Arbitral award challenge limitation starts only on receipt of the signed copy delivered under the statute.

Limitation for an application to set aside an arbitral award under section 34(3) begins only when the challenging party receives the signed copy of the award delivered in the manner required by section 31(5). Receipt of an unsigned copy, or a copy obtained from another source, does not start limitation. The statutory requirement to deliver a signed award copy to each party is treated as substantive, and the time limit for challenge is linked to that legally mandated delivery and receipt.

---

---

Issues: Whether the period of limitation for an application to set aside an arbitral award under section 34(3) begins from receipt of any copy of the award or only from delivery of a signed copy of the award under section 31(5).

Analysis: Section 31(5) requires that after an award is made, a signed copy shall be delivered to each party. Read with section 34(3), the expression referring to the party having received the arbitral award cannot be isolated from that statutory mandate. The limitation period therefore commences only when the party making the challenge receives the signed copy delivered in the manner contemplated by law. A mere copy received from another source does not trigger limitation. This construction is supported by the earlier authority holding that delivery of the award is a matter of substance and receipt by the party sets limitation in motion.

Conclusion: Limitation under section 34(3) starts only from receipt of the signed copy of the arbitral award delivered under section 31(5), not from receipt of any other copy.

Ratio Decidendi: Where a statute requires delivery of a signed copy of an arbitral award to each party, the limitation period for challenging the award begins only on such delivery and receipt by the party concerned.

---