Say the ratio out loud before you open Reasoning — recalling it unprompted is exactly what the exam pays for.
Why it matters
It marks the other side of the line from K.P. Poulose. Misconduct is a real ground; dissatisfaction with the arbitrator's conclusions is not. This is the first authority in the group that protects the finality of an award.
Facts
The award was attacked on the ground that the arbitrator had drawn his own conclusions and had failed to appreciate the facts.
Held
The arbitrator is the final arbiter of the dispute between the parties. It is not open to challenge the award on the ground that he has drawn his own conclusions or has failed to appreciate the facts.
Reasoning
Step one — the parties chose the decision-maker. Having agreed to have their dispute decided by an arbitrator, they agreed to his findings, right or wrong, on the matters referred.
Step two — error within jurisdiction is not excess of jurisdiction. A wrong conclusion on material properly before the tribunal is an error, if it is one at all, inside the mandate. Misdirection about the scope of the mandate is a different thing, and that is where Continental Construction and Jivrajbhai operate.
Step three — the alternative would be an appeal. Allowing a challenge on appreciation of facts would turn every setting-aside petition into a rehearing, which is the evil the statute is designed to prevent.
Exam use
It opens: To what extent may a court interfere with an arbitral award?
Group it with its companions. M.C.D. v. Jagan Nath Ashok Kumar holds the arbitrator to be the sole judge of the quality and quantity of evidence, so that the court will not re-appreciate it even if it might have reached a different conclusion on the same material. Alopi Parshad holds that where a question of law is specifically referred, the possibility of an alternative view is no ground of challenge. Cite the three together as the finality trio.
Then draw the line. Against that trio, put K.P. Poulose (ignoring very material documents, inconsistent conclusion on the face of the award) and Continental Construction (awarding what the contract bars). The examinable skill is placing a given fact pattern on the correct side.
Bring it up to date. Under the 1996 Act, interference runs through s. 34; after the 2015 amendment an award cannot be set aside merely for an erroneous application of law or by re-appreciation of evidence, which is this case in statutory form.
It does not decide that an award is immune from challenge; it decides which complaints are not challenges at all.