Court Affirms Limited Scope of Judicial Review Under Arbitration Act, Dismisses Allegations of Procedural Irregularities
In a significant ruling, the Delhi High Court dismissed an appeal challenging an arbitral award, emphasizing the limited scope of judicial interference under the Arbitration and Conciliation Act, 1996. The Division Bench, comprising Justices Anil Kshetarpal and Amit Mahajan, upheld the decisions of the Arbitral Tribunal and the Commercial Court, which had directed the appellant, Om Prakash, to pay Rs. 6,00,000 along with interest and litigation costs to the respondent, Smt Laxmi Maurya.
The appellant sought to set aside the arbitral award on multiple grounds, including alleged delays in pronouncement, admissions regarding the loan amount, and the insufficient stamping of mortgage agreements. The court, however, reiterated that mere delay in delivering an arbitral award is not a ground for setting it aside unless it demonstrably impacts the fairness or validity of the decision.
The court further noted that the appellant had admitted to borrowing Rs. 6,00,000, albeit in different tranches, and that the agreements, even if insufficiently stamped, were admissible for collateral purposes under the Registration Act, 1908. The appellant's failure to substantiate repayment claims with credible evidence further weakened his case.
This judgment underscores the judiciary's limited role in arbitral matters, with interference warranted only in cases of patent illegality, violation of public policy, or procedural irregularity causing substantial injustice. The court's decision aligns with established legal precedents, reinforcing the autonomy and finality of arbitral awards.
Bottom Line:
Arbitration and Conciliation Act, 1996 - Mere delay in pronouncement of an arbitral award, by itself, is not a ground for setting aside the award under Section 34 unless it explicitly impacts the reasoning, fairness, or validity of the award.
Statutory provision(s): Arbitration and Conciliation Act, 1996 Sections 34, 37, Indian Stamp Act, 1899 Section 36, Registration Act, 1908 Section 49.
Om Prakash v. Smt Laxmi Maurya, (Delhi)(DB) : Law Finder Doc Id # 2837426
