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Issues: Whether the dispute regarding revision of electricity rates fixed by the State Government before constitution of the Board arose under the Electricity (Supply) Act, 1948 so as to attract arbitration under section 76.
Analysis: The dispute over enhanced rates was founded on the State Government's pre-Board action and rested in contract or unilateral governmental action rather than on any provision of the Electricity (Supply) Act, 1948. Section 60 could not apply because the underlying matter was not one done for any purpose of that Act, and section 49 was inapplicable because it governed the Board after its constitution and not the earlier governmental revision. The Act did not contain any provision making a dispute of this nature one required to be referred to arbitration, and section 76 could not be read as covering every dispute between the Government or Board and any person irrespective of nexus with the Act.
Conclusion: The dispute did not arise under the Electricity (Supply) Act, 1948, and therefore section 76 did not compel arbitration; the objection to arbitration failed in favour of the appellant.
Ratio Decidendi: Section 76 of the Electricity (Supply) Act, 1948 applies only to disputes having their source in or relation to that Act, and a pre-Board rate revision resting on contract or governmental action outside the Act is not compulsorily referable to arbitration under that provision.