Arbitration reference cannot be expanded to add a non-party without derivative title or legal entitlement.

Under the Arbitration Act, only parties to the arbitration agreement or persons lawfully claiming under them can be brought within the reference; a stranger with no assignment or other derivative title cannot be compelled to join merely because the dispute may affect him. The court's power over arbitration proceedings does not extend to creating a new party to the reference in the absence of legal entitlement, and a direction to implead such a third party is without jurisdiction and cannot stand.

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Issues: Whether the court could direct the arbitrator to implead a person who was not a party to the arbitration agreement or reference.

Analysis: The Arbitration Act contemplates enforcement and reference only by parties to the arbitration agreement or persons claiming under them. A third party who neither entered the agreement nor established an assignment or other derivative right cannot, as a matter of contract and arbitration law, be compelled into the reference merely because the dispute may affect him. The court's power under the Act to deal with arbitration proceedings does not extend to creating a new party to the reference in the absence of legal entitlement.

Conclusion: The direction to implead the third party was without jurisdiction and could not stand.

Ratio Decidendi: Only parties to an arbitration agreement, or persons lawfully claiming under them, can enforce or be bound by the reference; the court cannot add an outsider to the arbitration proceedings absent a valid derivative title.

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