Unreasoned arbitral award and pendente lite interest: principal award upheld, but arbitration-period interest deleted.

An arbitral award made after a full hearing was not invalid merely because it was unreasoned, ambiguous, or said to show non-application of mind, where no misconduct, denial of natural justice, or error of law apparent on the face of the award was established; the principal award was accordingly sustained. Pendente lite interest, however, was not payable on the governing law unless the reference fell within the limited category where the arbitrator exercised the court's own powers in a suit-type reference, and that basis was absent here; the interest component was therefore deleted. The principal award remained intact, but the arbitration-period interest was set aside.

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Issues: (i) whether the arbitral award could be set aside for absence of reasons, ambiguity, and alleged non-application of mind; (ii) whether the award of pendente lite interest could be sustained.

Issue (i): whether the arbitral award could be set aside for absence of reasons, ambiguity, and alleged non-application of mind.

Analysis: The award was a lump sum award made after a full arbitration hearing extending over several sittings. No misconduct in the proceedings, violation of natural justice, or error of law apparent on the face of the award was shown. Mere absence of reasons did not, by itself, invalidate the award on the settled law then prevailing. The Court held that the High Court was justified in restoring the award on the principal claims.

Conclusion: The challenge to the award on the ground of absence of reasons, ambiguity, and non-application of mind failed.

Issue (ii): whether the award of pendente lite interest could be sustained.

Analysis: The arbitrators had awarded interest up to the date of the award. On the law as declared in the relevant precedent, pendente lite interest was not payable in such a case unless the reference fell within the limited category where the arbitrator exercised the Court's own powers in a suit-type reference. That situation was absent here.

Conclusion: The grant of pendente lite interest was unsustainable and was deleted.

Final Conclusion: The award was substantially upheld, but the component granting interest for the period during the arbitration was set aside, leaving the principal award intact.

Ratio Decidendi: An unreasoned arbitral award is not invalid merely because reasons are absent, unless an error of law apparent on the face of the award or misconduct in the proceedings is shown, and pendente lite interest cannot be awarded in the absence of a legal basis recognized by the governing law.

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