In Meenambakkam Realty Private Limited v. Airports Authority of India (O.M.P.(MISC.)(COMM.) 864/2026, decided 6 November 2026), Justice Om Prakash Shukla of the High Court of Delhi extended the mandate of a three-member arbitral tribunal by eight weeks under Section 29A of the Arbitration and Conciliation Act, 1996. The proceedings had concluded and the matter stood reserved for award since May 2026; the tribunal’s office had indicated that the award needed a little more time. The respondent raised no objection, and the court also regularised any intervening period between expiry and extension.
The case in one view
| Case | Meenambakkam Realty Pvt. Ltd. v. Airports Authority of India, O.M.P.(MISC.)(COMM.) 864/2026 |
|---|---|
| Court | High Court of Delhi, Om Prakash Shukla J |
| Decided | 6 November 2026 |
| Provision | Section 29A, Arbitration and Conciliation Act, 1996 |
| Tribunal | Three former judges, with the matter reserved for award since 28 May 2026 |
| Outcome | Mandate extended by eight weeks from the order; intervening period regularised |
The application
The petitioner sought a further eight-week extension of the mandate of an arbitral tribunal comprising three former judges of the superior courts. The arbitration itself was at the very last stage: by a procedural order of 28 May 2026, the matter had been reserved for pronouncement of the award. In October 2026, a communication from the presiding arbitrator’s office indicated that the award required more time. Rather than let the mandate run out with the award unpronounced, the petitioner moved the court; the respondent’s counsel accepted notice and stated there was no objection.
From the order (para 5): “the mandate of the learned Arbitral Tribunal is extended for a further period of 8 weeks from today” — with any intervening period also regularised.
Section 29A in brief
Section 29A disciplines domestic arbitration with a statutory clock: twelve months from completion of pleadings, a further six by consent, and thereafter only court-sanctioned time. The provision was designed against the old culture of arbitrations that meandered for years; its cost is that even a well-run arbitration needs a court visit if the award cannot be delivered within the consented period. The courts’ working approach distinguishes between extensions sought to continue dragging proceedings and extensions sought to let a completed proceeding reach its natural end. This case sat firmly in the second category — everything was done except the pronouncement.
Practical sequence for parties
The takeaway
For commercial parties arbitrating in Delhi, this order is a clean illustration of Section 29A working as intended: a short, consent-based extension, granted in a two-page order, protecting months of completed hearings from a technical lapse. The discipline of the provision remains real — but where the only step left is pronouncement, the courts’ door is open, and the sensible course for both sides is to walk through it together.
Frequently Asked Questions
What is the Section 29A timeline for domestic awards?
The award in a domestic arbitration must be made within twelve months of completion of pleadings, extendable by six months with the parties' consent. Beyond that, the mandate continues only if a court extends it — on an application made before or after expiry — for sufficient cause and on such terms as the court imposes.
Is an extension easier when the award is already reserved?
As a practical matter, yes. Where hearings are over and only the pronouncement remains, refusing an extension would waste the entire proceeding and force a restart. In this case the court noted that the proceedings had concluded, the award was reserved, and both parties agreed — the extension of eight weeks followed without controversy.
What does "regularising the intervening period" mean?
Where the mandate lapses before the extension application is decided, acts done by the tribunal in the gap could be questioned. A direction regularising the intervening period protects the proceedings from that technical attack, treating the mandate as continuous through to the extended date.
Who can apply for the extension?
Either party may apply under Section 29A to the court. In practice, as here, the party interested in the award moves promptly once the tribunal signals that more time is needed, and a consent position between the parties makes the hearing short.