Arbitral award completeness: silence on submitted claims can amount to rejection, and agreed property values limited jurisdictional challenge.

An arbitral award expressed to decide all matters referred to arbitration is presumed complete, and silence on a submitted claim ordinarily amounts to rejection unless the reference or the nature of the claim requires express adjudication. On that basis, the omission to specifically address accounting on a void lease, future company management, and misappropriation did not make the award incomplete; the general law on company management would operate and the unaddressed allegations were treated as rejected. The arbitrator also did not exceed authority by dealing with the Ketugram land, which was only a cost-and-balance distribution mechanism, or by using property values already agreed by the parties. The award was upheld.

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Issues: (i) Whether the arbitral award was incomplete for failure to expressly deal with the claim for accounting on the void lease, directions for future management of the company, and the allegation of misappropriation; and (ii) whether the arbitrator exceeded his authority by dealing with the Ketugram land and by adopting the values of properties used in the partition.

Issue (i): Whether the arbitral award was incomplete for failure to expressly deal with the claim for accounting on the void lease, directions for future management of the company, and the allegation of misappropriation.

Analysis: The award stated that it was made after considering all allegations and evidence and professed to decide all disputes referred to arbitration. An award framed as one made of and concerning all matters in difference carries a presumption of completeness, and silence on a claim ordinarily means that the claim has been rejected. The claim for accounting did not necessarily follow from the declaration that the lease was void, and the absence of a specific direction on future management did not create a legal lacuna because the general law governing company management would operate. The omission to grant relief on the misappropriation allegation was likewise consistent with an implied rejection of that claim.

Conclusion: The award was not incomplete on any of these grounds, and the challenge failed on this issue.

Issue (ii): Whether the arbitrator exceeded his authority by dealing with the Ketugram land and by adopting the values of properties used in the partition.

Analysis: The provision regarding the Ketugram land was only a mechanism to meet costs and distribute the balance among the persons entitled, and not an impermissible creation of a trust over disputed property. The property valuations were those to which the parties themselves had agreed before the arbitrator, so the award did not depend on an unauthorized valuation exercise by the arbitrator.

Conclusion: No excess of jurisdiction or legal infirmity was shown on these grounds.

Final Conclusion: The award was upheld in full and the appeal was dismissed with costs.

Ratio Decidendi: Where an award is expressed to decide all matters referred to arbitration, it is presumed to be complete and silence on a submitted claim may amount to its rejection, unless the reference or the nature of the claim requires an express adjudication.

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