In Brief
Two companies formed a Limited Liability Partnership in 2012 to undertake oil and gas projects. Disputes arose over accounts reconciliation. One partner initiated arbitration but served notice only to the first respondent company, not the LLP itself (second respondent) or its CEO (third respondent). The arbitral tribunal rejected impleadment of the second and third respondents, holding that without a formal arbitration notice and court referral, it lacked jurisdiction. The Supreme Court allowed the appeal, clarifying that formal notice and court referral are not prerequisites for impleading non-signatories. An arbitral tribunal can determine its own jurisdiction by examining whether a person consented to the arbitration agreement through their conduct. Since the LLP was created under the agreement and the CEO performed duties under it, both were parties to the arbitration agreement and could be impleaded.
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