#Arbitral Tribunal Composition

The Supreme Court held that jurisdiction to extend an arbitral mandate under Section 29A lies exclusively with the 'court' defined in Section 2(1)(e), not the Section 11 appointing authority. A party waives its right to a three-member tribunal by twice consenting to a sole arbitrator and participating for 18 months. The IBC moratorium does not bar a corporate debtor from initiating arbitration to recover dues.

Allahabad High Court rules that once an arbitral tribunal is constituted under Section 11, parties cannot later challenge its composition based on contractual clauses not raised during appointment. The court held that waiver under Section 4 of the Arbitration Act precludes post-appointment review, reinforcing party autonomy in arbitration proceedings.