In the captioned case, the arbitral award was pronounced in a virtual hearing attended by advocates of both parties. A signed copy of the award was emailed to the advocates on the same day.

A challenge under Section 34 of the Arbitration and Conciliation Act, 1996 ("Act") came to be filed before the Delhi High Court beyond the 3-month limitation period. It was argued that the service of award through email did not amount to a valid delivery under Section 31(5) of the Act and that the limitation period should run from the date of receiving the physical copy of the award.

The Court while analysing the issue, turned its attention to precedents including Ministry of Youth Affairs and Sports V/s Ernst & Young (P.) Ltd.1, wherein the Court had held that the delivery of a digitally singed or authenticated copy of an award by email is sufficient to trigger the limitation period emphasizing that technological advancements allow for authenticated digital copies to be considered valid for all legal purposes. The Court reaffirmed that "signed copy" will include the original award and authenticated electronic versions. Accordingly, service of an award through email satisfies the requirements of Section 31(5) of the Act.

The Court, further, also went on to mention that delivery of the signed copy of the award by Arbitral Institution on behalf of the Tribunal to the parties and / or their authorized counsel shall be a valid service under Section 31(5) of the Act.