NATURAL JUSTICE AND ARBITRAL PROCEEDING: A COMMENT ON SECTION

18: A LIMITAION ON ARBITRAL AUTONOMY UNDER ARBITRATION AND

CONCILIATION ACT, 1996.

DATE: 1ST SEPTEMBER, 2015

SUBJECT: LAW OF ARBITRATION AND ADR

NATIONAL LAW UNIVERSITY, JODHPUR

SUBMITTED BY: SUBMITTED TO:

DEEPA MOONDRA (909) MS. AAKANKSHA

KUMAR SEMESTER IX NLU

– JODHPUR

Word length

The text of this paper (excluding footnotes) comprises approximately 4,280 words.

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ACKNOWLEDGEMENT

I would like to express my deepest gratitude and sincerest thanks to Ms. Aakanksha Kumar for

giving me the opportunity to go ahead with this project. She has constantly encouraged and

guided me in the compilation and completion of this project.

I would also like to thank the entire library staff for providing me with the various sources of

information that I utilized during the course of my project, thereby helping me in completing this

endeavor successfully.

Lastly, I would thank all the people who cooperated with me in the preparation and presentation

of this project.

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RESEARCH METHODOLOGY

The research methodology adopted for the purpose of this project is the doctrinal method of

research. The various library and Internet facilities available at National Law University, Jodhpur

have been utilized for this purpose. Most of the information is, however, from the Internet.

SCOPE OF THE PROJECT

The obligation to treat parties with equality requires the arbitral tribunal to apply similar

standards to all parties and their representatives throughout the arbitral process. Commenting and

analysing this statement with various Judgment of courts and interpretation given by them.

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TABLE OF CONTENTS

1. Introduction………………………………………………………………………….……5

2. Comment on Section 18 of Arbitration and Conciliation Act…………………………….6

Arbitral Tribunal's Duty to Treat the Parties with Equality……………………….7

Arbitral Tribunal's duty to give each party a full opportunity to present his case...9

3. Cases dealing with section 18 of the Arbitration and conciliation act……………...……10

1. Union of India vs. Bharath Builders & Contractors…………………………10

2. Rishi Electricals (P) Ltd. Vs. H.P. State Electricity Board………………….12

3. Viraj Holdings Vs. Motilal Oswal Securities Pvt. Ltd. and Ors…………….13

4. Impex Corporation and Ors. Vs. Elenjikal Aquamarine Exports Ltd……….14

4. Conclusion……………………………………………………………………………….15

5. Bibliography……………………………………………………………………………..16

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INTRODUCTION:

Arbitration is becoming more popular tool to resolve dispute between two parties privately by an

independent party. Being an alternate dispute resolution mechanism and possibly a less-time

consuming one, most agreements in India contained clauses for resolution of disputes by the

method of arbitration. Arbitration is becoming more popular because of increase in cross-border

transactions that are feature of globalization.

In India, there is no particular statute, laying down the minimum standard, which the judicial or

quasi judicial bodies must follow while exercising their decision making powers. The legitimacy

and integrity of any system that adjudicates the right and duties of persons would be evaluated by

reference to the standards required by the principles of natural justice. The principles

of natural justice have been developed by the courts, in order to secure fairness in judicial

functions as it form a substantial part of law and apply wherever administrative decision is

involved1. The doctrine of natural justice pervades the procedural law of arbitration as its

observance is the pragmatic requirement of fair play in action. The doctrine of natural justice

seeks not only to secure justice but also to prevent miscarriage of justice2.

Under arbitration parties autonomy to agree upon their own terms or conduct of arbitration, but

the same cannot be done by infringing the provision of equal treatment of parties. Parties under

the agreement can impose unfair procedural terms and conditions and same can lead to unfair

treatment, so it becomes duty of arbitrators or courts to maintain basic attributes of the institution

of arbitration. If the technical rules which relates to equality of parties such as presenting the case,

notice of hearings, cross –examination, information regarding the material being presented are not

followed or are restricted by the party agreement ,such agreements are void and have no validity.

This restriction is widely accepted. The New York Convention3 and UNICITRAL4also recognise

it as a mandatory provision which should not be derogated5.

1 Pullé, Austin I., Securing Natural Justice in Arbitration Proceedings, Asia Pacific Law Review.2Rustam Singh Thakur., Arbitral Proceedings and Principles of Natural Justice, SSRN Electronic Journal, 2011.3 New York Convention Article V (1) (b).4 Model Law, Article 18.5 Asst. Prof. Pallavi Bajpai., Limitations of Party Autonomy in International Regime of Arbitration, journal lawmantra, 2015.

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Under Arbitration and Conciliation Act, 1996 Section 18 defines obligations on the arbitral

tribunal, i.e., to treat the parties with equality and to give full opportunity to each party to present

his case. The section caste duty on arbitral tribunal not to act arbitrarily since an action based on

arbitrariness negation of equality. Further it belongs to the family of mandatory provisions of the

Act.

COMMENT ON SECTION 18 OF ARBITRATION AND CONCILIATION ACT, 1996:

SECTION 18 EQUAL TREATMENT TO PARTIES: parties shall be treated with equality and each

party shall be given a full opportunity to present its case.

Parties are to be treated with equality and each party to be given an opportunity to present his

case. This section, embodying the principle that “justice should not only be done but should

appear to have been done”, imposes to fold duty on the arbitral tribunal:

The arbitral tribunal shall give equal treatment to each party to the reference.

The arbitral tribunal shall give to each party to the reference full opportunity to present its

case.

The Arbitration tribunal is body being a quasi-judicial authority and hence we can say that the

judges should not be appointed as arbitrators6. In India, all judicial as well as administrative

authorities are required to follow the principles of natural justice in the proceedings7. The

principle of natural justice, enshrined in the legal culture of all mature legal system, may be said

to be grundnorms of any system of adjudication forming part of a legal system based on the rule

of law.

The Arbitral Tribunal should treat the parties equally and each party should be given full

opportunity to present his case8. In State Bank of Patiala Vs SK Sharma9 the Supreme Court

stated that it would not be correct to say that for any and every violation of a facet of Natural

Justice or of a rule incorporating such facet, the order passed is altogether void and ought to be

set aside without further enquiry. The Arbitral Tribunal is required to comply with the rules of

6 R.S. Bachawat, Law of Arbitration and Conciliation, Nagpur, Wadhwa & Co. 1999, p. 414.7 Indu Ramchandra Bharwani v. UOI (1988) 4 SCC 1.8 The Arbitration and Conciliation Act, 1996. Section 18.9 1996 (3)SCC 346,387.

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Natural Justice as enshrined in Section18, which will cover all the necessary procedural

requirements. In the case of Moti Lal Vs State of Himachal Pradesh10, it was held that the

arbitrator has the power to administer oath to the parties and the witnesses before recording their

evidences.

Further in case of D.C. Saxena v. State of Haryana11, it was held by the court that if the statute is

silent on the matter, the natural justice principle has to be followed. The principles which

constitute the essential norms of Arbitration, they are as follow:

Nemo judex in causa sua, i.e. no man can be a judge in his own cause.

No party shall be condemned unheard. Each party should be given an opportunity to

represent his case and cross- examines others.

Each party is entitled to know the reasons for the decisions.

The person who hears the case must decide finally. If in the matter principles of natural

justice are violated while deciding the case then that award shall be deemed to be passed

without jurisdiction and hence award shall be annulled.

It was held by Supreme Court in International Airports Authority of India v. K.D. Bali12, there

must be purity in the administration of justice as well as in administration of quasi justice as are

involved in the adjudicatory process before the arbitrators. Once the arbitrators enter the arbitral

reference he ceases to be an arbitrator only of the party who appointed him. He must not be

guilty of any act which possibly be construed as indicative of partiality or unfairness on his part.

The purity of administration requires that the party to the tribunal proceedings should not have

apprehension that the authority is biased and is likely to decide against the party.

Arbitral Tribunal's Duty to Treat the Parties with Equality

The first principle is that the arbitrator must act fairly to both parties, and in the proceedings

throughout the reference he must not favour one party more than another, or do anything for one

party which he does not do or offer to do for the other. He must observe in this the ordinary well-

understood rules for the administration of justice13.

10 AIR 1996 HP 90; State of Haryana Vs JK Jain AIR 1989 P& H 24.11 AIR 1987 SC 1463.12 AIR 1988 SC 1099.13 Russell, 19th Edn., (1979), p. 225.

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Equality before Arbitration Where the parties entered into an agreement to refer their matter

before the Arbitration and they have created their own rule to apply thereon even though they are

required to be treated equally otherwise there will be no justice at all. Thus in the Arbitration

proceedings there should be bias less conduct on the part of the arbitrator and if the biasness of

the arbitrator is proved then the appointment as well as award be annulled.

The Supreme Court correctly held that it was important to ensure that no doubts were cast on the

neutrality, impartially and independence of the arbitral tribunal. Before arriving at the reasoned

conclusion, the Supreme Court referred to notable commentators14 and applied their view that

qualification, experience and integrity should be the criteria for appointment of an arbitrator.

Therefore, in the Indian scenario the CJI has been vested with a wide discretion to appoint an

arbitrator in an ICA, taking into consideration all necessary factors which would preserve the

integrity of the arbitration, and in essence, would not lead to any possibility of bias at a later

date.

The arbitrators are masters of their own procedure and subject to parties’ agreement, may

conduct the proceedings ‘in the manner they consider appropriate’. This power includes the

power to determine the admissibility, relevance, materiality and weight of any evidence15.The

only restraint on them is that they shall treat the parties with equality and each party shall be

given a full opportunity to present his case16, which includes sufficient advance notice of any

hearing or meeting17.

It is the duty of the arbitral tribunal to act fairly to both the parties as such; the arbitral tribunal

must not hear one party in the absence of the other. The tribunal does however have power in the

absence of a party and for a hearing to take place even if one of the parties is not present, or for

the case to proceed in the absence of submissions, evidence or indeed any case at all from one of

the parties. Before proceeding in this way, a tribunal should ensure that the non-attending party

has been given due notice of the hearing18 but if proceedings are between arbitral board and one

party only then the other party need not be given the notice.

14 Redfern and Hunter on International Arbitration, Fifth Edition (2009), at. 263.15 Section 19(3) and (4) of Arbitration and Conciliation Act, 1996.16 Section 18 of Arbitration and Conciliation Act, 1996.17 Section 24(2) of Arbitration and Conciliation Act, 1996.18 Schumacher t/a Vita Konzern v. Laurel Island Ltd. (“The Santa Cruz Tres”) (1995) I Lloyd’s Rep, 208.

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In Husein Ebrahim v. Kesardeo Kanaria & Co19., the arbitrators asked for certain information

from a third person without any reference to the parties and the arbitrators also did not disclose

the letter which they wrote to the third person, to the parties. It was held that the arbitrators were

guilty of misconduct.

Russel observed in 'Russel on Arbitration20: "Not every meeting between an arbitrator and one

party alone will amount to misconduct or invalidate the award: there must be a substantial

suggestion of injustice".

In Vengamma v. Kesanna21, an arbitrator examined the defendant in the absence of the plaintiff,

who was the widow of the testator. The Will was also considered by the arbitrator without giving

an opportunity to the plaintiff to have her say in the matter. It was held that the arbitrator was

guilty of legal misconduct, which was sufficient to vitiate the award.

Arbitral Tribunal's duty to give each party a full opportunity to present his case

The section mandates the arbitral tribunal to give full opportunity to each party to present his

case. Section 34(2) (a) (ii) of the Act provides that where a party was not given proper notice of

the arbitral proceedings or was otherwise unable to present his case in the arbitral proceedings,

the resulting award is to be annulled. The objective of these two sections i.e., sections 18 and

34(2)(a)(ii) is to ensure that the arbitrator must act impartially and give full opportunity to the

parties by giving them proper notice and every possible opportunity to present their respective

case and thereby to ensure a fair trial by an impartial tribunal22.

The parties who are to be directly affected by the proceedings or the award must be given

adequate notice of the appointment of the arbitrator, subject-matter of the dispute, time and

venue of the proceedings. It is the duty of the arbitrator to inform the parties to the proceedings

in writing about the particulars of the reference. A party has the right to be present throughout

the arbitral proceedings and the tribunal has no right to exclude one party at any stage of the

arbitral proceedings unless he consents, or does not wish to attend the proceedings throughout23.

19 AIR 1954 Cal 111.20 19th Edn., (1979), p. 228.21 AIR 1953 SC 21.22Arbitration and ADR-Chapter V-Conduct of Arbitral Proceedings (Manupatra)23Id.

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The requirement that each party shall be given a full opportunity to present his case, applies

equally both to the presentation of evidence as well as argument24. He is required to comply with

the directions of the tribunal in regard to the conduct of the proceedings and the admissibility and

relevancy of the evidence.25 In case of non- compliance i.e. if a party was not given proper notice

of the arbitral proceeding or otherwise failed to present the case before arbitral tribunal, then the

resulting award to be annulled when challenged for the violation of Section 18 of the Arbitration

and Conciliation Act,1996.

CASES DEALING WITH SECTION 18 OF THE ARBITRATION AND CONCILIATION ACT:

1. UNION OF INDIA VS. BHARATH BUILDERS & CONTRACTORS26

The respondent/contractor was awarded the contract work, construction of an AED Hangar at

INS Garuda, Naval Base, for a sum of Rs. 1,42,58,880. While the contract work was in progress

with nearly 86% of such work completed, the AED Hangar constructed collapsed down on

27.03.1992. Rehabilitation work was carried out by the same contractor/respondent without

entering into any fresh contract, and, later, the work was completed within the extended period

by 30.09.1999. After completion of the work, the respondent, who is hereinafter referred to as

the claimant, raised various claims over the execution of the work and sought for resolving the

disputes by reference to the arbitration as provided under the agreement. The claimant, seeking a

number of reliefs over the work executed filed the writ petition and the directions issued by this

court in the writ petition, a sole arbitrator (D.K. Sharma, Engineer-in-Chief, Army Head

Quarters, New Delhi) was appointed invoking arbitration Clause of contract. Award passed by

the arbitrator was challenged by the appellant before the court below mainly on grounds under

Section 34(2)(a)(iv) and under Section 34(2)(b)(ii) of the Act27.

Expert agency chosen for analysis and study of design of collapsed hangar was in fact the one

proposed by the Union of India themselves. Non-supply of copy of the expert's report to Union

of India cannot be considered as denial of opportunity as alleged. The arbitrator, perhaps, was

totally oblivious of the conduct of procedure for arbitration proceedings covered by the Act.

24 Maneka Gandhi v. Union of India, AIR 1978 SC 597.25 Subsection (3) and (4) of Section 19 of Arbitration and Conciliation Act, 1996.26 Union of India Vs. Bharath Builders & Contractors 2012 (4) ARBLR 448(Kerala).(Bharath Case)27 Bharath Case.Para1.

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Section 18 of the Act mandates that not only the party shall be treated with equality but each of

them shall be given full opportunity to present its case. The aforesaid section reads thus: Equal

treatment of parties--The party shall be treated with equality and each party shall be given a full

opportunity to present his case.

It is not only impartiality and absence of bias from the part of the arbitrator that is postulated in

the aforesaid section, but an inviolable binding obligation to conduct a fair trial in the arbitration

proceedings. Fair trial requires something more than treating the parties with equality. It

contemplates of providing each party reasonable opportunity to present his case also. A party to

the proceedings must know what the evidence that has been given is and he must also be given

an opportunity to show why it is not to be used against him28.

In any view of the matter, the non-supply of a copy of the report of expert to the appellant and

also denying it an opportunity to examine that expert amounted to denial of equal opportunity to

present its case. The arbitral award is liable to be set aside if arbitral procedure followed by the

arbitrator was not in consonance with the provisions under Part I of the Act. Section 34(2)(a)(v)

of the Act reads thus: (v) the composition of the arbitral tribunal or the arbitral procedure was not

in accordance with the agreement of the parties, unless such agreement was in conflict with a

provision of this Part from which the parties cannot derogate, or, failing such agreement, was not

in accordance with this Part29.

Parties to the arbitral proceedings in the present case have not agreed to a different procedure

than what is contemplated under Part I of the Act. Where the arbitrator has followed a procedure

conflicting and violating the mandatory prescriptions in the conducting of the proceedings under

Sections 18, 24(3) and 26(2) of the Act it is a clear case that the award passed by him in

derogation of the provisions of Part I of the Act is vitiated and liable to be set aside30. Hence,

Award challenged in the appeal is declared void and it is set aside; and the case is remitted for

determination of the claims of both parties through arbitration afresh in accordance with law.

2. RISHI ELECTRICALS (P) LTD. VS. H.P. STATE ELECTRICITY BOARD31

28 Bharath Case para 10.29 Bharath Case Para 14.30 Bharath Case Para14.31 Rishi Electricals (P) Ltd. Vs. H.P. State Electricity Board 2006 (2) Shim LC 270.(Rishi Case)

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The respondent/Board issued a notice inviting tenders for supply of Galvanized Steel wires. The

objector submitted his tender which was accepted and purchase order was issued to it on

9.6.1995. Disputes arose between the Board and the objector and in terms of the arbitration

agreement the dispute was referred to arbitration. Initially Shri R.P. Goel, Chief Engineer

(Projects) was appointed as the sole Arbitrator but later on he was replaced by Shri O.C.

Kaushal, who was the then Chief Engineer (Hydro Planning) of the respondent / Board. The

Arbitral Tribunal announced its award on 23.10.200232.

One of the contentions in the present case was that the Arbitrator did not act fairly in accordance

with Section 18 of the Act which states: Equal treatment of parties.-The parties shall be treated

with equality and each party shall be given a full opportunity to present his case33. This Section

provides that the Arbitrator should treat both the parties equally and should give them equal

opportunities. In the present case, it was the Board which was the claimant. There was no issue

the onus of which was on the claimant. On 9.6.1995 the objector, who was the defendant before

the Arbitrator, concluded his evidence. Thereafter, request was made on behalf of the Board that

they want to produce a witness in rebuttal to prove statement RA-1. This was objected to but the

Arbitrator allowed the claimant Board to examine a witness to prove this document. No error can

be found with this portion of the order of the Arbitrator. However, thereafter on the next hearing

when the Board examined Shri M.R. Sharma to prove the statement the Counsel for the objector

requested that in view of the fact that an additional opportunity had been given to the claimant

and new document has been placed on record, the supplier may also be granted a date to lead

further evidence to counter the statement RA-1. This was not accepted34.

No doubt, an Arbitrator can evolve his own procedure and is not bound by the provisions of the

Civil Procedure Code or the strict rules of evidence. However, rules of natural justice must be

held to be part and parcel of the Public Policy of India. If after closure of the evidence of the

defendant he could permit the claimant to examine another witness on a very material issue it

would have been much fairer on his part to have permitted the supplier to lead such evidence as

32 Rishi Case .Para 2.33 Rishi Case .Para 7.34 Rishi Case .Para 8.

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the supplier wanted to lead. He did not treat the parties equally inasmuch as he did not give an

opportunity to the objector to rebut the evidence of the Board35.

Hence, the award of the Arbitral Tribunal is set aside. Since the award is being set aside on

procedural grounds, the claimant may apply for appointment of fresh Arbitrator who shall decide

the matter afresh.

3. VIRAJ HOLDINGS VS. MOTILAL OSWAL SECURITIES PVT. LTD. AND ORS36.

The petitioner Viraj Holdings challenges the arbitral award dated 18-1-2000 made by the

Arbitrator at the National Stock Exchange. By the award, the learned Arbitrator has held that

respondent No. 1 M/s. Motilal Oswal Securities Pvt. Ltd. is entitled to receive a sum of Rs.

21,66,489.7337.

One of the contention urged by the learned counsel for the petitioner is that since the

respondent's written submissions dated 1-11-1999 were not handed over to the petitioner in

advance, there is a breach of Section 18 of the Act which reads as follows:- Equal treatment of

parties.-The parties shall be treated with equality and each party shall be given a full opportunity

to present his case38.

Firstly, written submissions are not incorporated as part of any procedural law governing either

the functioning of Courts or Arbitrators. They are often required by Arbitrator or submitted by

the parties voluntarily for the sake of convenience. Merely because a written submission is not

served in advance on the other side, it would not be possible to infer that there is denial of equal

treatment to the parties who are required to be given a full opportunity to present their case.

Moreover, Section 18 requires the Arbitrator to treat the party with equality. If one party does not

submit its written submission to the other party in advance, it could hardly be said to be a lapse

on the part of the Arbitrator. There is, therefore, no merit in the contention that Section 18 of the

35 Rishi Case Para 9.36 Viraj Holdings Vs. Motilal Oswal Securities Pvt. Ltd. and Ors [2003] 115CompCas 102(Bom) (Viraj Holdings Case)37 Viraj Holdings Case.Para1.38Viraj Holdings Case.para16.

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Act has been violated and, therefore, the award is liable to be set aside under Section 34(2) (a)

(v). As observed earlier, no principles of equality in the matter of procedure has been violated39.

4. IMPEX CORPORATION AND ORS. VS. ELENJIKAL AQUAMARINE EXPORTS LTD40.

Appellants were Respondents in arbitration proceedings. They challenged the arbitral award on

the ground that there is no arbitration agreement, that the arbitrator was not properly appointed

and that the award was passed in violation of principles of natural justice. All the contentions

were repelled by the District Court and appeal was taken. Division Bench of the High Court set

aside the arbitral award for violation of principles of natural justice and appointed new arbitrator.

Allowing the appeal, the court41;

Though arbitrator is not bound by technical rules of procedure, he cannot ignore basic principles

of natural justice. Thread of natural justice should run through the entire arbitration proceedings

and the principles of natural justice require that sufficient notice of posting shall be given to both

sides and equal opportunities shall be given to both sides to prosecute the case and that the

arbitral tribunal is not bound by technical rules of Code of Civil Procedure. Even if Appellants

were absent on 12-11-1999 and the matter was adjourned to 20-12-1999, Appellants ought to

have been allowed to participate in that proceedings. In fact notice of posting on 20-12-1999 was

issued to them for that purpose. But admittedly, there was no sitting on 20-12-1999 and matter

was adjourned to 3-1-2000 without any notice. On the facts of the case, no proper and sufficient

notice was given to Appellants by arbitrator before they were declared ex parte or thereafter.

Even the copy of the claim was forwarded to the Appellant only after he was declared ex parte.

No notice at all was given for the posting on 3-1-2000. The date of posting was not intimated

when the case was adjourned from 20-12-1999 as there was no sitting on that date which was the

only date informed to the Appellant42. Hence there is violation of principles of natural justice and

these are violation of Sections 18 and 25. Here impugned arbitration award is liable to be set

aside under Section 34 (2) (iii). Accordingly we set aside the award only for violation of

principles of natural justice and not on merit.

39 Viraj Holdings Case.para 16.40 Impex Corporation and Ors. Vs. Elenjikal Aquamarine Exports Ltd AIR 2008 Ker 119(Impex case).41 Impex case. Headnote.42 Impex case.Para.4.

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CONCLUSION:

Under section 18 of the Arbitration and Conciliation Act, 1996 which lays down the fundamental

requirements for arbitral tribunal for procedural justice:

1. Equal treatment of parties; and

2. Full opportunity to present one’s case.

This provision is mandatory in nature and due to which it has been consistently upheld by courts

as being so foundational that parties cannot derogate from them.

The arbitral tribunal cannot ignore principles of natural justice in arbitral proceedings this sets an

limitation to arbitral autonomy. They are required to act fair, impartial, in good faith and in

judicial temper giving opportunity to each party to present his case and proving that the evidence

and document produced by the other party against him does not prove him guilty. He should also

be allowed to adequately state his case and correcting and contradicting any relevant statement

prejudicial to his case. So arbitral tribunal is not allowed to hear one side behind the back of the

other to reach the end of justice. If the award is passed ignoring this provision the same can be

challenged and will be declared annulled due to violation of section 18 read with section 34 of

the Arbitration and Conciliation Act.

If ay statutory provision being violative of the principles of natural justice should be struck down

as being bad in law and unconstitutional. The modification can be done by opting an option for

referring to the court of law or other arbitrational institution or bodies consisting of unbiased

judge and arbitrators.

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BIBLIOGRAPHY:

PRIMARY SOURCE

1. Arbitration and conciliation Act, 1996.

2. UNCITRAL Model Law on International Commercial Arbitration, 1985.

BOOKS

1. Bachawat, Justice R.S., Justice R.S. Bachawat’s Law of Arbitration &Concoliation,

LexisNexis ButterworthsWadhwa Nagpur, 5th ed. (2010).

2. Malhotra, O.P., The Law and Practice of Arbitration and Conciliation, LexisNexis

Butterworths, 1st ed., 2002.

3. Basu, N.D., Law of Arbitration and Conciliation, Orient Publishing Company, 10thed.

2003.

ARTICLES

1. Agrwal Anurag K., Party Autonomy in International Commercial Arbitration, W.P. No.

2007-05-06.

2. Jamshed Ansari., Party Autonomy in Arbitration: A Critical Analysis, Asstt. Professor

(Guest Faculty), Faculty of Law, University of Delhi, Delhi (INDIA)

3. Daniel Brady., Review of Arbitral Awards for Breach of Natural Justice: An

Internationalist Approach, Victoria University of Wellington, 2013.

4. Manupatra: Arbitration and ADR-Chapter V-Conduct of Arbitral Proceedings.

5. Rustam Singh Thakur., Arbitral Proceedings and Principles of Natural Justice, SSRN

Electronic Journal, 2011.

INTERNET SOURCES/LEGAL WEBSITES

1. www.legalsutra.org

2. www.jstore

3. www.manupatra.com .

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