Stamping and registration objections to arbitral awards are not decided at the Section 34 setting-aside stage.

A challenge to an arbitral award under Section 34 of the Arbitration and Conciliation Act is confined to the grounds expressly provided in that provision. Questions of stamping and registration do not arise for decision at the setting-aside stage, because objections to admissibility on those grounds become relevant when enforcement is sought under Section 36. The court therefore held that determining non-stamping and non-registration in Section 34 proceedings is premature and unnecessary, and that such objection may be raised at the enforcement stage.

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Issues: Whether the question of stamping and registration of an arbitral award could be decided in proceedings under Section 34 of the Arbitration and Conciliation Act, 1996.

Analysis: The challenge to an award under Section 34 is confined to the grounds expressly enumerated in that provision. The question whether the award requires stamping and registration does not arise for decision at the setting-aside stage, because objections as to admissibility on that score become relevant when the award is sought to be enforced under Section 36. The determination of such an objection at the Section 34 stage was therefore premature and unnecessary.

Conclusion: The objection based on non-stamping and non-registration could not be adjudicated in Section 34 proceedings and was open to be raised at the enforcement stage.

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