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Issues: Whether the arbitral award was liable to be set aside for want of reasons, and whether the matter ought to have been remitted to the arbitral tribunal for furnishing reasons before final adjudication of the objections.
Analysis: The requirement under Section 31(3) of the Arbitration and Conciliation Act, 1996 is mandatory unless the parties have agreed otherwise or the award falls within a statutory exception. Mere reference to pleadings, documents, or submissions is not a substitute for reasons. Reasons must disclose the thought process linking the material before the tribunal to the conclusion reached, even if the reasons are brief. On the record, no discernible reasons supported the award on claim Nos. 1 and 4B, and the award on claim No. 5 was inter-related to claim No. 1. In such circumstances, the appropriate course was to invoke Section 34(4) and afford the tribunal an opportunity to state reasons rather than finally nullify the award without that opportunity.
Conclusion: The award was found deficient for want of reasons in respect of claim Nos. 1 and 4B, but the matter was required to be remitted for reasons to be furnished and for the objections to be reheard.
Ratio Decidendi: An arbitral award must contain reasons that reveal the basis of the conclusion, and where such reasons are absent, the court may remit the matter to the tribunal under Section 34(4) to cure the defect before deciding whether the award should be set aside.