Arbitral award review is limited where reasons are supported by record and no natural justice breach is shown.

A speaking arbitral award will not be interfered with under Article 136 merely because a different view on the evidence or reasons is possible. The Court held that the arbitrator had considered the relevant material on delay, extension of time, site availability, rescission, and rival monetary claims, and that the question whether time was of the essence was a mixed question of law and fact. It further stated that arbitral proceedings are not governed in full rigour by the Indian Evidence Act, 1872, and that interference is warranted only for violation of natural justice, non-consideration of relevant material, or a manifest legal infirmity. The challenge failed and the award remained undisturbed.

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Issues: Whether the reasonableness of the reasons given by an arbitrator in a speaking award is open to challenge under Article 136 of the Constitution of India, and whether the award was vitiated for want of natural justice or improper appraisal of evidence.

Analysis: The award was supported by reasons based on the material on record, and the arbitrator had considered the relevant circumstances bearing on delay, extension of time, availability of site, rescission of contract, and the rival monetary claims. The Court held that the question whether time was the essence of the contract was a mixed question of law and fact, and that the Court would not reappraise evidence merely because a different conclusion might have been possible. It further held that section 1 of the Indian Evidence Act, 1872 does not apply in its rigour to arbitral proceedings, and that an award cannot be set aside unless there is violation of natural justice, non-consideration of relevant material, or a manifest legal infirmity.

Conclusion: The reasonableness of the arbitrator's reasons was not justiciable in the present challenge, and the award was not vitiated. The challenge to the award failed.

Final Conclusion: The petition failed on merits, and the arbitral award as upheld by the High Court remained undisturbed.

Ratio Decidendi: A speaking arbitral award cannot be interfered with merely because the Court may prefer a different view on the evidence or the reasons, so long as the arbitrator acts within jurisdiction, considers relevant material, and does not violate natural justice.

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