Arbitration model clause

Arbitration · Model Clauses · Schedule J

The FEAM Arbitration Clause

A dispute-resolution clause is the switch that routes a future dispute to FEAM. Adopt one of the clauses below into your contracts, agreements, or standard templates — and any dispute that arises is administered under the FEAM Arbitration Rules, with a fixed procedure, a vetted panel, and a published fee schedule. Ten drafted variants cover standard, expedited, MSME, multi-tier, online, and international matters.

10
Model clause variants
Institutional Rule
FEAM Institutional Rules, 2026
1996
Aligned with the Arbitration & Conciliation Act
Configurable
Seat, language & tribunal size are yours to set
How Adoption Works

From clause to institutional resolution, in four steps

Adopting a FEAM clause takes minutes and needs no prior relationship with FEAM. The clause does the work — it decides, in advance, where a future dispute will go and how it will be run.

STEP 01

Choose the variant

Pick the clause that matches your contract — standard, expedited, sector, or international.

STEP 02

Specify four essentials

State the seat, governing law, language, and number of arbitrators explicitly.

STEP 03

Insert into your agreement

Drop the clause into the dispute-resolution section of your contract or standard template.

STEP 04

Disputes route to FEAM

Any future dispute is administered by FEAM under its Rules — no further step required.

Before You Insert Any Clause

The four things every clause should state

Schedule J asks you to specify four elements in every clause. The FEAM Rules supply a default for each where your contract is silent — but stating them explicitly is what prevents argument once a dispute has already begun.

01 · Seat

Where the arbitration is legally anchored

The seat fixes the supervisory court and the law governing the proceedings. Absent agreement, the seat is New Delhi, India, unless the Tribunal determines another Indian seat is more appropriate after consulting the parties.

Legal basis — Rule 3.1; Section 20, Arbitration & Conciliation Act, 1996
02 · Governing Law

The law applied to the substance of the dispute

As agreed by the parties. Absent agreement, the Tribunal applies the law it considers most appropriate. The law governing the proceedings themselves (the lex arbitri) is the law of the seat.

Legal basis — Rule 4; Section 28, Arbitration & Conciliation Act, 1996
03 · Language

The language of the proceedings

As agreed by the parties. Absent agreement, the language is English. In MSME Fast-Track proceedings (Schedule C), Hindi-language proceedings may be facilitated by FEAM on request.

Legal basis — Rule 3.3; Section 22, Arbitration & Conciliation Act, 1996
04 · Number of Arbitrators

Sole arbitrator or three-member tribunal

As agreed. Absent agreement, by amount in dispute: up to ₹2 crore, one arbitrator; ₹2–10 crore, one or three at FEAM's determination; above ₹10 crore, three unless the parties agree to one. Streamlined, Expedited and MSME tracks are sole-arbitrator only.

Legal basis — Rule 15.1
Schedule J · The Clause Library

Ten model clauses, ready to copy

Each clause below is reproduced from Schedule J of the FEAM Institutional Rules. Tap Copy to lift the exact text, then replace each [●] with your own detail before inserting it into your contract.

Start here — the two you'll reach for most
J.1 · STANDARD FEAM ARBITRATION

Standard clause

Use when: most commercial contracts. The full FEAM Arbitration Rules apply, with the tribunal size scaled to the dispute.

“Any dispute, controversy, or claim arising out of or in connection with this Agreement, including its breach, termination, or invalidity, shall be finally resolved by arbitration administered by the Forum for Excellence in Arbitration & Mediation (FEAM) in accordance with the FEAM Arbitration Rules in force at the time of commencement. Seat of arbitration: [●]. Language: English. Number of arbitrators: [one / three]. Governing law: Indian law.”
Replace [●] before use
J.8 · INTERNATIONAL COMMERCIAL

International commercial arbitration

Use when: cross-border contracts with parties of different nationalities. Three-member tribunal; the chair is of a neutral nationality.

“All disputes arising out of or in connection with this Agreement shall be resolved by international commercial arbitration administered by FEAM under FEAM Arbitration Rules. Seat: [●]. Language: English. Three arbitrators. The Chairperson shall be of a nationality different from all parties.”
Replace [●] before use
Faster & lower-value tracks
J.2 · EXPEDITED (SCHEDULE B)

Expedited procedure

Use when: disputes up to ₹2 crore, targeting an award within six months, before a sole arbitrator.

“Any dispute shall be finally resolved by arbitration administered by FEAM under FEAM Arbitration Rules and Schedule B (Expedited Procedure). Seat: [●]. Language: English.”
Replace [●] before use
J.3 · STREAMLINED (SCHEDULE A)

Streamlined procedure

Use when: disputes up to ₹50 lakh — documents-only, no oral hearing, roughly 90 days.

“Any dispute shall be finally resolved by arbitration administered by FEAM under FEAM Arbitration Rules and Schedule A (Streamlined Procedure). Seat: [●].”
Replace [●] before use
J.4 · MSME FAST-TRACK (SCHEDULE C)

MSME fast-track

Use when: MSME disputes up to ₹50 lakh, resolved on a fixed, all-in fee.

“Any dispute shall be resolved by arbitration under the FEAM MSME Fast-Track Procedure (Schedule C of FEAM Arbitration Rules,2026). Seat: [●].”
Replace [●] before use
Step-tiered & mediation
J.5 · MULTI-TIER

Negotiation → mediation → arbitration

Use when: you want an escalation ladder — talk first, mediate next, arbitrate only if needed — in a single clause.

“(1) Good-faith negotiations for 30 days from written dispute notice. (2) If unresolved: FEAM mediation under FEAM Mediation Rules for up to 60 days. (3) If unresolved: final resolution by FEAM arbitration under FEAM Arbitration Rules. Non-compliance with steps (1) or (2) shall not bar arbitration. Seat: [●]. Governing law: [●].”
Replace [●] before use
J.6 · MEDIATION ONLY

Mediation only

Use when: you want a mediated settlement — binding and enforceable under the Mediation Act, 2023 — without arbitration.

“The parties agree to resolve any dispute by mediation administered by FEAM under FEAM Mediation Rules. A Mediated Settlement Agreement shall be binding and enforceable under the Mediation Act, 2023.”
Ready as written

A pre-arbitration step won't cost you the right to arbitrate

A common worry with multi-tier clauses is that skipping the negotiation or mediation step could sink the arbitration. Under the FEAM Rules it does not — failure to complete an earlier tier does not, of itself, deprive the Tribunal of jurisdiction, unless that tier is an express condition precedent to arbitration and binding precedent at the seat confirms that strict non-compliance defeats jurisdiction.

FEAM encourages parties to use the earlier tiers, and rewards it: parties who first attempt FEAM mediation on the same dispute receive a 10% reduction in arbitration administrative fees.

Legal basis — Rule 88.1 and Rule 88.2
Specialised
J.7 · FULL ODR / ONLINE

Online arbitration

Use when: you want the entire matter run online — filing, hearings, and award — through FEAM's ODR platform (Schedule G).

“Any dispute shall be resolved by online arbitration administered by FEAM through FEAM's ODR platform, under FEAM Arbitration Rules and FEAM ODR Protocol (Schedule G). All submissions, hearings, and the award shall be in electronic form. Seat: [●].”
Replace [●] before use
J.9 · EMERGENCY ARBITRATOR OPT-IN

Emergency arbitrator opt-in

Use when: you may need urgent interim relief before a tribunal is constituted (Schedule E), expressly agreed in advance.

“Disputes shall be finally resolved by FEAM arbitration under FEAM Arbitration Rules. The Emergency Arbitrator Procedure (Schedule E) shall apply and is expressly agreed to by the parties. Seat: [●]. Governing law: [●].”
Replace [●] before use
J.10 · APPOINTING AUTHORITY ONLY

UNCITRAL ad hoc — FEAM as appointing authority

Use when: you want ad hoc arbitration under the UNCITRAL Rules, with FEAM appointing the tribunal but not administering the case.

“Disputes shall be resolved by ad hoc arbitration under the UNCITRAL Arbitration Rules, with the Forum for Excellence in Arbitration & Mediation (FEAM) designated as the Appointing Authority. Seat: [●]. Language: English. Number of arbitrators: [one / three].”
Replace [●] before use
For Organisations

Adopting FEAM's clause across a portfolio of contracts?

For organisations standardising dispute resolution across loan documents, vendor agreements, or policy templates, FEAM offers clause-adoption support and empanelment arrangements. Talk to us about rolling a FEAM clause into your standard forms.

These model clauses are starting points, not legal advice. Adapt them with legal advice to your transaction, and always specify the seat, governing law, language, and number of arbitrators explicitly. Clauses reproduced from Schedule J, FEAM Institutional Rules, Version 1.0 (2026).