1. The present petition has been filed under Section 11 (6) of the Arbitration and Concilation Act, 1996 r/w Clause 2 of the Appointment of Arbitrator's Scheme by the Chief Justice of Madras High Court's Scheme, 1996, for appointment of an independent sole Arbitrator to resolve the disputes between the parties arising out of the Insurance claim under Policy No.710700/11/13/01/00000035.

2. The petitioner company is public limited company engaged in the manufacture of Poly woven bags, having substantial portion of equity shares held by the public. The company has been insuring their manufacturing units covering stocks, plant and machineries and other fixtures for the last 20 years and no prior claim has been made.

3. It is the case of the petitioner that they took insurance coverage for their manufactured goods under the Standard Fire and Special Perils Policy from the respondent/New India Assurance Company, for a total sum of Rs.24.15 Crores, which was subsequently enhanced to Rs.27.15 Crores during the policy period from 01.05.2013 to 30.04.2014, covering the stocks in its Factory units at Ponneri, Athipedu and Cholavaram. The petitioner had already insured plant and machinery along with other fixtures and fittings situated in these three locations with another Insurance Company viz., United India Insurance Company Ltd., for the period from 11.01.2013 to 10.01.2014 for a total sum of Rs.8,82,48,610/-.

4. While so, a fire accident occurred on 23.11.2013 at about 10.30 p.m., at the petitioner's Athipedu factory unit, as a result of which petitioner company had a huge loss due to the damage to stocks, plant and machineries and other fixtures. The petitioner lodged separate claims with the Insurance company.

5. It is the case of the petitioner that the insurance policy issued by the respondent herein covered the petitioner's stocks and stock in process at its Athipedu factory unit where the fire accident had occurred, for a sum of Rs.11.5 Crores, which was subsequently enhanced by 1 Crore Rupees for each location at the request of the respondent vide its letter dated 15.10.2013 to cover the additional stock of finished goods. The respondent also made an endorsement under the policy for enhancement of the sum insured at all the three locations by 3 Crores in all.

6. Petitioner claims that pursuant to the investigation done by the surveyors by both the Insurance companies and subsequent investigation done by them to ascertain the cause and extent of loss, United India Insurance Company Ltd., had released an initial amount of Rs.70,00,000/- (rupees seventy lakhs) towards claim for damage/loss to the petitioner's plant and machineries, fixtures and fittings. Petitioner submits that they are on the verge of getting the balance claims Policy settled with United India Insurance Company Ltd. On 24.11.2013 and thereafter, petitioner submitted various documents in support of their claim at the instance of the Surveyor appointed on behalf of the respondent herein. Nearly one year after the accident, after several communications for settlement of the claim, the respondent repudiated the petitioner's claim on the ground that it was not a reasonable, fair and bona fide estimation of loss and alleged that the quantum of loss was exaggerated and supported by manipulated documents. The petitioner submits that without giving an opportunity of hearing, the respondent rejected the petitioner's claim, invoking condition No.8 of the policy conditions.

7. Petitioner claims that the cause of fire is covered under the policy conditions and it is on the basis of this, that the other Insurance company namely United India Insurance Company Ltd has paid the interim amount of Rs.70,00,000/- as claimed by the petitioner before them. Thus, the petitioner submits that the allegation of the respondent herein that the accident is doubtful is only a pretext to avoid their liability. According to the petitioner, the primary issue involved in this petition is t