Settling a dispute by referring it to a third person was well known in ancient and medieval India. If any of the parties to the dispute was not satisfied with the decision, he could go on an appeal to the Court of law and ultimately to the King itself.1 The modern law of arbitration evolved in the form of Regulations framed by the East India Company whereby the courts were empowered to refer the suits to arbitration. The first Indian Arbitration Act of 1899 was based on the English Arbitration Act of 1889. Then came the Indian Arbitration Act, 1940 and finally The Arbitration and Conciliation Act, 1996 (the ‘Act’) was enacted by Parliament based on the UNCITRAL Model Law on International Commercial Arbitration, 1985.2 Prior to the enactment of the 1996 Act, S.30 of the Indian Arbitration Act 1940 contained rather broad grounds for setting aside an arbitral award. By contrast, S.34 (2) of th ....