Dispute Resolution Arbitration

8/14/2019 Dispute Resolution Arbitration

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Dispute resolution-Arbitration

By

S.K.Rao


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Construction contract-mutualobligations A construction contract is between two parties-Employer

and contractor. The work is executed based on Contract provisions and

the rights and obligations of the parties are governed by

these documents Both parties have to fulfill their respective obligations

under the contract. Non fulfillment of any obligation by one party affects the

interests of the other party Long duration of contract-various issues arise during

construction Views of one party may not be acceptable to the other

resulting in disagreement


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Unresolved issues result in

disputes Most of the issues are resolved by mutual discussions

with the spirit of accommodating each others point ofview and in the overall interest of work.

The Engineer plays an important role in ascertaining theviews of both sides. The Engineer, with his professionalexperience and fairness, endeavours to convince bothparties to come to a common understanding andagreement. If there is a disagreement, the Engineergives his decision/ determination in accordance with the

contract. In case the issue can not be resolved, the dispute is

precipitated


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Sources of disputes

Sources of disputes could be: Inconsistencies/discrepancies in contract provisions

Delay in giving possession of site

Denial of extension, Liquidated damages Rejection of work, Cancellation of contract, Foreclosure

Variations, Fixing rates,

Delays and denial of payments, etc.

Delays in execution and failure of contractor Non adherence to contract conditions and specifications by

contractor


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Interpretation of contracts incase of discrepancies The following aspects are to be considered while

interpreting contract documents

a) Contract to be read as a whole

c) Local custom or usage

d) Reasonable meaning

e) Order of precedence among various documentsforming part of contract

f) Words versus figures

g) Written words versus printed words

h) General versus special provisions


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Inconsistencies in differentparts of Contract In order to resolve apparent inconsistencies or

contradictions, in cases where the subject matter iscovered several times in different parts of theContract, the order of precedence to be considered

is laid down in the General Conditions of Contractadopted by various organisations

There is a sub-clause in FIDIC contract form also(Federation Internationale des Ingenieurs-Conseils)

laying down the order of precedence forinterpretation


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Interpretation of contracts-Orderof precedence- FIDIC The contract agreement

The letter of acceptance

The letter of tender

The Particular Conditions

The General Conditions

The Specification The Drawings

The schedule or any other documents


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Engineers clarification

If an ambiguity or discrepancy is found in the

documents, the Engineer shall issue

necessary clarification or instruction

The work will be executed as per the

instruction of Engineer

Disagreement on any issue may result in

claim/dispute which will have to be resolvedby various procedures of dispute resolution


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Lodging claims-notice andsubstantiation

If contractor intends to claim any additional payment, heshall give notice to Engineer with copy to Employer,immediately on occurrence of an event leading to claim

Contractor shall keep contemporary record necessary tosupport his claim

Without necessarily admitting the Employers liability,Engineer may inspect the records

Contractor shall send detailed particulars and supportingdetails to substantiate his claim

Contractor shall also submit any further particulars,documents or clarifications as desired by the Engineer

Copies of the correspondence shall be endorsed to theEmployer


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Engineers response to theclaim If the Engineer agrees to the claim, he shall

issue a variation order admitting payment

If the Engineer does not agree, he shall state

reasons for his disagreement The Contractor may advance further

arguments in support of his claim The Engineer may reconsider and give his

decision/determination Copies of the correspondence shall be

endorsed to the Employer


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Various stages of resolution ofdisputes-Domestic/Government

contract form Mutual discussion Decision of Accepting officer Conciliation- provision in the Arbitration and

Conciliation Act, 1996 Arbitration as per the Arbitration and

Conciliation Act, 1996

Intervention by Court


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Various stages of resolution ofdisputes-FIDIC contract Mutual discussion

Decision of the Engineer

Dispute review board-or Dispute Resolution

Board-(Dispute Adjudication Board in FIDIC

99)

Arbitration

Intervention of Court


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Dispute Review Board-

appointment FIDIC contract provides for DRB to settledisputes during execution / completion ofproject

Normally formed by 3 Members experiencedwith the type of construction

A Member should have no financial interest inany party-no previous employment with anyparty

One Member nominated by each party-Third

Member nominated by two Members-acts asChairman Any disputes that cannot be settled may be

referred to the DRB


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DRB proceedings-proceduredecided in consultation with

parties DRB calls for Claims statement with details-copyto opposite party

On receipt ,calls for Defence statement from theparties

DRB visits site along with parties-conductshearing Full opportunity is given to both parties to

present their cases DRB Members have their internal meeting,

deliberate the issues among them and maketheir Recommendations If this is not acceptable to either party, the matter

may be referred to Arbitration


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Dispute Adjudication Board

DRB is replaced by DAB in FIDIC 99 DAB is formed in a similar way and conducts

proceedings in similar way While DRB gives Recommendations, DAB gives

its Decision which shall be binding on parties Within a specified period, any party may give notice

of dissatisfaction to the other party with copy toDAB.

The case may be referred to arbitration there after If no such notice is given with the specified period,

then the DABs decision shall be final and bindingon both parties


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The Arbitration and ConciliationAct, 1996 This is a very recent act formulated and enacted to

make it more responsive to contemporary requirements. The old act, The Arbitration Act, 1940 was considered

outdated. The new act replaces the old act

It was recognized that our economic reforms may notbecome fully effective if the law dealing with settlementof both domestic and international commercial disputesremains out of tune with such reforms

Conciliation, which is getting worldwide recognition asan instrument for settlement of disputes , is included inthe act


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Objectives of the Act

To comprehensively cover international and commercialarbitration and conciliation taking into account theModel Law adopted by United Nations Commission onInternational Trade Law (UNCITRAL)

Also domestic arbitration and conciliation To make provision for an arbitral procedure which is

fair, efficient and capable of meeting the needs ofspecific arbitration

To provide that the arbitral tribunal gives reasons for itsaward

To ensure that the tribunal remains within the limits ofits jurisdiction

To minimise the supervisory role of courts


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Other objectives of the Act

To provide that every final award is enforced in thesame manner as if it were a decree of the court

To provide that a settlement agreement reached by theparties as a result of conciliation proceedings will have

the same status and effect as an arbitral award onagreed terms on the substance of the dispute renderedby an arbitral tribunal

To permit an arbitral tribunal to use mediation,conciliation or other procedures during the arbitral

proceedings to encourage settlement of disputes


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Conciliation

Conciliation is the process by which the parties are facilitated to reachan amicable settlement of their disputes (part III of Arbitration andConciliation Act,1996)

This is adopted prior to Arbitration like DRB for settlement of disputeswithout resorting to Arbitration

Conciliation takes place only if the parties agree to it. Conciliator is appointed as per contract provision He shall be guided by the principles of objectivity, fairness and justice.

He facilitates the parties to come together for an agreed settlement When the parties sign settlement agreement ,it shall be final and

binding on the parties Conciliator authenticates settlement agreement The settlement agreement shall have the status of arbitral award


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Arbitration agreement

Arbitration agreement means An agreement by the parties to submit to arbitration

All or certain disputes

Which have arisen or which may arise between them In respect of a defined legal relationship

Whether contractual or not

An arbitration agreement shall be in writing

May be a clause in a contract agreement


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Matters that cannot be referredto arbitration Broadly the matters involving morality, status and public policy

cannot be referred to arbitration, such as

b) Matrimonial matters like divorce, restitution of conjugal rights

c) Matters relating to guardianship of a minor

d) Testamentary matters, like, questions about validity of a will

e) Insolvency mattersf) Criminal proceedings

g) Questions relating to charitable trusts

h) Matters coming within the purview of the Monopolies andrestrictive trade practices act

i) Dissolution or winding up of a companyj) And such other matters


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Arbitral TribunalNumber of arbitrators There may be a single arbitrator (sole arbitrator) Tribunal may have more than one arbitrator, not even number, as

determined by the parties. This may be stipulated in thearbitration agreement

Arbitrator may be of any nationality unless otherwise agreed bythe parties

Arbitration agreement may stipulate certain qualifications for thearbitrators

There may be designated appointing authority for appointment ofarbitrator as may be provided in the arbitration agreement


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Appointment of arbitrators byparties-three arbitrators The parties are free to agree on a procedure for

appointing an arbitrator or arbitrators Failing any such agreement, in an arbitration

with three arbitrators, each party shall appointone arbitrator, and the two appointed arbitratorsshall appoint the third arbitrator, who shall act aspresiding arbitrator.,

In Government contract form, provision may bemade for appointment of arbitrator by adesignated authority specified in the arbitrationclause/agreement


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Failure to appoint arbitrator

If a party fails to appoint an arbitrator within 30

days from the receipt of request from the other

party; or

If the two appointed arbitrators fail to agree onthe third arbitrator within thirty days from the

date of their appointment;

the appointment shall be made, upon request of

a party, by the Chief Justice of High Court or

any person or institution designated by him.


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Appointment of arbitrator byparties- sole arbitrator In arbitration by sole arbitrator, if the parties fail to

agree on the arbitrator within 30 days from receipt of

request by one party from the other party, upon

request by a party, the appointment shall be made

by Chief Justice or any person or institution

designated by him.

In Government contract form, provision may be

made for appointment of arbitrator by a designatedauthority specified in the arbitration

clause/agreement


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Interest of both parties

The delays and disagreements can be minimized if

sole arbitrator is to be appointed instead of three or

more arbitrators

If both parties feel that their interest is served byproceeding with the arbitration, the things will move

fast.

They some how find a commonly acceptable

arbitrator, cooperate in early finalisation of the case Otherwise the party who feels that proceeding with

the arbitration is detrimental to his interest, finds all

excuses to delay the matter


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Arbitrator to disclose- groundsfor challenge When a person is approached in connection with his

possible appointment as arbitrator, he shall disclose

in writing any circumstances likely to give rise to

justifiable doubts as to his independence or

impartiality

If not already done, the arbitrator shall disclose such

circumstances during the proceedings at the earliest

If the arbitrator fails to disclose such circumstances,his appointment may be challenged

He may also be challenged if he does not possess

requisite qualifications as per arbitration agreement


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Decision on challenge

The challenged arbitrator may withdraw from his

office

The other party may also agree to the challenge

If none of the above happens, the arbitral tribunalshall decide on the challenge

If the challenge is not successful, the tribunal shall

continue the proceedings and make the award

The party challenging the arbitrator may make anapplication for setting aside such an award, as and

when made, in accordance with section 34


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Failure or impossibility to act-termination of mandate of

arbitrator The mandate of an arbitrator shall terminate if He becomes de jure or de facto unable to perform

his functions or

for other reasons fails to act without undue delay He withdraws from office for any reason or

the parties agree to the termination of his

mandate


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Substitution of arbitrator

Where the mandate of an arbitratorterminates, a substitute arbitrator shall beappointed according to the rules that were

applicable to the appointment of arbitratorbeing replaced Where an arbitrator is replaced, any hearings

previously held may be repeated

The rulings earlier made by the tribunal priorto replacement of the arbitrator shall not beinvalid solely because there has been achange in the composition of tribunal


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The arbitration clause isindependent of rest of the

contract An arbitration clause which forms part of a contractshall be treated as an agreement independent ofother terms of the contract

For example, even if a contract is cancelled for

contractors default, the arbitration clause survivesbased on which arbitrator can be appointed

If arbitral tribunal rules that a contract is null andvoid, this shall not entail ipso jure the invalidity of

arbitration agreement


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Ruling on the jurisdiction ofarbitral tribunal Parties may question the jurisdiction of

arbitral tribunal

Arbitral tribunal is competent to rule on its own jurisdiction

To rule on the validity of arbitration clause or

arbitration agreement


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Objections on jurisdiction orexceeding the scope of authority Objection not later than submission of statement of

defence

If any matter raised by a party is considered to be

beyond the scope of the arbitrators authority by theopposite party, the opposite party may raise

objection but this shall be raised immediately without

delay

The arbitral tribunal may admit if it considers delayjustified


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Decision of arbitral tribunal

If the arbitral tribunal considers that the

objections are not valid and rejects the plea,

the tribunal shall continue with the

proceedings and publish the award The party aggrieved by such an award may

make an application to the court for setting

aside the award under section 34


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Conduct of arbitral proceedings-Equal treatment of parties The parties shall be treated with equality

Each party shall be given a full opportunity to

present his case

All the correspondence is addressed to both

parties

All the discussions are held only during

presence of both parties


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Parties are free to agree

Many sections (clauses) start with the

provision parties are free to agree

Failing an agreement the arbitral tribunal

takes decision Many sections start with the provision unless

otherwise agreed by the parties. That means

that the rest of the provision in the sectionshall be operative only if the parties have not

agreed otherwise


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Agreement between the partiesis given the highest importance The whole purpose of arbitration is resolve

disputes between the parties If both parties agree on an issue, that means

there is no dispute as far as that issue isconcerned When the issue is not disputed, where is the

need for an arbitrator or any body to

interfere? Arbitrator comes in picture only in respect of

the issues which continue to be under dispute


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Determination of rules ofprocedure The parties are free to agree on a procedure to be

followed by the arbitral tribunal in conducting itsproceedings

If the parties fail to agree, the arbitral tribunal

decides the procedure The tribunal has also got power to determine the

admissibility, relevance, materiality, and weight ofany evidence

The arbitral tribunal shall not be bound by The Code of civil procedure, 1908(5 of 1908) The Indian evidence act ,1872(1 of 1872)


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Place of arbitration

The parties are free to agree on the place ofarbitration

If they fail to agree, the arbitral tribunal shalldetermine the venue having regard to the

circumstances and convenience of the parties The arbitral tribunal may meet at any place itconsiders appropriate, for consultation among itsmembers, for hearing witnesses, experts or theparties, or for inspection of documents, goods or

other property Normally, venue is fixed after consulting all

concerned


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Commencement of arbitralproceedings The arbitral proceedings in respect of a

particular dispute commence on the date on

which a request for that dispute to be referred

to arbitration is received by the respondent Time for making award is counted from this

date

Language: as agreed by the parties. If notarbitral tribunal shall determine


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Statement of claim anddefence Within the time agreed upon by the parties, or Determined by the arbitral tribunal, The claimant shall state the facts supporting his

claim, The points at issue and the relief or remedy sought The respondent shall state his defence in respect of

these particulars

Parties may also submit all documents theyconsider relevant with their statements Either party may amend or supplement his claim or

defence as may be allowed by the arbitrator


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Hearing or writtenproceedings Arbitral tribunal shall decide whether to hold oral hearings for the

presentation of evidence or oral argument or whether theproceedings shall be conducted on the basis of documents orother materials

In practice, in most of the cases oral hearings will be conducted

The parties shall be given sufficient advance notice Copies of all communications made by one party to the arbitrator

shall be sent to the other party. Similarly, the communications made by the presiding arbitrator

shall be sent to both parties as well as other arbitrators Any expert report or evidentiary document on which the arbitral

tribunal may rely in making its decision shall be communicated tothe parties


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Default of a party

Unless otherwise agreed by the parties; If claimant fails to submit his statement within the

stipulated time with out showing sufficient cause, thearbitral tribunal shall terminate the proceedings

If the respondent fails to submit his defence withinstipulated time without showing sufficient cause, thearbitral tribunal shall continue the proceedings,without treating that the failure in itself as anadmission of the allegations by the claimant

If a party fails to appear at an oral hearing or toproduce documentary evidence, the tribunal maycontinue the proceedings and make the award onthe evidence before it


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Expert appointed by arbitraltribunal Unless otherwise agreed by the parties,

The arbitral tribunal may appoint one or more

experts to report to it on specific issues to be

determined by the arbitral tribunal, and Require a party to give the expert any

relevant information or to produce access to,

Any relevant documents, goods or

any other property for his inspection


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Participation of expert in thehearing The expert shall submit his report to the tribunal

copies of which will be made available to the parties There after he shall participate in the hearing where

the parties have the opportunity to put questions to

him and to present expert witnesses in order totestify on the points at issue

If requested by a party, the expert shall makeavailable for examination of the party, the

documents, goods or other property in hispossession (which were provided to him for makinghis report)


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Making arbitral award by panelof arbitrators Any decision by arbitral tribunal shall be

made by majority of all its members

Questions of procedure may be decided by

presiding arbitrator if authorised by parties orall arbitrators


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Form and contents of arbitralaward- signature, date and place Shall be made in writing Shall be signed by the members of the

tribunal

Signatures of majority of members issufficient if the reason for omitted signature isstated

Shall state the date and place of award Signed copy shall be delivered to each party


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Form and contents of award-reasons upon which it is based Shall state the reasons upon which it is

based

This is obligatory unless The parties have agreed that no reasons are to be

given

The award is on agreed terms where settlement is

reached by parties


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Form and contents of award-interim award Arbitral tribunal may make interim award

Any time during proceedings

This is subject to final award

Normally this may be needed to give interim

relief to the affected party


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Form and contents of award-interest up to the date of award Where the award is for payment of money

The tribunal may award interest

At the rate considered reasonable by tribunal

On the whole or part of the money awarded For the whole or any part of the period

Between the date on which the cause of action

arose and the date on which the award is made


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Form and contents of award-interest from the date of award

to the date of payment Unless the award otherwise directs,

The sum directed to be paid by the award

shall carry interest at the rate of 18% per

annum

From the date of award to the date of

payment


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Form and contents of award-Costs of an arbitration costs means reasonable costs relating to

The fees and expenses of the arbitrators and the

witnesses,

Legal fees and expenses, Any administration fees of the institution

supervising the arbitration and

Any other expenses incurred in connection with

the proceedings and the award


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Form and contents of award-award of costs Unless otherwise agreed by the parties The costs of an arbitration shall be fixed by

the arbitral tribunal

The tribunal shall specify The party entitled to costs The party who shall pay the costs The amount of costs or method of determining the

amount and The manner in which the costs shall be paid


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Termination of proceedings

The arbitral proceedings shall be terminated

by the final arbitral award or

By an order for termination by arbitral tribunal


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Application to court under Sec.34 contesting the award After receipt of award, if a party is not

satisfied with the award, recourse to a court

against the award may be made only by an

application for setting aside such award The new Act, with the objective of minimising

the supervisory role of courts in arbitral

process, provided for limited grounds forsetting aside the award


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Grounds for setting asideaward An arbitral award may be set aside by the

court only if

(b) The party making application must furnish

proof of certain procedural irregularities.(The court does not interfere with the arbitraltribunals analysis of a claim and theassessment of the awarded amount out of

the claimed amount)(c) The court finds some other legal grounds


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Grounds for setting aside award (a) proof to be

furnished by party-(I) The award may be set aside by the court onlyif

(a) The party making application furnishes

proof that(i) A party was under some incapacity, or

(ii) The arbitration agreement is not valid under thelaw to which the parties have subjected it or,

failing any indication there on, under the law forthe time being in force; or


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Grounds for setting aside award

(a) proof to be furnished by aparty-(II)

Only if the party furnishes proof that

(iii) The party making application was not

given proper notice of the appointment of

arbitrator or of the arbitral proceedings orwas otherwise unable to present his case;

or


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Grounds for setting aside award- (a) proof to be furnished by

a party-IIIOnly if the party furnishes proof that(iv) The arbitral award deals with a dispute not

contemplated by or not falling within the terms of the

submission to arbitration, or it contains decisions on

matters beyond the scope of the submission to arbitration.Provided that, if the

decisions on matters submitted to arbitration can be

separated from those not submitted, only that part of the

award which contains decisions on matters beyond not

submitted to arbitration may be set aside; or

d f i id d


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Grounds for setting aside award-

(a) proof to be furnished by aparty-(IV)

Only if the party furnishes proof that

(v) the composition of the arbitral tribunal or the

arbitral procedure was not in accordance with the

agreement of the parties, unless such agreement

was in conflict with a provision of this Part from

which the parties cannot derogate, or, failing such

agreement, was not in accordance with this Part

G d f i id


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Grounds for setting asideaward-

(b) if the court finds thatThe award may be set aside by the court only if(b) The court finds that

(i) the subject-matter of the dispute is not

capable of settlement by arbitration under thelaw for the time being in force, or

(ii) the arbitral award is in conflict with the

public policy of India

Ti f ki li i f


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Time for making application forsetting aside award An application for setting aside award may not be

made

After 3 months from the date on which the party

making that application had received the arbitral

award or,

If a request had been made under section 33

(correction and interpretation of award, additional

award), from the date on which that request hadbeen disposed of by the tribunal

id i


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court may consider extension

If the court is satisfied that an applicant was

prevented by sufficient cause from making

the application within the said period of

THREE months, it may entertain theapplication within a further period of THIRTY

days

And not there after

Th t i t it


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The court may give opportunityto the arbitral tribunal On receipt of application from the party for setting

aside the award, the court may, Where it is considered appropriate and it is so

requested by a party,

Adjourn the proceedings for a period of time asdetermined by it In order to give the arbitral tribunal an opportunity to resume the arbitral proceedings or to take such other action as in the opinion of the

tribunal will eliminate the grounds for setting asidethe arbitral award

E f t f d A d


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Enforcement of award-Awardfinal and binding The arbitration award shall be final and binding on

the parties and persons claiming under themrespectively

If both parties are satisfied with the award, it can be

implemented. However, if any party is not satisfied with the award

and they find that there are grounds for getting theaward set aside as per section 34, the party may file

application in the court.

Enforcement of award


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Enforcement of award-Courts decision on application The section 34 provides very limited grounds

for setting aside the award

The court may find that there are no valid

grounds to set aside the award and pass adecree in terms of award

With the decree, the award can be enforced

as per law

Enforcement of award Courts


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Enforcement of award-Courtsdecision to give opportunity to

tribunal The court may give opportunity to the arbitraltribunal under section 34(4) and tribunal may take

action to eliminate the grounds for setting aside the

award

The court may, there after, be satisfied that no

grounds exist for setting aside the award and pass

decree which can be enforced as per law

Enforcement of a ard


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Enforcement of award-award as if it were a decree Time for making application to the court for setting

aside an award is 3 months from the date of receiptof receipt of arbitral award (or within the period asmay be extended by the court-not exceeding thirty

days) Once the period expires, the arbitral award shall be

enforced under the Code of Civil Procedure, 1908(5of 1908) in the same manner as if it were a decreeof a court

Enforcement of award


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Enforcement of award-Improvement in new act As per old act, separate application was to be filed

in a court and decree obtained for enforcing theaward even if the award was not contested.

This involved prolonged litigation and delay inenforcement of award

In the new act, once the period for contesting theaward expires, the award shall be enforced as if itwere a decree and there is no need to go to thecourt for a decree


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Settlement of disputes inArbitration Sole arbitrator/Arbitral tribunal is appointed as stipulated in the

Arbitration agreement An arbitrator shall be independent, impartial and shall possess the

qualification stipulated in the agreement The arbitrator shall not be bound by Code of Civil Procedure or the

Indian Evidence Act.

The parties shall be treated with equality and each party shall be givenfull opportunity to present his case Claimant submits claims statement; respondent submits counter claims

with copies to the opposite party On receipt, Arbitrator asks both parties to submit their pleadings in

defense with copy to the opposite party

On receipt, the Arbitrator fixes hearing in consultation with both parties Claims and counter claims are heard in the hearing; both parties given

full opportunity Award published with in the stipulated time

Statement of claims


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Statement of claims

Description of claim

Amount

Relevant contract provisions

Facts supporting the claim

The points at issue

Remedy sought

Detailed calculations

Relevant documents/other evidence

Pleadings in Defence


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Description of claim Relevant contract provisions against the claim Facts against the claim The points at issue- Respondent's point of view

Refuting the claim Scrutiny of detailed calculations and amount as

corrected (without prejudice to disagreement to theclaimants arguments)

Comments on documents/ evidence submitted bythe claimant Corresponding documents refuting claimants

documents to disprove the claim

Counter to Pleadings


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Counter to Pleadings

This may be submitted as reply to the


Counter arguments given in the Pleadings in

Defence Any further clarifications on calculations

Any further documents relevant to documents

submitted by Respondent

Engagement of advocate or


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Engagement of advocate orconsultant by either party If either party intends to present their claims/

defence through an advocate or a consultant,the party has to intimate the details to theArbitral Tribunal well in advance with copy tothe other party

This will give ample time for the oppositeparty who may also decide to engage an

advocate or a consultant and intimate thedetails to the Arbitral Tribunal with copy to theother party

Hearing


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Hearing

Place of hearing, date and time will be fixed by theArbitrator in consultation with the parties

Sufficient advance notice will be given to the parties

All documents submitted to the Arbitrator by eitherparty shall be endorsed to the other party

Similarly, all communications made by the Arbitrator

shall be addressed to both parties

All inspections and discussions shall be made bythe Arbitrator in presence of both parties

Application to Court for setting


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Application to Court for settingaside an Arbitral Award Time limit is THREE months from the date of receipt

of the Award by the party This may be extended by maximum of thirty days by

the Court considering the justification

Where the time for making an application to setaside an award has expired, or where suchapplication has been refused by the Court, theaward shall be enforced as if it were a decree of aCourt. This is a great improvement from old act

As per old Arbitration Act, obtaining a court decreewas compulsory for enforcement of award. Thisresulted in prolonged litigation and delay inenforcement


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Documents

Dispute Resolution Arbitration