Arbitral award review under Section 34 is narrow; evidence reappreciation was refused and the challenge failed.

Section 34 interference with an arbitral award remains narrow: re-appreciation of evidence is impermissible, and interference lies only where illegality goes to the root, the view is impossible, reasons are absent, or vital evidence is ignored. Applying that standard, the HC held that the tribunal had considered the contractual framework, imports, supplies, returns, refunds, and party communications, including the warranty and indemnity clauses. The tribunal's treatment of the proviso to Section 16(1) of the Sale of Goods Act, 1930, did not justify interference because it was consistent with the express contract and the evidentiary record. The challenge to the award failed.

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Issues: Whether the arbitral award was liable to be set aside under Section 34 of the Arbitration and Conciliation Act, 1996 on the grounds of patent illegality, conflict with public policy of India, improper appreciation of evidence, and alleged non-consideration of the proviso to Section 16(1) of the Sale of Goods Act, 1930.

Analysis: The challenge was tested against the narrow scope of interference under Section 34. Re-appreciation of evidence is impermissible, and an award can be interfered with only where the illegality goes to the root of the matter, the view taken is impossible, the award is unsupported by reasons, or vital evidence is ignored. On the facts, the arbitral tribunal had examined the contractual framework, the sequence of imports, supplies, returns, refunds, and the parties' communications. The Court accepted that the tribunal had considered the petitioner's case on the returned kits and the impact of the contractual warranty and indemnity clauses. The Court also held that the tribunal's interpretation of the proviso to Section 16(1) of the Sale of Goods Act, 1930 did not justify interference, particularly in view of the express contractual terms and the evidentiary record.

Conclusion: The award did not suffer from patent illegality or any ground warranting interference under Section 34, and the challenge failed.

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