Guru Nanak Foundation v. Rattan Singh & Sons

This case explains a simple but powerful rule: once a court is properly approached in an arbitration matter, that court keeps exclusive control over it. Here, the Supreme Court appointed the arbitrator and watched over the process. Because of that, the award had to be filed in the Supreme Court, not in the High Court.

Section 31(4) of the Arbitration Act works like a “single forum lock.” It gives one court the sole key to accept and handle the award, and it closes the doors of other courts for the same matter.

1. Which court had jurisdiction over the arbitration proceedings and the filing of the award?
2. Does Section 31(4) give exclusive power to the first court moved in the reference?

Section 31(4) of the Arbitration Act: when an application is made to a court in any reference, that court gets exclusive jurisdiction. It also ousts the jurisdiction of other courts that might otherwise have power.

If a higher court (like the Supreme Court) takes control by appointing an arbitrator and supervising the process, that higher court becomes the proper place for filing the award.

The Supreme Court held that it had complete control over the arbitration proceedings after it appointed the arbitrator. Therefore, under Section 31(4), the Supreme Court alone had jurisdiction to receive the award.

The Court clarified that this arrangement does not defeat any right under Article 136. It only identifies the correct forum for filing and dealing with the award.

Once the Supreme Court assumes seisin by appointing the arbitrator and supervising the process, Section 31(4) gives it exclusive jurisdiction. Any other court’s jurisdiction over the award is ousted.

• Clarity on forum: Avoids duplicate filings and conflicting orders.
• Efficiency: Saves time and cost by fixing one court as the hub.
• Hierarchy respected: When the Supreme Court is in control, it remains the proper forum.

Mnemonic: “One Court, One Award”

1. Find Control: Which court appointed/supervised?
2. Lock Forum: Section 31(4) gives exclusive power.
3. File There: Award goes to that court only.

Section 31(4)

Provision fixing exclusive jurisdiction in the court first moved in the arbitration reference.

Filing of Award

Submission of the arbitrator’s award to the proper court for further action.

Ouster of Jurisdiction

When one court’s authority excludes others from dealing with the same matter.