Final And Binding: Delhi High Court's Approach To DRB Awards And Limitation

On 27 May 2025, the Hon'ble High Court of Delhi delivered it judgment in M/s Jaiprakash Hyundai Consortium (hereinafter referred as JHC) v. M/s SJVN Limited¹ (Satluj Jal Vidyut Nigam Limited), examining whether a Dispute Review Board's (DRB) recommendation could be treated as an Arbitral Award and whether the same can be enforced under Section 36 of the Arbitration and Conciliation Act, 1996. The dispute in the current case arose out of the development of Nathpa Jhankari Hydro Electric Project undertaken by SJVN. To execute the hydroelectric power projects, SJVN entered into a contract with JHC.

Under the terms of the contract, the parties had agreed to a structured dispute resolution mechanism involving a Dispute Review Board (DRB) to address project-related disagreements. As per the Clause 67 of General Conditions of Contract of the signed contract, any dispute involving claims of less than Rs. 5 crores would be referred to the DRB, and its decision would be