Judicial review under Section 37 of the Arbitration Act cannot extend to re-appreciating evidence for land valuation.

The National Highways Authority of India (NHAI) challenged an arbitral award passed under Section 3G(5) of the National Highways Act, 1956

The Arbitrator (District Collector) had re-determined the market value of the acquired land by applying the highest 'jantri' (government-fixed guideline) value of the village and adding a 5% annual enhancement

NHAI’s challenge under Section 34 of the Arbitration and Conciliation Act, 1996, was dismissed by the Commercial Court (6th Additional District Judge, Ahmedabad) on December 31, 2025

NHAI subsequently filed this appeal under Section 37 of the Arbitration Act

1. Whether the Arbitrator committed a patent illegality by adopting the highest jantri rate and adding 5% enhancement for determining market value

2. Whether the arbitral award was unreasoned or violated the principles of natural justice by ignoring evidence adduced by the NHAI

3. Whether the High Court, in its limited jurisdiction under Section 37 of the Arbitration Act, should interfere with the findings of the Commercial Court

Section 3G(7) of the National Highways Act, 1956, and Section 26 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, which mandates the criteria for assessing market value

National Highways Authority of India v. Nagraju [(2022) 15 SCC 1], confirming that market value must be determined per the 2013 Act

restrictive standards for judicial intervention under Sections 34 and 37 of the Arbitration and Conciliation Act, 1996, which prohibit the re-appreciation of evidence and limit interference to cases of patent illegality or violations of public policy

The High Court observed that the Arbitrator conducted a factual inquiry based on Section 26 of the 2013 Act using the available material and evidence

The Court held that the choice of 'jantri' rates is a valid parameter for ensuring uniformity and transparency in valuation

The Court reasoned that NHAI’s grievances regarding the methodology of quantification and the weight given to evidence fall within the exclusive domain of the Arbitrator and cannot be re-examined by a court acting as an appellate authority

The Court noted that the Commercial Court had already verified that the award was duly signed and that the NHAI had participated in the proceedings without prior objection

Consequently, there was no evidence of patent illegality or a shock to the conscience of the court that would justify setting aside the award

The determination of compensation based on government-prescribed jantri rates is neither illegal nor arbitrary

The High Court dismissed the First Appeal, the judgment and order of the Commercial Court dated 31.12.2025 were upheld, and all connected civil applications were disposed of