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Trf Ltd. vs Energo Engineering Projects Ltd. & Anr. on 17 February, 2017

It is thus necessary that there be an "express" agreement in writing. This agreement must be an agreement by which both parties, with full knowledge of the fact that Shri Khan is ineligible to be appointed as an arbitrator, still go ahead and say that they have full faith and confidence in him to continue as such. The facts of the present case disclose no such express agreement. The appointment letter which is relied upon by the High Court as indicating an express agreement on the facts of the case is dated 17-1-2017. On this date, the Managing Director of the appellant was certainly not aware that Shri Khan could not be appointed by him as Section 12(5) read with the Seventh Schedule only went to the invalidity of the appointment of the Managing Director himself as an arbitrator. Shri Khan's invalid appointment only became clear after the declaration of the law by the Supreme Court in TRF Ltd. [TRF Ltd. v. Energo Engg. Projects Ltd., (2017) 8 SCC 377 : (2017) 4 SCC (Civ) 72] which, as we have seen hereinabove, was only on 3-7-2017.

Bharat Broadband Network Limited vs United Telecoms Limited on 16 April, 2019

23. We are unable to agree that the decision in Bharat Broadband Network Limited v. United Telecoms Limited (supra) can be distinguished on the aforesaid ground. The said decision had authoritatively held that in terms of the proviso of Section 12(5) of the A&C Act, the ineligibility of an arbitrator under Section 12(5) of the A&C Act could be waived only by an express agreement in writing and cannot be inferred by the conduct of the parties. Thus, the fact that the parties had participated before the arbitral tribunal cannot be construed as a waiver of their rights to object to the ineligibility of the arbitrator(s). We are unable to accept that while such a right could be exercised prior to the delivery of the award, it would cease thereafter. If the arbitrator is ineligible to act as an arbitrator, the arbitral award rendered by the arbitral tribunal would be without jurisdiction."
Supreme Court of India Cites 30 - Cited by 440 - R F Nariman - Full Document

Perkins Eastman Architects Dpc vs Hscc (India) Limited on 26 November, 2019

18. Per contra, counsel for the Respondents strenuously urged that it is not open to the Petitioner to raise a plea that there was no waiver to the applicability of Section 12(5) and/or the appointment was in contravention of the judgment of the Supreme Court in Perkins (supra), allegedly being a unilateral appointment. The objection qua appointment of the sole Arbitrator was raised by the Petitioner at the initial stage, but was consciously withdrawn during the hearing on 09.11.2020, wherein counsel for the Petitioner had specifically stated that the objection be dismissed as not pressed. The statement was duly recorded in the order sheet dated 09.11.2020 and the objection was dismissed as withdrawn. It is on account of this concession that the sole Arbitrator proceeded with the matter directing the Respondent to file the Statement of Claim and thereafter the Statement of Defence. Even after 09.11.2020, Petitioner participated in the proceedings, albeit selectively, but no objection was raised thereafter to the appointment nor was any recourse taken to a legal remedy seeking termination of the mandate. Having taken a calculated chance, the plea of unilateral appointment is not available to the Petitioner, after conclusion of the proceedings and their culmination in arbitral Awards.
Supreme Court of India Cites 33 - Cited by 1034 - U U Lalit - Full Document
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