In Brief
I-Pay Clearing Services challenged a High Court order dismissing its application to remit an arbitral award to the arbitrator for additional reasons. The arbitrator had awarded I-Pay ₹50 crores for losses from abrupt contract termination by ICICI Bank, but without explicitly finding on whether the termination was illegal. The Supreme Court held that remission under Section 34(4) of the Arbitration and Conciliation Act applies only where reasons are inadequate on a finding already recorded, not where no finding exists on a contentious issue. Patent illegality from missing findings cannot be cured by remission but must be addressed through a Section 34(1) set-aside application. The appeal was dismissed.
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