Scope of Section 37 appeal is limited to verifying Section 34 compliance without re-appreciating evidence.

The appellant’s land (0.56 hectare in Village Panagar, Jabalpur) was acquired by the Sub-Divisional Officer under Section 3A of the National Highways Act, 1954, for the purpose of widening National Highway No. 7

The competent authority awarded compensation of Rs. 5,14,250/-. Dissatisfied with the quantum, the appellant filed an application under Section 3G(5) of the National Highways Act, 1956, before the Arbitrator/Commissioner, Jabalpur, who dismissed the claim on 13.04.2016 for lack of documentary evidence

The appellant subsequently challenged this dismissal under Section 34 of the Arbitration and Conciliation Act, 1996, before the 15th District Judge, Jabalpur, who rejected the application on 06.01.2024

The appellant then moved the High Court under Section 37 of the 1996 Act

1. Whether the findings of the Arbitrator and the District Court were perverse or suffered from jurisdictional errors regarding the quantification of compensation

2. Whether the High Court, exercising jurisdiction under Section 37 of the Act of 1996, can reappreciate evidence or adjudicate on the quantum of compensation

The court applied Section 34 and Section 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 followed the precedent in Mcdermott International Inc vs. Burn Standard Co. Ltd. (2006), which limits the court's role to supervision and ensuring fairness rather than correcting arbitral errors

It further relied on MMTC Limited vs. Vedanta Limited (2019) and Punjab State Civil Supplies Corp. vs. Sanman Rice Mills (2024), establishing that Section 37 jurisdiction is narrower than Section 34 and does not permit independent assessment of merits or reappraisal of evidence

The High Court observed that the scope of Section 37 is extremely limited and does not permit the substitution of the court's view for that of the arbitrator

The court noted that the lower court had properly considered every point raised by the appellant under Section 34

The appellant failed to demonstrate any patent legality or perversity that would fall under the restricted grounds of Section 34(2) or the "public policy" exception

The court reasoned that disputes regarding the assessment of compensation based on market price guidelines are factual determinations that fall outside the supervisory ambit of the Act

Citing Dyna Technology Pvt. Ltd. (2019), the court emphasized that judicial interference in facts frustrates the commercial wisdom of alternative dispute resolution

The court answered that it cannot interfere with concurrent findings merely because an alternative view is possible

Consequently, the appeal was dismissed, and no costs were awarded