 Court cannot reassess evidence even if arbitrator committed an error.

1
 The Court has no power to substitute its own valuation of conclusion on law/fact.2
 The Court cannot sit in appeal over conclusions of arbitrators and reexamine or
reappraise evidence which had already been considered by the arbitrator.3
 However erroneous the decision of the arbitrator may be, any Court cannot interfere with
it.4
 The arbitral award is not open to challenge on the ground that the arbitral tribunal has
reached a wrong conclusion or has failed to appreciate facts/evidence since it is outside
the scope of section 34.5
 The findings of the arbitrator appointed by the parties should normally be accepted
without demur.6
 Even in the cases of non-speaking awards, it is not open to the Court to probe into the
mental process of the arbitrator where he has not provided any reasoning for his
decision.7
 The findings of the arbitrator on factual matrix should not be disturbed even if these are
erroneous. The scope of challenge as to the findings of facts based on material evidence
is almost non-existent.8
 The 1996 Act makes provisions for the supervisory role of courts for the review of
arbitral award only to ensure fairness. Intervention of the Court is only envisaged in a few
circumstances like in case of ‘fraud’ or ‘bias’ by the arbitrators, violation of natural
justice, etc. The supervisory role of the Court at minimum can be justified as parties to
the agreement make a conscious decision to exclude the court’s jurisdiction by opting for
arbitration as they prefer the expediency and finality offered by it.9

1
Eastern And North East Frontier Railway Co-operative Bank v B Guha & Co AIR 1986 Cal 146; Uttar Pradesh
State Electricity Board v Searsole Chemicals (1995) 2 Arb LR 320.
2
Francis Klein Pvt Ltd v Union of India (1995) 2 Arb LR 298.
3
RS Builders v DDA AIR 1995 Del 10; Swaran Singh v University of Delhi AIR 1994 Del 290.
4
Bharu Kure Jat v Tara Lal AIR 1962 Punj 173.
5
Laxmi Mathur v Chief General Manager, MTNL (2000) 2 Arb LR 684 (Bom); State of Rajasthan v Puri
Construction Co (1994) 6 SCC 485.
6
Numatigarh v. Daclim Industries (2007) 8 SCC 466.
7
Markfed Vanaspati v Union of India (2007) 7 SCC 679; New India Civil Erectors v ONGC (1997) 11 SCC 75;
State of AP v Rayanim (1990) 1 SCC 433.
8
Bumbrah Electrical Co v DDA (2003) 1 Arb LR 423 (Ori).
9
McDermott International Inc v Burn Standard Co Ltd (2006) 11 SCC 181.