Scope of Section 37 Appeal is limited to verifying compliance with Section 34 parameters.

The appellant, a registered Co-operative Society, entered into an agreement (2014-15) with the respondent for the procurement and transportation of wheat

The appellant claimed that despite supplying 61,066.06 quintals, the respondent failed to pay an outstanding balance of ₹21,75,233.05

The appellant initiated proceedings before the Collector, Harda, acting as the Arbitrator, who dismissed the claim on 13.02.2020 due to discrepancies in supply quantity and lack of cogent evidence

The appellant challenged this under Section 34 of the Arbitration and Conciliation Act, 1996, before the Principal District Judge, Harda, who dismissed the application on 01.07.2022, holding that the appellant was seeking an impermissible reappreciation of evidence

The appellant subsequently filed this appeal under Section 37

1. Whether the scope of interference under Section 37 of the Arbitration and Conciliation Act, 1996, allows the Court to reappreciate evidence or substitute the Arbitrator's view with its own.

2. Whether the lower court's order affirming the arbitral award suffered from any patent legal infirmity or violation of public policy under Section 34 of the Act.

The Court primarily applied Sections 34 and 37 of the Arbitration and Conciliation Act, 1996, which restrict judicial intervention to specific grounds such as fraud, bias, or violation of natural justice

It relied on Mcdermott International Inc. v. Burn Standard Co. Ltd. (2006), establishing that the court's role is supervisory and limited to ensuring fairness; MMTC Limited v. Vedanta Limited (2019), which mandates that Section 37 jurisdiction cannot exceed Section 34 restrictions; and Dyna Technology Pvt. Ltd. v. Crompton Greaves Ltd. (2019), which emphasizes respecting party autonomy and the finality of awards unless perversity is shown.

The Court cited Punjab State Civil Supplies Corp. Ltd. v. Sanman Rice Mills (2024), clarifying that Section 37 powers are akin to revisionary powers and not a full-fledged appeal on merits

The Court observed that the Arbitrator (Collector) had dismissed the claim based on factual findings regarding discrepancies in weighment, bilty documents, and the appellant’s failure to explain shortages despite notices

The High Court reasoned that under Section 37, it is prohibited from undertaking an independent assessment of the merits or reappraising evidence if the Arbitrator's view is a "possible view"

The Court found that the Principal District Judge correctly identified that the appellant’s grounds for challenge were essentially requests for factual reconsideration, which is impermissible under Section 34

Applying the "minimal judicial interference" doctrine, the Court held that the concurrent findings of the Arbitrator and the Section 34 Court did not portray any "unpardonable perversity" or violation of the fundamental policy of Indian law

The Court concluded that the arbitral award and the Section 34 order were in consonance with the scheme of the 1996 Act. Consequently, the appeal was dismissed, and the order of the Principal District Judge, Harda, was affirmed