Arbitral procedure and bias claims fail where belated evidence requests are rejected after closure of proceedings.

Arbitral procedure under the Arbitration and Conciliation Act requires equal treatment and a full opportunity to present the case, but that right is not unlimited. A tribunal may regulate procedure and decline a belated request to reopen evidence or seek expert assistance, especially where repeated adjournments were already granted and the request came after evidence had closed. A disputed document cannot be treated as proved evidence, and the tribunal is not obliged to appoint an expert on its own. Allegations of bias must be supported by a timely and substantive challenge and cannot rest on an adverse award alone; absent material showing prejudice or partiality, the award was upheld and the Section 34 petitions were dismissed.

---

---

Issues: (i) Whether the arbitral proceedings violated the requirement of full opportunity and the mandate of oral hearing by rejecting the petitioner's belated request to lead further evidence and seek expert assistance; (ii) Whether the arbitral award was vitiated by bias or prejudice on the part of the arbitrator.

Issue (i): Whether the arbitral proceedings violated the requirement of full opportunity and the mandate of oral hearing by rejecting the petitioner's belated request to lead further evidence and seek expert assistance.

Analysis: The statutory scheme under Sections 18, 19 and 24 of the Arbitration and Conciliation Act, 1996 requires equal treatment and a full opportunity to present the case, but that right is not unfettered. The arbitral tribunal is empowered to regulate procedure and to decide whether oral hearings are required at the appropriate stage. The record showed repeated adjournments at the petitioner's request, closure of evidence after opportunity had been given, and a belated attempt to reopen the matter when the respondents' arguments were nearly complete. The request to produce further expert evidence was therefore not made at an appropriate stage. The Court also held that an unproved disputed document could not be treated as evidence and that the tribunal was not bound to appoint an expert suo motu.

Conclusion: The rejection of the belated request did not amount to denial of full opportunity or breach of natural justice.

Issue (ii): Whether the arbitral award was vitiated by bias or prejudice on the part of the arbitrator.

Analysis: The allegation of bias was found to be unsupported by any timely or substantive challenge under the Act. The petitioner had earlier raised similar allegations, which had been rejected, and no valid challenge was made within the statutory framework. The award itself disclosed consideration of the evidence and reasons on merits, and an adverse decision on the claim could not, by itself, establish bias. The Court found no material to show prejudice or partiality in the conduct of the proceedings or in the making of the award.

Conclusion: The allegation of bias was rejected and the award was not vitiated on that ground.

Final Conclusion: The arbitral award was upheld and the petitions under Section 34 were dismissed because no procedural illegality, denial of natural justice, or bias was established.

Ratio Decidendi: The right to present a case in arbitration is subject to the statutory scheme governing procedure and hearings, and a belated attempt to reopen evidence after closure of the case does not constitute denial of full opportunity unless actual prejudice is shown.

---