1. Section 29A, which defines the time limit for passing an award, does not apply retrospectively to arbitration proceedings that commenced before the Arbitration & Conciliation (Amendment) Act, 2015 came into force. Consequently, an award passed more than 12 months after the reference was not deemed non est for this defect.
2. There is no absolute rule prohibiting the consideration of sale instances relating to smaller pieces of land when determining the market value of a large tract of land. While necessary deductions may be warranted depending on the specific circumstances, the unavailability of large tract sale data does not operate to the disadvantage of the claimant. Deductions for development charges are not mandatory when the purpose of acquisition is widening a National Highway where no further development is contemplated.
3. Section 26 of the Arbitration Act, 1996 empowers the Arbitral Tribunal to appoint experts and consider their reports unless the parties have agreed otherwise. The Tribunal's consideration of an expert report or the inability of a party to replicate the evidence before the Competent Authority does not constitute a warrant for setting aside the award under Section 34 or 37.
4. The scope of jurisdiction under Section 37 of the Arbitration Act is extremely narrow, being essentially the same as under Section 34 but more limited. Courts cannot interfere with an award merely because an alternative view on facts or contract interpretation exists. Interference is permitted only in cases of patent illegality appraising to the root of the matter, impermissibility of delay, denial of natural justice, or perversity, and not on grounds of re-evaluating evidence or giving effect to all contract clauses.
