Arbitral award finality on signing means the arbitrator becomes functus officio and cannot reopen the same claim later.

An arbitral award is complete and final when it is made and signed by the arbitrator under section 14 of the Arbitration Act, 1940; notice to the parties is a separate later step and does not affect validity or finality. Once the award is signed, the arbitrator becomes functus officio on that dispute and cannot reopen or re-adjudicate the same claim in a later award. On the facts, the earlier award on item No. 1 was binding, and the subsequent award could not supersede it.

---

---

Issues: Whether an arbitral award becomes final and binding when it is made and signed by the arbitrator, so that the arbitrator becomes functus officio and cannot re-determine the same claim in a later award.

Analysis: Under section 14 of the Arbitration Act, 1940, an award is complete when it is made and signed. Notice to the parties of the making and signing of the award is a distinct subsequent step and does not control the validity or finality of the award. Once the arbitrator has signed the award, the mandate in relation to that dispute is exhausted and the arbitrator cannot reopen or supersede the same claim by a later award. On the facts, the earlier award concerning item No. 1 was complete and final, and the same claim could not validly be re-adjudicated in the later award.

Conclusion: The earlier award was binding and the arbitrator had become functus officio in relation to that item. The later award could not displace the earlier determination on item No. 1.

Ratio Decidendi: An arbitral award becomes final when it is made and signed by the arbitrator, and thereafter the arbitrator is functus officio in respect of the matter decided.

---