Statutory dichotomy between "particular dispute" under Section 21 and "claim" under Section 23

There is a deliberate legislative distinction between the phrase "particular dispute" used in Section 21 and the term "claim" employed in Section 23 of the Arbitration and Conciliation Act, 1996. While Section 21 specifies the date on which arbitral proceedings commence in respect of a particular dispute for limitation purposes without requiring any articulation of specific reliefs, Section 23 governs the substantive framing of issues and statement of claims before the arbitral tribunal. Sub-section (1) of Section 23 does not require, either expressly or impliedly, that the statement of claim must strictly mirror or be confined to the specific disputes set out in the Section 21 notice. Any limitations on the nature or content of claims, set-offs, or counterclaims must be sourced exclusively from the statutory text of Section 23 and the arbitration agreement, rather than importing artificial jurisdictional barriers from Section 21 into the tribunal's merits review. (M/s Bhagheeratha Engineering Ltd. Vs State of Kerala | 2026 INSC 4)