NATURAL JUSTICE AND ARBITRAL PROCEEDING: A COMMENT ON SECTION

18: A LIMITAION ON ARBITRAL AUTONOMY UNDER ARBITRATION AND

CONCILIATION ACT, 1996.

DATE: 1 ST

SUBJECT: L AW OF

NATIONAL LAW

SEPTEMBER, 2015

ARBITRATION

AND

ADR

UNIVERSITY, JODHPUR

SUBMITTED BY:
SUBMITTED TO:
DEEPA MOONDRA (909)

M S. AAKANKSHA

KUMAR SEMESTER IX
JODHPUR

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

NLU

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.

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.

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 & Contractors10
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

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
4

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 Pull, 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.

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 proceedings 7. 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

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.
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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
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 Haryana 11, 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.

8 The Arbitration and Conciliation Act, 1996. Section 18.

9 1996 (3)SCC 346,387.
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.
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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 wellunderstood rules for the administration of justice13.
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 commentators 14 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 evidence 15.The
only restraint on them is that they shall treat the parties with equality and each party shall be
13 Russell, 19th Edn., (1979), p. 225.
14 Redfern and Hunter on International Arbitration, Fifth Edition (2009), at. 263.
15 Section 19(3) and (4) of Arbitration and Conciliation Act, 1996.
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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 hearing 18 but if proceedings are between arbitral board and one
party only then the other party need not be given the notice.
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
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 Lloyds Rep,
208.
19 AIR 1954 Cal 111.
20 19th Edn., (1979), p. 228.
21 AIR 1953 SC 21.
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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 throughout 23. 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 argument 24. 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.
22Arbitration and ADR-Chapter V-Conduct of Arbitral Proceedings (Manupatra)
23Id.
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.
10

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.
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
26 Union of India Vs. Bharath Builders & Contractors 2012 (4) ARBLR 448(Kerala).(Bharath Case)
27 Bharath Case.Para1.
11

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 aside 30. 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
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
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)
12

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 case 33. 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.
13

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
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.
14

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
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
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.
15

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.
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 ones 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.

42 Impex case.Para.4.
16

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. Bachawats 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
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2. www.jstore
3. www.manupatra.com.

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