Form of Agreement for Reference to Three Arbitrators (India) by OLL

Open Legal LibraryUpdated 19 Oct 2026

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Form of Agreement for Reference to Three Arbitrators

This deed of agreement made on this _________, 2000 between:

1.     Shri PL, aged about ___ years s/o Shri SS r/o ___________________, Delhi, hereinafter called the 1st party.

2.     Shri KL, aged about ___ years s/o Shri SS r/o _________________, hereinafter called the 2nd party.

3.     Shri CL, aged about ___ years s/o Shri SS r/o _____________, hereinafter called the 3rd party.

Whereas the above parties are carrying on business of general

merchandise in partnership under name and style M/s. __________________, at _______________ since ________, 2000.

a.     And whereas share profit or loss in the firm is : 1st party 50%, 2nd party 30% and 3rd party 20%.

b.    And whereas all the three parties are active partners in the partnership business.

c.     And whereas some disputes have arisen among the parties above named and it has become impossible to carry on business under partnership

d.    And whereas the parties hereto have agreed to refer the matter to the arbitration mentioned here under :

                               i        Mr. PK s/o Mr. KP, r/o _________________ .

                              ii        Mr. PK s/o Mr. RP, r/o __________________, and

                             iii        Mr. SK, s/o Mr. JN r/o ___________________.

Now this Agreement Witnesses as Under:

1.             The arbitrators are entitled to decide and determine the following matter of disputes, which are referred to them for final determination and award.

a.     To determine the position of assets and liabilities of the firm.

b.    To prepare the list of sundry debtors and creditors

c.     To divide the assets and liabilities according to the share of the parties.

2.     That the arbitrators shall enter upon the reference with effect from ___________ and shall deliver their award within 4 months.

3.     That the award given by the arbitrators shall be final and binding on the arbitrators.

4.     That the award of the arbitrators shall be final and binding on heirs, legal representatives and assignees of the parties in case of death of any of the party during the course of arbitration proceedings.

5.     That Mr. RN, the 1st arbitrator shall be the President of the arbitration tribunal who will arrange the sitting for arbitration proceedings.

6.     In case of difference of opinion between the arbitrators , the decision of the majority shall be final.

7.     The arbitrators shall fix up the date of hearing and issue notices to the parties for appearance.

8.     That if the parties do not turn up on the date fixed for hearing, the arbitration will proceed ex-parte.

9.     That this agreement shall be binding on the legal representatives, heirs, and assignees in case of death of any of the parties.

10.  If the arbitrators think it proper, they shall appoint an accountant for preparation and finalisation of accounts on fixed remuneration and shall include the remuneration in the cost of arbitration award.

This is a preview. The full template is free on GitLaw.

This is a legal template for a partnership dispute resolution agreement used to refer conflicts between business partners to a panel of three arbitrators. It outlines the scope of the arbitrators' authority, including the valuation of assets, settlement of liabilities, and the binding nature of the final award under Indian law.

About this template

What is this template?

This document is a formal submission to arbitration for three partners carrying on a general merchandise business. It is not a standard partnership agreement, but rather a post-dispute agreement that appoints three named individuals to settle the firm's accounts. It specifically includes provisions for ex-parte proceedings and the appointment of an external accountant.

When should you use it?

Use this when a three-way partnership in India has reached a deadlock and the parties agree to settle the firm's liabilities through a private tribunal rather than litigation. If you only have two partners or wish to use a single arbitrator, use a standard Submission to Sole Arbitrator instead.

What's inside

ClauseNameWhat it does
1Matters of DisputeAuthorizes arbitrators to determine assets and liabilities, list sundry debtors and creditors, and divide firm assets according to party shares.
2Time Limit for AwardRequires the arbitrators to enter upon the reference on a specific date and deliver their final award within 4 months.
3Finality and Binding EffectEstablishes that the award given by the arbitrators is final and legally binding upon all three parties.
6Majority DecisionProvides that if the three arbitrators differ in opinion, the decision of the majority shall prevail as final.
8Ex-parte ProceedingsPermits the arbitration to proceed in the absence of a party if they fail to appear on the fixed hearing date.
10Appointment of AccountantGrants arbitrators the power to appoint an accountant for finalisation of accounts at a fixed remuneration included in the award costs.
12Governing LawMandates that the provisions of the Indian Arbitration & Conciliation Act, 1996 apply to all matters not expressly provided in the deed.

Who it's for

  • partners in an Indian firm holding 50%, 30%, and 20% shares seeking to resolve dissolution disputes
  • business partners who have found it impossible to carry on business and wish to appoint three specific arbitrators
  • legal representatives of partners who require the arbitration award to remain binding after a party's death

How long it runs and how it's signed

How long
Runs until the work is done
Stated duration
4 months
Signed by
1st party, 2nd party, 3rd party
Witness
Required
Notarisation
Not required

Law it's drafted under

Governed by
Indian Arbitration & Conciliation Act, 1996
Jurisdiction
India
Document info
MS Word. Document created on Thu Jul 23rd, 2026. Last updated on Mon Oct 19th, 2026.
This document is public
Licensed under CC BY 4.0 (Attribution).
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