Form for agreement between the Employer and Employees for Reference of Disputes to Arbitration

Updated 15 July 2026

A form of agreement between an employer and its workmen (or their union) to voluntarily refer an industrial dispute to arbitration under section 10A of the Industrial Disputes Act, 1947 in India. The parties identify the matters in dispute, the establishment and the number of workmen affected, and the agreed arbitrator(s), and agree that the arbitrators' majority decision — or an umpire's award, if the arbitrators are equally divided — will be binding, with the award to be made within an agreed period. Note: for such a reference to be effective, a copy of the agreement must be forwarded to the appropriate Government and the conciliation officer and notified in the Official Gazette, as required by section 10A.

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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?

Form for agreement between the Employer and Employees for Reference of Disputes to Arbitration is a free, ready-to-use Arbitration template you can open, customize, and download on GitLaw. It gives you a professionally structured starting point, so you never have to draft from a blank page. The wording is plain and modern, organized into clear sections that are easy to read, edit, and adapt to your own situation before you share or sign it.

When should you use it?

Reach for this Arbitration template whenever you need a reliable agreement quickly and want to be sure the essentials are covered. It suits individuals, freelancers, startups, and established businesses alike. Instead of paying for a document drafted from scratch, you can start here, tailor the details to your arrangement, and have a polished draft ready in minutes. This version is drafted with India in mind, though you should always review the final wording against the laws that apply to you.

What's typically included?

A well-drafted Arbitration usually sets out the parties involved, the scope of the agreement, and each side's rights and responsibilities. Expect sections covering key terms and definitions, how long the agreement lasts, how it can be ended, and what happens if something goes wrong. This template brings those building blocks together in a sensible order, so you can focus on the specifics rather than worrying about what to include. Open it to read the full document, then sign up to edit, negotiate, and e-sign it directly in GitLaw.