Business Law

Arbitrator Cannot Rewrite Contract Terms Based on Policy Directives

Supreme Court sets aside arbitral award that attempted to rewrite contractual terms contrary to Railway Board's policy directives. Court rules arbitrator exceeded jurisdiction by ignoring binding policy circulars and contractual terms agreed upon by parties.

Case Reference: Indian Railways Catering and Tourism Corp. Ltd vs M/s Brandavan Food Products Decided by: Supreme Court of India Date: November 07, 2025

❓ Questions

(i) CAN AN ARBITRATOR REWRITE CONTRACTUAL TERMS THAT ARE BASED ON BINDING POLICY DIRECTIVES OF THE RAILWAY BOARD?

(ii) IS AN ARBITRAL AWARD THAT CONTRADICTS EXPRESS POLICY CIRCULARS AND CONTRACTUAL TERMS PATENTLY ILLEGAL AND IN CONFLICT WITH PUBLIC POLICY?

✅ Answers

(i) No, an arbitrator cannot rewrite contractual terms that are based on binding policy directives. The arbitrator exceeded jurisdiction by interpreting contractual terms contrary to the language used therein, which merely mirrored the policy decisions of the Railway Board which were binding in nature.

(ii) Yes, an arbitral award that contradicts express policy circulars and contractual terms is both patently illegal and in conflict with the public policy of India. Such awards violate Section 34(2A) and Section 34(2)(b)(ii) of the Arbitration and Conciliation Act, 1996.

⚖️ Understanding the Legal Principles

🔹 Arbitrator Cannot Rewrite Contract

  • Arbitrator must respect binding policy directives incorporated in contracts
  • Cannot rewrite terms contrary to express language of agreement
  • Must take into account terms of contract under Section 28(3)
  • Policy decisions of statutory bodies are binding on arbitrators

🔹 Policy Directives Are Binding

  • Railway Board circulars form part of contractual framework
  • Contracts merely reflect policy decisions of statutory authority
  • Parties enter contracts with knowledge of policy framework
  • Policy changes during contract term must be complied with

🔹 Patent Illegality Ground

  • Awards violating policy directives are patently illegal
  • Such awards conflict with public policy of India
  • Violation of Section 28(3) constitutes patent illegality
  • Court can set aside under Section 34(2A) and 34(2)(b)(ii)

🔹 Contractual Interpretation Limits

  • Interpretation must respect contractual hierarchy
  • Policy circulars have precedence over other documents
  • Cannot create new contract contrary to policy framework
  • Must consider trade usages and policy context

📜 Key Legal Timeline

May 2013

Tender Issued: Northern Railway issues tender for catering services based on 1999 catering policy

Oct 2013

Policy Changes: Railway Board introduces combo meal concept, then replaces with regular meal at combo price

Jan 2014

Contract Award: BFP awarded contract with knowledge of revised policy terms

Apr 2014

MLA Signed: Master License Agreement executed incorporating policy terms

Jun 2015

First Representation: Caterers raise concerns about pricing disparity

Apr 2022

Arbitral Award: Arbitrator awards differential payments contrary to policy terms

Nov 2025

Supreme Court Ruling: "Arbitrator cannot rewrite contract terms based on policy" - sets aside award

🧭 Your Action Plan: Dealing with Arbitration & Policy Contracts

📝 When Entering into Contracts with Government Entities

✅ Understand Policy Framework

  • Review all relevant policy circulars and directives
  • Understand hierarchy of contractual documents
  • Note unilateral modification clauses in contracts
  • Assess risk of policy changes during contract term

✅ Challenge Policy Terms Before Contract

  • Challenge unfair policy terms before contract execution
  • Use writ jurisdiction if policy terms are arbitrary
  • Seek clarification on ambiguous policy provisions
  • Document objections to unfair contract terms

✅ Protect Rights During Arbitration

  • Argue binding nature of policy directives
  • Highlight arbitrator's limited jurisdiction
  • Cite contractual hierarchy and precedence clauses
  • Maintain challenge to arbitral award if violates policy

⚖️ Key Legal Provisions to Reference

Legal Provision What It Means Application in This Case
Section 34(2A)
Arbitration Act
Ground for setting aside domestic awards for patent illegality Award rewriting policy-based contract terms is patently illegal
Section 34(2)(b)(ii)
Arbitration Act
Ground for setting aside awards against public policy Award violating binding policy directives conflicts with public policy
Section 28(3)
Arbitration Act
Arbitrator must consider contract terms and trade usages Arbitrator failed to consider binding policy as trade usage
Clause 21.1 MLA
Contract Hierarchy
Policy circulars have precedence over other documents Arbitrator ignored contractual hierarchy giving primacy to policy

📘 Key Legal Terms Explained

Patent Illegality

Illegality that appears on the face of the award. When an award violates express terms of contract or statutory provisions, it becomes patently illegal.

Public Policy of India

The fundamental policy of Indian law, interests of India, justice or morality. Awards violating binding policy directives conflict with public policy.

Contractual Hierarchy

The order of precedence among contractual documents. Policy circulars often have higher precedence than other contractual terms.

Policy Directives

Official instructions issued by government authorities that form part of contractual framework and are binding on parties.

🚨 What to Avoid in Policy-Based Contracts

❌ Don't Ignore Policy Framework

  • Don't enter contracts without understanding policy context
  • Avoid assuming arbitrator can override policy directives
  • Don't ignore unilateral modification clauses
  • Avoid challenging policy terms only after contract execution

❌ Don't Rely on Equitable Arguments

  • Don't expect arbitrator to rewrite unfair but clear terms
  • Avoid equitable arguments against express policy terms
  • Don't assume financial hardship justifies contract rewrite
  • Avoid delaying policy challenges until arbitration stage

💡 Core Takeaway from the Supreme Court

"The Arbitrator was, therefore, not justified in undertaking interpretation of the contractual terms contrary to language used therein, which merely mirrored the policy decisions of the Railway Board which were binding in nature. In effect, the Arbitrator practically rewrote the contract between the parties in such a manner that it was in contradiction with the policy decisions... which he could not have touched."

This judgment reinforces that arbitrators must respect the contractual framework and binding policy directives. Parties entering into contracts with government entities must understand that policy terms form an integral part of the contractual relationship and cannot be rewritten through arbitration based on equitable considerations.

📞 When to Seek Professional Help

👨‍⚖️ Legal Counsel Essential For

  • Reviewing government contracts with policy frameworks
  • Challenging arbitral awards that rewrite policy terms
  • Navigating contractual hierarchies and precedence clauses
  • Challenging unfair policy terms before contract execution
  • Complex arbitration involving statutory policy directives

📝 You Can Handle With Support

  • Basic understanding of policy framework in contracts
  • Identifying unilateral modification clauses
  • Initial assessment of arbitrator's jurisdiction limits
  • Understanding basic principles from this judgment
  • Monitoring compliance with policy directives

⚠️ DISCLAIMER

This content is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for specific legal guidance. The information provided is based on judicial interpretation and may be subject to changes in law.

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This analysis decodes a complex arbitration judgment to help businesses understand their rights and limitations when dealing with government contracts and policy frameworks.