Section 89 of the Civil Procedure Code that makes reference to mediation as a formulation of alternative dispute resolution (ADR), casts an obligation on the court before which a case is brought for hearing to consider if the subject matter of dispute is fit for disposal by any process other than a trial of suit and refer to one or other modes of ADRs. Companies Act, 2013 contains provisions under Section 442 for the Adjudicating Authority to refer a matter pending before it for mediation to a person empanelled as mediator. Commercial Courts, Commercial Divisiion and Commercial Appellate Division of High Courts Act, 2015 mandates through Section 12 A that a person who has a dispute that could be tried only under the Act shall first go through mediation exercise, unless resort to court for urgent interim order is necessary, before resorting to litigation.