Limited judicial review of non-speaking arbitral awards bars reappraisal of evidence and merits-based interference.

Judicial interference with a non-speaking arbitral award under the Arbitration Act, 1940 is confined to the limited grounds in sections 30 and 33. A court cannot reappraise evidence, substitute its own conclusions for those of the arbitrator or umpire, or infer error by probing the arbitrator's mental process from a fresh review of the record. Interference is justified only where the award shows misconduct, follows supersession or invalid proceedings, or discloses patent illegality, perversity, or an error of law apparent on the face of the award. The High Court's merits-based scrutiny exceeded this narrow scope, and the award should not have been set aside.

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Issues: Scope of judicial interference with a non-speaking arbitral award under sections 30 and 33 of the Arbitration Act, 1940, and whether the High Court could set aside the award by reappraising evidence or treating it as otherwise invalid.

Analysis: The limited grounds in section 30 governed interference with an arbitral award, and the court could not reassess evidence or substitute its own view for that of the arbitrator or umpire. Where the award was non-speaking, the court could not probe the mental process of the arbitrator or infer errors from a fresh evaluation of the record. Interference was permissible only where the award disclosed misconduct, was made after supersession or invalidity of proceedings, or suffered from patent illegality, perversity, or an error of law apparent on the face of the award. The High Court's approach in setting aside the award on merits went beyond the permissible scope of review.

Conclusion: The High Court was not justified in interfering with the award, and the award ought not to have been set aside on the grounds recorded.

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