The Court held that the prohibition against the appointment of a sole arbitrator by one of the parties to the agreement as articulated in Perkins Eastman Architects DPC. v. HSCC (India) Limited would also apply to ongoing arbitrations which were being conducted under the Arbitration Act as amended by the Arbitration and Conciliation (Amendment) Act, 2015.

REFER : Proddatur Cable TV Digi Services v. Siti Cable Network Limited [Judgment dated January 20, 2020 in O.M.P. (T) (COMM.) 109/2019]