Conciliation confidentiality bars use of a demarcation report directly arising from settlement proceedings.

A demarcation report arising wholly from conciliation proceedings was held inadmissible because Sections 75 and 81 of the Arbitration and Conciliation Act, 1996 protect the confidentiality of matters connected with conciliation. Section 75 was read broadly, covering all material "relating to" conciliation, and Section 81 was treated as reinforcing that confidentiality in later arbitral or judicial proceedings. Even though the report did not fit neatly within each illustrative category in Section 81, its direct origin in conciliation meant it could not be relied on in evidence. The challenge succeeded and the impugned judgment was set aside.

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Issues: Whether a demarcation report originating in conciliation proceedings could be admitted in evidence in view of the confidentiality mandate under Sections 75 and 81 of the Arbitration and Conciliation Act, 1996.

Analysis: Section 75 uses the wide expression "relating to" and requires both the conciliator and the parties to keep confidential all matters connected with conciliation proceedings. Section 81 bars reliance on or introduction of certain categories of conciliation material in arbitral or judicial proceedings. The report in question had its genesis only in the conciliation process, so its connection with conciliation was direct and not merely incidental. The fact that the case did not fit neatly within each of the four categories in Section 81 did not matter, because allowing such material would undermine the confidentiality necessary for effective settlement efforts.

Conclusion: The demarcation report was not admissible in evidence; the challenge succeeded and the impugned judgment was set aside.

Ratio Decidendi: Material that originates in and is intrinsically connected with conciliation proceedings is protected by the confidentiality regime of Section 75 and cannot be admitted merely because it does not fall within one of the specific illustrations in Section 81.

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