In Brief
In this arbitration matter, the Supreme Court held that an arbitral tribunal retains jurisdiction to recall an order terminating proceedings under Section 25(a) of the Arbitration Act if the claimant shows sufficient cause for non-filing of their statement of claim. The Court endorsed the doctrine of procedural review, drawing analogy with Order 9, Rule 13 C.P.C., and rejected the doctrine of functus officio when applied mechanically to Section 25(a) termination orders. The Court set aside the High Court's decision but remitted the matter for the tribunal to reconsider the claimant's application on merits.
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