Section 34 is the exclusive route for legal representatives challenging an arbitral award after a party's death.

A legal representative aggrieved by an arbitral award must challenge it under Section 34 of the Arbitration and Conciliation Act, 1996, because that Act is a complete code for arbitral remedies and provides the exclusive statutory route to set aside an award. The statutory scheme treats legal representatives as stepping into the shoes of the deceased party, with awards binding on persons claiming under the parties and arbitration agreements enforceable against them. Article 227 of the Constitution and Section 115 of the Code of Civil Procedure are therefore not available as alternative challenge mechanisms. The High Court's view against the appellant was affirmed.

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Issues: Whether a legal representative aggrieved by an arbitral award must challenge it under Section 34 of the Arbitration and Conciliation Act, 1996, or may invoke Article 227 of the Constitution of India or Section 115 of the Code of Civil Procedure, 1908.

Analysis: The Arbitration and Conciliation Act, 1996 is a complete code for arbitral remedies. Section 34 provides the exclusive statutory route for setting aside an arbitral award, and the scheme of the Act contemplates continuity of arbitral proceedings despite the death of a party. The definition of legal representative, the binding effect of awards on persons claiming under parties, and the enforceability of arbitration agreements against legal representatives together indicate that such representatives step into the shoes of the deceased party. Denying them access to Section 34 would leave them remediless while still binding them to the award, which would be contrary to the statutory scheme.

Conclusion: A legal representative seeking to challenge an arbitral award must proceed under Section 34 of the Arbitration and Conciliation Act, 1996, and not under Article 227 of the Constitution of India or Section 115 of the Code of Civil Procedure, 1908. The legal position affirmed the High Court's view against the appellant.

Ratio Decidendi: Where the arbitration statute makes the award binding on parties and persons claiming under them, a deceased party's legal representative inherits both the burden and the remedy under Section 34, which is the exclusive route for challenge.

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