Reasoned arbitral award requirement excludes a non-speaking decision from section 34 challenge and remand under section 34(4).

An arbitral decision must state reasons under section 31(3) of the Arbitration and Conciliation Act, 1996 unless the parties agree otherwise or the award is on agreed terms; that requirement is mandatory and goes to the validity of the award. A document styled as an award but lacking reasons does not satisfy the statutory definition of an arbitral award, so it is outside the scope of section 34, which applies only to arbitral awards. Section 34(4) cannot cure the absence of reasons because it operates only in relation to a valid award capable of limited correction. Accordingly, a non-speaking arbitral decision cannot be set aside or remitted under those provisions.

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Issues: Whether an arbitral decision that does not state reasons is an arbitral award amenable to challenge under section 34 of the Arbitration and Conciliation Act, 1996, and whether the matter can be remitted under section 34(4) for supplying reasons.

Analysis: Under section 31(3) of the Arbitration and Conciliation Act, 1996, an arbitral award must state the reasons upon which it is based unless the parties have agreed otherwise or the award is on agreed terms. The requirement of reasons is mandatory and is an essential feature of a valid arbitral award. A document styled as an award but lacking reasons does not satisfy the statutory requirement of an arbitral award. Since section 34 provides for setting aside only an arbitral award, a non-speaking adjudication that omits reasons does not fall within the scope of section 34. Section 34(4) cannot be used to cure the absence of reasons, because that provision operates only where there is a valid arbitral award capable of being adjourned for limited corrective action.

Conclusion: The alleged award dated 30-3-2000, being without reasons, was not an arbitral award for the purpose of section 34 and could not be remitted under section 34(4).

Final Conclusion: The petition succeeded to the extent of obtaining a declaration that the impugned document was not an arbitral award, though the court did not set it aside under section 34.

Ratio Decidendi: An arbitral decision that does not contain reasons, where reasons are statutorily required, is not a valid arbitral award and therefore cannot be set aside under section 34 or cured by remand under section 34(4).

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