I. INTRODUCTION

Under Indian law, parties can choose to have their civil and commercial disputes resolved through the alternate dispute mechanism, such as - mediation, conciliation and arbitration. The Arbitration and Conciliation Act, 1996 (the “Act”) is the governing statute for both the domestic and international arbitration. Except for certain modification, the Act is complete adoption of the UNICTRAL Model Law. Apart from UNICTRAL Model Law, the Act also draws its source extensively from English Arbitration Act, 1996 but the provisions of the Act miss all-embracing approach of the English Arbitration Act, 1996.