.   Para 5.0 of the of the first of the aforesaid three LOAs, for
                            supply of plant and equipment and materials, stipulated thus:
                                  "5.0 The Sub-contractor for the Float Device Technology
                                  provider shall be M/s Yellow 2 Gen Energy Pvt. Limited.
                                  Gurugram. The Sub-contractor shall submit Performance
                                  Bank Guarantee equivalent to 5% of value of work sublet in
                                  addition to the Performance Bank Guarantee for whole
                                  contract submitted by the Contractor.

                                  The Contractor shall also submit a joint deed of undertaking
                                  (as per Annexure-B) from the proposed subcontractor and
                                  Contractor for joint and several responsibility of execution of
                                  work sub-contracted by the sub-contractor."

Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                  Page 19 of 76
Signing Date:19.02.2021
09:08:48
                             14.   The petitioner addressed several communications to the
                            respondent, requesting the respondent to permit engagement of
                            additional/alternative float technology providers, in view of the
                            advancement in design and technology of the floater device that had
                            taken place during the time consumed by the respondent in awarding
                            the contract to the petitioner.


                            15.   On 15th November, 2019, M/s Yellow 2 Gen Energy Private
                            Limited (hereinafter referred to as "Y2G"), the float technology
                            provider approved by the respondent, informed the respondent that it
                            was unable to meet the project schedule requirements of the petitioner
                            and suggested that a different float technology provider be engaged by
                            the respondent for the remainder capacity which Y2G had been unable
                            to provide. Admittedly, however, the 5% bank guarantee, which was
                            required to be submitted by Y2G, vide Clause 3.2.A.4 of the NIT and
                            ITB, was never so submitted.


                            16.   On or around 3rd March, 2020, the respondent invoked the bank
                            guarantees submitted by the petitioner towards earnest money deposit.
                            At around the same time, on 2nd March, 2020, the respondent
                            addressed the following communication to the petitioner:
                                                                           "Date: 02.03.2020

                                  Emoil;[email protected]/shubham.pratyush@mahindr
                                  a.com

                                  M/s Mahindro Susten Pvt. Ltd.,
                                  Mahlndro Towers G. M. Bhosle Road
                                  P. K. Kurne Chowk,
                                  Mumbai, Maharashtra -400018

Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020               Page 20 of 76
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09:08:48
                                   Kind Attention: Mr. Ankit Jain, General Manager

                                  Subject; "Engineering Procurement and Construction (EPC)
                                  contract for development of 10MW Floating Solar Power
                                  Project including evacuation arrangements of West Kallada
                                  site, Dist.- Kollam in the state of Kerala, along with its
                                  comprehensive operation and maintenance for 10 (ten) years"
                                  - Cancellation of Award of work.

                                  Ref:

                                  (i)     E ·TENDER ID. 2018NHPC_355399_1

                                  iii)    LOA      No.        NH/CCW/CC-III/Floating-Solar/
                                          LOA/2019/613, 614, 615 dated 20.09.2019

                                  iv)     Your acceptance vide No. MSPL/NHPC/FSPV-
                                          l0MW/2019/OO1 dated 30.09.2019

                                  v)      Our     letter   No.      NH/CCW/CC-III/Floating-
                                          Solar/EPC/2019/675 dated 10.10.2019

                                  vi)     Your letter MSPL/NHPC/FSPV-l0MW/2019/005 dated
                                          16.10.2019

                                  vii)    Your mail dated 18.10.2019

                                  (vi)    Our    letter    No.     NH/CCW/CC-lll/Floating-
                                  Solar/EPC/2019/754 dated 25.10.2019

                                  viii)   Your mail dated 05.11.2019

                                  ix)     Our     letter   No.      NH/CCW/CC-III/Floating-
                                          Solar/EPC/2019/781 doted 20.11.2019

                                  x)      Our     letter   No.      NH/CCW/CC-III/Floating-
                                          Solar/EPC/2019/839 doted 25.11.2019

                                  Dear Sir,

                                         This has reference to our letter of award no.
                                  NH/CCW/CC-III/Floating-Solar/LOA/2019/613, 614, 615
                                  dated 20.09.2019 vide which subject cited work was awarded
                                  to you.
Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020              Page 21 of 76
Signing Date:19.02.2021
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                                           As you have failed to submit the Performance Bank
                                  Guarantee @ 5% from the Sub-contractor for the value of
                                  work sublet to the sub-contractor along with Joint Deed of
                                  Undertaking from the Sub-contractor i.e. M/s Yellow 2 Gen,
                                  signed integrity Pact between the Contractor and Sub-
                                  contractor and could not sign the contract agreement within
                                  the extended time for signing of Contract Agreement, the
                                  award of work is hereby cancelled and further action shall be
                                  initiated against you and your Sub-contractor as per bid
                                  conditions.

                                        Thanking you
                                                                              Yours faithfully,

                                                                                         Sd/-
                                                        General Manager (Civil Contracts-III)"


                            17.   This was succeeded by the following communication, dated 9th
                            March, 2020, from the respondent to the petitioner:
                                                                             "Date: 09.03.2020

                                  To,

                                  MAHINDRA SUSTEN PVT.LTD.
                                  G.M. BHOSLE ROAD
                                  P.K. KURNE CHOWK, WORLI
                                  MUMBAI, MAHARASHTRA-400018

                                  Attention: Shri Ankit Jain, General Manager

                                  Subject: Intimation of Suspension of Business Dealings

                                  Dear Sir,

                                  Whereas the work of "Engineering Procurement and
                                  Construction (EPC) contract for development of 10MW
                                  Floating Solar Power Project including evacuation
                                  arrangements at West Kallada site, Dist.- Kallam in the state
                                  of Kerala, along with its comprehensive operation and
                                  maintenance for 10 (ten) years" was awarded to your firm
                                  vide Letter of Award No. NH/CCW/CC-III/Floating-
Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                Page 22 of 76
Signing Date:19.02.2021
09:08:48
                                   Solar/LOA/2019/613, 614, 615 dated 20.09.2019 amounting
                                  to Rs. 59.70 Crores (Rs. Fifty Nine Crore Seventy Lac Only)
                                  with M/s Yellow 2 Gen Energy Pvt. Ltd., Gurugram as
                                  approved Sub-contractor for the "Float Device Technology
                                  Provider".

                                  Whereas the conduct of your firm in respect of the following
                                  is under investigation:

                                  Brief of the default: M/s Mahindra Susten Pvt. Ltd. have
                                  failed to submit Performance Guarantee @5% from the sub-
                                  contractor for the value of work sublet to the Sub-contractor
                                  along with Joint Deed of Undertaking from the sub-contractor
                                  i.e. M/s Yellow 2 Gen, signed Integrity pact between the
                                  Contractor & sub-contractor and could not sign the Contract
                                  agreement within the extended time for Singing of contract
                                  agreement even after giving adequate opportunity to sign the
                                  same by extending the date of signing of contract agreement
                                  thrice at M/s Mahindra Susten Pvt. Ltd. request.

                                  "Whereas the Competent Authority prima facie considered the
                                  allegations (under investigation) are of a serious nature and
                                  decided pending investigation, it is not in the interest of the
                                  corporation to continue business dealing with your firm.

                                  This order shall have the following effects:

                                  i)      Further business dealings with your firm is Suspended
                                  within NHPC. The order of Suspension is effective with
                                  immediate effect and would operate for a period of six months
                                  or till the investigation is completed and whole process of
                                  final order is over within such period. However, if
                                  investigations are not completed in six months' time, the
                                  Competent Authority may extend the period of Suspension

                                  ii)    During the period of Suspension, no business dealing
                                  shall be held with your firm. No enquiry / bid / tender shall be
                                  issued to your firm nor will the bids submitted by your firm
                                  be entertained.

                                  iii)   In cases where tenders have already been issued to you
                                  and price bids are yet to be opened, the Price Bid submitted
                                  by you shall not be opened and BG/EMD, if any, submitted
                                  by you shall be returned.
Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                   Page 23 of 76
Signing Date:19.02.2021
09:08:48
                                   iv)   In cases where tenders have already been issued to you
                                  and Price Bids have already been opened, the tendering
                                  process shall be continued.

                                  v)     In case of ongoing contracts between you & NHPC,
                                  (including cases where contract has already been awarded
                                  before the issue of Suspension order) you will be required
                                  to continue with the execution and perform as per terms of the
                                  contract.

                                  vi) a) In case the Firm is in Joint Venture the following
                                  would also be applicable:

                                        i)     Participation of Agency in Joint Venture:

                                        Tenders in which your firm has been proposed as Joint
                                        Venture Partner by any of the bidders and price bids
                                        have been opened prior to Suspension of your firm in
                                        such cases the tendering process shall not be annulled
                                        on this ground and the Agency shall be permitted to
                                        continue as Partner in the Joint Venture for such
                                        bidding. However where event of Price Bid opening
                                        has not taken place prior to Suspension/Banning of
                                        Agency then in such case Agency shall not be
                                        permitted to participate as Partner in the Joint Venture.

                                        ii)    Banning of joint Venture:

                                        As the Joint Venture is Banned, your firm intends to
                                        bid as Partner(s) of Joint Venture in bidding process
                                        then it shall be permitted to participate in the bidding
                                        process if it has not been Banned on grounds of its role
                                        and responsibility in the tendering process for which
                                        the Joint Venture has been Banned in Past. In case if
                                        the Joint Venture which has been Banned does not
                                        indicate the roles and responsibility of individual
                                        Partner(s) then, the partner of the Banned Joint Venture
                                        shall only be allowed to participate in the bidding
                                        process if its participation share is less than 35%.

                                  b)   Your firm shall not be allowed to participate as Sub-
                                  Vendor/Sub-Contractor in the tenders. Further if your firm is
                                  an approved Sub-vendor under any Contract for such
Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                   Page 24 of 76
Signing Date:19.02.2021
09:08:48
                                   equipment/component/service, the Main Contractor shall not
                                  be permitted to place work order/Purchase order/Contract on
                                  your agency as a Sub-Vendor/Sub-Contractor after the date of
                                  Suspension/ Banning even though the name of the party has
                                  been approved as a Sub-Vendor/Sub-Contractor earlier.

                                  c)    There would be no bar on procuring the spares and
                                  awarding Contracts towards Annual Maintenance (AMC)/
                                  O&M/ Repair works on Agencies pertaining to the packages
                                  for which they have been Banned provided the Equipment has
                                  been supplied by such Agency.

                                  d)     Banning of business dealing shall not be applicable to
                                  the Subsidiary company of the Banned agency provided
                                  subsidiary company has not participated on the strength
                                  of the Banned agency.

                                  On expiry of the above period of Suspension/Banning, you
                                  may approach Contracts Civil Division, with request for
                                  revocation of the order mentioning inter-alia the steps taken
                                  by you to avoid recurrence of misconduct which has led to
                                  Suspension.

                                                                     Yours faithfully,

                                                                         Sd/-
                                                  General Manager (Contracts Civil -III)"


                            18.   Disputing the legitimacy of the aforesaid communications dated
                            2nd March, 2020 and 9th March, 2020, the petitioner addressed a
                            detailed notice to the respondent on 4th May, 2020, refuting all
                            allegations made by the respondent against the petitioner, and seeking
                            reference of the disputes to arbitration in accordance with Clause 6.3
                            of the GCC, which read thus:
                                  "6.3   Arbitration

                                  Except as otherwise provided, in GCC clause-6.2
                                  hereinbefore, all questions, dispute or difference in respect of
                                  which the decision has not been final and conclusive arising
Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                   Page 25 of 76
Signing Date:19.02.2021
09:08:48
                                   between the contractor and the Employer, in relation to or in
                                  connection with the contract shall be referred for arbitration in
                                  the manner provided as under:

                                  6.3.1 Either of the parties may give to the other notice in
                                  writing of the existence of such question, dispute or difference
                                  which shall be settled in accordance with the Arbitration and
                                  Conciliation Act, 1996, as amended up to date.

                                  6.3.2 Any dispute or difference what so ever arising between
                                  the parties and of or relating to the construction,
                                  interpretation, application, meaning, scope, operation /or
                                  effect of this contract or the validity of the breach thereof,
                                  shall be settled by arbitration in accordance with the rules of
                                  arbitration of the Delhi High Court Arbitration Centre and
                                  the award made in the pursuance thereof shall be final and
                                  binding on the parties. It is a term of the Contract that the
                                  Party invoking arbitration shall specify all disputes to be
                                  referred to arbitration at the time of invocation of arbitration
                                  and not thereafter.

                                  6.3.3 The cost and expenses of arbitration proceedings will
                                  be borne by each party as per terms of Delhi High Court
                                  Arbitration Centre in equal shares. However, the expenses
                                  incurred by each Party in connection with the document
                                  preparation, presentation etc. to produce to arbitral tribunal on
                                  its behalf shall be borne by each Party itself. Majority award
                                  rendered by arbitral tribunal shall be final and binding on the
                                  Parties."


                            19.   The petitioner also suggested the name of a learned retired
                            Chief Justice of the High Court of Punjab and Haryana as the
                            arbitrator to arbitrate on the disputes.


                            20.   The respondent replied to the aforesaid communication dated 4th
                            May, 2020 of the petitioner, on 22nd May, 2020, thus:
                                  "M/s Mahindra Susten Pvt. Ltd.,
                                  7th floor, We Work Raheja Platinum,
                                  Marol Co-operative Industrial Estate Road,
Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                    Page 26 of 76
Signing Date:19.02.2021
09:08:48
                                   Sag Baug, Marol, Andheri East Mumbai,
                                  Maharashtra-400059

                                  Sub: Request for Arbitration in the matter between M/s.
                                  Mahindra Susten Private Limited and NHPC Limited.

                                  Ref:   Your email dated 04/05/2020

                                  Sir,

                                  This is in reference to the above referred email whereby a
                                  request on your behalf for RFA has been received from legal
                                  firm Khaitan & Co. In this regard at the outset it is submitted
                                  that there is no arbitration agreement between the parties in
                                  terms of section 7 of A&C Act, 1996. Moreover terms of bid
                                  document does not confer power upon DIAC to act as Arbitral
                                  Institution, as Clause 6.3 of GCC does not confer power upon
                                  DIAC to act as Arbitral Institution. It only stipulates that
                                  dispute shall be settled by arbitration in accordance with the
                                  rules of DIAC.

                                  However, without prejudice to above it is also submitted that
                                  the Claimant has unilaterally proposed the name Hon'ble
                                  Justice (Retd.) Vijender Jain as sole arbitrator, which is being
                                  opposed vehemently. In this regard it is brought within your
                                  kind notice that Hon'ble Justice (Retd.) Vijender Jain is an
                                  arbitrator in four cases either as NHPC's nominee arbitrator or
                                  as Presiding Arbitrator or as nominee arbitrator of the
                                  claimant. As such he is ineligible as per the provisions of
                                  Arbitration and Conciliation Act, 1996. Moreover in terms of
                                  recent decision of Hon'ble Supreme Court a person interested
                                  in outcome of the dispute cannot appoint a sole arbitrator.

                                  In view of the above, your request for invocation of
                                  arbitration cannot be accepted.

                                  Thanking you,
                                                                            Yours faithfully,

                                                                                 Sd/-
                                                                     General Manager (CC-III)"


                            21.   The petitioner replied on 18th June, 2020, asserting that an
Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020                   Page 27 of 76
Signing Date:19.02.2021
09:08:48
                             arbitration agreement did exist between the petitioner and the
                            respondent, and that Clause 6.3.2 of the GCC required the arbitration
                            to be in accordance with the rules of arbitration of the Delhi
                            International Arbitration Centre (DIAC). However, as there was an
                            objection to the name suggested by the petitioner as the arbitrator to
                            arbitrate on the disputes, the petitioner suggested the name of another
                            learned retired Judge of this Court, in place of the name earlier
                            suggested.


                            22.   The respondent responded by issuing, on 19th June, 2020, a
                            Show Cause Notice to the petitioner, which read thus:
                                  "M/s Mahindra Suslen Pvt. Ltd .,
                                  G.M. BHOSLE ROAD.
                                  P.K. KURNE CHOWK. WORLI
                                  MUMBAI. Maharashtra-400018.

                                  Attn.: Sh. Anklt Jain. General Manager

                                  Subject: Show Cause Notice.

                                  Ref: 1.      LOA       No.      NH/CCW/CC-III/Floating-
                                  Solar/EPC/2019/613-615 Dated: 20.09.2019.

                                  2.    NHPC     Letter   No.     NH/CCW/CC-III/Floating-
                                  Solar/EPC/2020/253 Dated: 02.03.2020.

                                  3.    NHPC     Letter   No.     NH/CCW/CC-III/Floating-
                                  Solar/EPC/2020/289 Dated: 09.03.2020.

                                  Dear Sir,

                                         You are hereby required to Show Cause in writing
                                  within 15 days from the date hereof why Business Dealing
                                  with your firm should not be banned / your firm is placed in
                                  the Banning List (as the case may be) and be debarred from
                                  entering into any contracts with NHPC for the following
                                  reasons:
Signature Not Verified
Digitally Signed By:SUNIL
SINGH NEGI
                            ARB.P. 217/2020 & O.M.P.(I) (COMM.) 162/2020               Page 28 of 76
Signing Date:19.02.2021
09:08:48
                                   1.     Non submission of Performance Guarantee @5% from
                                  the approved subcontractor for the value of work sublet to the
                                  sub-contractor along with Joint Deed of Undertaking from the
                                  Sub contractor i.e. Yellow 2Gen, signed Integrity Pact
                                  between Contractor & Sub Contractor for the work of "EPC
                                  Contract for development of 10 MW Floating Solar Power
                                  Project including evacuation arrangements, at West Kallada
                                  Site. Dist. - Kollam in the state of Kerala, along with its
                                  comprehensive O&M for 10 years" as per LOA/ Bid
                                  Conditions.


                                  2.     Non signing of Contract Agreement within extended
                                  time even after giving adequate opportunity by extending the
                                  date of Signing of Contract Agreement thrice at M/s Mahindra
                                  Susten Pvt. Ltd. request.

                                         Your reply (if any) should be supported by documents
                                  and documentary evidence which you wish to rely in support
                                  of your reply. In case you desire to present your case in
                                  person to NHPC, an Oral Healing shall be conducted on 29th
                                  June,2020 at 15:00 Hours for which prior intimation be
                                  furnished to this office. Should you fail to reply to this Show
                                  Cause Notice within the time and manner aforesaid, it will be
                                  presumed that you have nothing to say and we shall proceed
                                  accordingly.

                                          Your reply, if any, and the documents / documentary
                                  evidence given in support shall be taken into consideration
                                  prior to arriving at a decision.

                                                                              Yours faithfully,
                                                                                          Sd/-
                                                                     General Manager (CC-III)"


                            23.   It is in these circumstances that the petitioner has moved this
                            Court by means of the two petitions which are being disposed of by
                            the present judgment, i.e. Arb. P. 217/2020, under Section 11(6) of the
                            1996 Act, seeking appointment of an arbitrator and OMP (I) (Comm)
                            162/2020 under Section 9 of the 1996 Act, seeking certain pre-arbitral
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                             interim reliefs. As already noted at the commencement of the present
                            judgment, Mr. Viswanathan, learned Senior Counsel for the petitioner
                            agreed to OMP (I) (Comm) 162/2020 being adjudicated by the
                            Arbitral Tribunal, to be constituted in accordance with the prayer
                            contained in Arb P 217/2020, treating the OMP as an application
                            under Section 17 of the 1996 Act.


                            24.   This Court, therefore, is only required to adjudicate on Arb P
                            217/2020. Pleadings have been completed in the petition, and detailed
                            written submissions have also been filed by learned Counsel.


                            Rival Contentions


                            25.   The respondent opposes, in writing as well as orally through
                            Mr. Tejas Karia, Arb. P. 217/2020, on the following grounds:


                                  (i)    The only concluded contract between the parties was the
                                  Integrity Pact. The GCC had not been signed by both parties.
                                  The Integrity Pact conferred jurisdiction exclusively on Courts
                                  at Faridabad. As such, this Court does not possess territorial
                                  jurisdiction to entertain the present matter.


                                  (ii)   The petition was not maintainable, as it was based on a
                                  "proposed EPC contract", which had never come into existence,
                                  as it was never signed by the respondent. Reference has been
                                  invited, in this context, to the following passages, from
                                  OMP(I)(COMM) 162/2020:
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                                         "2. The brief facts pertaining to the present
                                        petition are that on 05.07.2018, the Respondent
                                        issued a Notice Inviting Tender ("NIT") for the
                                        purpose of inviting bids for "Engineering
                                        Procurement Construction (EPC) Contract for 10
                                        MW capacity Floating Solar Power Project at West
                                        Kallada in the State of Kerala with its
                                        Comprehensive Operation and Maintenance for 10
                                        Years" ("Proposed EPC Contract"). In response to
                                        the NIT, the Petitioner duly submitted the Pre-
                                        Contract Integrity Pact on 03.09.2018 ("Integrity
                                        Pact"), its online bid on 04.09.2018 and its offline
                                        bid on 06.09.2018 in compliance with the terms of
                                        the NIT and submitted bid security/Earnest Money
                                        Deposit ("EMD") amounting to INR 97,00,000
                                        (Indian Rupees Ninety Seven Lacs Only) by way
                                        of a Bank Guarantee No. 136GM07182430001
                                        dated 31 August 2018 issued by Yes Bank Limited
                                        ("EMD Guarantee"), which guarantee was
                                        extended from time to time basis requests from the
                                        Respondent.

                                        3.     It is the case of the Petitioner that the terms
                                        of the NIT and the Instruction to Bidders ("ITB")
                                        contained in the Bid Document for the Engineering
                                        Procurement Construction (EPC) Contract for 10
                                        MW Capacity Floating Solar Power Project at
                                        West Kallada, Kollam District in the State of
                                        Kerala with its Comprehensive Operation and
                                        Maintenance for 10 Years ("Bid Document")
                                        stipulate that the bidder must propose the name of
                                        the float technology provider with whom the
                                        bidder expects to tie-up for the supply of floats for
                                        the 10 MW Capacity Floating Solar Power Project
                                        at West Kallada, Kollam District in the State of
                                        Ker ala ("Project"). Accordingly, the Petitioner
                                        proposed the names of four float solar vendors
                                        namely, M/s. Ciel et Terre, M/s. Hefei Jntech New
                                        Energy Co. Ltd., M/s. Quant Solar Technologies
                                        Pvt. Ltd., and Yellow 2 Gen Energy Pvt. Ltd.
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                                         ("Y2G"). The Petitioner emerged as the successful
                                        bidder and was awarded three letters of award for
                                        the Proposed EPC Contract by the Respondent.

                                        4.     The First LoA (defined below) stated that
                                        Y2G shall be the subcontractor for the purposes of
                                        supplying Float Device Technology ("Float
                                        Provider") and shall submit performance bank
                                        guarantee equivalent to 5% of the value of work
                                        sublet ("5% PBG"), in addition to the performance
                                        bank guarantee that was to be submitted for the
                                        entire Proposed EPC Contract by the Petitioner.
                                        Further, a joint undertaking was to be submitted by
                                        the Petitioner and Y2G for joint and several
                                        responsibilities of execution of work sub-
                                        contracted by the Petitioner to Y2G as the sub-
                                        contractor.

                                        5.      However, despite the Petitioner's repeated
                                        attempts at negotiations and sending reminders to
                                        expedite closure, Y2G refused to co-operate and
                                        failed to respond to the Petitioner's requests in
                                        respect of the same, for reasons best known to
                                        them. Consequently, the Petitioner was unable to
                                        enter into the Proposed EPC Contract with the
                                        Respondent on account of the failure of Y2G to
                                        submit the 5% PBG and joint undertaking by Y2G
                                        despite the Petitioner's best efforts to close all
                                        issues regarding the same with Y2G. In fact, Y2G
                                        itself informed the Respondent that it is unable to
                                        meet the project schedule requirements of the
                                        Petitioner and in fact even suggested that if the
                                        schedule proposed by the Petitioner is to be met
                                        then a different vendor be engaged for the
                                        remainder capacity that Y2G is unable to provide
                                        within the project schedule and that the 5% PBG
                                        may be accordingly split between the
                                        subcontractors."
                                                                           (Emphasis supplied)


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                                   (iii)   Clause 10.0 of the Integrity Pact specifically stipulated
                                  that the arbitration clause in the tender documents/contract
                                  would not be applicable to any issue/dispute arising under the
                                  Integrity Pact. As such, there was no arbitration agreement
                                  between the petitioners and the respondent.

                                  (iv)    In its e-mail dated 18th October, 2019 supra, the
                                  petitioner had admitted that the submission of performance
                                  bank guarantee from Y2G was a pre-requisite for signing of the
                                  contract. The said bank guarantee having not been submitted by
                                  Y2G till date, the petitioners could not seek to contend that a
                                  concluded contract existed between the petitioners and the
                                  respondent. The relevant paragraphs from the letter dated 18th
                                  October, 2019 from the petitioner to the respondent, read thus:
                                          "With         reference        to        our        letter
                                                                                           th
                                          MSPL/NHPC/FSPV‐10MW/2019/005 dated 16 Oct
                                          2019, MSPL had submitted PBG worth 10% of
                                          contract value, in original, in accordance with clause
                                          13.3 of GCC and proposed the date of 22nd Oct 2019
                                          for signature of the contract as per clause no 30 (ITB).
                                          In the said letter, we also proposed submission of
                                          performance bank guarantee from the float device
                                          technology provider upon finalization of floater
                                          subcontractor.

                                          It is however understood that submission of
                                          performance bank guarantee from floater subcontractor
                                          is prerequisite for signing of the contract. As we are
                                          still in the process of discussion and finalization of
                                          floater subcontractor in light of our letter no.
                                          MSPL/NHPC/FSPV‐10MW/2019/002 dated 30 th Sep
                                          2019, some more time will be required for submission
                                          of performance bank guarantee from floater
                                          subcontractor."

                                  (v)     Vide its letter dated 20th November, 2019, the respondent
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                                   had informed the petitioners that final extension for execution
                                  of the contract was granted only till 30th November, 2019 and
                                  that if the conditions under the LOAs were not complied with,
                                  the respondent would cancel the LOAs, forfeit the bank
                                  guarantee furnished towards EMD and suspend business
                                  dealings with the petitioner and Y2G, as well as initiate action
                                  for banning of business dealings. As the joint undertaking and
                                  5% performance bank guarantee was not submitted by Y2G, no
                                  contract was executed/signed by the respondent. Ultimately, on
                                  2nd March, 2020, the respondent was constrained to issue a
                                  notice of cancellation of the award of the work.


                                  (vi)   It was understood between the parties that mere issuance
                                  of LOAs did not result in a concluded contract, unless and until
                                  the prerequisite of the LOAs were complied with by the
                                  petitioners and Y2G.      Consensus, ad idem, on all material
                                  terms, is a prerequisite for a concluded contract.

                                  (vii) Under Section 7 of the Indian Contract Act, 1972
                                  (hereinafter referred to as "the Contract Act"), absolute and
                                  unqualified acceptance of an offer is necessary to convert a
                                  proposal into a promise. As there was no compliance by the
                                  petitioners, with the conditions stipulated in the LOAs dated
                                  20th September, 2019, no concluded contract could be said to
                                  have come into being, between the petitioners and respondent,
                                  in view of Section 7 of the Contract Act.


                                  (viii) All actions taken by the respondent against the
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                                   petitioners, including cancellation of the LOAs, suspension of
                                  business activities and issuance of Show Cause Notice were
                                  taken under the Integrity Pact, and not under the EPC contract.


                                  (ix)   By concealing the fact that Y2G was incapable of
                                  performing the contract, and by insisting on the respondent to
                                  add/substitute subcontractors, in violation of the covenants of
                                  the NIT and ITB, the petitioners had breached Clause 3.7 of the
                                  Integrity Pact, thereby justifying the invocation, against the
                                  petitioner, of the Guidelines for Banning of Business Dealings.


                            26.   As against this, the petitioners in its first written submissions,
                            dated 1st July, 2020, contended thus:


                                  (i)    Clause 6.3.2 of the GCC specifically required any dispute
                                  relating to the contract to be settled by arbitration in accordance
                                  with the rules of arbitration of the DIAC. Clause 1.1 of the
                                  GCC defined "contract" to mean the contract entered into
                                  between the employer and the contractor, and included the
                                  "contract documents". "Contract documents" in turn, included,
                                  by definition, the GCC.


                                  (ii)   Clause 6.1 of the ITB specifically stipulated that the GCC
                                  formed part of the bid documents. The GCC was also
                                  communicated, electronically, by the respondent to the
                                  petitioners, with the bid documents and the NIT, and was
                                  accepted by the petitioners by submission of its bid in response
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                                        thereto.

                                       (iii)   The issuance of the three LOAs dated 20th September,
                                       2019, issued by the respondent to the petitioners for proposed
                                       EPC contract, clearly vouchsafed the acceptance by the
                                       respondent, of the petitioners' bid, in accordance with the terms
                                       of the Bid Documents, including, specifically, the GCC.

                                       (iv)    It was trite, in law, that where the tender documents
                                       themselves contained an arbitration clause and had been
                                       accepted, a valid arbitration agreement existed between the
                                       parties. Clause 6.3 of the GCC satisfied the requirement of
                                       Section 7 of the 1996 Act and constituted a valid, binding and
                                       enforceable arbitration agreement between the petitioners and
                                       the respondent. Reliance was placed, in this context, on the
                                       judgment of the Supreme Court in Unissi (India) Pvt. Ltd. v.
                                       Post Graduate Institute of Medical Education and Research 1
                                       and State of U.P. v. Combined Chemicals Co. (P) Ltd. 2.


                            27.        In response to the aforesaid submissions of the petitioners, the
                            respondent further contended thus:


                                       (i)     Clause 29.1 of the ITB could not be read in isolation. The
                                       Court had to examine whether a contract existed and whether
                                       non-signing of the contract vitiated the entire contract, including
                                       the LOAs.


                            1
                                (2009) 1 SCC 107
                            2
                                (2011) 2 SCC 151
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                                       (ii)     Section 7 of the 1996 Act applied only where there was a
                                      defined legal relationship between the parties. Prior to applying
                                      Section 7 of the 1996 Act, therefore, it had to be examined
                                      whether a concluded contract existed between the parties, in
                                      terms of the Contract Act, for which purpose reliance was
                                      placed, by Mr. Karia, on the judgment of this Court in Benara
                                      Bearing & Pistons Ltd v. Mahle Engineering Components
                                      India Pvt. Ltd. 3.

                                      (iii)    Acceptance of a contract, while proposing variations
                                      therefrom, did not constitute acceptance in the eyes of law, but
                                      was in the nature of a counter proposal. A concluded contract
                                      came into being only when such counter proposal was accepted
                                      by the original proposer.         Reliance has been placed, in this
                                      context, on Padia Timber Company (P) Ltd. v. Board of
                                      Trustees of Visakhapatnam Port Trust 4, as well as the
                                      judgment of this Court in National Aluminum Co. Ltd. v.
                                      Subhash          Infraengineers   Pvt.    Ltd.   and   Ors. 5.     The
                                      communication dated 20th September, 2019 (supra), from the
                                      respondent to the petitioners was in the nature of a conditional
                                      acceptance and, therefore, a counter proposal, as it required a
                                      joint undertaking from Y2G as well as furnishing by Y2G, of
                                      5% performance bank guarantee. The LOAs were, therefore, in
                                      the nature of a counter offer.           Compliance of the aforesaid

                            3
                                (2018) SCC OnLine Del 8272
                            4
                                2021 SCC OnLine SC 1
                            5
                                MANU/PH/2107/2016
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                                   conditions contained in the LOAs by the petitioners, alone
                                  would result in a concluded contract between the parties. These
                                  conditions were never complied with; ergo, no concluded
                                  contract came into being between the petitioners and the
                                  respondent.


                                  (iv)   The Suspension Order dated 9th March, 2020 and the
                                  Show Cause Notice dated 19th June, 2020 were issued by the
                                  respondent in exercise of the authority conferred by Clause 6 of
                                  the Integrity Pact, specifically Clause 6.1(i) (which empowered
                                  the respondent to call off the pre-contract negotiations and
                                  forfeit the bank guarantee provided by the petitioners at the
                                  contract stage and Clause 6.1(vii) (which empowered the
                                  respondent to debar the petitioners in accordance with the
                                  guidelines for Banning of Business Dealings).

                                  (v)    Clause 13.3 of the GCC was required to be read in
                                  conjunction with Clause 3.2.A.4 of the ITB, which required
                                  submission of 5% performance bank guarantee by the float
                                  device service provider, i.e. Y2G.


                                  (vi)   The respondent wrote to the petitioners on 13th
                                  November, 2019 and, again, on 20th November, 2019 calling on
                                  the    petitioners   to   sign   the   contract   agreement.   Both
                                  communications evinced the intention and readiness of the
                                  respondent to proceed with the contract.           The petitioners,
                                  however, demurred from signing the contract and fulfilling the
                                  covenants of the LOAs, resulting in the respondent cancelling
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                                   the LOAs vide letter dated 2nd March, 2020, annulling the award
                                  of the contracts to the     ` in consequence. Mr. Karia was
                                  emphatic in pointing out that the respondent annulled the award
                                  and not the contract, the contract itself never having come into
                                  being in the first place.

                                  (vii) Unissi1 and Combined Chemicals2, on which Mr.
                                  Viswanathan relied, were distinguishable.       In Unissi1, the
                                  products were delivered by M/s. Unissi (India) Pvt. Ltd.
                                  (hereinafter referred to as "Unissi"), pursuant to a purchase
                                  order issued by the Post Graduate Institute of Medical
                                  Education and Research (hereinafter referred to as "PGIMER")
                                  and delivery of the products was accepted by PGIMER. In
                                  these circumstances, the Supreme Court held that the parties
                                  had acted upon the terms of the contract though it was signed by
                                  only one party and not by the other. In the present case, though
                                  the Letters of Award dated 20th September, 2019 were issued by
                                  the respondent to the petitioners, the petitioners failed to take
                                  steps in accordance with the said Letters of Award, resulting in
                                  non-conclusion of the contract. In Combined Chemicals Co.
                                  (P) Ltd.2, the bid documents itself included an arbitration
                                  agreement, and the letter of acceptance stipulated that, if so
                                  required, the successful tenderer would have to execute a formal
                                  agreement deed within the time fixed by the director of
                                  industries. Execution of a formal contract in that case was,
                                  therefore, optional, and by issuance of the letter of acceptance,
                                  the arbitration agreement had become enforceable.         In the
                                  present case, there was no arbitration agreement in the LOAs.
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                                   Rather, the petitioner, in its email dated 18th October, 2019 had
                                  specifically acknowledged the fact that submission of the
                                  performance bank guarantee by Y2G was a precondition for
                                  concluding of the contract with the respondent.           In these
                                  circumstances, the petitioners could not legitimately contend
                                  that, without a concluded signed contract coming into being
                                  between the parties, Clause 6.3 of the GCC became applicable.


                            28.   Without prejudice, it has been contended that the petitioners
                            have failed to exhaust the avenue of amicable settlement,
                            contemplated by Clause 6.3.2 of the GCC.


                            29.   In rejoinder, the petitioner has submitted thus:

                                  (i)     Clause 29.1 of the ITB specifically stipulated that the
                                  notification of award would constitute the formation of the
                                  contract and would be considered for all purposes as execution
                                  of the contract provisions till signing of the contract agreement.


                                  (ii)    Moreover, the respondent had directed the petitioner to
                                  commence works under Clause 8.0 of the Letters of Award. The
                                  Letters of Award specifically incorporated the terms of the
                                  GCC, including Clause 6.3 thereof.


                                  (iii)   It was not open, therefore, for the respondent to contend
                                  that there was no valid and binding contract between the parties.


                                  (iv)    Insofar as the Integrity Pact, and the proposal to ban
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                                   business dealings, was concerned, Clause 32(e) of the NIT
                                  stipulated intentional wrongdoing in the form of deception,
                                  fraud or other misconduct, as a pre-requisite for banning of
                                  business dealings.     Neither the suspension order dated 9th
                                  March, 2020, nor the Show Cause Notice, dated 19th June, 2020,
                                  even hinted at breach of any of the "commitments", enumerated
                                  in Clause 3.0 of the Integrity Pact. The attempt, of the
                                  respondent, to pigeonhole the alleged infractions of the
                                  petitioner into Clauses 3.6, 3.7 and 3.9 of the Integrity Pact,
                                  was, therefore, a desperate attempt to invoke the Pact, ex post
                                  facto, to defeat the case of the petitioner.


                                  (v)    Even on merits, the breaches alleged in the suspension
                                  order dated 9th March, 2020 and the Show Cause Notice dated
                                  19th June, 2020 could not be said to be breaches relatable to
                                  Clauses 3.6, 3.7 and 3.9 of the Integrity Pact. The Integrity Pact
                                  applied only in the cases of egregious default, in which the
                                  integrity of the contractor had become suspect. This was
                                  apparent from Clause 3 of the Integrity Pact itself.


                                  (vi)   Clause 6.2.2, or the application thereof, was never
                                  pleaded by the respondent in its counter affidavit, filed in the
                                  present proceedings. Even otherwise, once the petitioner had
                                  annulled the Letters of Award, suspended dealings with the
                                  respondent and issued Show Cause Notice, to ban all further
                                  business dealings, any possibility of amicable resolution of the
                                  disputes between the petitioner and the respondent stood
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                                     foreclosed, and any such attempt would be nothing other than
                                    empty formalities. In such a case, compliance with the
                                    covenants could not be insisted upon.                 Reliance has been
                                    placed, for this purpose, on Demerara Distilleries (P) Ltd. v.
                                    Demerara          Distillers   Ltd. 6,   Visa    International      Ltd.   v.
                                    Continental Resources (USA) Ltd. 7, , Ravindra Kumar Verma
                                    v. BPTP Ltd. 8, Saraswati Construction Company v. East Delhi
                                    Co-operative          Group     Housing         Society   Ltd. 9,    Sikand
                                    Construction Co. v. State Bank of India 10 and U.O.I. v. Baga
                                    Brothers 11.


                                    (vii) The reliance, by Mr. Karia, on Clause 31.2 of the ITB,
                                    was also misplaced, as no violation, of any of the covenants of
                                    Clause 30 or Clause 31.1, by the petitioner, could be said to
                                    have taken place.


                                    (viii) The 14-day period for signing of the contract, post receipt
                                    of notice of readiness of contract agreement from the
                                    respondent under Clause 30 of the ITB, would not apply, as the
                                    respondent had itself waived the said requirement, even by the
                                    covenants of the three Letters of Award dated 20th September,
                                    2019.




                            6
                              (2015) 13 SCC 610
                            7
                              (2009) 2 SCC 55
                            8
                              2014 SCC Online Del 6602
                            9
                              1994 SCC OnLine Del 563
                            10
                               ILR (1976) I Delhi 364
                            11
                               2017 SCC Online Del 8989
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                                     (ix)    Even if it were to be presumed that the annulment of the
                                    Letters of Award was valid, the arbitration agreement, being in
                                    the nature of a separate agreement, would, nevertheless,
                                    survive, for resolution of dispute arising under or in connection
                                    with the contract. For this purpose, the petitioner has relied on
                                    National Agriculture Co-op. Marketing Federation India v.
                                    Gains Trading 12, Naihati Jute Mills Ltd. v. Khyaliram
                                    Jagannath 13, Reva Electric Car Company v. Green Mobil 14
                                    and Enercon (India) Ltd. v. Enercon GMBH 15.

                            Analysis

                            30.     Section 11(6A) of the 1996 Act conrtains a statutory
                            proscription against a court, exercising jurisdiction under Section
                            11(6), examining any aspect other than the existence of the arbitration
                            agreement between the parties. A bench of three Hon'ble Judges of
                            the Supreme Court has, in its recent judgement in Vidya Drolia v.
                            Durga Trading Corpn 16,          authoritatively delineated the scope and
                            ambit of the jurisdiction of a Court, exercising authority under Section
                            11 (6), to examine the aspects of existence of the arbitration agreement
                            and arbitrability of the dispute. The ratio decidendi of the judgement,
                            on these two aspects, is captured in the following passages:
                                    "121. The courts at the referral stage do not perform
                                    ministerial functions. They exercise and perform judicial
                                    functions when they decide objections in terms of Sections 8
                                    and 11 of the Arbitration Act. Section 8 prescribes the courts
                                    to refer the parties to arbitration, if the action brought is the

                            12
                               (2007) 5 SCC 692
                            13
                               AIR 1968 SC 522
                            14
                               (2012) 2 SCC 93
                            15
                               (2014) 5 SCC 1
                            16
                               2020 SCC OnLine SC 1018
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                                        subject of an arbitration agreement, unless it finds that prima
                                       facie no valid arbitration agreement exists. Examining the
                                       term 'prima facie', in Nirmala J. Jhala v. State of
                                       Gujarat 17, this Court had noted:

                                                "48. A prima facie case does not mean a case proved
                                                to the hilt but a case which can be said to be
                                                established if the evidence which is led in support of
                                                the case were [to be] believed. While determining
                                                whether a prima facie case had been made out or not
                                                the relevant consideration is whether on the evidence
                                                led it was possible to arrive at the conclusion in
                                                question and not whether that was the only conclusion
                                                which could be arrived at on that evidence."

                                       122. Prima facie case in the context of Section 8 is not to be
                                       confused with the merits of the case put up by the parties
                                       which has to be established before the arbitral tribunal. It is
                                       restricted to the subject matter of the suit being prima
                                       facie arbitrable under a valid arbitration agreement. Prima
                                       facie case means that the assertions on these aspects
                                       are bona fide. When read with the principles of separation
                                       and competence-competence and Section 34 of the
                                       Arbitration Act, referral court without getting bogged-down
                                       would compel the parties to abide unless there are good and
                                       substantial reasons to the contrary.

                                       123. Prima facie examination is not full review but a
                                       primary first review to weed out manifestly and ex facie non-
                                       existent and invalid arbitration agreements and non-
                                       arbitrable disputes. The prima facie review at the reference
                                       stage is to cut the deadwood and trim off the side branches in
                                       straight forward cases where dismissal is barefaced and
                                       pellucid and when on the facts and law the litigation must
                                       stop at the first stage. Only when the court is certain that no
                                       valid arbitration agreement exists or the disputes/subject
                                       matter are not arbitrable, the application under Section 8
                                       would be rejected. At this stage, the court should not get lost
                                       in thickets and decide debatable questions of facts. Referral
                                       proceedings are preliminary and summary and not a mini
                                       trial. This necessarily reflects on the nature of the jurisdiction
                                       exercised by the court and in this context, the observations of

                            17
                                 (2013) 4 SCC 301
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                                      B.N. Srikrishna, J. of 'plainly arguable' case in Shin-Etsu
                                     Chemical Co. Ltd. 18 are of importance and relevance. Similar
                                     views are expressed by this Court in Vimal Kishore Shah v.
                                     Jayesh D. Shah 19 wherein the test applied at the pre-
                                     arbitration stage was whether there is a "good arguable case"
                                     for the existence of an arbitration agreement. The test of
                                     "good arguable case" has been elaborated by the England and
                                     Wales High Court in Silver Dry Bulk Company
                                     Limited v. Homer Hulbert Maritime Company Limited 20, in
                                     the following words:

                                               "Good arguable case" is an expression which has been
                                               hallowed by long usage, but it means different things
                                               in different contexts. For the purpose of an application
                                               under Section 18, I would hold that what must be
                                               shown is a case which is somewhat more than merely
                                               arguable, but need not be one which appears more
                                               likely than not to succeed. It shall use the term "good
                                               arguable case" in that sense. It represents a relatively
                                               low threshold which retains flexibility for the Court to
                                               do what is just, while excluding those cases where the
                                               jurisdictional merits were so low that reluctant
                                               respondents ought not to be put to the expense and
                                               trouble of having to decide how to deal with arbitral
                                               proceedings where it was very likely that the tribunal
                                               had no jurisdiction. In this connection it is important to
                                               remember that crossing the threshold of "good
                                               arguable case" means that the Court has power to
                                               make one of the orders listed in Section 18(3). It
                                               remains for consideration whether it should do so as a
                                               matter of discretion."

                                     124. Appropriate at this stage would be a reference to the
                                     judgment of the Delhi High Court in NCC Ltd. v. Indian Oil
                                     Corporation Ltd. 21, wherein it has been held as under:

                                               "59.1 In my view, the scope of examination as to
                                               whether or not the claims lodged are Notified Claims
                                               has narrowed down considerably in view of the
                                               language of Section 11(6A) of the 1996 Act. To my

                            18
                               (2005) 7 SCC 234
                            19
                               (2016) 8 SCC 788
                            20
                               (2017) EWHC 44 (Comm)
                            21
                               Judgement dt 8th February, 2019 in Arb P 115/2018
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                                                 mind, once the Court is persuaded that it has
                                                jurisdiction to entertain a Section 11 petition all that is
                                                required to examine is as to whether or not an
                                                arbitration agreement exists between the parties which
                                                is relatable to the dispute at hand. The latter part of
                                                the exercise adverted to above, which involves
                                                correlating the dispute with the arbitration agreement
                                                obtaining between the parties, is an aspect which is
                                                implicitly embedded in sub-section (6A) of Section 11
                                                of the 1996 Act, which, otherwise, requires the Court
                                                to confine its examination only to the existence of the
                                                arbitration agreement. Therefore, if on a bare perusal
                                                of the agreement it is found that a particular dispute is
                                                not relatable to the arbitration agreement, then,
                                                perhaps, the Court may decline the relief sought for by
                                                a party in a Section 11 petition. However, if there is a
                                                contestation with regard to the issue as to whether the
                                                dispute falls within the realm of the arbitration
                                                agreement, then, the best course would be to allow the
                                                arbitrator to form a view in the matter.

                                                59.2 Thus, unless it is in a manner of speech, a chalk
                                                and cheese situation or a black and white situation
                                                without shades of grey, the concerned court hearing
                                                the Section 11 petition should follow the more
                                                conservative course of allowing parties to have their
                                                say before the arbitral tribunal."

                                       125. The nature and facet of non-arbitrability could also
                                       determine the level and nature of scrutiny by the court at the
                                       referral stage. Stravos Brekoulakis has differentiated between
                                       contractual aspects of arbitration agreement which the court
                                       can examine at referral stage and jurisdictional aspects of
                                       arbitration agreement which he feels should be left to the
                                       arbitral tribunal. John J. Barcelo III, referring to some
                                       American decisions had divided the issue of non-arbitrability
                                       into procedural and substantive objections. The procedurals
                                       are 'gateway questions' which would presumptively be for
                                       the arbitrator to decide at least at the first stage. In the Indian
                                       context, we would respectfully adopt the three categories
                                       in Boghara Polyfab Private Limited 22. The first category of
                                       issues, namely, whether the party has approached the

                            22
                                 National Insurance Co. Ltd v. Boghara Polyfab Pvt Ltd, (2009) 1 SCC 267
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                                   appropriate High Court, whether there is an arbitration
                                  agreement and whether the party who has applied for
                                  reference is party to such agreement would be subject to
                                  more thorough examination in comparison to the second and
                                  third categories/issues which are presumptively, save in
                                  exceptional cases, for the arbitrator to decide. In the first
                                  category, we would add and include the question or issue
                                  relating to whether the cause of action relates to action in
                                  personam or rem; whether the subject matter of the dispute
                                  affects third party rights, have erga omnes effect, requires
                                  centralized adjudication; whether the subject matter relates
                                  to inalienable sovereign and public interest functions of the
                                  State; and whether the subject matter of dispute is expressly
                                  or by necessary implication non-arbitrable as per mandatory
                                  statue(s). Such questions arise rarely and, when they arise,
                                  are on most occasions questions of law. On the other hand,
                                  issues relating to contract formation, existence, validity and
                                  non-arbitrability would be connected and intertwined with the
                                  issues underlying the merits of the respective disputes/claims.
                                  They would be factual and disputed and for the arbitral
                                  tribunal to decide. We would not like be too
                                  prescriptive, albeit observe that the court may for legitimate
                                  reasons, to prevent wastage of public and private resources,
                                  can exercise judicial discretion to conduct an intense yet
                                  summary prima facie review while remaining conscious that
                                  it is to assist the arbitration procedure and not usurp
                                  jurisdiction of the arbitral tribunal. Undertaking a detailed
                                  full review or a long-drawn review at the referral stage would
                                  obstruct and cause delay undermining the integrity and
                                  efficacy of arbitration as a dispute resolution mechanism.
                                  Conversely, if the court becomes too reluctant to intervene, it
                                  may undermine effectiveness of both the arbitration and the
                                  court. There are certain cases where the prima
                                  facie examination may require a deeper consideration. The
                                  court's challenge is to find the right amount of and the context
                                  when it would examine the prima facie case or exercise
                                  restraint. The legal order needs a right balance between
                                  avoiding arbitration obstructing tactics at referral stage and
                                  protecting parties from being forced to arbitrate when the
                                  matter is clearly non-arbitrable.

                                  126. Accordingly, when it appears that prima facie review
                                  would be inconclusive, or on consideration inadequate as it
                                  requires detailed examination, the matter should be left for
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                                        final determination by the arbitral tribunal selected by the
                                       parties by consent. The underlying rationale being not to
                                       delay or defer and to discourage parties from using referral
                                       proceeding as a rue to delay and obstruct. In such cases a full
                                       review by the courts at this stage would encroach on the
                                       jurisdiction of the arbitral tribunal and violate the legislative
                                       scheme allocating jurisdiction between the courts and the
                                       arbitral tribunal. Centralisation of litigation with the arbitral
                                       tribunal as the primary and first adjudicator is beneficent as it
                                       helps in quicker and efficient resolution of disputes.

                                       127. The Court would exercise discretion and refer the
                                       disputes to arbitration when it is satisfied that the contest
                                       requires the arbitral tribunal should first decide the disputes
                                       and rule on nonarbitrability. Similarly, discretion should be
                                       exercised when the party opposing arbitration is adopting
                                       delaying tactics and impairing the referral proceedings.
                                       Appropriate in this regard, are observations of the Supreme
                                       Court of Canada in Dell Computer Corporation v. Union des
                                       consommateurs and Olivier Dumoulin 23, which read:

                                                "85. If the challenge requires the production and
                                                review of factual evidence, the court should normally
                                                refer the case to arbitration, as arbitrators have, for
                                                this purpose, the same resources and expertise as
                                                courts. Where questions of mixed law and fact are
                                                concerned, the court hearing the referral application
                                                must refer the case to arbitration unless the questions
                                                of fact require only superficial consideration of the
                                                documentary evidence in the record.

                                                86.    Before departing from the general rule of
                                                referral, the court must be satisfied that the challenge
                                                to the arbitrator's jurisdiction is not a delaying tactic
                                                and that it will not unduly impair the conduct of the
                                                arbitration proceeding. This means that even when
                                                considering one of the exceptions, the court might
                                                decide that to allow the arbitrator to rule first on his
                                                or her competence would be best for the arbitration
                                                process."

                                                                  *****

                            23
                                 (2007) 2 SCR 801
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                                        130. As observed earlier, Patel Engineering Ltd. 24 explains
                                       and holds that Sections 8 and 11 are complementary in nature
                                       as both relate to reference to arbitration. Section 8 applies
                                       when judicial proceeding is pending and an application is
                                       filed for stay of judicial proceeding and for reference to
                                       arbitration. Amendments to Section 8 vide Act 3 of 2016 have
                                       not been omitted. Section 11 covers the situation where the
                                       parties approach a court for appointment of an
                                       arbitrator. Mayavati Trading Private Ltd. 25, in our humble
                                       opinion, rightly holds that Patel Engineering Ltd. has been
                                       legislatively overruled and hence would not apply even post
                                       omission of sub-section (6-A) to Section 11 of the Arbitration
                                       Act. Mayavati Trading Private Ltd. has elaborated upon the
                                       object and purposes and history of the amendment to Section
                                       11, with reference to sub-section (6-A) to elucidate that the
                                       Section, as originally enacted, was facsimile with Article 11
                                       of the UNCITRAL Model of law of arbitration on which the
                                       Arbitration Act was drafted and enacted. Referring to the
                                       legislative scheme of Section 11, different interpretations, and
                                       the Law Commission's Reports, it has been held that the
                                       omitted sub-section (6-A) to Section 11 of the Arbitration Act
                                       would continue to apply and guide the courts on its scope of
                                       jurisdiction at stage one, that is the pre-arbitration stage.
                                       Omission of sub-section (6-A) by Act 33 of 2019 was with
                                       the specific object and purpose and is relatable to by
                                       substitution of sub-sections (12), (13) and (14) to Section 11
                                       of the Arbitration Act by Act 33 of 2019, which, vide sub-
                                       section (3A) stipulates that the High Court and this court shall
                                       have the power to designate the arbitral institutions which
                                       have been so graded by the Council under Section 43-I,
                                       provided where a graded arbitral institution is not available,
                                       the concerned High Court shall maintain a panel of arbitrators
                                       for discharging the function and thereupon the High Court
                                       shall perform the duty of an arbitral institution for reference
                                       to the arbitral tribunal. Therefore, it would be wrong to accept
                                       that post omission of sub-section (6-A) to Section 11 the ratio
                                       in Patel Engineering Ltd. would become applicable.

                                       131. We now proceed to examine the question, whether the
                                       word 'existence' in Section 11 merely refers to contract

                            24
                                 S.B.P. Ltd v. Patel Engineering Corpn Ltd, (2005) 8 SCC 618
                            25
                                 Mayavati Trading Pvt Ltd v. Pradyuat Deb Burman, (2019) 8 SCC 714
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                                        formation (whether there is an arbitration agreement) and
                                       excludes the question of enforcement (validity) and therefore
                                       the latter falls outside the jurisdiction of the court at the
                                       referral stage. On jurisprudentially and textualism it is
                                       possible to differentiate between existence of an arbitration
                                       agreement and validity of an arbitration agreement. Such
                                       interpretation can draw support from the plain meaning of the
                                       word "existence'. However, it is equally possible,
                                       jurisprudentially and on contextualism, to hold that an
                                       agreement has no existence if it is not enforceable and not
                                       binding. Existence of an arbitration agreement presupposes a
                                       valid agreement which would be enforced by the court by
                                       relegating the parties to arbitration. Legalistic and plain
                                       meaning interpretation would be contrary to the contextual
                                       background including the definition clause and would result
                                       in unpalatable consequences. A reasonable and just
                                       interpretation of 'existence' requires understanding the
                                       context, the purpose and the relevant legal norms applicable
                                       for a binding and enforceable arbitration agreement. An
                                       agreement evidenced in writing has no meaning unless the
                                       parties can be compelled to adhere and abide by the terms. A
                                       party cannot sue and claim rights based on an unenforceable
                                       document. Thus, there are good reasons to hold that an
                                       arbitration agreement exists only when it is valid and legal. A
                                       void and unenforceable understanding is no agreement to do
                                       anything. Existence of an arbitration agreement means an
                                       arbitration agreement that meets and satisfies the statutory
                                       requirements of both the Arbitration Act and the Contract Act
                                       and when it is enforceable in law. We would proceed to
                                       elaborate and give further reasons:

                                                (i) In Garware Wall Ropes Ltd. 26, this Court had
                                                examined the question of stamp duty in an underlying
                                                contract with an arbitration clause and in the context
                                                had drawn a distinction between the first and second
                                                part of Section 7(2) of the Arbitration Act, albeit the
                                                observations made and quoted above with reference to
                                                'existence' and 'validity' of the arbitration agreement
                                                being apposite and extremely important, we would
                                                repeat the same by reproducing paragraph 29 thereof:



                            26
                                 Garware Wall Ropes Ltd. v. Coastal Marine Construction & Engineering Ltd, (2019) 9 SCC 209
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                                                          "29. This judgment in Hyundai Engg.
                                                         case 27 is important in that what was specifically
                                                         under consideration was an arbitration clause
                                                         which would get activated only if an insurer
                                                         admits or accepts liability. Since on facts it was
                                                         found that the insurer repudiated the claim,
                                                         though an arbitration clause did "exist", so to
                                                         speak, in the policy, it would not exist in law, as
                                                         was held in that judgment, when one important
                                                         fact is introduced, namely, that the insurer has
                                                         not admitted or accepted liability. Likewise, in
                                                         the facts of the present case, it is clear that the
                                                         arbitration clause that is contained in the sub-
                                                         contract would not "exist" as a matter of law
                                                         until the sub-contract is duly stamped, as has
                                                         been held by us above. The argument that
                                                         Section 11(6-A) deals with "existence", as
                                                         opposed to Section 8, Section 16 and Section
                                                         45, which deal with "validity" of an arbitration
                                                         agreement is answered by this Court's
                                                         understanding of the expression "existence"
                                                         in Hyundai Engg. case, as followed by us.";

                                                Existence and validity are intertwined, and arbitration
                                                agreement does not exist if it is illegal or does not
                                                satisfy mandatory legal requirements. Invalid
                                                agreement is no agreement.

                                                (ii)   The court at the reference stage exercises
                                                judicial powers. 'Examination', as an ordinary
                                                expression in common parlance, refers to an act of
                                                looking or considering something carefully in order to
                                                discover something (as per Cambridge Dictionary). It
                                                requires the person to inspect closely, to test the
                                                condition of, or to inquire into carefully (as per
                                                Merriam-Webster Dictionary). It would be rather odd
                                                for the court to hold and say that the arbitration
                                                agreement exists, though ex facie and manifestly the
                                                arbitration agreement is invalid in law and the dispute
                                                in question is non-arbitrable. The court is not
                                                powerless and would not act beyond jurisdiction, if it
                                                rejects an application for reference, when the

                            27
                                 United India Insurance Co. Ltd v. Hyundai Engineering & Construction Co. Ltd, (2018) 7 SCC 607
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                                         arbitration clause is admittedly or without doubt is
                                        with a minor, lunatic or the only claim seeks a probate
                                        of a Will.

                                        (iii) Most scholars and jurists accept and agree that
                                        the existence and validity of an arbitration agreement
                                        are the same. Even Starvos Brekoulakis accepts that
                                        validity, in terms of substantive and formal validity,
                                        are questions of contract and hence for the court to
                                        examine.

                                        (iv) Most jurisdictions accept and require prima
                                        facie review by the court on non-arbitrability aspects at
                                        the referral stage.

                                        (v)     Sections 8 and 11 of the Arbitration Act are
                                        complementary provisions as was held in Patel
                                        Engineering Ltd. The object and purpose behind the
                                        two provisions is identical to compel and force parties
                                        to abide by their contractual understanding. This being
                                        so, the two provisions should be read as laying down
                                        similar standard and not as laying down different and
                                        separate parameters. Section 11 does not prescribe any
                                        standard of judicial review by the court for
                                        determining whether an arbitration agreement is in
                                        existence. Section 8 states that the judicial review at
                                        the stage of reference is prima facie and not
                                        final. Prima facie standard equally applies when the
                                        power of judicial review is exercised by the court
                                        under Section 11 of the Arbitration Act. Therefore, we
                                        can read the mandate of valid arbitration agreement in
                                        Section 8 into mandate of Section 11, that is,
                                        'existence of an arbitration agreement'.

                                        (vi) Exercise of power of prima facie judicial review
                                        of existence as including validity is justified as a court
                                        is the first forum that examines and decides the request
                                        for the referral. Absolute "hands off" approach would
                                        be counterproductive and harm arbitration, as an
                                        alternative dispute resolution mechanism. Limited, yet
                                        effective intervention is acceptable as it does not
                                        obstruct but effectuates arbitration.


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                                                 (vii) Exercise of the limited prima facie review does
                                                not in any way interfere with the principle of
                                                competence-competence and separation as to obstruct
                                                arbitration proceedings but ensures that vexatious and
                                                frivolous matters get over at the initial stage.

                                                (viii) Exercise of prima facie power of judicial review
                                                as to the validity of the arbitration agreement would
                                                save costs and check harassment of objecting parties
                                                when there is clearly no justification and a good
                                                reason not to accept plea of non-arbitrability.
                                                In Subrata Roy Sahara v. Union of India 28, this Court
                                                has observed:

                                                      "191. The Indian judicial system is grossly
                                                      afflicted with frivolous litigation. Ways and
                                                      means need to be evolved to deter litigants from
                                                      their compulsive obsession towards senseless
                                                      and ill-considered claims. One needs to keep in
                                                      mind that in the process of litigation, there is an
                                                      innocent sufferer on the other side of every
                                                      irresponsible and senseless claim. He suffers
                                                      long-drawn anxious periods of nervousness and
                                                      restlessness, whilst the litigation is pending
                                                      without any fault on his part. He pays for the
                                                      litigation from out of his savings (or out of his
                                                      borrowings) worrying that the other side may
                                                      trick him into defeat for no fault of his. He
                                                      spends invaluable time briefing counsel and
                                                      preparing them for his claim. Time which he
                                                      should have spent at work, or with his family, is
                                                      lost, for no fault of his. Should a litigant not be
                                                      compensated for what he has lost for no fault?
                                                      The suggestion to the legislature is that a
                                                      litigant who has succeeded must be
                                                      compensated by the one who has lost. The
                                                      suggestion to the legislature is to formulate a
                                                      mechanism that anyone who initiates and
                                                      continues a litigation senselessly pays for the
                                                      same. It is suggested that the legislature should
                                                      consider the introduction of a "Code of
                                                      Compulsory Costs".

                            28
                                 (2014) 8 SCC 470
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                                              (ix) Even in Duro Felguera 29, Kurian Joseph, J., in
                                             paragraph 52, had referred to Section 7(5) and
                                             thereafter in paragraph 53 referred to a judgment of
                                             this Court in M.R. Engineers and Contractors Private
                                             Limited v. Som Datt Builders Limited 30 to observe
                                             that the analysis in the said case supports the final
                                             conclusion that the Memorandum of Understanding in
                                             the said case did not incorporate an arbitration clause.
                                             Thereafter, reference was specifically made to Patel
                                             Engineering Ltd. and Boghara Polyfab Private
                                             Limited to observe that the legislative policy is
                                             essential to minimise court's interference at the pre-
                                             arbitral stage and this was the intention of sub-section
                                             (6) to Section 11 of the Arbitration Act. Paragraph 48
                                             in Duro Felguera specifically states that the resolution
                                             has to exist in the arbitration agreement, and it is for
                                             the court to see if the agreement contains a clause
                                             which provides for arbitration of disputes which have
                                             arisen between the parties. Paragraph 59 is more
                                             restrictive and requires the court to see whether an
                                             arbitration agreement exists - nothing more, nothing
                                             less. Read with the other findings, it would be
                                             appropriate to read the two paragraphs as laying
                                             down the legal ratio that the court is required to see if
                                             the underlying contract contains an arbitration clause
                                             for arbitration of the disputes which have arisen
                                             between the parties - nothing more, nothing less.
                                             Reference to decisions in Patel Engineering
                                             Ltd. and Boghara Polyfab Private Limited was to
                                             highlight that at the reference stage, post the
                                             amendments vide Act 3 of 2016, the court would not go
                                             into and finally decide different aspects that were
                                             highlighted in the two decisions.

                                             (x)    In addition to Garware Wall Ropes Limited
                                             case, this Court in Narbheram Power and Steel
                                             Private Limited 31 and Hyundai Engg. & Construction
                                             Co. Ltd., both decisions of three Judges, has rejected
                                             the application for reference in the insurance contracts
                                             holding that the claim was beyond and not covered by
                            29
                               Duro Felguera S.A. v. Gangavaram Port Ltd, (2017) 9 SCC 729
                            30
                               (2009) 7 SCC 696
                            31
                               Oriental Insurance Co. Ltd v. Narbheram Power & Steel Pvt Ltd, (2018) 6 SCC 534
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                                               the arbitration agreement. The court felt that the legal
                                              position was beyond doubt as the scope of the
                                              arbitration clause was fully covered by the dictum
                                              in Vulcan Insurance Co. Ltd 32. Similarly, in PSA
                                              Mumbai Investments PTE. Limited 33, this Court at the
                                              referral stage came to the conclusion that the
                                              arbitration clause would not be applicable and govern
                                              the disputes. Accordingly, the reference to the arbitral
                                              tribunal was set aside leaving the respondent to pursue
                                              its claim before an appropriate forum.

                                              (xi) The interpretation appropriately balances the
                                              allocation of the decision-making authority between
                                              the court at the referral stage and the arbitrators'
                                              primary jurisdiction to decide disputes on merits. The
                                              court as the judicial forum of the first instance can
                                              exercise prima facie test jurisdiction to screen and
                                              knockdown ex facie meritless, frivolous and dishonest
                                              litigation. Limited jurisdiction of the courts ensures
                                              expeditious, alacritous and efficient disposal when
                                              required at the referral stage.

                                     132. Section 43(1) of the Arbitration Act states that the
                                     Limitation Act, 1963 shall apply to arbitrations as it applies to
                                     court proceedings. Sub-section (2) states that for the purposes
                                     of the Arbitration Act and Limitation Act, arbitration shall be
                                     deemed to have commenced on the date referred to in Section
                                     21. Limitation law is procedural and normally disputes, being
                                     factual, would be for the arbitrator to decide guided by the
                                     facts found and the law applicable. The court at the referral
                                     stage can interfere only when it is manifest that the claims
                                     are ex facie time barred and dead, or there is no subsisting
                                     dispute. All other cases should be referred to the arbitral
                                     tribunal for decision on merits. Similar would be the position
                                     in case of disputed 'no claim certificate' or defence on the
                                     plea of novation and 'accord and satisfaction'. As observed
                                     in Premium Nafta Products Ltd. 34, it is not to be expected
                                     that commercial men while entering transactions inter
                                     se would knowingly create a system which would require that
                                     the court should first decide whether the contract should be

                            32
                               Vulcan Insurance Co. Ltd v. Maharaj Singh, (1976) 1 SCC 943
                            33
                               PSA Mumbai Investments Pte Ltd v. Board of Trustees of the Jawaharlal Nehru Port Trust, Civil
                               Appeal No. 9352 of 2018, decided on 11th September, 2018
                            34
                               Filli Shipping Co. Ltd v. Premium Nafta Products Ltd, 2007 UKHL 40 : 2097 Bus LR 1719 (HL)
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                                   rectified or avoided or rescinded, as the case may be, and
                                  then if the contract is held to be valid, it would require the
                                  arbitrator to resolve the issues that have arisen.

                                                               *****

                                  136. Which approach as to interpretation of an arbitration
                                  agreement should be adopted in a particular case would
                                  depend upon various factors including the language, the
                                  parties, nature of relationship, the factual background in
                                  which the arbitration agreement was entered, etc. In case of
                                  pure commercial disputes, more appropriate principle of
                                  interpretation would be the one of liberal construction as
                                  there is a presumption in favour of one-stop adjudication.

                                  137. Accordingly, we hold that the expression 'existence of
                                  an arbitration agreement' in Section 11 of the Arbitration
                                  Act, would include aspect of validity of an arbitration
                                  agreement, albeit the court at the referral stage would apply
                                  the prima facie test on the basis of principles set out in this
                                  judgment. In cases of debatable and disputable facts, and
                                  good reasonable arguable case, etc., the court would force
                                  the parties to abide by the arbitration agreement as the
                                  arbitral tribunal has primary jurisdiction and authority to
                                  decide the disputes including the question of jurisdiction and
                                  non-arbitrability.

                                  138. Discussion under the heading               'Who   decides
                                  Arbitrability?' can be crystallized as under:

                                         (a)    Ratio of the decision in Patel Engineering
                                         Ltd. on the scope of judicial review by the court while
                                         deciding an application under Sections 8 or 11 of the
                                         Arbitration Act, post the amendments by Act 3 of 2016
                                         (with retrospective effect from 23.10.2015) and even
                                         post the amendments vide Act 33 of 2019 (with effect
                                         from 09.08.2019), is no longer applicable.

                                         (b)    Scope of judicial review and jurisdiction of the
                                         court under Section 8 and 11 of the Arbitration Act is
                                         identical but extremely limited and restricted.

                                         (c)     The general rule and principle, in view of the
                                         legislative mandate clear from Act 3 of 2016 and Act
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                                          33 of 2019, and the principle of severability and
                                         competence-competence, is that the arbitral tribunal is
                                         the preferred first authority to determine and decide
                                         all questions of non-arbitrability. The court has been
                                         conferred power of "second look" on aspects of
                                         nonarbitrability post the award in terms of sub-clauses
                                         (i), (ii) or (iv) of Section 34(2)(a) or sub-clause (i) of
                                         Section 34(2)(b) of the Arbitration Act.

                                         (d)     Rarely as a demurrer the court may interfere at
                                         the Section 8 or 11 stage when it is manifestly and ex
                                         facie certain that the arbitration agreement is
                                         nonexistent, invalid or the disputes are non-arbitrable,
                                         though the nature and facet of non-arbitrability would,
                                         to some extent, determine the level and nature of
                                         judicial scrutiny. The restricted and limited review is
                                         to check and protect parties from being forced to
                                         arbitrate when the matter is demonstrably 'non-
                                         arbitrable' and to cut off the deadwood. The court by
                                         default would refer the matter when contentions
                                         relating to non-arbitrability are plainly arguable;
                                         when consideration in summary proceedings would be
                                         insufficient and inconclusive; when facts are
                                         contested; when the party opposing arbitration adopts
                                         delaying tactics or impairs conduct of arbitration
                                         proceedings. This is not the stage for the court to enter
                                         into a mini trial or elaborate review so as to usurp the
                                         jurisdiction of the arbitral tribunal but to affirm and
                                         uphold integrity and efficacy of arbitration as an
                                         alternative dispute resolution mechanism."
                                                                             (Emphasis supplied)

                            31.   The import of the above passages from Vidya Drolia16 is clear
                            and unmistakable. Section 11(6A) of the 1996 Act has been held to
                            continue to apply, as a guiding principle to be followed by courts at
                            the referral stage, even after its omission. Even while holding that the
                            "arbitrability" of the dispute, along with the aspect of existence of an
                            arbitration agreement between the parties, could be examined, to a
                            limited extent, by the Court exercising jurisdiction under Section 8 or
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                             Section 11 of the 1996 Act, the Supreme Court has been circumspect,
                            many times over, in emphasising the limitations of the Court in this
                            regard. It has been made unmistakably clear that, in exercise of its
                            limited scope of authority, to examine the questions of existence of
                            the arbitration agreement and arbitrability of the dispute, at the
                            referral stage, the Court has to be careful not to usurp the jurisdiction
                            of the arbitral tribunal which, ideally, should examine these aspects.
                            The scope of examination by the referral court under Section 11(6),
                            into the aspects of existence of the arbitration agreement, or
                            arbitrability of the dispute, is, strictly, prima facie. In other words, it
                            is only if, prima facie, the Court finds that no valid arbitration
                            agreement exists, that it would refuse to refer the dispute to
                            arbitration. In undertaking this exercise, the Court should not get lost
                            in thickets, or enter into debatable factual issues. Unless there are
                            good and substantial reasons to the contrary, the Court is required to
                            compel the parties to abide by the arbitration agreement. It is only in
                            the case where the arbitration agreement is "ex facie non-existent or
                            invalid", or the dispute is ex facie non-arbitrable, that the court would
                            refuse to refer the dispute to arbitration. The intention is "to cut off
                            the deadwood and trim off the side branches in straightforward cases
                            where dismissal is barefaced and pellucid and when on the facts and
                            law the litigation must stop at the first stage", and to ensure that
                            "vexatious and frivolous matters get over at the initial stage". This
                            would also "save costs and check harassment of objecting parties
                            when there is clearly no justification and a good reason not to accept
                            the plea of non-arbitrability". "Senseless and ill-considered claims"
                            and "ex facie meritless, frivolous and dishonest litigation" were
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                             required to be weeded out, as, "on the other side of a very
                            irresponsible and senseless claim", there was an innocent sufferer.
                            Certainty, in the mind of the Court, that no valid arbitration agreement
                            exists or that the disputes/subject matter are not arbitrable, is the sine
                            qua non for rejection of the prayer for referring the dispute to
                            arbitration, whether made under Section 8 or Section 11. The scope
                            of examination at this stage is preliminary and summary and not in the
                            nature of a mini-trial.


                            32.   The Supreme Court also clarified that the "existence" of the
                            arbitral agreement also included, within its scope, the enforceability
                            thereof, as an unenforceable agreement could not be regarded as
                            "existing". As such, existence and validity were intertwined. An
                            arbitration agreement does not exist if it is illegal or does not satisfy
                            the mandate of the legal requirements. An invalid agreement is no
                            agreement.     "Existence" and "validity" were, to an extent, even
                            synonymous. Examples were cited, to clarify the position, as in the
                            case of an agreement with the minor, or a lunatic, or where the only
                            claim was for probate of a will.


                            33.   It has been made further clear that the dispute would be
                            regarded as "non-arbitrable", at the Section 8 or Section 11 stage, only
                            where the nature of the dispute is ex facie non-arbitrable, or where the
                            dispute does not relate to the arbitration agreement. The situation has
                            to be "chalk and cheese" or, alternatively, "black and white... without
                            shades of grey". In all other cases, the Section 11 court should follow
                            the more conservative course of allowing the parties to have their say
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                             before the arbitral tribunal. Cases where the dispute is, by law, ex
                            facie non-arbitrable, would, for example, be criminal cases, cases
                            involving exercise of sovereign power, cases which, by statutory fiat,
                            are required to be determined by courts, cases in which the cause of
                            action is in rem, or where the subject matter of the dispute affects
                            third parties or has erga omnes effect, requiring centralised
                            adjudication.    "On the other hand, issues relating to contract
                            formation, existence, validity and non-arbitrability ... would be factual
                            and disputed and for the arbitral tribunal to decide".        Questions
                            involving mixed issues of fact and law have to be left to the arbitral
                            tribunal.


                            34.   In order to underscore the limitations of the Section 8, or
                            Section 11 Court, in entering into debatable issues of existence of the
                            arbitration agreement or arbitrability, the Supreme Court has
                            emphasised the purpose behind conferring a limited jurisdiction, on
                            the referral court, to examine these aspects. The conferral of such
                            limited jurisdiction is intended "to prevent wastage of public and
                            private resources", and to protect parties from being forced to arbitrate
                            when the matter is clearly non-arbitrable. Where, however, prima
                            facie review appears to be inconclusive, or inadequate as it requires
                            detailed examination, the matter has to be left for determination by the
                            arbitral tribunal. Parties should not be allowed to use the referral
                            proceedings as a ruse to delay or obstruct resolution of the dispute.
                            Unjustified impairment of the referral proceedings should not be
                            permitted. Even in cases which may fall under one of the limited
                            categories where prima facie examination is permitted under Section
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                             8 or Section 11, the Court may, nevertheless, decide that allowing the
                            arbitrator to rule first on her, or his, competence would be best for the
                            arbitration process.


                            35.   This position was alternately exposited, by the Supreme Court,
                            as clarifying that the requirement of the court was "to see if the
                            underlying contract contains an arbitration clause for arbitration of the
                            disputes which have arisen between the parties - nothing more,
                            nothing less". The court was permitted to interfere at the referral
                            stage "only when it is manifest that the claims are ex facie time-barred
                            and dead, or there is no subsisting dispute", all other cases requiring to
                            be referred to the arbitral tribunal for decision on merits. The position
                            was summed up by holding that "in case of debatable and disputable
                            facts and good reasonable arguable case, etc., the court would force
                            the parties to abide by the arbitration agreement as the arbitral tribunal
                            has primary jurisdiction and authority to decide the disputes including
                            the question of jurisdiction and non-arbitrability".


                            36.   Significantly, the Supreme Court opined that, in the case of
                            pure commercial disputes, the more appropriate principle of
                            interpretation would be one of liberal construction, as there was a
                            presumption in favour of one-stop adjudication.


                            37.   On the aspect of examination of the arbitrability of the dispute
                            at the referral stage, the Supreme Court held that "the court by default
                            would refer the matter when contentions regarding to non-arbitrability
                            are plainly arguable; when consideration in summary proceedings
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                             would be insufficient and inclusive; when facts are contested; when
                            the party opposing arbitration adopts delaying tactics or impairs
                            conduct of arbitration proceedings", cautioning the court not to usurp
                            the jurisdiction of the arbitral tribunal, but to affirm and uphold the
                            integrity and efficacy of arbitration as an alternative dispute resolution
                            mechanism.


                            38.        Nearly two decades ago, an Hon'ble Single Judge of the
                            Supreme Court had, in Nimet Resources. Inc. v. Esaar Steel Ltd 35,
                            expressed much the same view, by holding that "in a matter where
                            there has been some transaction between the parties and the existence
                            of the arbitration agreement is in challenge, the proper course for the
                            parties is to thrash out such question under Section 16 of the Act and
                            not under Section 11 of the Act".


                            39.        Nimet Resources16, I may note, was subsequently followed by
                            the Supreme Court in Unissi1, which was also a case in which the
                            formal contract was signed by one of the parties, on which Mr.
                            Viswanathan placed reliance. Unissi1 also involved a case in which
                            the contract had not been signed by both parties. Even so, in para 19
                            of the report, the Supreme Court concluded thus:
                                       "Therefore, considering the above aspects of the matter in this
                                       case, we must come to this conclusion that no formal
                                       agreement was executed, the tender documents indicating
                                       certain conditions of contract contained an arbitration clause.
                                       It is also an admitted position that the appellant gave his
                                       tender offer which was accepted and the appellant acted on it.
                                       Accordingly, we are of the view that the learned Additional
                                       District Judge, Chandigarh erred in holding that there did not

                            35
                                 (2000) 7 SCC 497
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                                   exist any arbitration agreement between the parties and,
                                  therefore, the order passed by him is liable to be set aside."


                            40.   Can the objection, of Mr. Karia, be regarded as so impressive,
                            as to reject the prayer for referring the disputes to arbitration, applying
                            the standards prescribed in Vidya Drolia16 ? I think not. In my view,
                            all the issues raised by Mr. Karia, in opposition to the case set up by
                            the petitioner for reference of dispute to arbitration, stand answered by
                            the aforesaid decisions.


                            41.   Unquestionably, the parties - including the respondent - have
                            acted in accordance with the covenants of the GCC. As has been
                            correctly pointed out by Mr. Viswanathan, consequent to issuing of
                            the letters of award, the respondent called upon the petitioner to
                            perform in accordance with the said letters. In these circumstances, it
                            would be appropriate for the issue of the existence of the arbitration
                            agreement to be examined, not by this Court under Section 11(6), but
                            by the Arbitral Tribunal under Section 16 of the 1996 Act.


                            42.   Nevertheless, given the opposition put up by Mr. Karia to the
                            very issue of existence of an arbitration agreement, the matter may be
                            examined in somewhat greater detail.


                            43.   For this purpose, it would be appropriate to proceed
                            sequentially, through the various agreements and communications, in
                            the present case.


                            44.   The NIT was brought out by the respondent on 5th July, 2018.
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                             Clause 3.2.A.1.2 required the bidder to propose the name of a Float
                            Technology Provider, for supply of floats for use in the project.
                            Clause 3.2.A.4 set out the criteria to be fulfilled by a bidder who
                            sought to engage the services of a Float Technology Provider as sub-
                            contractor.   Sub-clause (vi) therein required the sub-contractor to
                            submit a Performance Bank Guarantee (hereinafter referred to as
                            PBG), equivalent to 5% of the value of work sub-let to it. This was in
                            addition to the PBG for the entire contract, to be submitted by the
                            bidder, i.e., in the present case, the petitioner. Clause 4 required the
                            work to be completed within 10 years of Notice of Award/Letter of
                            Award.


                            45.    The covenants of the ITB were, to a large extent, overlapping
                            with those of the NIT. Clause 3.2.A.1.2 of the ITB replicated the
                            corresponding clause in the NIT. The requirement of an Integrity Pact
                            is to be found in Clause 3.7 of the ITB, which required the bidder to
                            submit an Integrity Pact, duly signed, as per Clause 33 of the ITB.
                            The format of the Integrity Pact was contained in Annexure 2 to the
                            ITB.


                            46.    Clause 27 of the ITB set out the "Award Criteria". Clause
                            27.1(b) stipulated that the mode of contracting, with the successful
                            bidder, would be as per the relevant clauses of the GCC/SCC. Three
                            contracts were to be executed, the first for supply of plant, equipment
                            and materials, the second for providing services and the third for
                            comprehensive operation and maintenance after commissioning of the
                            project. Clause 29 dealt with notification of the award, and sub-clause
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                             29.1 thereunder required the employer, i.e. the respondent to notify the
                            successful bidder regarding acceptance of its bid prior to the expiry of
                            the bid validity period. The said clause went on to state in clear and
                            categorical terms, that "the notification of award (would) constitute
                            the formation of the contract and (would) be considered for all
                            purposes of execution of contract provisions till such time the signing
                            of the Contract Agreement". There can be, therefore, no manner of
                            doubt that the contract between the parties cannot be said to have
                            come into existence only when the Contract Agreement between them
                            was signed, but that a contractual relationship commenced from the
                            date of notification of award by the respondent, i.e. from the date of
                            issuance of the three LOAs in the present case.


                            47.   Clause 30 of the ITB required the employer to prepare a
                            Contract Agreement. The second part of the said Clause required the
                            employer and the bidder, i.e. the petitioner and the respondent, to sign
                            the Contract Agreement within 14 days of receipt of notice of
                            readiness of the Contract Agreement. I may note that there is no other
                            reference, either in the NIT or in the ITB of the "notice of readiness"
                            of the "Contract Agreement".


                            48.   Clause 31 of the ITB required the bidder to furnish performance
                            security, as per Clause 13.3 of the GCC, within 28 days of receipt of
                            notification of award.   Clause 31.2 provided that, in the event of
                            failure, by the bidder, to comply with Clause 30 or Clause 31.1, the
                            employer i.e. the respondent could annul the award and forfeit the bid
                            security. According to Mr. Karia, this has already happened in the
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                             present case, vide letter dated 2nd March, 2020 addressed to the
                            petitioner.


                            49.   Clause 32 dealt with corrupt, fraudulent, collusive or coercive
                            practices by the bidder. "Corrupt practice" was defined in Clause
                            32.1(a)(i) as meaning "the offering, giving, receiving or soliciting,
                            directly or indirectly of anything of value to influence the action of a
                            public official in the procurement process or in contract execution".
                            Clause 32.1(b) envisaged the signing of an Integrity Pact between the
                            prospective bidder and the employer, binding both parties not to
                            exercise any corrupt influence on any aspect of the tender/contract.
                            Clause 32.1(e) dealt with banning of business dealings, and
                            enumerated the various circumstances in which business dealings
                            could be banned. These were if
                                  (i)     any question of loyalty of the bidder to NHPC arose,
                                  (ii)    the director, owner, proprietor or partner of the bidder
                                  firm was convicted by a court of law, for offences, involving
                                  moral turpitude, during the last five years,
                                  (iii)   the bidder resorted to corrupt, fraudulent, collusive or
                                  coercive practices, including misrepresentation of facts and
                                  violation of any of the provisions of the Integrity Pact,
                                  (iv)    the bidder used intimidation/threatening or exercised
                                  undue outside pressure on NHPC, for obtaining the contract,
                                  (v)     the bidder misused the premises or facilities of the
                                  respondent,
                                  (vi)    the bidder did not fulfil the obligations as required under
                                  the contract, and violated its terms and conditions, which
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                                   seriously affected the continuation of the contract,
                                  (vii) the work was terminated by the respondent due to poor
                                  performance of the contract in the preceding five years,
                                  (viii) banning of business dealings were recommended by any
                                  Central Government Investigating Agency or
                                  (ix)   continuation of business dealings with the bidder was not
                                  in the public interest or
                                  (x)    business dealings with the bidder have been banned by
                                  the Ministry of Power or any PSU or authority under the
                                  Ministry of Power.


                            50.   Clause 33 specifically dealt with the Integrity Pact, which was
                            required to be signed by the prospective bidder, as well as by
                            respondent, and proscribed exercise of any corrupt, fraudulent,
                            collusive or coercive practice by the prospective bidder in the
                            tendering process and during implementation of the contract.
                            Execution of the Integrity Pact was a qualifying requirement for
                            participating in the bidding process.


                            51.   The specifics of the Integrity Pact were to be found in
                            Annexure-2 to the ITB. Clause 3.0 set out the various commitments of
                            the bidder/contractor under the Integrity Pact, and also stands
                            reproduced hereinabove. Any breach of the said provisions by the
                            bidder entitled the employer, i.e. NHPC, to take action as per the
                            "Guidelines of Banning of Business Dealings", and initiate any or all
                            of the eight courses of action contemplated by the various sub-clauses
                            under Clause 6.1 of the Integrity Pact.
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                             52.   Annexure-2A to the ITB contained the "Guidelines on Banning
                            of Business Dealings". Clauses 4.0 and 5.0 dealt with suspension of
                            business dealings and the procedure to be followed in respect thereof,
                            and Clauses 6.0 and 7.0 dealt with banning business dealings. Clause
                            7.4 contemplated issuance of a Show Cause Notice. The Annexures to
                            the NIT were in six volumes, of which (i) Volume 0 contained
                            instructions to bidders (ITB), (ii) Volume-1 contained information to
                            bidder (IFB), (iii) Volume-2 contained the conditions of contract, of
                            which Part-A contained the General Conditions of Contract (GCC)
                            and Part-B contained the Special Conditions of Contract (SCC), (iv)
                            Volume-3    contained    the   employer's      requirement    (Technical
                            requirement) and (v) Volume-4 contained Technical Data Sheets and
                            (vi) Volume-5 contained Forms & Procedures.


                            53.   In the present case, the recital of facts hereinabove indicate,
                            prima facie, that the respondent has proceeded in accordance with this
                            procedure, by first suspending the business dealings with the
                            petitioner, thereafter, banning business dealings and, thereafter,
                            issuing the Show Cause Notice.


                            54.   The GCC and the SCC constituted volume 2A and 2B to NIT.
                            The notes on the GCC read thus:
                                  "Notes on the General Conditions of Contract

                                  The General Conditions of Contract in Volume 2A, read in
                                  conjunction with the Special Conditions of Contract in
                                  Volume 2B and other documents listed therein, is a complete
                                  document expressing all the rights and obligations of the
                                  parties."
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                             55.   Volume-2 to the Annexure to the NIT, as already noted
                            hereinabove, contained the conditions of contract, of which Part-A
                            contained the GCC and SCC.


                            56.   It is not necessary to go into the various clauses of the GCC.
                            Suffice it to state that Clause 6.3 provided for arbitration as the mode
                            of resolution of dispute between the parties.


                            57.   Vide letter dated 30th November, 2018, the respondent informed
                            the petitioner that its bid had been found techno-commercially
                            responsive treating Y2G as the sub-contractor under Clause 3.2.A.1.2
                            of the NIT/ITB. Thereafter, the auction took place and the petitioner
                            emerged as the successful bidder. After several extensions of the
                            period of validity of the bid of the petitioner, the respondent issued
                            three LOAs, on 20th September, 2019, to the petitioner, in accordance
                            with Clause 27 of the ITB, which contemplated the execution of three
                            contracts.


                            58.   Para 2.0 of each of the said LOAs, dated 20th September, 2019,
                            clearly stated that the respondent accepted the petitioner's proposal
                            and awarded the petitioner the contract for the work. Para 3.0 of each
                            of the said Letters of Award made cross-reference to the award, to the
                            petitioner, of the other two contracts and went on to caution the
                            petitioner that the "breach of any one contract (would) automatically
                            be construed as breach of other contracts", resulting in a right, to
                            NHPC, to recover liquidated damages under Clause 26.2 of the GCC
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                             or terminate the other contracts. Para 5.0 confirmed the selection of
                            Y2G as the sub-contractor for providing float device technology and
                            required the sub-contractor to submit PBG equivalent to 5% of the
                            value of work sub-let to it. Para 6.0 of the LOAs called upon the
                            petitioner to prepare and finalise the contract documents for filing of
                            the formal contract document, within 28 days from the LoA - which
                            is, alternatively, referred to as "notification of the award".


                            59.   Prima facie, by virtue of Clause 29.1 of the ITB, with the
                            communications of the aforesaid three LOAs/notification of award to
                            the petitioner, a contract had come into being between the petitioner
                            and the respondent, which would continue to remain in force till the
                            formal contract agreements were signed.


                            60.   On 13th November, 2019, the respondent called upon the
                            petitioner to sign the Contract Agreement by 15th November, 2019.
                            Thereafter, vide letter dated 20th November, 2019, the petitioner was
                            requested to sign the Contract Agreement on or before 30th November,
                            2019, with the further stipulation that no further extension for signing
                            of the Contract Agreement, beyond 30th November, 2019, would be
                            granted.


                            61.   Thereafter, vide communication dated 2nd March, 2020, the
                            respondent cancelled the award of work to the petitioner on the ground
                            that (i) the petitioner had not submitted bank guarantee equivalent to
                            5% of the value of work sub-let to Y2G, along with joint deed of
                            undertaking from Y2G, (ii) the Integrity Pact, between the petitioner
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                             and Y2G had not been signed, (iii) the petitioner had not signed
                            formal Contract Agreement with the respondent within the extended
                            time therefor.


                            62.   It is in the backdrop of these facts, that I am required to
                            examine whether a clear case for holding that no arbitration agreement
                            existed between the parties, as there was no concluded Contract
                            Agreement between them, save and except for the Integrity Pact, as
                            Mr. Tejas Karia would seek to contend, exists, so as to non-suit the
                            petitioner entirely, or whether this issue ought to be left for decision
                            by an Arbitral Tribunal, to be constituted by this Court.


                            63.   The first contention of Mr. Karia is that the invocation, by the
                            petitioner, of Clause 6.3 of the GCC, was unjustified in law, as the
                            only concluded agreement between the parties was the Integrity Pact.
                            The judgements cited hereinabove make it clear that the mere non-
                            signing of the contract by both parties does not conclude the issue,
                            especially where there are other correspondences and transactions
                            between them, or the parties have acted on the basis of the covenants
                            of the unsigned contract. Unissi1 appears to have dealt with a similar
                            situation, and the attempt of Mr Karia to distinguish the said decision
                            on the basis of some facts which may not obtain in the present case
                            may be open to debate, especially in the light of the observations
                            contained in para 19 of the report in the said case, already reproduced
                            hereinbefore. The fact that the Integrity Pact is essentially in the
                            nature of an Annexure to the Bid Documents, may also be relevant.
                            Another consideration, to which Mr. Viswanathan has correctly
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                             alluded, is that an arbitration agreement exists independent of the main
                            contract, and the unenforceability of the main contract, even if
                            presumed, does not invalidate, or render unenforceable, the arbitration
                            agreement. Besides, the effect of Clause 29.1 of the ITB also merits
                            examination.


                            64.   In response to the submission, of Mr. Viswanathan, that, by
                            virtue of Clause 29.1 of the ITB, a contractual relationship, between
                            the petitioner and the respondent, was in existence consequent to the
                            issuance of the LOAs dated 20th September, 2019, even before signing
                            of the formal contract agreement, Mr. Karia sought to submit that the
                            respondent had withdrawn the LOAs, vide communication dated 2nd
                            March, 2020. Mr. Viswanathan contested, inter alia, the legality of
                            such annulment. The letter dated 2nd March, 2020 cites, as a
                            justification for the decision to annul the LOAs, (i) failure, on the part
                            of the petitioner, to submit the Performance Bank Guarantee @ 5%
                            from Y2G, for the value of work sublet, along with Joint Deed of
                            Undertaking, as well as the Integrity Pact signed by Y2G and (ii)
                            failure, on the part of the petitioner, to sign the Contract Agreement
                            within the extended time provided by the respondent. Annulment of
                            the LOAs is contemplated by Clause 31.2 of the ITB. (It may require
                            consideration whether, having invoked Clause 31.2 of the ITB, it is
                            open to the respondent to contend that the only contractual document,
                            signed between the parties, having effect in law, was the Integrity
                            Act.) Clause 31.2 permits annulment of the LOAs on failure, of the
                            bidder, to comply with Clause 30 or Clause 31.1 of the ITB. Clause
                            31.1 envisages furnishing, by the bidder, of performance security as
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                             per Clause 13.3 of the GCC.        (Here, again, it becomes arguable
                            whether the respondent can, on the one hand, allege infraction of
                            Clause 31.1 of the ITB and, simultaneously, contend that the GCC was
                            not enforceable.)       Clause 13.3 of the GCC does not envisage
                            furnishing of any bank guarantee by the subcontractor.         It merits
                            consideration, therefore, whether non-furnishing of the 5% bank
                            guarantee by Y2G can be treated as constituting non-compliance with
                            Clause 31.1 of the ITB. Similarly, Clause 30 of the ITB undoubtedly
                            envisages signing of the Contract Agreement within 14 days of receipt
                            of notice of readiness by the employer, i.e. by the respondent. Mr.
                            Viswanathan has disputed the mandatory nature of the said 14-day
                            period, once the respondent had itself extended the period. As to
                            whether the said 14-day period is, therefore, of the essence of the
                            contractual relationship between the petitioner and respondent also,
                            therefore, becomes arguable. In sum, the legality of the decision, of
                            the respondent, to annul the LOAs, is open to debate.                The
                            justifiability of the reliance, by the respondent, on the said
                            "annulment", vide the communication dated 2nd March, 2020 is also,
                            therefore, debatable.


                            65.   Issues relating to formation of the contract, as well as its
                            existence and validity have, expressly, been held, in Vidya Drolia16,
                            to, ideally, merit resolution by the arbitral process, rather than by the
                            referral Court, especially where the contract is commercial in nature.


                            66.   Mr. Karia next contended that the actions against the petitioner
                            had been taken under the Integrity Pact, and not under the main
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                             contract.   This, in my view, is highly contestable.        There is no
                            reference to the Integrity Pact, in the letter, dated 2nd March 2020,
                            proposing to annul the LOAs, the communication dated 9th March,
                            2020, informing the petitioner that it had been decided to ban business
                            dealings with it, or the Show Cause Notice dated 19th June, 2020. Nor
                            do the allegations, contained in these communications, prima facie,
                            relate to any of the commitments of the petitioner, under the Integrity
                            Pact, or allege, directly or indirectly, collusion, corruption, or any
                            other such misfeasance. The submission of Mr. Viswanathan, that the
                            respondent has sought to piggyback on the Integrity Pact, only in its
                            response to the present petition of the petitioner, so as to defeat the
                            petition also, therefore, merits consideration. It cannot be said that the
                            material on record unequivocally discloses that the communications
                            from the respondents to the petitioner, with which the petitioner is
                            aggrieved, have been issued under the Integrity Pact.


                            67.   The objection to territorial jurisdiction being also premised on
                            the contention that, apart from the Integrity Pact, there was no
                            concluded contract between the petitioner and the respondent, I am not
                            convinced that the present petition can be dismissed as incompetent
                            before this Court.


                            68.   Mr. Karia also sought to invoke Section 7 of the Contract Act,
                            in juxtaposition with his contention that the petitioner had failed to
                            comply with the requirements of the LOAs.            This contention is,
                            however, premised on the assumption that the LOAs constituted offers
                            and that, sans any unconditional acceptance of these offers, no
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                             contract came into being. Mr. Viswanathan contends, per contra, that
                            the very issuance of the LOAs indicated acceptance of the petitioner's
                            bids, in terms of the Bid Documents, which included the GCC - for
                            which purpose reliance is placed on Clause 6.1 of the ITB. This,
                            again, is an arguable issue, which ought, appropriately, to be examined
                            by the Arbitral Tribunal.


                            69.   All other questions on which the petitioner and respondent have
                            joined issue, clearly, are amenable to resolution by the arbitral
                            process, given the overarching jurisdiction of the Arbitral Tribunal
                            under the provisions of the 1996 Act, including, inter alia, Section 16.
                            I do not deem it necessary or appropriate to deal with all the
                            submissions, here. I am, nevertheless, constrained to hold that Mr.
                            Karia has not been able to make out a case either of clear non-
                            existence of the arbitration agreement, contained in Clause 6.3 of the
                            GCC, within the Vidya Drolia16 parameters. The issue is, at the very
                            least, arguable, and, especially given the fact that it relates to purely
                            commercial contracts, ought, in my view, to be agitated before the
                            learned Arbitral Tribunal which, in its kompetenz-kompetenz
                            jurisdiction, is well within its authority to pronounce on the existence
                            of the arbitration agreement as well.


                            70.   The prayer for referring of the disputes to arbitration, as
                            contained in Arb. P. 217/2020, therefore, deserves to succeed.




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                             Conclusion


                            71.      Accordingly, Arb. P. 217/2020 is allowed.        The disputes
                            between the petitioner and respondent are referred for arbitration to
                            the Delhi International Arbitration Centre. The Delhi International
                            Arbitration Centre would proceed in the matter in accordance with the
                            various subclauses of Clause 6.3 of the General Conditions of
                            Contract and in accordance with the DIAC (Arbitration Proceedings)
                            Rules, 2018. The DIAC would appoint a suitable sole arbitrator to
                            arbitrate on the disputes, out of the panel maintained by it or as
                            otherwise agreed between the parties.


                            72.      The learned arbitrator, appointed by the DIAC, would proceed
                            with the matter uninfluenced by the observations contained in this
                            judgement, which are only intended to address the objections, of Mr
                            Karia, regarding the very maintainability of the present proceedings,
                            especially regarding the existence, or otherwise, of the arbitration
                            agreement. On all aspects, including the existence of the arbitration
                            agreement as well as the arbitrability of the dispute, therefore, the
                            learned arbitrator would be free to take a view, unencumbered by this
                            judgement or the opinions expressed therein, which are merely prima
                            facie.


                            73.      OMP (I) (Comm) 162/2020 is disposed of, by allowing the
                            petitioner to prefer the said petition before the Arbitral Tribunal to be
                            constituted by the DIAC, as an application under Section 17 of the

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                             1996 Act, to be decided by the Arbitral Tribunal in accordance with
                            law.


                            74.    There shall be no orders as to costs.




                                                                           C. HARI SHANKAR, J.

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