Legal Representatives Must Challenge An Arbitral Award Under Section 34 And Not Under Article 227: Supreme Court

Introduction

In V.K. John v. S. Mukanchand Bothra and HUF (Died) Represented by LRs. & Ors. [2026 INSC 393], the Supreme Court considered whether a legal representative aggrieved by an arbitral award can challenge the award under Article 227 of the Constitution of India or Section 115 of the Code of Civil Procedure, 1908, instead of taking recourse to Section 34 of the Arbitration and Conciliation Act, 1996.

The Supreme Court held that the appropriate remedy for a legal representative seeking to challenge an arbitral award is under Section 34 of the Arbitration Act. The Supreme Court reiterated that the Arbitration Act is a complete code and that judicial interference outside the statutory framework of Section 34 must be exercised only in exceptional cases.