Chhattisgarh High Court Reiterates That Additional Evidence In Section 34 Arbitration Challenges Can Only Be Introduced In Exceptional Circumstances

Introduction

The Chhattisgarh High Court inHira Carbonics Private Limited v. Kunwar Virendra Singh Patel [2025:CGHS:2571], examined an important procedural question in arbitration law: whether additional documents can be introduced at the stage of a challenge under Section 34 of the Arbitration and Conciliation Act, 1996 ("Arbitration Act").

The case arose from an arbitration award dispute where the Respondents sought to introduce additional evidence under Section 65 of the Indian Evidence Act, 1872 ("Evidence Act"). The High Court's ruled that such evidence can only be admitted in exceptional circumstances. In this article, we navigate through the facts of the case and the findings rendered by the Chhattisgarh High Court.