In Brief
SBI General Insurance sought to resist arbitration of a fire insurance claim by relying on a discharge voucher signed as full and final settlement. The claimant Krish Spinning disputed the settlement, alleging it was signed under financial duress, and invoked the arbitration clause for quantum dispute. The Supreme Court held that an arbitration agreement survives discharge of the underlying contract by accord and satisfaction. Disputes about whether accord and satisfaction actually occurred are themselves arbitrable and should be decided by the arbitrator, not the referral court. The court's role under Section 11 is limited to examining the prima facie existence of the arbitration agreement. The appointment of the arbitrator was upheld, affirming minimal judicial interference at the referral stage.
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