Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
Form for agreement between the Employer and Employees for Reference of Disputes to Arbitration
Open Legal LibraryUpdated 15 Jul 2026
FORM OF AGREEMENT BETWEEN THE EMPLOYER AND EMPLOYEES FOR REFERENCE OF DISPUTES TO ARBITRATION
AGREEMENT
BETWEEN
Names of the Parties:
Representing the Employer(s): ____________________
Representing the Workmen/Workman: ____________________
It is hereby agreed between the parties to refer the following dispute to the arbitration of ____________________ [here specify the name(s) and address(es) of the arbitrator(s)]:
(i) Specific matters in dispute;
(ii) Details of the parties to the dispute, including the name and address of the establishment or undertaking involved;
(iii) Name of the workman, in case he himself is involved in the dispute, or the name of the Union, if any, representing the workmen or workman in question;
(iv) Total number of workmen employed in the undertaking affected;
(v) Estimated number of workmen affected, or likely to be affected, by the dispute.
We further agree that the majority decision of the arbitrator(s) shall be binding on us. In case the arbitrators are equally divided in their opinion, they shall appoint another person as umpire, whose award shall be binding on us.
The arbitrator(s) shall make his (their) award within a period of ____________ [here specify the period agreed upon by the parties], or within such further time as is extended by mutual agreement between us in writing. In case the award is not made within the period aforementioned, the reference to arbitration shall stand automatically cancelled, and we shall be free to negotiate for fresh arbitration.
Signature of the parties:
For the Employer: ________________________
For the Workman / Workmen (or Union representative): ________________________
WITNESSES:
1. ________________________
2. ________________________
About this template
What is this template?
This document is a formal submission agreement used to initiate arbitration for industrial or labor disputes. It is not an employment contract or a general arbitration policy; it is a specific instrument for an existing dispute. It contains unique requirements for stating the total and affected number of workmen in the undertaking.
When should you use it?
Use this form when both parties in an industrial relationship have already disagreed and choose arbitration over a tribunal or court. Use a Settlement Agreement instead if the parties are ending the relationship and waiving claims without a third-party award.
What's inside
| Clause | Name | What it does |
|---|---|---|
| Agreement | Reference to Arbitration | Parties commit to refer specific matters in dispute to named arbitrators at a specified address for a binding resolution. |
| Paragraph 2 | Binding Nature and Umpire | A majority decision of the arbitrators binds both parties; if equally divided, they must appoint an umpire whose award is final. |
| Paragraph 3 | Time for Award | The arbitrator must issue the award within the agreed period or the reference stands automatically cancelled unless extended in writing. |
Who it's for
- an employer and a workman seeking to resolve a specific industrial dispute through a private arbitrator
- a trade union representative and a business establishment formalising a reference to arbitration for affected workmen
How long it runs and how it's signed
How long
Runs until the work is done
Stated duration
[here specify the period agreed upon by the parties]
Signed by
For the Employer, For the Workman / Workmen (or Union representative)
Witness
Required
Notarisation
Not required
Categories
Jurisdiction
India
Document info
GitLaw document. Document created on Fri Jun 26th, 2026. Last updated on Wed Jul 15th, 2026.
This document is public
Licensed under CC BY 4.0 (Attribution).
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