KUMBHA MAWJI vs UNION OF INDIA

The Supreme Court held that under Section 14(2) of the Indian Arbitration Act, 1940, mere filing of an award in court by a party without the authority of the arbitrator or umpire does not comply with statutory requirements. The Court clarified that the phrase 'in a reference' in Section 31(4) encompasses applications made after arbitration completion, granting exclusive jurisdiction to the court where the first application for filing was made. The Court affirmed the jurisdiction of the Gauhati Court over the dispute, as the umpire had sent a signed copy of the award to it prior to the filing in Calcutta High Court.