ALTERNATIVE DISPUTE RESOLUTION THE SOCIAL MECHANISM AIDING INDIAN JUDICIARY By - Ramashankar Dashrath Singh

ALTERNATIVE DISPUTE RESOLUTION
THE SOCIAL MECHANISM AIDING INDIAN JUDICIARY
 
Authored  By - Ramashankar Dashrath Singh
Address - House No. 901, Viju Sheth Building,
Sai Colony, Kon-Gaon, Kalyan-Bhiwandi Road.
Bhiwandi, Thane, Maharashtra - 421311
Mobile No.  - +91-8976534543
 
ABSTRACT
The conventional system of justice delivery is deeply flawed; as a result of which there is a backlog of pending cases in the Indian Courts. The judicial infrastructure is inadequate and is on the verge of a collapse. It was imperative that an alternate innovative mechanism be provided to cater to the needs of the society. Settlement of disputes through reference to a third party is a part of the volksgeist of India since times immemorial. A unique system of Alternative Dispute Resolution (hereafter referred to as ADR) was introduced. India has put in place a progressive piece of legislation which is essentially based on the Model Law and the UNCITRAL Arbitration Rules. But how will the various forms of ADR help in reducing the burden of the judiciary? Should we resort to ADR? Has this mechanism proved to be effective and has the Legislature made any reforms in this aspect? These are some of the key issues discussed in this Article along with Origin, Issues & Need of ADR in India with respect to Judicial precedents & Legislative bodies regulating ADR. The Article will also focus on benefits & contemporary challenges and the future of ADRS in India & at the International level. There are some Suggestions for improving mechanisms of Indian Judiciary & ADRS so that the ultimate purpose of both the bodies shall be achieved i.e., to secure the ends of justice.
 
KEYWORDS: Judiciary; ADR; IDRC; IIArb; IIMed; IIDR; Arbitration; Mediation; Conciliation; Negotiation; Lok Adalat; Volksgeist; Justice.
 
INTRODUCTION:
Justice is the foundation and the focus of every civilized society. The quest for justice was an ideal that the human race aspired to down the line for decades. Dispute resolution is one of the Indian judiciary’s major functions and is essential to a stable society. The Government of India operates through various organs and the judiciary is directly responsible for the administration of justice. The judiciary of India is a system of courts that interpret and apply the law in the Republic of India. India uses a common law system, first introduced by the British East India Company and with influence from other colonial powers and Indian princely states, as well as practices from ancient and medieval times. The constitution provides for a single unified judiciary in India.
As we all know there are a few methods available for two parties to resolve disputes. The first and most common approach is to resolve disputes through courts when a dispute occurs between two individuals belonging to the same government, there is the same sense for the dispute to be resolved by the parties through the courts set up by that country’s law. Our conventional judicial system has become outdated and there has also been a need for another structure to sustain our judicial system as a replacement or alternative for settling disputes between peoples. With the rising development of the nation the burden falls over the judiciary. Our judicial system has some drawbacks, such as an overburdened court, time-consuming, requiring a costly technical process with a low population ratio of judges, and unfilled vacancies with long procedural and pendency of cases. India has the largest number of pending court cases in the world. Many judges and government officials have said that the pendency of cases is the biggest challenge before the Indian judiciary. According to a 2018 Niti Aayog strategy paper, at the then-prevailing rate of disposal of cases in our courts, it would take more than 324 years to clear the backlog. With the cases taking time in courts, it leads to delays in the delivery of justice for both victims and accused. Pendency of court cases in India is the delay in the disposal of cases (lawsuits) to provide justice to the aggrieved person or organization by judicial courts at all levels. In 2022, the total number of pending cases of all types and at all levels rose to around 50 million or 5 crores, including over 1,69,000 court cases pending for more than 30 years in District and High Courts. 4.3 crore out of 5 crores cases, i.e., more than 85% cases are pending in District Courts as of December 2022.
 
 
DATA OF PENDING CASES - INDIAN COURTS:
 
PARTICULARS
 
 
CIVIL
 
CRIMINAL
 
TOTAL
 
0 to 01 Years
 
 
2936708 (26.74%)
 
8292158 (25.74%)
 
11228866 (26%)
 
01 to 03 Years
 
 
2870582 (26.14%)
 
8209173 (25.48%)
 
11079755 (25.65%)
 
03 to 05 Years
 
 
2242201 (20.42%)
 
6289063 (19.52%)
 
8531264 (19.75%)
 
05 to 10 Years
 
 
2066413 (18.82%)
 
6109117 (18.96%)
 
8175530 (18.93%)
 
10 to 20 Years
 
 
710713 (6.47%)
 
2792354 (8.67%)
 
3503067 (8.11%)
 
20 to 30 Years
 
 
118172 (1.3%)
 
442753 (1.3%)
 
560925 (1.3%)
 
Above  30 Years
 
 
36151 (0.33%)
 
79504 (0.25%)
 
115655 (0.27%)
 
Total
 
 
10980940
 
32214122
 
43195062
 
Source of table: Data of Pending Cases from National Judicial Data Grid[1]
Even in this 21st century there is a lack of required law for establishing social norms and peace. Our judiciary system should give scope to such alternative methods. To fasten the process of resolution, Alternative Dispute Resolution System (ADRS) plays an evolutionary role. With the advent of the idea of Conflict Management via ADR, a new, less adversarial method of settling legal disputes has become available. Legally speaking, a lawsuit is a “lis inter partes,” however the Indian legal system has developed an alternative to adversarial litigation known as the ADR Mechanism. As the saying goes, “The spirit of the law, not its letter, is what gives life to justice.”Lord Justice Earl Warren.
 
ALTERNATIVE DISPUTE RESOLUTION SYSTEM:
Alternative Dispute Resolution which includes various methods of settling a dispute without getting into the intricacies of the court. It is a method where parties try to resolve their disputes privately in front of a third-person expert. The decision is binding on the parties like the decision of the court. The ADR system works on the principles of justice, legal aid and speedy trial as given under Article 39A of the Indian Constitution. Even Section 89 of the Code of Civil Procedure, 1908 provides settling disputes by way of ADR. The proceedings are flexible and creative. It provides satisfying solutions with reduced cost and time and thus, is an emerging field in Law. The article deals with an act on arbitration and conciliation known as Arbitration and Conciliation Act, 1996. The parties to a disagreement can save time and money by using ADR techniques including mediation and arbitration. These processes also have the added benefit of allowing the people involved to lessen their animosity toward one another, reclaim some measure of control over the situation, come to terms with the decision, settle the dispute amicably, and improve their sense of fairness. Disputes are best settled in private settings, where they can be handled in a way that is more practical, cost-effective, and efficient. There are few distinct forms of Alternative Dispute Resolution (ADR): Arbitration, Conciliation, Mediation, Negotiation and The Lok Adalat.
HISTORY OF ALTERNATIVE DISPUTE RESOLUTION:
Third-party settlement of disputes is a part of ancient Indian ethos and culture. However, the settlement of disputes through the institution of the judiciary is a little over a century old and is a result of British rule in India. Despite the long history of the settlement of disputes by alternative means in our country, the first statutory recognition given to domestic arbitration was given by way of the Indian Arbitration Act, 1940.
Retired law professor of Osmania University, Dr. V. Nageswara Rao presented an overview of conciliation proceedings under the Arbitration and Conciliation Act,1996 before the Law Commission of India. He stated that the settlement of disputes through reference to a third party has been part of the “volksgeist” or body of customs of India for time immemorial. There are basically two types of arbitration proceedings which are conducted. Domestic Arbitration proceedings which are conducted between two Indians & International Commercial Arbitration proceedings which are conducted between the parties, where at least one of the parties is an individual who is a national of, or habitually resident in, any country other than India or a company, or an association, or a body of individuals whose central management and control is exercised in any country other than India or the government of a foreign country. The Arbitration and Conciliation Act, 1996, was passed followed by the UNCITRAL Model in order to encourage the establishment of Arbitration, Conciliation and other alternative dispute resolution.
OVERVIEW & KEY HIGHLIGHTS OF THE INDIAN ARBITRATION ACT, 1940:
The Indian Arbitration Act, 1940[2] dealt solely with the previously uncodified body of law concerning domestic arbitration proceedings. The objective of the 1940 act was to consolidate and amend the law relating to arbitration.
?       It gave wide discretionary and supervisory powers to the courts allowing them to regularly intervene in arbitration proceedings.
?       It also severely limited the freedom of the parties to choose their preferred means of settlement by imposing a number of regulations.
?       Section 3 of the 1940 Act, imposes certain implied terms and conditions that were required to be present in any arbitration agreement unless those terms were specifically contracted away.
?       The 1940 Act, also grants wide power to the court in matters of appointment or removal of arbitrators and allows the court to modify or remit the award and also pass interim orders.
From the above highlights, it is clear that the arbitral tribunal constituted under the 1940 Act had no real powers but rather acted as a proxy for the court.
THE ARBITRATION & CONCILIATION ACT, 1996:
The Arbitration & Conciliation Act, 1996[3] repeals the Arbitration Act, 1940; The Arbitration (Protocol and Convention) Act, 1937[4]; and The Foreign Awards (Recognition and Enforcement) Act, 1961[5] and reformulates the law in one consolidated statute. It also seeks to amend and consolidate the law relating to domestic arbitration, international arbitration and the enforcement of foreign arbitral awards.
 
 
The Arbitration & Conciliation Act, 1996 is divided into three parts as:-
?       Part I of the act is a reproduction of the Model Law which deals with rules regarding practice and procedure before the arbitral tribunal.
?       Part II deals with the recognition and enforcement of foreign awards. Part II is divided into two chapters.
?     Chapter I concerns award made pursuant to agreements under the New York Convention.
?     Chapter II deals with the enforcement of foreign awards under the Geneva Convention.
?       Part III deals with conciliation proceedings.
UNCITRAL MODEL LAW:
UNCITRAL stands for United Nations Commission on International Trade Law. It adopted the UNCITRAL Model Law on International Commercial Arbitration on 21 June 1985. The objective of the Model Law is to provide a set of rules which would facilitate the settlement of International Commercial disputes by bringing about uniformity in the laws of member countries in reforming and modernising their national laws on arbitration.
Key Highlights: It covers every stage in the arbitration process as:-
?       Beginning from the recognition of the need to curtail judicial intervention to the formation of the arbitration agreement.
?       Appointment of the arbitral tribunal
?       Any challenges to such appointment
?       Basic rules of conduct of arbitration proceedings
?       Termination of proceedings by the making of the award
?       Finality of awards and grounds on which the arbitral award challenged before the national courts.
The Model Law also forms the basis for the Arbitration & Conciliation Act, 1996 in keeping with India’s International obligations.
 
 
INDIAN DISPUTE RESOLUTION CENTRE (IDRC):
Indian Dispute Resolution Centre (IDRC)[6] is one of a kind of Arbitral, Mediation and Conciliation Institution. IDRC is also registered with NITI Aayog and empanelled with the Ministry of Law & Justice, Government of India. It was inaugurated by Justice A.K. Sikri, former Judge of the Supreme Court of India. The IDRC provides a unique blend of both offline as well as online ADR platforms and has its own indigenously developed e-ADR software. The  IDRC envisions signals of our continued passion to spearhead an era of development and expansion, both for the Centre and the global ADR ecosystem.  IDRC aspires to continue to be a provider of international-class institutional support as a neutral and independent venue for the conduct of Domestic and International Arbitrations, and other ADR proceedings.
Today, IDRC is the leading digital Arbitration Institution in India. It has its Affiliate Centres not only pan India, but also in Asia Pacific and Europe, handling hundreds of domestic and international arbitrations. IDRC also provides services of Expert Determination and Early Neutral Evaluation, as well as education and training in alternative dispute resolution mechanisms through its Indian Institute of Arbitration – IIArb, Indian Institute of Mediation (IIMed) and Indian Institute of Dispute Resolution (IIDR).
MEDIATION BILL, 2021 [“DRAFT BILL”]:
Mediation at an Alternate Dispute Redressal [ADR] offers an informal, simple, non-adversarial approach to resolve predominantly civil, commercial and family disputes arising between parties and can help to lessen the burden of Courts. To expand the scope and reach of this form of ADR, the Department of Legal Affairs, Government of India, has proposed a draft Mediation Bill, 2021 [“Draft Bill”][7] on 29 October 2021 to facilitate timely and consensual resolution of disputes and serve the interest of stakeholders as an effective alternative remedy.
The Draft Bill has been introduced with the primary objective to promote, encourage and facilitate mediation, especially institutional mediation, for resolution of disputes, enforce domestic and international mediation settlement agreements, provide for a body for the registration of mediators, to encourage community mediation and make online mediation an acceptable and cost-effective process.
Further, to strengthen the legal framework on international dispute settlement, on 7 August 2019, India became one of the first signatories to the United Nations Convention on Enforcement of International Settlement Agreements resulting from Meditation [“The Singapore Convention"]. Pursuant to this, it was considered expedient that India gives effect to the Singapore Convention by introducing a standalone mediation law for the enforcement of international settlement agreements.
The Draft Bill aims to organise mediation in India and provides for the regulation of all its aspects such as mediation agreements, the mediation process, appointment and termination of the mandate of a mediator, the mode of conduction of a proceeding, settlement agreements executed as a consequence of mediation and setting up of the Mediation Council of India. The Draft Bill also recognizes and provides for the enforcement of international mediation settlement agreements. The Draft Bill aims to facilitate and promote mediation in India, particularly institutional mediation for the resolution of disputes, encourage community mediation, and make online mediation an acceptable and cost effective process with confidential proceedings & impartial mediators having sole objective to secure the ends of justice.
PRINCIPAL FEATURES OF THE DRAFT MEDIATION BILL:
?       Mandatory pre-litigation mediation and settlement under section 6(1) of the Draft Bill
?       Recognition and enforcement of Domestic and International Mediation Settlement Agreements
?       90 days Time-limit for completion of mediation under Section 20 of the Draft Bill. Additional period of 90 days with the consent of parties is also permitted.
?       Recognition of institutional mediation
?       Recognition to online mediation governed by the provisions of the Information Technology Act, 2000.
?       Establishment of the Mediation Council of India
?       Community mediation
 
 
OBJECTIVES OF THE BILL:
?       It provides an undeviating procedure to be followed for mediation in the country and also explains the meaning of specific legal terms.
?       The ultimate objective of the Bill is to educate people about mediation, which is a less time-consuming and more cost-effective method to resolve disputes, in order to reduce the number of pending cases in court.
?       The Bill also deals with pre-litigation mediation, which clarifies the position of such mediation.
?       It further gives the power and functions of courts and tribunals in the mediation process.
?       Mediation involves an unprejudiced third party acting as a mediator. Currently, there is no authority to ensure that the principles of confidentiality, neutrality, impartiality, and participation of parties are achieved. But the Bill, if passed and enacted, will deal with such situations and clarify the position of mediation proceedings and their relevance.
ISSUES IN MEDIATION BILL, 2021 [“DRAFT BILL”]:
?       The Bill does not provide qualifications of a trained mediator nor is there any reference to the 'capacity to mediate'.
?       The most important aspect of mediation and arbitration is "party autonomy". However, mandatory pre-litigation mediation mechanism would defeat the essence of mediation where the parties are unwilling to mediate.
?       Principle of confidentiality is also a fundamental aspect of mediation proceedings. However, the requirement in Section 18 of the Draft Bill that the mediator shall communicate 'the view of each party to the other to the extent agreed to by them' could give rise to possible conflict of interest, besides striking at the root of the requirement of confidentiality of the mediation process
?       The Draft Bill does not address as to what provisions would govern an International mediation that takes place in India but relates to non-commercial disputes that have arisen under a foreign law, such mediation not being covered by either Part I or Part III of the Draft Bill.
?       The Draft Bill does not specify whether a Mediation Service Provider can be a company.
?       The Draft Bill provides that a domestic mediated settlement may be challenged on the ground of 'gross impropriety', without making any venture to define the term or specify its outline or profile.
?       The consequences of non-registration of a Mediated Settlement Agreement have not been mentioned under the Draft Bill.
BENEFITS OF ALTERNATIVE DISPUTE RESOLUTION:
With so many cases pending in Indian courts, ADR has become increasingly important in the country.
?       In order to alleviate the workload of the Indian judicial system, the country’s alternative dispute resolution process employs tried and true methods backed by science.
?       Arbitration, conciliation, mediation, negotiation, and Lok Adalat are only few of the alternative dispute resolution methods available through ADR. In this context, negotiation refers to parties engaging in mutual self-counseling in an effort to resolve the disagreement; nevertheless, this method is not recognized by Indian law.
?       Articles 14 and 21, which guarantee everyone the same protections under the law and the right to life and liberty, are also the cornerstones of ADR.
?       Motivated by a desire to uphold the preamble’s ideals of social, economic, and political fairness, ADR seeks to resolve disputes amicably and keep the society it serves intact.
?       Equal justice and the right to free legal representation guaranteed by Article 39-A, Directive Principle of State Policy, are two additional goals of alternative dispute resolution (DPSP).
?       Alternative dispute resolution has been effective in reducing the backlog of cases at all judicial levels.
?       Over the course of the last three years, Lok Adalats have closed more than 50 lakh cases annually on average.
ISSUES IN ADR MECHANISM IN INDIA:
There are some issues with the ADR mechanism in India.
?       Generally, arbitrators can only resolve disputes that involve money.
?       They cannot issue orders requiring one party to do something or refrain from doing something.
?       They cannot change the title to the property, either.
?       Also, some of the safeguards designed to protect parties in court may not be present in ADR.
?       It cannot give remedies like punishment, imprisonment, injunction, etc. which are given in courts.
?       Also, other issues in the ADR mechanism in India include a limited opportunity for judicial review of an arbitrator’s decision. While a large arbitration service could, if it so chose, have some kind of process for internal appeals, the decision is usually final and binding, and can only be reviewed by a court in limited cases.[8]
 
INDIAN JUDICIARY ON ADR  MECHANISM:
The judiciary in India is the real point of the provision of justice. Resolving conflicts is one of the key factors for society’s peaceful existence. Arbitration, the ADR style, is accepted as an instrument of dispute settlement by the Indian judiciary. Originally, arbitration was regulated by the Indian Arbitration Act, 1940. The courts were mainly concerned about the control of the arbitral tribunals, and they were very keen to see if the arbitrator had exceeded his authority in determining the matter referred to him for arbitration.
The judicial process in India is not only expensive for an ordinary person but also it takes years and years to deliver justice. To address the much-criticized delay in the delivery of justice, the implementation of Alternative Dispute Resolution (ADR) mechanisms such as Lok Adalats, Arbitration, Mediation, and Conciliation were considered and followed with praiseworthy results afterward. The judiciary has figured prominently in developing and transforming India into an arbitration-friendly country, and the day is not far away when India will be a significant contender in hosting international arbitrations. When a party challenges an arbitration ruling, the Supreme Court of India and different High Courts have taken a hands-off attitude.
In recent years, Indian courts have repeatedly embraced an arbitration-friendly attitude. There have been numerous cases where courts have sustained arbitration agreements despite small flaws, thereby recognising the parties’ decision to have their problems resolved through arbitration. Despite adopting a pro-arbitration stance, the Supreme Court approved an arbitration agreement despite an error, concluding that because the parties’ purpose to arbitrate was obvious, the Court can make the arbitration agreement viable even if it contains certain faults.
The Mediation and Conciliation Project Committee, Supreme Court of India has sought to tie together the various strands that have been the subject-matter of debate from time to time as regards the benefits and/or suitability of ADR methods of dispute resolution, by way of various Regional Conferences organized across the length and breadth of the country. Conferences have been successfully held at Guwahati, Lucknow, Jammu, Bangalore, and Mumbai. These Conferences have witnessed brainstorming discussions of the strategies for integration of mediation within the conventional Court System. It is these exploring and inspirational discussions held at the Regional Conferences that have fructified into this National Conference on Mediation.
The first and foremost task before the Committee was to train the mediators. The Committee decided 40-Hours Mediation Training and 10 actual mediations as the essential qualification required for a mediator to be able to be entrusted with the task of mediating disputes. Further, it was felt by the Committee that various schools of thought were prevalent in the country regarding the topics, curriculum and methodology for training of the mediators. The Committee thought it appropriate that a uniform training manual adaptable to local situations, but at the same time assimilating the cream of various mediation centres, was essential to be uniformly followed throughout the country in order to streamline the functioning of mediation in India. Based on that, a Sub-Committee was constituted under the able guidance of Hon'ble Mr. Justice Cyriac Joseph (former Judge, Supreme Court of India and Member, MCPC) to lay down a uniform Mediation Training Manual of India.[9]
This Manual is the product of a team work and intellectual exercise of the experts. The Sub Committee has accomplished a major project of the Committee, initiated by the visionary Judge, Hon'ble Mr. Justice S.B. Sinha, carried forward by Hon'ble Mr. Justice R.V. Raveendran, who conceptualized and popularized mediation, and Hon'ble Mr. Justice Dalveer Bhandari, under whose able guidance mediation has become a vast movement in the country.
“The Law Commission of India in its 129th Report recommended that it should be made obligatory for the Court to refer disputes to Arbitration / Mediation for settlement”.
1. In Tamil Nadu v/s. Union of India the Supreme Court held: “In certain countries of the world where Arbitration has been successful to the extent that over 90 percent of the cases are settled out of court, there is a requirement that the parties to the suit must indicate their intention to refer to mediation during the pendency of the trail.”
2. In the case of Emkay Global Financial Service Limited v/s. Giridhar Sondhi[10] it was held that Arbitration & Mediation aims at a speedy resolution of disputes.
3. In the landmark case of Afcons Infra Ltd v/s. M/S Cherian Varkey Constructions (2010)[11] the Supreme Court of India held that all cases relating to trade, commerce and contracts, consumer disputes and even tortious liability could normally be mediated.
4. Another landmark decision by the Supreme Court was arrived at on 22nd Feb, 2013 in the case of B. S. Krishnamurthy v/s. B. S. Nagaraj[12], wherein it directed the Family Courts to strive to settle matrimonial disputes via mediation and to also introduce parties to mediation centres with consent of the parties, especially in matters concerning maintenance, child custody, and others.
In fact, it has been noted that during the proceedings of important cases such as the one regarding the demolition of the Babri Masjid, the Chief Justice of India himself has stepped in to facilitate mediation between the disputed parties.
As Mr. Nani Palkhivala the Indian Jurist & Economist said “a court of law is like an ancient castle, constantly under repair. There comes a time when it no longer pays to patch it up and it is better to resort to a new, compact house built on modern lines”.
ALTERNATIVE DISPUTE RESOLUTION (ADR) – NEED OF THE HOUR:
To overcome the delay and to provide effective justice to the consumer of justice, it has become imperative to resort to ADR with a view to bringing an end to litigation between the parties at an early date. In the words of Abraham Lincon: “Discourage litigation. Persuade your neighbors, make compositions whenever you can. As a peacemaker one should encourage being a good human being, to refrain from resorting to lies. There will still be business enough”.
The legal principle of ‘Justice Delayed is Justice Denied’ as quoted by William Gladstone clearly signifies the importance of timely fashion of redressal for a legal dispute. The principle forms the foundation for the right to a speedy trial and articulates that if the existing system is unable to deliver first hand justice at a faster pace, then it is equivalent to having no remedy at all. Legislature must understand the need of Mediation Bill also citizens all over the country must discuss with the Legislative body about the need of Mediation Bill to secure the ends of justice.
CONCLUSION & SUGGESTIONS:
As the dominance of commercial elements are increasing and service character diminishing, and the hierarchical system of law cannot meet the growing demands for justice, people are opting for alternatives. It has been observed since the previous decade Alternative Dispute Resolution has been catching up and is viewed as a successful instrument in diminishing the load off the judiciary.
The most popular forum of Alternative Dispute Resolution is arbitration which is akin to litigation; other forums of ADR should also be encouraged and given due importance which will help in timely and peaceful disposal of disputes. The Legislature should enact statutes covering all aspects of ADR. The Conciliation part of the 1996 Act should be brought into effect immediately. Alternate methods such as negotiation and mediation should be cheered as they are the best, effective, informal and autonomous methods of resolution.
Alternative Dispute Resolution as an instrument should not be confined only to address international commercial transactions, state, private or foreign business firms, inter- corporation conflicts or inter- country disputes but should be advanced and used as an effective tool for solving problems of the middle class society and conflicts amongst the poor.
Alternative Dispute Resolution in India had embarked upon a journey with the aim of facilitating access to justice and to relieve court congestion. ADR must be adopted in order to resolve common disputes of all categories of people. The legal community and social personalities must support and develop a positive attitude to rely on the ADR movement to achieve complete justice, the goal of the Constitution and rule of law, which will go a long way in reducing the load on judiciary.


[1]  National Judicial Data Grid, www.njdg.ecourts.gov.in (22nd January 2023)
[2]  The Indian Arbitration Act, 1940, Acts of Parliament, 1940 (India)
 
[3]  The Arbitration & Conciliation Act, 1996, Acts of Parliament, 1996 (India)
[4]  The Arbitration (Protocol and Convention) Act, 1937.
[5]  The Foreign Awards (Recognition and Enforcement) Act, 1961, Acts of Parliament, 1961 (India)
 
[6]  Indian Dispute Resolution Centre, www.theidrc.com (23rd January 2023)
 
[7]  GNLU SRDC ADR Magazine Vol II (Iss III.), pp. 10-15, January 2022.
[8] Legal Service, www.legalserviceindia.com (22nd January 2023)
[9]  Mediation Training Manual - Supreme Court of India, www.main.sci.gov.in (23rd January 2023)
[10]  Emkay Global Financial Service Limited v. Girdhar Sondhi (2018) SCC OnLine.
[11] Afcons Infra Ltd v. M/S Cherian Varkey Constructions (2010) 8 SCC 24.
[12] B. S. Krishnamurthy v/s. B. S. Nagaraj (2011) SCC OnLine.