Introduction
The case of Krishna Devi @ Sabitri Devi (Rani) v. Union of India & Ors [2025] 1 S.C.R. 81 : 2025 INSC 24 addresses quite complex and interesting questions under the Arbitration Act, 1940, specifically regarding the commencement of the limitation period for filing objections to an arbitral award under Section 17, read with Section 14(2) and Article 119(b) of the Limitation Act, 1963. The issue which came before the Supreme Court was whether the limitation should begin from the date of formal notice of the award or from the date the party becomes aware of the award’s existence. Where the Court held that mere awareness of the filing of the award, as opposed to formal notice, is sufficient for the limitation period to commence, thereby overturning the decisions of the District Court and High Court that relied on a formalistic interpretation. The Court’s interpretation concentrates on the importance of substantive knowledge rather than rigid procedural formalities, thereby overturning the stricter, rule-bound approach taken by the District Court and the High Court. This decision marks a significant step towards reflecting the judiciary’s progressive stance which sets base for India’s pro-arbitration policy and the broader legislative goal of reducing unnecessary procedural delays.
Background
The dispute arose out of a work order issued to M/s S.R. Engineering Construction in 1987–88 for the construction of an armament section at Tezpur. After couple of litigation rounds and several procedural hurdles, an arbitrator was finally appointed in 2019. The arbitral award, delivered on 31 May 2022, directed the Union of India to pay ₹1,33,47,268.92 along with 9% interest. However, the publication of the award was delayed because the respondent failed to pay the arbitrator’s fees. On 21.09.2022, the District Judge directed the respondents to pay the balance fees, and explicitly stated that upon payment, the award would be furnished to the parties. The appellant received a copy on 22.09.2022, but the respondents only paid their fees and received formal notice on 18.11.2022. On 10 November 2022, the appellant filed an application under Section 17, where the court to was asked to pronounce judgment in accordance with the arbitral award. The Trial Court, however, dismissed the plea as premature, noting that the 30-day limitation period for filing objections had not commenced because no formal notice had been issued. The High Court upheld this reasoning. This ambiguity in the procedure has therefore led the Supreme Court to step in, seeking to clarify exactly when the limitation period for objections under the Arbitration Act begins to run.
Analysis
The Supreme Court held that the lower courts erred in holding that formal notice was necessary for the limitation period to begin. It reasoned that the order of 21.09.2022 constituted a valid “notice” as it sufficiently intimated the respondents of the award’s existence. The Court relied on a few prior rulings that are in the case of Nilkantha Sidramappa Ningashetti v. Kashinath Somanna Ningashetti, where the SC held that “notice” under Section 14(2) of the 1940 Act need not be formal or written; mere knowledge of the filing is enough to start limitation. In the case of Food Corp. of India v. E. Kuttappan, the Court spread light on awareness through a pleader satisfies the requirement of notice under the Act. And in Bharat Coking Coal Ltd. v. C.K. Ahuja, the Supreme Court reaffirmed that substantive compliance rather than procedural rigidity should guide the application of limitation principles. Thereby, the judgment confirms to the line of reasoning that prioritises substantive awareness over procedural formalities.
By invoking these authorities, the Supreme Court underscored that arbitration proceedings must be viewed through the lens of efficiency and substantive justice rather than procedural technicalities. It also highlighted that allowing parties to wait for formal notices before initiating or responding to proceedings would defeat the purpose of arbitration as a quick and final method of dispute resolution. The judgment thus reinforces the pro-enforcement and pro-efficiency stance of Indian arbitration law, discouraging dilatory tactics by award-debtors.
The Court not only relied on precedents but also interpreted the statutory scheme in light of arbitration’s purpose speedy and final resolution of disputes. It warned against allowing technicalities to be exploited to delay enforcement. The judgment discourages award-debtors from waiting for formal notices to buy time for objections. It stands as best example for pro-arbitration stance of Indian jurisprudence and attributes that procedural compliance should not overshadow substantive justice.
CONCLUSION
The Supreme Court’s ruling clears up a long-standing uncertainty in arbitration law by affirming that mere awareness of an arbitral award is enough to start the limitation period under Article 119(b) of the Limitation Act, 1963. By rejecting a rigid requirement of formal notice, the Court reinforced arbitration as a speedy and effective method of resolving disputes. This interpretation balances the judiciary’s consistent approach,giving clarification and predictability to arbitration practice. The decision also underscores the need to interpret procedural laws with purpose and fairness rather than through a mechanical lens. It closes the door to potential misuse of procedural gaps by litigants seeking to delay justice under the pretext of incomplete notice. In reaffirming that the substance of the law must prevail over strict formalism, the Court strengthened India’s pro-arbitration stance and brought domestic practice closer to international standards that value efficiency and finality. Overall, the judgment marks a significant step in developing Indian arbitration jurisprudence by maintaining a careful balance between substantive justice and procedural discipline.
