Template letter to arbitral tribunal seeking additional award for omitted claims under Arbitration Act 1996, s 57(3)(b) (England, Wales and Northern Ireland), including 56-day time limit

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Precedents

[ Insert date ]

[ Insert names and addresses of members of the Tribunal ]

cc: [ Insert names and addresses of other parties to the arbitration ]

Dear [ Members of the Tribunal or name(s) of the arbitrator(s) ],

[ Insert title of arbitration including any reference number ]

We write concerning the award [ insert details, including number (if applicable), and date of award ] (the Award). This is an application for a supplementary award under section 57(3)(b) of the Arbitration Act 1996.

We respectfully contend that the Tribunal did not address [ identify claim(s) omitted ] in the Award. The [ identify issue ] was presented to the Tribunal in the following ways:

[ Include references to pleadings, skeleton arguments and oral evidence in the arbitration including agreed transcripts if available ]

We ask the Tribunal to issue an additional award addressing the [ issue ], and submit that it should [ set out the award sought ].

Under section 57(6) of the Arbitration Act 1996, we request that the additional award be made within 56 days of this application (i.e. by [ insert relevant date ]).

We look forward to your response.

Yours faithfully,

[ Insert signature of respondent’s counsel ]...

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