Full and final settlement bars arbitration unless coercion or duress is prima facie shown to displace accord and satisfaction.

A discharge voucher, no-claim certificate, or full and final settlement bars arbitration where it is voluntarily executed and the record shows accord and satisfaction. A party alleging fraud, coercion, undue influence, or duress must first produce prima facie material; a bald or belated assertion is insufficient. On the facts, the final bill was accepted in full and final settlement, the completion certificate followed, and the later attempt to reopen the claim lacked supporting particulars or evidence of economic compulsion. The settlement was therefore binding, no arbitrable dispute survived, and appointment of an arbitrator was refused.

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Issues: Whether the dispute was arbitrable and whether appointment of an arbitrator was warranted despite the issuance of a no-dues or no-claim certificate allegedly obtained under duress and coercion.

Analysis: A discharge voucher, no-claim certificate, or full and final settlement bars arbitration when it is voluntarily and validly executed and the record shows accord and satisfaction. If a party alleges fraud, coercion, undue influence, or duress, the allegation must be supported by prima facie material; a bald or belated assertion is insufficient. On the facts, the no-dues certificate was issued, the final bill was accepted in full and final satisfaction, the completion certificate followed, and the later withdrawal of the certificate and claim for losses lacked supporting particulars. The circumstances did not show any prima facie economic compulsion or coercion sufficient to displace the settlement.

Conclusion: The dispute had stood concluded by accord and satisfaction, so no arbitrable dispute survived for appointment of an arbitrator under Section 11.

Final Conclusion: The order of the High Court appointing an arbitrator was set aside because the claim was found to be finally settled and not open to arbitration.

Ratio Decidendi: A party seeking to avoid the bar of a full and final settlement must prima facie establish that the discharge was obtained by fraud, coercion, undue influence, or duress; absent such showing, the settlement is binding and arbitration cannot be compelled.

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