In Brief
An arbitral tribunal had terminated proceedings under Section 25(a) of the Arbitration and Conciliation Act, 1996, because the claimant failed to file a statement of claim. The claimant later sought recall of the termination order, showing sufficient cause. The tribunal refused, holding it had become functus officio. The High Court set aside the refusal and remitted the matter for reconsideration. The Supreme Court held that an arbitral tribunal retains jurisdiction to recall an order terminating proceedings under Section 25(a) if the claimant subsequently shows sufficient cause, relying on principles of procedural review and natural justice. The tribunal is not functus officio in such circumstances.
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