Section 14(2) notice for filing of an award can be valid through court-directed intimation to counsel, even orally.

Section 14(2) of the Arbitration Act, 1940 is satisfied when the court communicates, or directs communication of, the filing of the award to the parties or their counsel; written notice is not mandatory and oral intimation may suffice. Notice to the pleader, when recorded on the order sheet pursuant to the court's direction, operates as notice to the party. The provision does not require the court to wait until all connected documents are filed by the umpire, so notice given after the award is filed remains valid even if supporting papers are filed later.

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Issues: Whether intimation of filing of the award recorded by the court and noted by counsel amounted to valid notice under Section 14(2) of the Arbitration Act, 1940.

Analysis: Section 14(2) requires the court, after filing of the award, to give notice to the parties of that filing. The notice need not be in writing and may be oral. What is essential is communication of the fact of filing by or pursuant to an act of the court. Where the court records that counsel for the parties be informed and the endorsement is made on the order sheet, notice to the pleader operates as notice to the party. The court also held that notice need not await the filing of all connected papers by the umpire; a notice after the award is filed is sufficient even if the remaining documents are filed later.

Conclusion: The order dated 13.11.1998 constituted valid notice under Section 14(2), and the High Court was in setting aside the order making the award rule of court.

Final Conclusion: The appeals succeeded, the impugned judgment was set aside, and the order making the award rule of court was affirmed.

Ratio Decidendi: Notice under Section 14(2) of the Arbitration Act, 1940 is satisfied by court-ordered intimation of the filing of the award, including oral communication through counsel, and such notice need not await filing of all accompanying documents.

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