Limited judicial review of arbitral awards: factual complaints and gratuity objections did not justify interference with the award.

Arbitral awards are subject to only limited judicial interference: correction is confined to clerical or formal errors, remission to matters left undetermined, and setting aside to corruption, misconduct, or an error of law apparent on the face of the award. Mere allegations of factual mistake, inequity, or poor appreciation of evidence do not justify reappraisal of the merits. The Court found no erroneous legal proposition in the award or incorporated documents, and rejected the challenge. It also held that the workers' gratuity claim had been sufficiently recognised and provided for, so the award was not incomplete. The award was upheld and made the rule of the Court.

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Issues: (i) whether the arbitral award could be set aside or corrected on the grounds of legal misconduct, inconsistency, or error apparent on the face of the award; (ii) whether the workers' gratuity claims were left insufficiently protected so as to render the award incomplete.

Issue (i): whether the arbitral award could be set aside or corrected on the grounds of legal misconduct, inconsistency, or error apparent on the face of the award.

Analysis: The Court reiterated that judicial interference with an arbitral award is limited. An award may be corrected for clerical or formal errors, remitted when matters referred are left undetermined, or set aside for corruption, misconduct, or an error of law apparent on the face of the award. The Court cannot reappreciate the merits merely because a party alleges factual mistakes, inequity, or an erroneous appreciation of evidence. On the materials before it, no legal proposition in the award or in any incorporated document was shown to be erroneous, and the alleged grievances were treated, at most, as questions of fact.

Conclusion: The objection to the award on this ground was rejected.

Issue (ii): whether the workers' gratuity claims were left insufficiently protected so as to render the award incomplete.

Analysis: The Court found that the concern about inadequate provision for gratuity proceeded on a misconception. It accepted that sufficient provision had been made for existing liabilities and contingencies, that the right to gratuity had been recognised, and that the award had not left that dispute undetermined.

Conclusion: The workers' objection failed, and the award was held to sufficiently protect their gratuity claims.

Final Conclusion: The arbitral award was upheld and made the rule of the Court, with the objections dismissed and judgment directed in terms of the award.

Ratio Decidendi: Courts will not interfere with an arbitral award on alleged factual mistakes or general inequity; interference is confined to errors of law apparent on the face of the award, severable excess of authority, or proven misconduct.

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