Does Supreme Court Define Powers Available To Court Under Section 37 Of The Arbitration & Conciliation Act, 1996

In a recent judgement, the Hon'ble Supreme Court ("SC"), in the matter of S.V. Samudram vs. State of Karnataka & Another,¹set aside an order and judgment dated 07.02.2017 passed by the Hon'ble High Court of Karnataka ("HC") under Section 37 of the Arbitration & Conciliation Act, 1996 ("Act"). The issue was concerning a challenge to an arbitral award, which was accepted by the courts below. The court under Section 34 of the Act modified the arbitral award dated 18.02.2003 ("Award"), which was affirmed by the HC under Section 37 of the Act. However, the SC restored the Award with the finding that both the courts below had failed to limit themselves within the contours of Section 34 and Section 37 of the Act, respectively. The question framed by the SC for its decision, was as under: